ML20108A288
| ML20108A288 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 10/02/1984 |
| From: | Morgan R CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20108A275 | List: |
| References | |
| RSEP-84-575, NUDOCS 8411140525 | |
| Download: ML20108A288 (4) | |
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Carolina Power & Light Compsey L
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ROBINSON STEAM ELECTRIC PLANT-POST OFFICE BOX 790
~ HARTSVILLE, SOUTH CAROLINA 29550
.OCT 2 1984 Robinson File No.:
13510E Serial: RSEP/84-575 w
1 Mr. James P. O' Reil.ly x
Regional Administrator U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Atlanta, Georgia 30323 H. B. ROBINSON' STEAM ELECTRIC PLANT,iUNIT NO. 2 DOCKET No. 50-261 LICENSE NO. DPR-23 I
IE INSPECTION REPORT-IER-84-23 REV. 1
Dear Mr. O'Reilly:
Carolina Power 'abd Light Company (CP&L) has ' received and reviewed the subject report and provides the following response.
i Severity Level IV Violation (IER-84-23-01-SL4)
Technical Specification 6.5.1.1 requires that written procedures shall be established, implemented, and maintained that meet the requirements of Appendix A of USNRC Regulatory Guide 1.33, Revision 2.
Contrary to the above, procedures were not adequately implemented in tbat:
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1.
Operating Procedures OMM-1009, Operating Notes, Note 63 requires that only'one maintenance crew at a timeJe allowed to work in the Safeguards Racks or associated field instruments. No work may be performed on.
instruments in the field coincident with activities in the Safeguards Racks, unless the work involves the same channel. Appr val of the Maintenance Supervisor or Operations Supervisor is rec ed to deviate from this policy.
Contrary to the above, on June' 71, 1984, these requirements were not
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implemented in that separate maintenance crews were performing calibrations on containment pressure instruments in different channels at locations in the field and in the Safeguards Racks. Appropriate management approval had not been obtained. This resulted in an Engineered Safety Features actuation on the high containment pressure
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signal.
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L;ttar to:Mr. Jamen P.LO'Reilly-
-j~Sarials' RSEP/84-575' Page 2-y
' 2.' cAdministrative Procedure AP-027 Section 2.1.32 requires all Plant employees to initiate-maintenance work requests on all observed nonconforming conditions,: particularly -those on safety-related equipment.:
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' Contrary to the above, as'of June 19, 1984,'a maintenance. work request had not.been. initiated by the licensed operator who had observed that oil had sprayed onto the' surfaces of
'A' emergency diesel generator from the engine furing engine =tartup for the' weekly surveillance test conducted June 18,.1984.
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-Health Physics. Procedure HPP-006, Revision 2, Radiation Work Permits-
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(RWP), establishes the; Plant. requirements for development and use of 1
proper radiation work' permits for protection of' personnel. RWP.2404 established. requirements for-certain construction activities in the pipe alley of the auxiliary building, including the requirement that'all tools
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and equipment shall be bagged at the step off pad prior to exiting a contaminated area.
Contrary to the above, as of June 24, 1984, workers conducting activities under RWP 2404 were observed placing unbagged tools outside the high contamination'. area associated with pipe alley,
Response
A.
Admission or Denial of the Alleged Violation CP&L acknowledges the alleged violation.
B.
Reason for the Violation 1.
The Instrument and Control (I&C) Foremen assign work to their I&C Technicians and the Operations Shift Foremen approve the work to be performed on Plant equipment.
In this case, the Plant was shut down with the fuel removed to the Spent Fuel Pit, and the safety injection pump breakers were racked out.
The Shift Foreman did not understand that the two I&C crews would be working on separate channels of containment pressure. He thought the two I&C crews were working together and therefore did not implement Note 63 of Operations Management Manual Procedure OMM-1009. One I&C crew worked at the transmitters, and a second I&C crew worked at the instrument racks on the same instrument logic as the I&C crew at the transmitters. There crews performed calibrations on containment pressure instruments in different channels at the same time -
resulting in a safety injection signal.
4 OMM-1009, Note 63 was intended to prevent this incident.
OMM-1009, l
Note 63, requires a higher level of approval which would have l
stopped the simultaneous work on the same instrument logic.
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-w L5ttsr ta Mr. Jcmea P. O'Railly S2ricle RSEP/84-575
-Page 3 4
2.
The operator observed an oil leak that stopped during the running of the diesel generator. The operator, in error, did not immedia -ly initiate a work request on the oil leak. Approximately one-aalf pint of oil had leaked out and was subsequently cleaned up by the janitorial crew. The NRC resident inspector questioned the origin of the oil he observed on the diesel.
3.
The individual involved was accustomed to working in areas that had a high potential for_ contamination and, therefore, used double step-off pads. With double step-off pads, the outer shoe covers are removed at the first step-off pad, but tools may be carried, unbagged, across the first step-off pad.
In the event which resulted in the violation, the individual was exiting an area which used only the single step-off pad. The individual was working in a high temperature area and was eager to exit.
In his haste, he confused exiting across the single step-off pad with exiting across a double step-off pad and mistakenly laid his unbagged tools across the step-off pad.
C.
Corrective Steps Which Have Been Taken 1.
The calibrations of the containment pressu e channele were scopped.
The I&C Foremen and Shift Foremen were involved in determining the cause of the safety injection signal. Those involved were counseled and made aware of the violation of OMM-1009, Note 63 which was caused by a breakdown in communications. This breakdown resulted in the safety injection signal. OMM-1009, Note 63 has been reviewed by Operations Shift Foremen and appropriate maintenance personnel.
2.
The operator who observed the leak was counseled and made aware that he should have initiated a work request, which, per Plant procedure, is required to be initiated on all non-conforming conditions, particularly those on safety related equipment. The operator then initiated the work request which resulted in identifying and repairing the oil leak. This work request was completed on June 27, 1984.
3.
The personnel involved in pm iLn,q unbagged tools across the step-off pad were restricted r; m i
the Radiation Control Area. Although only one individual.ac 24}J iolated the procedure, the entire crew went through Radiation Contest Area Mock-up Dressout Training on July 13, 1984.
In addition, these individuals were given additional radiation control retraining by the ALARA group. This retraining should prevent recurrence of this violation.
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' LettOr to Mr..J mea P. O'Reilly Saricle-RSEP/84-575 Page4 D.
Corrective Steps Which Will Be Taken
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1.
A note similar to Note 63 of OMM-1009 will be included in a Maintenance Procedure which is part of the Plant Operating Manual rewrite effort commitment.
2.
No further action is deemed necessary.
3.
No further action is deemed necessary.
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E.
Date When Full Compliance Will Be Achieved 1.
' Full compliance has been achieved. The note to be included in the Maintenance Procedure is scheduled per previous commitments to develop this new manual.
If you have any questions concerning this response, please contact my staff or me.
I Very truly yours, k'"
R. E. Mo gan General Manager H. *,. Robinson SEG Plant REM /wp 9
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