IR 05000261/1981012

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IE Insp Rept 50-261/81-12 on 810311-0410.Noncompliance Noted:Failure to Control & Maintain Plant Drawings & to Implement Operator Requalification Program
ML14176A631
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 04/28/1981
From: Donat T, Julian C, William Orders, Weise S
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML14176A627 List:
References
50-261-81-12, NUDOCS 8106230594
Download: ML14176A631 (16)


Text

UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGIA 30303 Report No. 50-261/81-12 Licensee: Carolina Power and Light Company 411 Fayetteville Street Raleigh, NC 27602 Facility Name:

H. B. Robinson Steam Electric Plant Docket No. 50-261 License No. DPR-23 Inspection at H. B. Robinson site ear Hartsville, South Carolina Inspectors: __

e__-

S. Weise

Date Signed W. Orders V

Date Signed T. Don Date Signed Approved by: C.

z $7 C. Juli Y, Acting Section Chief, Division of Date Signed Resident and Reactor Project Inspection SUMMARY Inspection on March 11, thru April 10, 1981 Areas Inspected This routine announced inspection involved 288 resident inspector-hours on site in the areas of emergency drill, technical specification compliance, previous enforcement action followup, outstanding items review, plant tour, operations performance, reportable occurrences, housekeeping, site security, surveillance activities, TMI Action Plan requirements, maintenance activities, quality assurance practices, radiation control activities, requalification training, and IE Notice revie Results Of the 16 areas inspected, no violations or deviations were identified in fourteen areas; two violations were found in two areas (Failure to control and maintain plant drawings, paragraph 13.a; Failure to implement the operator requalification program, paragraph 11).

8310 628 0

DETAILS 1. Persons Contacted Licensee Employees

  • R. B. Starkey, Plant Manager
  • J. Bohannon, Manager, Nuclear Training Section
  • J. Curley, Manager, Technical Support
  • C. Bethea, Training Supervisor
  • C. W. Crawford, Manager, Operations and Maintenance
  • R. T. Connolly, Assistant to Plant Manager
  • M. Page, Engineering Supervisor S. Crocker, Manager, Environmental and Radiation Control
  • F. Lowery, Unit 2 Operating Supervisor
  • W. Flanagan, Project Engineer
  • W. Blaisdell, Training Specialist Other licensee employees contacted included technicians, operators, mechanics, security force members, and office personne *Attended exit interview Exit Interview The inspection scope and findings were summarized on March 20, April 3, and April 9, 1981 with those persons indicated in Paragraph 1 above. Licensee representatives acknowledged their understanding of the finding They questioned the training violation, but acknowledged that this area needed improvemen. Licensee Action on Previous Inspection Findings (Closed) Unresolved item 80-30-01. Requalification Training Program. This item dealt with concerns that modifications were being installed and subse quently operated without the benefit of formal training for the operations personne This item is closed based on further review, as discussed in paragraph 1 Unresolved Items Unresolved items were not identified during this inspectio.

Emergency Drill During the period March 10-13, 1981, the inspector participated in the preparation for, monitoring of, and critiquing of the H. B. Robinson annual emergency dril This portion of the inspection is documented in IE Inspection Report 50-261/81-0. Plant Tour a. The inspector conducted plant tours periodically during the inspection interval to verify that monitoring equipment was recording as required, equipment was properly tagged, operations personnel were aware of plant conditions, and plant housekeeping efforts were adequat The inspector determined that appropriate radiation controls were properly established, excess. equipment or material was stored properly, and combustible material was disposed of expeditiousl During tours the inspector looked for the existence of unusual fluid leaks, piping vibrations, pipe hanger and seismic restraint abnormal settings, various valve and breaker positions, equipment clearance tags and component status, adequacy of firefighting equipment, and instrument calibration dates. Some tours were conducted on backshifts and week end During tours of the area of boric acid heat tracing recorders, the inspector noted the following:

