ML20207L628

Responds to Violations Noted in Insp Rept 50-261/86-28. Corrective Actions:Event Discussed W/Operators Involved & Disciplinary Action W/Operator & Two I&C Technicians Taken to Emphasize Importance of Following Procedures Correctly

ML20207L628
Person / Time
Site:	Robinson
Issue date:	01/06/1987
From:	Morgan R CAROLINA POWER & LIGHT CO.
To:	NRC OFFICE OF ADMINISTRATION (ADM)
References
RNPD-87-8, NUDOCS 8701120277
Download: ML20207L628 (4)

Text

_..

+

4 Cp&L Carolina Power & tight Company ROBINSON NUCLEAR PROJECT DEPARTMENT POST OFFICE BOX 790 HARTSVILLE, SOUTH CAROLINA 29550 JAN D 61987 Robinson File No 13510E Serials RNPD/87-8 10CFR2.201 U. S. Nuclear Regulatory Commission ATTN: Document Control Dask.

Washington, DC 20555 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET No. 50-261 LICENSE NO. DPR-23 INSPECTION REPORT 86-28

Dear Sir:

Carolina Power & Light Company (CP&L) provides this response to the alleged violation discussed in USNRC Inspection Report 86-28.

Alleged Severity Level IV Violation Part A (RII-86-28-05A-SL4) 10CFR50, Appendix B, Criterion V, as implemented by Section 6 of the CP&L Corporate QA Manual, requires that activities affecting quality be accomplished in accordance with documented instructions, procedures, or drawings.

a. Licensee Abnormal Operating Procedure AOP-010 (Revision 1), at Step 3.1.3, prescribes the manual insertion of control rods to maintain reactor power and core average temperature following the loss of the heater drain pumps.

Contrary to the above, activities affecting quality were not accomplished in accordance with AOP-010, in that the licensee attempted to use emergency boration instead of control rods to maintair. reactor power and core average temperature subsequent to the loss of the heater drain pumps. Overboration of the primary system resulted in a reactor trip on low pressurizer pressure.

i 8701120277 870106 PDR ADOCK 05000261 G PDR gg i ll

,, Lett:r to Do:ument Contest Desk 10CFR2.201 Bert:13 RNPD/87-8 Page 2 RgSPONSE

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

2. Reason for the Violation if Admitted While at 100% power on August 25, 1986, maintenance on the heater drain tanks level controller to control oscillation resulted in both heater drain pumps tripping. Turbine load was decreased as attempts to manually restart the pumps failed.

The control Operator cycled, then inadvertently left open, the emergency boration valve in an effort to reduce reactor power quickly and stabilise the unit. It was espected that use of the emergency boration valve would minimise control rod motion and so minimise reactor core power distribution oscillations following stabilisation from the feedwater transient. This action, however, caused an overboration of the reactor coolant system, followed by a rapid decrease in reactor poder, resulting in system cooldown and a pressuriser low pressure reactor trip from about 13% power.

3. Corrective Steps Which Have Been Taken and Results Achieved The event has been discussed with the operators involved to ensure understanding of the impact of using emergency boration.

4. Corrective Steps Which Will Be Taken to Prevent Repetition of the Violation The Operations staff will review the use of emergency boration and provide additional guidance to operators as well as to Training personnel for inclusion as appropriate in the operator training / retraining programs.

5. Date When Full Compilance Will Be Achieved CP&L Licensee Event Report (LER)86-012, dated September 24, 1986, describes this August 25, 1986 reactor trip in detail. The LER describes discussions held with Operations personnel to ensure understanding of the impact of using emergency boration. The LER also describes review by the Operations staff of the use of emergency boration to determine any additional guidance necessary for inclusion in Operator training /

retraining programs.

• Letter to Do ume;t Conte:1 Desk 10CFR2.201 Seri:18 RNPD/87-8 2 Page 3 The Operations staff will complete the review of the use of emergency boration and provide any necessary additional guidance to Training by February 27, 1987. Training will include this inforn.ation as appropriate in the 1987 operator requalification program. if necessary, Training will also update initial training lesson plans and/or simulator training programs by the end of 1987.

A11eaed severity Level IV Vloistion Part B (RII-86-28-058-5L4) 10CFR50, Appendix B, Criterion V, as implemented by Section 6 of the CP&L Corporate QA Manual, requires that activities affecting quality be accomplished in accordance with documented instructions, procedures, or drawings.

b. Maintenance Surveillance Test Procedure MST-014, " Steam Cenerator Pressure Protection Channel Testing," requires the sequential execution 7 and independent verification of certain steps which could, if performed (

improperly, lead to reactor trips.

~

Contrary to the above, activities affecting quality were not accomplished in accordance with MST-014 in that the control operator involved in the test failed to position the Steam Flow Channel Selector Switch as prescribed by Step 7.6.5, and the Instrumentation and Control Technician responsible for the proper execution of MST-014 failed to verify that the "B" Steam Generator Flow Channel Selector Switch was shifted from the 484 to the 485 position. Execution of subsequent steps resulted in a reactor trip as a result of low water level coincident with steam flow greater than feed flow in "B" steam generator.

RESPONSE

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

2. Reason for the Vloistion if Admitted On September 10, 1986, two Instrumentation and Control (I&C) technicians and a licensed Control Operator were performing MST-014, Revision 9, a monthly test of steam generator pressure protection channels. The channel for "B" Steam Cenerator was being tested. The procedure requires the operator to perform several steps to remove feedwater control from the channel under test and an I6C technician to visually verify completion of these steps. Apparently, the operator overlooked MST-014, Step 7.6.5, which shifts the Steam Flow Channel Selector Switch position to the channel not under test, and the 1&C technicians failed to adequately verify the position of the selector switch.

6 Lett:r t3 Document Contr:1 Desk 10CFR2.201 S:rict: RNPD/87-8 Page 4

3. Corrective Steps Which Have Been Taken and Results Achieved Disciplinary action with the operator and the two I&C technicians has been taken to emphasize the importance of following survelliance test procedures correctly and completely. Also, MST-014 has been changed to improve the human factor aspects of the sign-off steps to minimize the potential of mispositioning the selector switch. Temporary procedure changes have been issued since August 25, 1986, pending permanent revision to MST-014.

4. Corrective Steps Which Will Be Taken to Prevent Repetition of the Violation In addition to the change to MST-014 discussed above, other maintenance i surveillance test procedures which may allow the potential for causing a reactor trip are under evaluation for revisions as necessary to improve the human factor aspects.

5. Date When Full Compliance Will Be Achieved The evaluation of maintenance surveillance test procedures discussed above will be accomplished by March 1, 1987.

CP&L Licensee Event Report (LER)86-013, dated October 10, 1986, describes this September 10, 1986, reactor trip in detail. The LER discusses counseling given to personnel involved as to the particular attention that is necessary during the perforaance of survelliance tests, and in particular, tests involving the manipulation of controls on the Reactor Turble.e Cenerator Board (RTCB). This counseling has been accomplished. The LER also requires I&C Maintenance and Operations to review the report as a means of additional operational experience training. The Maintenance training was completed December 4, 1986. The Operations training is scheduled for completion by February 27, 1987.

If you have any questions concerning this response, please contact Mr. J. M. Curley at (803) 383-1367.

, Very truly yours, k k R. E. Morgan D

Ceneral Manager H. B. Robinson S. E. Plant i

DASJch ces Dr. J. N. Crace H. E. P. Krug i

R. W. Prunty H. J. Young