ML14175B488
| ML14175B488 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 10/23/1987 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Utley E CAROLINA POWER & LIGHT CO. |
| References | |
| NUDOCS 8710290186 | |
| Download: ML14175B488 (25) | |
See also: IR 05000261/1987010
Text
OCT
3 1987
Docket No. 50-261
License No. DPR-23
Carolina Power and Light Company
ATTN:
Mr. E. E. Utley
Senior Executive Vice President
Power Supply and Engineering
and Construction
P. 0. Box 1551
Raleigh, NC 27602
Gentlemen:
SUBJECT:
ENFORCEMENT CONFERENCE SUMMARY
(NRC INSPECTION REPORT NO. 50-261/87-10)
This letter refers to the Enforcement Conference held at our request on
September 17, 1987.
This meeting concerned activities authorized for your
H. B. Robinson Steam Electric Plant.
The issues discussed at this conference
related to environmental qualification of electrical equipment. A summary, a
list of attendees, and a copy of your handout are enclosed.
.0
It is our opinion that this meeting was beneficial and has provided a better
understanding of the inspection findings, the enforcement issues, and the
status of your corrective actions.
We are continuing our review of these
issues to determine the appropriate enforcement action.
In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2,
Title 10, Code of Federal Regulations, a copy of this letter and its enclosures
will be placed in the NRC Public Document Room.
Should you have any questions concerning this matter, please contact us.
Sincerely,
J. Nelson Grace
Regional Administrator
Enclosures:
1. Enforcement Conference Summary
2. List of Attendees
O 3. Handout
cc w/encls:
(See page 2)
S71029O 126 371023
ADOCK 05000261
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OCT 2 31987
Carolina Power and Light Company
2
cc w/encls:
G. P. Beatty, Jr., Vice President
Robinson Nuclear Project Department
R. E. Morgan, Plant General Manager
bcc w/encls:
J. Lieberman, DOE
G. R. Jenkins, EICS
NRC Resident Inspector
Document Control Desk
State of South Carolina
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ENCLOSURE 1
ENFORCEMENT CONFERENCE SUMMARY
The licensee did not take exception to any of the information described in the
inspection report.
The licensee acknowledged that the potential enforcement
issues identified in the inspection report did, in fact, constitute violations
of NRC requirements but considered that three of the items did not merit NRC
enforcement action. A description of the items and the basis for the licensees
positions are outlined on pages 14-19 of the licensee's handout.
In addition,
CP&L stated that a detailed write-up of their position and presentation would
be submitted to the NRC within 30 days.
ENCLOSURE 2
ENFORCEMENT CONFERENCE
LIST OF ATTENDEES
Licensee:
Carolina Power & Light Company
Date:
September 17, 1987
Facility: H. B. Robinson Steam Electric
IR No.:
50-261/87-10
Plant Unit 2
Location:
NRC Region II Office
Atlanta, Georgia
Carolina Power & Light Company
E. E. Utley, Senior Executive Vice President, CP&L
M. A. McDuffie, Senior Vice President Nuclear Generation, CP&L
L. Eury, Senior Vice President, Operations Support
S. R. Zimmerman, Manager, Nuclear Licensing
R. B. Richey, Manager, Licensing and Nuclear Manager
P. Salas, Senior Licensing Engineer
G. Beatty, Vice President, H. B. Robinson Nuclear Project