1. Safety-related heat tracing temperature recorders frequently exhibit alarm setpoint drift, temperature range drift, and various other mechanical/electrical problem. The numbers which print on the recorder paper for each heat tracing circuit are illegible, requiring the operator to watch the entire recording sequence to determine circuit recorder tempera tur. On March 27, 1981, on recorder #4 for Safety Injection system heat tracing:

a. Circuit 50, Leakoff Line forvalves SI-868 A, B, and C was not alarming, but its temperature was at 1430 F. Alarm setpoint is 1500 Circuit 52 was in the alarm conditio c. Circuit 53, Line to valve SI-868 A was alarming at 1940 F, a satisfactory temperatur Further inspection revealed that the recorder alarm cam had slipped one notch so that the circuit 50 alarm appeared on the circuit 52 indicat ing light and circuit 52 alarmed on the circuit 53 indicating ligh While no violations or deviations were noted, the inspector expressed concern over the reliability and maintenance of the heat tracing recorder systems. The licensee has initiated corrective action to monitor recorder system reliabilit The inspector will review this area at a later dat Inspector followup item (50-261/81-12-01).

  • 3 Plant Operations Review The inspector periodically during the inspection interval reviewed shift logs and operations records, including data sheets, instrument traces, and records of equipment malfunctions. This review included control room logs, auxiliary logs, operating orders, standing orders, jumper logs and equipment tagout records. The inspector routinely observed operator alertness and demeanor during plant tours. During abnormal events, operator performance and response actions were observed and evaluated. The inspector conducted random off-hours inspections during the reporting interval to assure that operations and security remained at an acceptable leve Shift turnovers were observed to verify that they were conducted in accordance with approved licensee procedures. The inspector had no further comment.

Technical Specification Compliance During this reporting interval, the inspector verified compliance with selected limiting conditions for operation (LCO's) and reviewed results of selected surveillance test These verifications were accomplished by direct observation of monitoring instrumentation, valve positions, switch positions, and review of completed logs and record The licensee's com pliance with selected LCO action statements were reviewed as they happene The inspector observed no violations or deviation. Physical Protection The inspector verified by observation and interview during the reporting interval that measures taken to assure the physical protection of the facility met current requirement Areas inspected included the organi zation of the security force, the establishment and maintenance of gates, doors and isolation zones in the proper condition, that access control and badging was proper, that search practices were appropriate, and that escorting and communications procedures were followe.

Review of IE Notices IEN's The inspector verified that IE Notices had been received onsite and reviewed by cognizant licensee personne Selected applicable IE Notices were discussed with licensee personnel to ascertain the licensees actions on these items. The inspector also verified that IE Notices were reviewed by the Plant Nuclear Safety Committee in accordance with facility admini strative policy. Licensee action on the following IE Notices were reviewed by the inspector and are close IE Notices 79-37 80-19 80-03 80-23 80-05 80-24 80-07 80-25

4, 80-10 80-31 80-12 80-32 80-13 80-36 80-14 80-39 80-16 80-40 1 Requalification Training Program The operator requalification training program was reviewed, and findings are discussed below:

a. Training On Facility Design Changes References:

-

10 CFR 55, Appendix A

- Technical Specification 6. ANSI N18.1-1971 Section CFR 55, Appendix A, states in part that the licensed operator requalification program include training such that each licensed operator and senior operator is cognizant of facility design changes, that requalification training (e.g. on design changes) based solely on individual study is not an acceptable substitute for a lecture series, and that written examinations which determined licensed operators' and senior operators' knowledge of subjects covered in the requalification program (e.g. design changes) be administere The H. B. Robinson licensed operator.requalification program currently does not adequately provide for formal training of operations personnel in order to familiarize them with installed modifications. As a rule, operations personnel are made aware of modifications through routine routing of the modification packag These modification packages contain information such as installation instructions, and logistics information but do not afford the required, concise, operations-related information. The routing slip, attached to each package, is initialed or signed by the operators/senior operators and is subsequently placed in the training files as documentatio Discussions with four operating crews revealed that the information presently presented in the modification packages does not provide them adequate information concerning the operational aspects of plant modification A review of the operator and senior operator requalification exams administered during 1979 and 1980 revealed that no plant design change questions were asked, thus indicating that the operating staff has, historically, not been evaluated concerning their knowledge of facility design change b. Preplanned Lectures References:

-

10 CFR 55, Appendix A

- Technical Specification 6. CFR 55, Appendix A, requires in part that the requalification program include preplanned lectures on a regular and continuing basis and further specifies the subject areas of those lectures as detailed below:

1. Theory and principles of operatio. General and specific plant operating characteristic. Plant instrumentation and control system. Plant protection system. Engineered safety system. Normal, abnormal, and emergency operating procedure. Radiation'control and safet.

