ML20198K663

Responds to NRC 971212 NOV & Proposed Imposition of Civil Penalty in Amount of $55,000.Corrective Actions:Switch Was Examined & Returned to Normal on 970820.Check for $55,000 for Payment of Civil Penalty Encl.W/O Encl

ML20198K663
Person / Time
Site:	Robinson
Issue date:	01/09/1998
From:	Keenan J CAROLINA POWER & LIGHT CO.
To:	Lieberman J NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
50-261-97-10, EA-97-490, NUDOCS 9801150063
Download: ML20198K663 (7)

Text

-

10 CFR 2.201 -

g.

CP&L

- + .

Corobne Poww & Light Company [~ -J.S.Keenon - -

Vice President 3581 West Entrance Road ikxtwille. SC 29550 ""'"""*'"'"'

09m Robinson File No: 13510E Seriali RNP-RA/98-0002 United States Nuclear Regulatory Commission Attn: Document Control Desk Was'ington, DC 20555 Mr. James Lieberman Director, Office of Enforcement United States Nuclear Regulatory Commission One White Flint North 11555 Rockville Pike

' Rockville, MD 20852-2738

11. H. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261/ LICENSE NO. DPR-23 NRC INSPECTION REPORT NO. 50-261/97-10 REPLY TO A NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY - $55,000 (EA 97-490)

Gentlemen:

The attachment to this letter provides the Carolina Power & Light (CP&L) Company reply to the apparent violations initially identified in NRC Inspection Report No. 50-261/97-10 and subsequently identified in a Notice of Violation and Proposed Imposition of Civil Penalty (EA-97-490). The Notice of Violation and Proposed Imposition of Civil Penalty for the

11. B. Robinson Steam Electric Plant (HBRSEP), Umt No. 2, was transmitted by NRC letter dated December 12,1997. The violatior.s involve failure to establish measures to assure that conditions adverse to quality were promptly identified and corrected and failure to take adequate conective action to preclude repetition of a Severity Level 111 violation issued in March 14,1994,(EA 93-298) involving position control errors affecting the EDG local control

- panels. in accordance with the letter transmitting the Notice of Violation, the attachment restates the violations, followed by the HBRSEP reply. Also enclosed is a check, number 052830, dated January 6,1998, drawn on the Wachovia Bank of Georgia, N.A., in the amount of $55,000 for payment of the civil penalty. 7,

/

, , = .,

A o 6

• 1 .

ElllllllRE.ll!!E Tel 803 8571499 Fox 803 8571319 l

._ .- 1

.United States Nuclear Regulatory Commission 10 CFR 2.201 Serial: RNP-RA/98 0002 Page 2 of 2

~

Should you have any questions regarding this matter, please contact Mr. H. K. Chernoff at

- (803) 857-1437.' ,

Very truly yours, S. . $+- --.

/

. S. Keena Vice President WMW/ww Attachment c: Mr. B. B. Desai, USNRC Senior Resident Inspector, llBRSEP Mr. L. A. Reyes, Regional Administrator, USNRC, Region II Mr. J. W. Shea, USNRC Project Manager, ilBRSEP t

t s

l 4

.<1 S:

Affidavit .

State of South Carolina i County of Dertington >

J S. Keenan, having been first duly sworn, did depose and say that the information contained

. In letter RNP-RA/9862 is true and correct to the best of his information, knowledge and >

belief; and the sources of his information are officers, employees, contractors, and agents of Carolina Power & Light Company.

d S./rw' A '

G f Sworn to and subscribed before me this 9 day of Juoney 199 Y -

(Scal)? md g____

Notary Public (orTouth Carolina NY COMMISSION DLPIRES My commission expires: MA8CH i!!ST,2005 2

X 4

y .- . - . . . . . , .

6

.,  : United States Nuclect Regulatory Commission .

Attachment to Serial: RNP-RA/98-0002 Page1of4 REPLY TO A NOTICE OF VIOLATION Violation 50-261/97-10 A and H 10 CFR 50, Appendix B, Criterion XVI," Corrective Action," requires, in part, that measures shall be established to assure that conditions adverse to quality, such as failures, .

malfunctions, deficiencies, devittions, defective material and equipment, and nonconformances are promptly identified and corrected. In the case of significant conditions adverse to quality, the measures shall assure that the cause of the condition is determined and corrective action taken to prech* repetition.

A'. Contrary to the above, as of August 20,1997, the licensee failed to establish measures to assure that conditions adverse to quality were promptly identified and corrected.

Specifically, the licensee failed to identify that the "B" Emergency Diesel Generator (EDG) output breaker control switch was mispositioned; and, therefore, failed to correct the switch position error resulting in the inoperability of the EDO. (01013)

B. Contrary to the above, as of August 20,1997, the licensee failed to take adequate corrective action to preclude repetition of a Severity Level III violation issued in March 14,1994 (EA 93-298) involving position control errors affecting the EDG local control panels. Specifically, the licensee did not take comprehensive corrective action in that they failed to include the EDG output breaker control switches in Auxiliary Operator logs to be checked on rounds or take other measures to control activities affecting the EDG local control panels. (01023)

These violations represent a Severity Level 111 problem (Supplement I).

Civil Penalty - $55,000,

l. Admission or Denial of the Allened Violation The Carolina Power & Light (CP&L) Company agrees that Violations A and B occurred as described.