A. R. Wallace, Manager, Technical Support, H. B. Robinson Steam Electric Plant
(RSEP)
P. W. Howe, Vice President Brunswick Nuclear Project, CP&L
C. R. Dietz, General Manager, BSEP, CP&L
E. R. Eckstein, Manager - Technical Support, BSEP, CP&L
K. Enzor, Director, Regulatory Compliance, BSEP
B. Parks, Jr., Engineer Supervisor, BSEP, CP&L
USNRC Region II
M. L. Ernst, Deputy Regional Administrator, RH
L. A. Reyes, Director, Division of Reactor Projects, RH
A. F. Gibson, Director, Division of Reactor Safety, RII
G. R. Jenkins, Director, Enforcement and Investigation Coordination
Staff (EICS)
D. M. Verrelli, Chief, Reactor Projects Branch 1, DRP
A. R. Herdt, Chief, Engineering Branch, DRS
H. C. Dance, Chief, Reactor Projects Section 1,
T. E. Conlon, Chief, Plant Systems Section, DRS
P. E. Fredrickson, Chief, Reactor Projects Section 1A, DRP
H. J. Krug, Senior Resident Inspector, RSEP
W. H. Ruland, Senior Resident Inspector, BSEP
A. B. Ruff, Reactor Inspector, DRS
S. J. Vias, Project Engineer, DRP
B. Uryc, Enforcement Coordinator, EICS
NRC Headquarters
E. Merschoff, Chief, Vendor Inspection Branch, Office of Nuclear Reactor
Regulation (NRR)
H. J. Wong, Senior Enforcement Specialist, Office of Enforcement
E. Eccleston, Senior Project Manager, NRR
R. C. Wilson, Engineer, NRR
ENCLOSURE 3
H. B. ROBINSON STEAM ELECTRIC PLANT
UNIT NO. 2
REVIEW OF FINDINGS
RELATED TO
ENVIRONMENTAL QUALIFICATION
AT
NRC REGION 11
HEADQUARTERS
SEPTEMBER 17, 1987
MIS:87-4282(1)
Erclosure 3
2
AGENDA
1. DESCRIPTION OF PROGRAM
2. OVERVIEW OF FINDINGS
3. FINDINGS INVOLVING EXTENUATING CIRCUMSTANCES
4. FINDINGS CP&L BELIEVES DO-NOT MERIT ENFORCEMENT ACTION
5. PROGRAM IMPROVEMENTS
6. PROGRAM ASSESSMENT
MIS:87-4282(2)
Enclosure 3
3
H. B. ROBINSON EQ PROGRAM
DEVELOPMENT
VINTAGE PLANT, PRIOR TO APPX, B QA PROGRAM
DOR GUIDELINES
CONSISTENT WITH INDUSTRY PRACTICE
PERCEPTION OF EQ REQUIREMENTS HAS BROADENED
COSTLY, CHANGING ENVIRONMENT
REVIEW
INITIAL INTERNAL PROCESS
SUBMITTAL TO NRC
INTERNAL AUDITORS
NRC INSPECTIONS
IMPLEMENTATION
.*
FILE DEVELOPMENT
EQ COORDINATOR AT SITE
SITE PROCEDURES UPGRADED
TRAINING COMPLETED
COMMITMENT
ACTIVE IN INDUSTRY GROUPS
PROACTIVE REVIEW
PROMPT RESOLUTION OF DEFICIENCIES
CONSERVATIVE CORRECTIVE ACTION
PROMPT REPORTING PER NRC GUIDELINES
STATUS
FINDINGS RESOLVED IN CV
ADDITIONAL REVIEW UNDERWAY
.*
TESTING PROGRAM COMPLETED
EQUIPMENT FULLY QUALIFIED
MIS:87-4282(3)
Enclosure 3
4
STAFF FINDINGS
CABLE QUALIFICATION (87-10-01)
CROUSE-HINDS PENETRATIONS (87-10-02)
LIMITORQUE MOTOR OPERATORS (87-10-03)
CABLE ENTRANCE SEALS (87-10-04)
RAYCHEM SPLICES - CP&L IDENTIFIED FAILURE TO FOLLOW
PROCEDURE (87-10-05)
LOOP ACCURACY (87-10-06)
TAPED SPLICES - CP&L IDENTIFIED (87-10-07)
0
MIS:87-4282(4)
Enclosure 3
5
FINDINGS INVOLVING EXTENUATING CIRCUMSTANCES
MIS:87-4282(5)
Enclosure 3
6
QUALIFICATION OF CABLE (87-10-01)
STAFF FINDING
-
CABLE IDENTIFICATION - TYPE AND USE
-
QUALIFICATION DOCUMENTATION - INSULATION RESISTANCE
CP&L'S PERSPECTIVE
-
METHODOLOGY OF IDENTIFICATION VALID, IMPLEMENTATION
WAS DEFICIENT
-
QUALIFICATION OF CABLE WAS CONSISTENT WITH INDUSTRY
TESTING STANDARDS AT THE TIME
-
DEFICIENCY EXISTED IN THAT UNDOCUMENTED PVC CABLE
FOUND IN CP&L WALKDOWN
-
SAMUEL MOORE CABLE A R.G. 1.97 ISSUE ONLY
-
ENVIRONMENT OUTSIDE CV REQUIRED NO SPECIAL
QUALIFICATION
.