Technical specification. Applicable portions of Title 10, Chapter 1, Code of Federal Regulation H. B. Robinson's Operator Requalification Program entails the following categorization of formal classroom lectures:

1. Theory and Principles of Operation 2. General and Specific Plant Operating Characteristics 3. Plant Instrumentation and Control Systems 4. Normal and Abnormal Procedures and Emergency Instructions 5. Radiation Control and Safety 6. Technical Specifications Chemistry Quality Assurance Responsibilities Heat Transfer, Fluid Flow, and Thermodynamics 1 Mitigating Core Damage A review of Robinson's existing preplanned lesson plans revealed that, of the subjects detailed above, the following comprise the extent of written approved lesson plans:

1. Nuclear Theory Reactor Theory Mathematics Heat Transfer and Fluid Flow Metallurgy Radiation Protection Reactor Coolant System Turbine 9. Auxiliary Feedwater 1 Reactor Construction 1 Chemical and Volume Control System 1 Safety Injection System 1 Residual Heat Removal System 1 Chemistry 1 Circulating Water 1 Radiation Monitoring

1 Service Water 1 Primary Sampling 1 Component Cooling Water 2 Electrical System Lesson plans on the required subject areas detailed below apparently have never been formulated:

a. General and specific plant operating characteristics b. Plant Instrumentation and Control Systems c. Plant Protection Systems d. Normal, Abnormal, and Emergency Operating Procedures e. Technical Specifications CFR (Applicable sections)

Failure to provide adequate training and to examine operator's knowledge of plant design changes and failure to establish and/or maintain preplanned lectures, (i.e., lesson plans) on all subjects required by 10 CFR 55, Appendix A violates the requirements of 10 CFR 55, Appendix A, as implemented by Technical Specification 6.4.1. (50-261/81 12-02).

12. TMI Action Plan Items a. TAP No. I.A.1.3 Shift Manning The inspector reviewed the licensee's administrative instructions for implementation of overtime limitations. The licensee does not fully meet these overtime requirements and has documented its disagreement with some of the requirements and guidelines in CP&L letter NO-81-346 dated February 26, 1981, to the Division of Licensing, Office of NR b. TAP No. I.C.1 Short Term Accident and Procedure Review Small break LOCA event emergency procedures have been reviewed as documented in IE Inspection Reports 50-261/80-28 and 50-261/81-0 NUREG 0737, TAP No I.C.1. item 1 is close c. TAP N III.D.3.3, NUREG 0578, Section 2.1. Improved In-plant Iodine Instrumentation The equipment and associated training and procedures for accurately determining the airborne iodine concentration in areas within the facility where plant personnel may be present during an accident were inspected. Based on a review of the equipment, Health Physics Pro cedures HP-3 and HP-16, and discussions with Health Physics personnel, the inspector determined that the current iodine sampling procedures are not as reported in CP&L letter GD-79-3306, Lessons Learned Short Term Requirements, dated December 31, 1979. This letter states that Robinson has cart-mounted (portable) iodine air sampling equipment with

a single channel analyzer (SCA)

capable of being calibrated for Iodine-131. Due to an apparent design or calibration deficiency, the licensee has been unable to make the portable analyzer perform reliabl Instead, the licensee's procedures call for collecting in-plant iodine grab samples by placing silver zeolite cartridges in portable air sampling equipment and/or in the continuous air monitors with SCA. Based on discussions with D. Collins, Radiological Assess ment Branch, ONRR, the present procedures for in-plant iodine monitoring appear to meet the requiremen NUREG 0737, TAP N III.D.3.3, item 1 is close TAP No. I.C.6 Correct Performance of Operating Activities This item requires inspector review of the implementation of procedures to assure correct performance of operating activities as a means of reducing human errors and improving the quality of operation The inspector reviewed the following against NUREG 0737 and CP&L's letter, Post TMI Requirements contained in NUREG 0737, dated December 31, 1980:

1. Operating and General Procedures OP-3B Electrical OP-6A Service Water OP-14A Auxiliary Feedwater OP-25A Reactor Coolant OP-34C-1 and -2 Waste Disposal (liquid)

