ML20101T544

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Responds to NRC Re Violations Noted in Insp Rept 50-261/84-41.Corrective Actions:Operation Surveillance Test OST-162 Corrected
ML20101T544
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 01/09/1985
From: Morgan R
CAROLINA POWER & LIGHT CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20101T529 List:
References
RNPD-85-20, NUDOCS 8502060220
Download: ML20101T544 (3)


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ROBINSON NUCLEAR PROJECT DEPARTMENT POST- 0FFICE BOX 790 HARTSVILLE, JAN - 91985 SOUTH CAROLINA 29550 Robinson File No:

13510E Serial: RNPD/85-20 Mr. James P. O'Reilly Regional-Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.

Atlanta, Georgia 30323 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261

,, LICENSE NO. DPR-23 NRC INSPECTION REPORT IER-84-41

Dear Mr. O'Reilly:

Carolina Power and Light Company (CP&L) has received and reviewed the subject report and provides the following response.

Severity Level V Violation IER-84-41-02-SL5 10CFR50, Appendix' B, Criteria V and XI, as implemented by the Licensee's Corporate Quality Assurance Program, requires' adherence to procedural measures established for documentation of test results to assure that test requirements have been satisfied.

Contrary to the above, during performance of Operations Surveillance Test Procedure 'OST-162 on November 7,1984, data recorded for the duration of the sequence for the emergency diesel generators to start and assume the required loads after initiation of a loss of power, combined with a manual safety injection signal, were rounded off instead of recording ~ the actual value obtained from the stopwatch.

Response

1.-

Admission or Denial of the Alleged Violation CP&L acknowledges the alleged violation.

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. Reason'for the Vio'lation

'During the performance of Operations Surveillance Test OST-162,.the

- procedure srequired that a stopwatch be used to record the duration of the: sequence from~ the time the manual safety injection (SI) signal;and

- < loss.of power were initiated to the time the emergency diesel

generators assumed.the required load. The acceptance criteria for this

-duration was to complete the cycle in less than 50 seconds. The time

obtained on the stopwatch was 50.45 seconds. At that time, those individuals involved in the test made a brief review of the data.

favailable.

Individuals performing the test-made a 'prelisinary decision to round off the value to 50 seconds because the acceptance criteria was in-seconds,_and the data available appeared to support this.

Additionally,' the knowledge of the inaccuracies associated with starting and stopping a hand-held stopwatch influenced-this decision.

It was also known at that time that'a thorough evaluation of all the data would -be initiated following completion of the-test.to resolve the timing issue and determine the acceptability of the test. A miscommunication between those involved in the preliminary decision to round off the.value and those actually performing the test resulted in the initial' recording of the rounded off value without a supporting evaluation.

3 Corrective Steps Which Have Been Taken-During the evaluation following the test,~it.was decided that rounding off to 50 seconds was inappropriate and that the actual (as found) value obtained:should have been documented inste'ad-of the rounded off value. Also, it was decided that a correction would be'made on the OST.

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to indicate the actual (as'found) stopwatch value obtained during the'

. test along with attaching supporting documentation providing justification for surveillance test acceptance.

The same individuals involved in the preliminary decision to round off the stopwatch value'-were also involved in the test evaluation and final decision to correct the test.

The test (OST 162) has been corrected and accepted as satisfactory with supporting documentation attached' indicating that~even though~the actual (as found) ' stopwatch value was greater than 50 ~ seconds, post

~ test maintenance testing-performed on the timing. sequences brought the effective time'within the acceptance criteria.'-

Since rounding off of data is not a normal practice, this occurrence is considered an isolated case,'and those individuals involved'in this-occurrence are cognizant;of their inappropriate actions.

4.

Corrective Stoos Which Will Be Taken No further' action is necessary.

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- : Letter to Mr..-J. P. O'R: illy Se'ricl: RNPD/85-20

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Date When Full Compliance Will~Be Achieved

-Full compliance has been achieved.

Very truly yours, b4-R. E.

rgan General Manager H. B. Robinson S. E. Plant CLW/wp i

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