BACKGROUND
-
CABLE LIST DEVELOPED FROM ORIGINAL PROCUREMENT
DOCUMENTATION; KERITE AND CONTINENTAL
-
1980 SAMPLE WALKDOWN SUPPORTED DOCUMENTATION REVIEW
-
CP&L 90 DAY REPORT IDENTIFIES CABLE AND
DOCUMENTATION
-
NRC MAY 21, 1981 SER REQUESTS FURTHER INFORMATION
-
NRC SER/FRANKLIN TER JANUARY 5, 1983 ACCEPTS KERITE;
CITES CONTINENTAL DEFICIENCIES
-
CP&L MAY 20, 1983 RESPONSE TO IOCFR50.49 CLOSES
CONTINENTAL DEFICIENCIES
-
CP&L MARCH 2, 1984 LETTER CONFIRMS CONTINENTAL
QUALIFICATION
-
NRC MARCH 19, 1985 SER:
"THE PROPOSED RESOLUTION
FOR EACH OF THE ENVIRONMENTAL QUALIFICATION
DEFICIENCIES IDENTIFIED FOR ROBINSON 2 IS
ACCEPTABLE"
MIS:87-4282(6)
Enclosure 3
7
QUALIFICATION OF CABLE (87-10-01)
(CONTINUED)
ROOT CAUSE
-
INADEQUATE DOCUMENT REVIEW
CORRECTIVE ACTION
-
WALKDOWN CONDUCTED DURING 1987 OUTAGE
-
ADDITIONAL DOCUMENT REVIEW COMPLETED
-
JCO DEVELOPED AND SUBMITTED
-
ADDITIONAL CABLE TEST CONDUCTED
SAFETY SIGNIFICANCE
-
TESTING AND ADDITIONAL ANALYSIS HAVE CONFIRMED
COMPONENTS WOULD HAVE PERFORMED THEIR SAFETY
FUNCTION
SUMMARY
-
A DOCUMENTATION DEFICIENCY EXISTED FOR PVC CABLE
IDENTIFIED IN CP&L WALKDOWN
-
PROMPTLY REPORTED (LER 87-007)
-
UNDOCUMENTED CABLE REPLACED WITH KNOWN QUALIFIED
CABLE PRIOR TO STARTUP
-
A SAMPLE OF SAMUEL MOORE PVC CABLE REMOVED HAS BEEN
QUALIFIED BY TESTING
-
KERITE AND CONTINENTAL CABLE INSULATION RESISTANCE
CONFIRMED ACCEPTABLE BY TESTING
MIS:87-4282(7)
CABLE ENTRANCE SEALS (87-10-04)
STAFF FINDING
-
ASCO SOLENOID VALVES AND ROSEMOUNT 1153A
TRANSMITTERS NOT QUALIFIED BECAUSE ELECTRICAL
CONNECTION PENETRATIONS WERE NOT SEALED,
CP&L'S PERSPECTIVE
-
DEFICIENCY EXISTED SINCE THE INSTALLED CONFIGURATION
WAS NOT SUPPORTED BY QUALIFICATION DOCUMENTATION.