OP-35C Waste Disposal (gaseous)

OP-40A Component Cooling Water OP-42A Safety Injection and Containment Spray OP-50A Low Temperature Overpressure Protection OP-52A Containment Integrity OP-7A Diesel Generators GP-1 Fill and Vent Reactor Coolant System GP-2 Cold Solid to Hot subcritical 2. Operating Work Procedures (OWP)

of Appendix A to Standing Order 9 Section 1 Auxiliary Feedwater Section 2 Containment Air Handling Section 3 Component Cooling Water Section 4 Containment Spray Section 5 Chemical and Volume Control Section 7 Diesel Generators Section 9 Containment Fan coolers Section 12 Reactor Coolant Section 13 Residual Heat Removal Section 16 Safety Injection Section 17 Service Water Section 11.6 and 4.1.5 of the plant administrative instructions in conjunction with ANSI 18.7-1976 section 5. *

The inspector determined that the licensee appears to have fully implemented their commitments as described in their December 31, 1980 letter to NRR. In the area of second independent equipment verification, the inspector had the following concerns:

1. Diesel Generators - Double verification is not required by OP-7A or section 7 of the OWP's for the diesel fuel oil and air start system. Boric Acid Tanks, Transfer Pumps, and Filter -

OWP's for these components do not require independent verification for removing them from or restoring them to servic.

Low Temperature Overpressure Protection -

OP-50A does not require independent verification. This is in accordance with the licensee's position that OPs which are used during unit shutdown condition do not require such check. Standing Order 9, the general guidance for OWP's does not stipulate which systems require double verification when a special (vice standing) OWP is written. The licensee stated a revision was in process to correct thi The inspector feels that the above three systems are sufficiently important to plant safety to justify independent verificatio The licensee stated that these areas would be reviewed in light of the inspector's concern These concerns are an open item (50-261/81-12-03).

NUREG 0737, TAP No. I.C.6 is close.

Outstanding Items Review (Closed)

Open item 80-30-0 Drawing Control Administatio The inspector reviewed the following areas pertinent to drawing control:

1. Safety-related Controlled Wiring Diagrams (CWD's). The inspector reviewed CWD's maintained in the Engineering Sub-unit, the Control Room, the Computer Room, and the Instrumentation and Control (I&C)

Sho (a) As outlined below, the current revisions of safety-related drawings were not being maintained for use by plant personne Revision in use at:

CWD Engineering I&C Shop Control Room 500B452 SH. 191

8

500B452 SH. 192

7

500B452 SH. 214

6

  • 2

500B452 SH. 216

5

500B452 SH. 237

5

500B452 SH. 238

6

500B452 SH. 239

5

500B452 SH. 279

1

500B452 SH. 287

3

500B452 SH. 290

4

The licensee stated that the I&C Shop CWD's were actually more current, since changes had been made to these drawings as modifications occurred. However, the revision numbers were not updated at the time of the drawing revisions. The licensee acknowledged that the CWD's are in need of updating and re-issue. Action was taken by the licensee to institute a new drawing control program in November, 1980. Procedures were placed in Volumes 1, 20, and 21 of the Plant Operating Manual, and a memorandum from the Plant Manager to plant management concerning existing sets of drawings and their identification as Controlled or For Information Only was issued December 12, 198 The inspector noted that the Control Room and Computer Room sets of CWD's were not marked in accordance with the December 12, 1980 memo randum, and should have been properly marked or destroye. Safety-related Piping and Instrumentation Diagrams (P&ID's).

The inspector reviewed controlled P&ID's maintained in the Engineering Sub-unit, the Control Room, the Auxiliary Building, and the Vaul The following discrepancies were noted:

(a) The vault master drawing index does not always reflect the latest revision, when other controlled copies in use in the plant d (b) Some P&ID's at the Auxiliary Operator's desk have been damaged or los One drawing being maintained in this controlled copy was supercede (c) The Control Room laminated P&ID's were not marked as con trolled copies as required by the memorandum of December 12, 198 This was promptly corrected by the license (d) Waste evaporator drawings were found at the 'B'

waste evaporator panel that were not marked as required by the December 12, 1980 memorandu (e) Heat tracing drawing 5379-4524, Revision 7, does not accurately reflect the location of Technical Specification required circuit 69. This circuit covers the piping between the C charging pump suction and the volume control tank. An unapproved drawing on tablet paper had been stapled to the above drawing in the I&C Shop to reflect the circuit locatio (f)

Drawing CP-200-5379-685, Revision 11, does not accurately reflect the location of valve CVC 356A and erroneously shows it being cappe.