2. The Reasons for the Violation Reasons forViolation A The "B" EDG output breaker control switch was determined to be in the " trip-pull-out" position on August 20,1997. The last recorded manipulation of the switch was on July 8,1997, during testing of the EDG. The EDG test procedure did not require verification of switch position following manipulation.

. . United Stat:s Nuclear Regul: tory Commission Attachment to Serial: RNP RA/98 0002 Page 2 0f 4 e .

The position of this switch is not indicated or annunciated in the control room. Local indication of switch position is provided at the EDG generator control panel by both handle position and indicator lights. Although operators were required to log information from this control panel each shill, logging the position of this switch was not required.

The investigation of thia event was not able to definitively determine the e mse of the switch mispositioning. The investigation report concluded that the most probable cause of this event vas inadvertent operation of the switch sometime on or aller 1612 hours0.0187 days <br />0.448 hours <br />0.00267 weeks <br />6.13366e-4 months <br /> on August 16,1997. This conclusion was reached based on a thorough review of work activities that took place in the vicinity of the switch and interviews with operations personnel that had been in the area as well as the consideration and subsequent climination of other possible scenarios.

Reasons for Violation H As a result of the 1993 EDG automatic voltage control knob mispositioning event, CP&L committed to add, "... other equipment with no automatic indication of equipment misalignment . . ." to operator logs for routine checks. Ilowever thes review conducted to detennine the equipment to be monitored was not sufficiently detailed to identify the EDG output breaker control switches as equipment encompassed by the commitment. A contributing factor in not identifying these switches as afTected by the commitment may nave been the routine uses for the switches. These switches, which are spring return to neutral, have four positions:

close; neutral; trip; and trip-pull-out. Ilowever, routine use of the switch does not include use of the " trip-pull-out" position.

3. I_he Corrective Steps That llave licen Taken and the Results Achieved On August 20,1997, the switch was examined and returned to the normal (i.e.,

neutral) position. On August 20-21,1997, a check to verify that other selected switches in the plant were in the correct position was completed.

Following the discovery and restoration of the switch to its correct position, plant tnanagement formed an Event Review Team to investigate the cause of the switch mispositioning, along with any generic implication, and to identify appropriate corrective actions. The evaluation report for this event was approved by the Plant Nuclear Safety Committee chairman on September 5,1997.

As a result of this investigation protective covers were added to the "A" and "B" EDG generator control panels. These covers are hinged plexiglas enclosures that protect the exposed controls on the panels without hindering observation of the panels or imnecessarily inhibiting operation of the controls.

. United States Nuclear Regulatory Commission

,. Attachment to Serial: RNP RA/98 0002 Page 3 of 4 A review of other switches outside the control room that could disable safety significant equipment without giving indication or annunciation in the control room was performed. This review identified a list of switches that are being reviewed to determine if additional protective cove- me needed.

Additionally, Auxiliary Operator logs were revised to include position checks for the EDG output breakers and the breaker position for the B Safety Injection pump.

Operations Procedure OP-603," Electrical Distribution," was also revised to include position verification for the 4KV breakers that can be operated locally.

As an added administrative measure, the EDG operating and test procedures were revised to ensure that co./71s manipulated during performance of the procedures are verified to be in the correct position following operation or maintenance.

The results of the event evaluation have been shared with plant personnel in a variety of settings by the Site Vice President, the Director Site Operations, and the Plant General Manager. Examples include a discussion of the event by the Site Vice President in the the onsite newsletter the Robinson Review, a discussion on inadvertent operation of equipment by the Director Site Operations at the October Safety Meetings, and a discussion of the event by the Plant General Manager during the October meeting of the Site Supervisors. Additional training for licensed and non licensed operators on the self checking technique, STAR (i.e., STOP, TillNK, ACT, REVIEW), with emphasis on verification of switch position aller manipulation, was provided during 1997 Cycle 5 continuing training.

4. The Corrective Steps That Will He Taken to Avoid Further Violations An Engineering Services Request has been initiated to review the need for protective covers for other switches or control panels located outside the control room that could disable safety significant equipment without giving indication or annunciation in the control room. This review and the installation of the protective covers determined to be needed will be completed by January 30,1998.

Training will be provided to Operations, Maintenance, and Engineering personnel on switches that could disable safety significant equipment without giving indication or annunciation in the control room by February 28,1998.

Additional procedural controls are being developed to provide added assurance that the potential for equipment mispositioning is thoroughly considered in both the design and operation of safety significant plant equipment. These procedural controls will be in place by January 15,1998.

In addition. CP&L is in the process of determining the best practice in the nuclear industry for increasing the visibility of high safety significant controls on local L

. a* -

.v- United States Nuclea Regul: tory Commission

.. _ Attachment to Serial: RNP-RA/98 0002:

- Page 4 of 4 -

- control panels. The decision on the action to be taken will be made to support implementation during RFO-18.

13ccause the e,rrective actions for the 1993 event were not detailed enough to preclude repetition, a review of the completion of corrective actions was determined to be appropriate.- Licensee Event Report 97-011-00 included a commitment to conduct a review of corrective action completed as a result of selected equipment failures between.1991 and 1994 by June 30,1998.: This review to ensure that corrective actions to prevent recurrence were satisfactorily completed, provides an -

additional measure of assurance that safety significant corrective action from other -  ;

events have been successfully completed.

5. The Date When Full Compliance Will Be Achieved Full compliance has been achieved.

i 1

_ __