BACKGROUND
-
ASCO TEST REPORT INADVERTENTLY MISINTERPRETED TO
SUPPORT QUALIFICATION WITHOUT SEALS
-
ROSEMOUNT TESTING CONFIGURATION IMPLIED USE OF SEALS
NOT NEEDED.
-
INSTALLED CONFIGURATION BASED ON CP&L INTERPRETATION
OF TEST REPORTS.
ROOT CAUSE
-
INADVERTENT MISINTERPRETATION OF TEST DATA.
CORRECTIVE ACTION
-
SEALS INSTALLED ON ASCO SOLENOIDS AND ROSEMOUNT
TRANSMITTERS DURING 1987 REFUELING OUTAGE.
-
INITIATED A SYSTEMATIC REVIEW OF EQ FILE
DOCUMENTATION.
SAFETY SIGNIFICANCE
-
ASCO SOLENOIDS WOULD HAVE PERFORMED THEIR SAFETY
FUNCTION.
-
ROSEMOUNT TRANSMITTERS REQUIRED SEALS.
MIS:87-4282(8)
Enclosure 3
9
CABLE ENTRANCE SEALS (87-10-04)
(CONTINUED)
SUMMARY
-
DEFICIENCY EXISTED.
-
PROMPTLY REPORTED (LER 87-007)
- DEFICIENCY CORRECTED BY INSTALLATION OF SEALS PRIOR
TO STARTUP.
MIS:87-4282(9)
Enclosure 3
10
QUALIFICATION OF RAYCHEM SPLICES (87-10-05)
(CP&L IDENTIFIED)
STAFF FINDING
-
CP&L FILES DID NOT ADEQUATELY DOCUMENT QUALIFICATION
OF NUMEROUS ELECTRICAL SPLICES USING RAYCHEM
SLEEVING.
CP&L'S PERSPECTIVE
-
A DEFICIENCY EXISTED IN THAT THE SPLICES DID NOT
COMPLY WITH INSTALLATION PROCEDURES.
-
WITH ONE EXCEPTION, ALL SPLICES QUALIFIABLE.
BACKGROUND
-
MID-1986 SEVERAL UTILITIES NOTED RAYCHEM SPLICE
PROBLEMS.
-
CP&L PROACTIVE IN WORKING WITH NRC AND INDUSTRY ON
THE RAYCHEM ISSUE.
-
NRC ISSUED IEN 86-53 ON JUNE 26, 1986.
-
CP&L SCHEDULED INSPECTIONS AT NEXT REFUELING OUTAGE.
-
CP&L DISCOVERED QUESTIONABLE RAYCHEM INSTALLATION.
(LER 87-003)
-
INSPECTION SUBSTANTIALLY COMPLETE BEFORE AUDIT.
-
INSPECTION TEAM FOUND SPLICE INSPECTION CRITERIA AND
PROGRAM ACCEPTABLE.
ROOT CAUSE
-
INADEQUATE TRAINING IN SELECTION AND INSTALLATION OF
SPLICES.
SAFETY SIGNIFICANCE
-
WITH ONE EXCEPTION, ALL COMPONENTS WOULD HAVE
PERFORMED THEIR SAFETY FUNCTION.
MIS:87-4282(10)
Enclosure 3
11
QUALIFICATION OF RAYCHEM SPLICES (87-10-05)
(CONTINUED)
CORRECTIVE ACTION
-
INSPECTION PROGRAM ESTABLISHED TO ADDRESS ALL
SPLICES.
-
SPLICES REPLACED WITH KNOWN QUALIFIED SPLICES.
-
PROCEDURE REVISED TO INCLUDE ADDITIONAL INDEPENDENT
VERIFICATION.
-
ADDITIONAL PERSONNEL TRAINING PROVIDED
SUMMARY
-
DEFICIENCY EXISTED IN THAT INSTALLATION PROCEDURE
NOT PRECISELY FOLLOWED,
-
SELF-IDENTIFIED; PROACTIVE RESPONSE.
-
PROMPTLY REPORTED (LER 87-003).