New or revised P&ID's and CWD's resulting from plant-initiated modifications, TMI Action Plan requirements, and Fire Protection requirements have not been issued in either controlled or infor mation only for In several instances these modifications have been installed and operable for at least one yea Thus, the control room has no drawings to cover these modification The licensee personnel stated that some of the plant modification drawings had been provided to the maintenance shops pending formal drawing approval and issuance and that final review and approval of plant modifications was holding up drawing issuanc The inspector expressed concern that the routing procedure for plant modifications resulted in operating procedures and drawings being issued many months after the equipment was in use by operations personne. The drawing control program instituted in November, 1980 requires that holders of controlled drawings be notified of pending drawing changes (due to installed modifications or errors discovered) via a Drawing Revision Notification (DRN).

As of April 1, 1981 the status of DRN's was as follows:

(a) Four drawing change requests were received by the drafting personnel on December 11, 198 These were processed for issuance of DRN's by January 30, 198 No DRN's have been issued or distribute (b) Two drawing change requests were received by drafting personnel on February 12, 198 They have not yet been processed for issuance of a DR The inspector acknowledges the licensee's identification of many drawing control problems and their issuance of procedures for corrective action. The established program appears adequate but has not been fully implemented as require Based on the unsatisfactory condition of drawings which has existed throughout the plant for several years, the unimplemented drawing revision notification and drawing marking program, and the length of time required to provide operations personnel with drawings resulting from plant modifications, this failure to control and maintain plant drawings is a violation of the requirements of Criterion VI of Appendix B of 10 CFR 5 (50-261/81-12-04). (Open) Open item 80-30-0 In a previous inspection report (50-261/80-30)

a review of auxiliary electrical Technical Specification 3.7 revealed no requirement for emergency electrical power when the plant is less than critical. The licensee maintains that the present auxiliary electrical technical specification is sufficien Having

further reviewed this item, the inspector is concerned that, as a minumum, one source of off site power and one diesel generator should be required to be operable when the plant is in the cold shutdown and refueling modes. This requirement would ensure that the facility can be safely maintained in the shutdown or refueling modes for extended periods with sufficient instrumentation and control capability. This position is consistent with NUREG-0452 Revision 3, Standard Technical Specifications, for Westinghouse Pressurized Water Reactors, Section 3/4.8.1 and 3/4.8.2. This item remains open pending further review with the Region II staf c. (Closed)

Inspector Follow-up Item 78-16-0 This item dealt with the need for operator administrative guidance on logging of known faulty indications. This is similar to violation 81-02-02 and is addressed in the corrective action of the CP&L response letter dated March 2, 1981 to Inspection Report 81-0 This item is close (Closed)

Open Item 80-30-0 This item identified that the carbon dioxide fire suppression system for the emergency diesel-generators and the halon fire suppression system for the electrical equipment rooms were both rendered inoperable during periods when both A and B emergency diesel generators were run and the equipment contained in the electrical equipment rooms was energized. A review of the fire pro tection Technical Specification revealed that fire protection for specified equipment is only required to be operable if the equipment it is protecting is required to be operabl Emergency power is not required to be operable during shutdown and/or refueling by current Robinson Technical Specifications, thus the licensee maintains that fire protection for that equipment was not require Subsequent conversations with licensee representatives indicate that other fire protection equipment is available during diesel generator operations and that a fire watch may also be statione This item is close e. (Closed)

Inspector followup item 80-15-0 This item dealt with verification of administrative controls to prevent improper defeat of the containment isolation signals to and manual opening of the purge valves. The inspector reviewed correspondence between CP&L and NRR since November 197 Administrative controls are in the form of procedural steps and precautions in section 9 of Precautions, Limit ations, and Setpoints; General Procedure-2; General Procedure-6; and in the Annunciator Procedures. Manual operation of the purge valves is not part of the valve design. The inspector had no further question This item is close.