-
EXTENSIVE CORRECTIVE ACTION; SPLICES REPLACED FOR
CONSERVATISM.
-
INSPECTION TEAM CONCURRED WITH CP&L ACTION.
MIS:87-4282(11)
Enclosure 3
12
LIMITORQUE MOTOR OPERATORS (87-10-03)
STAFF FINDING
-
UNQUALIFIED GREASE USED IN VALVE OPERATORS (744A &
B, 866A & B).
-
T-DRAINS AND GREASE RELIEF VALVES WERE MISSING (744A
& B, 866A & B).
-
UNQUALIFIED MOTOR LEAD SPLICES (866A & B).
-
UNQUALIFIED INTERNAL WIRING (744A & B).
-
UNQUALIFIED TERMINAL BLOCK (744A & B).
-
UNQUALIFIED MOTOR BRAKE (744A & B).
CP&L'S PERSPECTIVE
-
DEFICIENCIES EXISTED ON 866A & B.
-
744A & B QUALIFIED AS IS DUE TO SHORT DURATION OF
SERVICE,
.*
BACKGROUND
-
ORIGINAL MOTOR OPERATORS NOT CONSIDERED QUALIFIED BY
STAFF.
-
866A & B UPGRADED TO QUALIFIED CONFIGURATION.
-
744A & B SAFETY FUNCTIONS REDEFINED.
-
GREASE SELECTED PER CONSULTATION WITH TEXACO AND
LIMITOROUE.
-
INTERNAL WIRING REPLACED IN 866A & B IN RESPONSE TO
IEN 86-03.
-
TAG FILE FOR 744A & B REMOVED DUE TO CHANGE IN
STATUS.
ROOT CAUSE
-
INADEQUATE CONTROL OF MODIFICATIONS OF EQ EQUIPMENT.
-
INADEQUATE PROCEDURES FOR MAINTAINING EQUIPMENT
QUALIFIED.
MIS:87-4282(12)
Enclosure 3
13
LIMITORQUE MOTOR OPERATORS (87-10-03)
(CONTINUED)
CORRECTIVE ACTION
-
DEFICIENCIES IN 866A & B RESOLVED BY HARDWARE
CHANGES
-
DEFICIENCIES IN 744A & B RESOLVED BY DOCUMENTATION
OF ADEQUACY
-
ADDITIONAL PROCEDURAL GUIDANCE PROVIDED FOR
MODIFICATION AND MAINTENANCE CONTROL OF EQ EQUIPMENT
SAFETY SIGNIFICANCE
-
744A & B WOULD HAVE PERFORMED THEIR SAFETY FUNCTION
-
REASONABLE ASSURANCE EXISTS THAT 866A & B WOULD HAVE
PERFORMED THEIR SAFETY FUNCTIONS
SUMMARY
-
DEFICIENCIES EXISTED IN 866A & B
-
PROMPTLY REPORTED (LER 87-007)
-
DEFICIENCIES CORRECTED BEFORE STARTUP
-
744A & B QUALIFIED AS INSTALLED
-
GREASE PREVIOUSLY USED CONFIRMED QUALIFIED BY TEST
MIS:87-4282(13)
Enclosure 3
14
FINDINGS CP&L BELIEVES DO NOT MERIT
ENFORCEMENT ACTION
MIS:87-4282(14)
Enclosure 3
15
CROUSE-HINDS PENETRATIONS (87-10-02)
STAFF FINDING
-
PENETRATION ELECTRICAL CONNECTORS AND SHRINK-FIT
SLEEVE SPLICES NOT TYPE-TESTED AND NOT QUALIFIED BY
SIMILARITY ANALYSIS
CP&L'S PERSPECTIVE
-
EVOLVING ISSUE
-
CROUSE-HINDS PENETRATIONS (INCLUDING PIGTAIL
ASSEMBLIES) PURCHASED AS A UNIT
-
SHRINK-FIT SLEEVE SPLICES QUALIFIED AS A PART OF