Licensee Event Report (LER) followup The inspector reviewed the following LER's to verify that the report details met license requirements, identified the cause of the event, described appropriate corrective actions, adequately assessed the event and addressed any generic implications. Corrective action and appropriate licensee review of the below events was verifie The inspector had no further comment LER Event 80-08 Failure of PT 495 80-13 Improper operator action for Flux Tilt condition 80-20 A SI Pump Breaker problem 81-05 Reactor coolant system leak 81-08 Module LC 475A failure 80-10 Hagan Module output shift

R-0 UNITED STATES NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGIA 30303 APR 14 1981 Docket No /81-07 50-325/81-07 Carolina Power and Light Company ATTN: J. A. Jones, Senior Executive Vice President and Chief Operating Officer 411 Fayetteville Street Raleigh, NC 27602 Gentlemen:

This refers to the meeting held with Mr. L. Eury, Senior Vice President, Power Supply and others of your staff in the Region II office on March 30, 1981 at our request.. This meeting related to activities authorized by NRC Operating Licenses DPR-62 and DPR-71 for Brunswick and OPR-23 for Robinso The subjects discussed are detailed in the enclosed inspection repor Our concern about the effectiveness of your management controls were expressed to you at the meeting and your positive response to our concern is appreciate It is our opinion that this meeting was beneficial and has provided for-a better understanding of inspection and enforcement issue In accordance with Section 2.790 of NRC's "Rules of Practice", Part 2, Title 10, Code of Federal Regula tions, a copy of this letter and enclosure will be placed in the-NRC's Public Document Roo Should you have any questions concerning this matter, we will be pleased to discuss the

Sincerely, ames P. O'Reilly

'rector

Enclosure:

Inspection Report Nos. 50-324/81 50-325/81-07, and 50-261/81-11

REGION I1 101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGIA 30303 Report Nos. 50-324/81-07, 50-325/81-07, and 50-261/81-11 Licensee: Carolina Power and Light Company 411 Fayetteville Street Raleigh, NC 27602 Fac lity Names:

Brunswick 1, 2 and Robinson 2 Docket Nos. 50-324, 50-325, and 50-261 License Nos. DPR-62, DPR-71 and DPR-23 Meeting in Region II office, Atlanta, Georgia Approved by:

C. JuliaA',Acting Secti Chief RRPI Branch Date Signed SUMMARY An enforcement meeting was held on March 30, 1981, to discuss investigation findings concerning offsite releases from the auxiliary boilers and the environ mental effluents monitoring programs at the Brunswick site and radiation over exposure during steam generator work at the Robinson sit DETAILS I. Personnel Attending Meeting Carolina Power and Light Company (CP&L)

L. Eury, Senior Vice President, Power Supply B. Furr, Vice President, Nuclear Power P. Howe, Vice President, Technical Services J. O'Neill, Legal Counsel for CP&L C. Dietz, General Manager, Brunswick R. Starkey, Jr., General Manager, Robinson G. Oliver, Manager, Environmental and Radiation Control S. Crocker, E&RC Supervisor, Robinson Office of Inspection and Enforcement, Region II James P. O'Rei.ly, Director E. Alderson, Director, Enforcement and Investigation Staff R. C. Lewis, Acting Director, Division of Resident & Reactor Project Inspection P. Kellogg, Acting Chief, Reactor Projects Branch 2, RRPI C. Julian, Acting Chief, Section IC, RRPI C. M. Hosey, Acting Chief, Facilities Radiation Protection Section R. Butcher, Project Inspector, Section IC, RRPI 0. F. Johnson, Senior Resident Inspector, Brunswick R. J. Marsh, Regional Investigator J. M.-Puckett, Radiation Specialist J. R. Wray, Radiation Specialist 2. Management Meeting An NRC representative summarized the issues raised by the investigation of offsite releases from the auxiliary boilers and the environmental effluents monitoring program at Brunswick and stated the preliminary findings. CP&L representatives acknowledged their understanding of the general concerns and requested a followup meeting to respond to specific issues. NRC represent atives agreed that another meeting will be hel An NRC representative stated that from review of Robinson personnel radiation exposure records,after adjustments. for spatial variation of radiation fields, it appears that three individuals received slight over exposure during recent steam generator work. This will be cited-by the NRC as a violation. CP&L representatives acknowledged their understanding o the finding.