QUALIFIED PENETRATION ASSEMBLY
-
ELECTRICAL CONNECTOR FURTHER QUALIFIED BY SIMILARITY
ANALYSIS
-
DEFICIENCIES NOT IDENTIFIED IN PRIOR REVIEWS
-
SIMILAR PENETRATION ASSEMBLIES ACCEPTED AT OTHER
PLANTS
BACKGROUND
-
CP&L 45-DAY REPORT (1980) IDENTIFIES PENETRATIONS
-
NRC SEPTEMBER 30, 1980 INSPECTION REPORT QUESTIONED
CONNECTORS
-
CP&L 90-DAY REPORT SUPPLEMENTED INFORMATION ON CABLE
AND CONNECTOR
-
NRC MAY 21, 1981 SER REQUESTS ADDITIONAL INFORMATION
-
NRC SER/FRANKLIN TER (JANUARY 5, 1983) REPORTED NO
DOCUMENTATION PROVIDED
-
CP&L MAY 20, 1983 RESUBMITS DOCUMENTATION PROVIDED
FRANKLIN
-
CP&L MARCH 2, 1984 LETTER OUTLINES RESOLUTIONS TO
ALL FRANKLIN ITEMS
-
NRC MARCH 19, 1985 SER FINDS EQ RESOLUTIONS
ACCEPTABLE
MIS:87-4282(15)
Enclosure 3
16
CROUSE-HINDS PENETRATIONS (87-10-02)
(CONTINUED)
ACTIONS TAKEN
-
ALTHOUGH PREVIOUSLY CONSIDERED QUALIFIED,
PENETRATION CONNECTORS AND HEAT-SHRINK SLEEVING WERE
REPLACED WITH RAYCHEM SPLICES
SUMMARY
-
SPLICES AND CONNECTORS PURCHASED AS PART OF
QUALIFIED PENETRATION ASSEMBLY
-
CONNECTOR SIMILARITY ANALYSIS IN ACCORDANCE WITH DOR
GUIDELINES
-
PENETRATIONS EXTENSIVELY REVIEWED BY NRC WITHOUT
DEFICIENCY
-
BASED ON ANALYSES AND STAFF REVIEWS, CP&L REASONABLY
BELIEVED THAT THERE WERE NO OUTSTANDING
QUALIFICATION DEFICIENCIES
-
CONNECTORS, HEAT-SHRINK SLEEVES REPLACED PRIOR TO
STARTUP
-
PROMPTLY REPORTED (LER 87-007)
MIS:87-4282(16)
Enclosure 3
17
LOOP ACCURACY (87-10-06)
STAFF FINDING
-
REQUIRED LOOP ACCURACIES NOT DOCUMENTED AND SHOWN TO
BE SATISFIED
CP&L'S PERSPECTIVE
-
DOR REQUIREMENTS FOR INSTRUMENT ACCURACY MET
-
INSTRUMENT LOOP ACCURACY IS AN EMERGING ISSUE
BACKGROUND
-
CP&L 45-DAY REPORT DETAILS USE OF ROSEMOUNT 176KF
RTD'S AND MODEL 1153A TRANSMITTERS
-
INSTRUMENT ACCURACY SPECIFIED PER VENDOR DOCUMENTS
-
ACCURACY PROACTIVELY ADDRESSED
ACTIONS TAKEN
-
LOOP ACCURACY CALCULATIONS BEING ADDED TO EQ FILE
-
CALCULATIONS BASED ON ACTUAL CABLE TEST DATA
SUMMARY
-
LOOP ACCURACY IS A NEW STAFF POSITION THAT SHOULD
NOT BE SUBJECT TO ENFORCEMENT ACTION
MIS:87-4282(17)
EncTosure 3
18
INADEQUATE QUALIFICATION OF TAPED SPLICES (87-10-07)
(CP&L IDENTIFIED)
STAFF FINDING
-
CP&L DID NOT ADEQUATELY EVALUATE UNDOCUMENTED TAPED
SPLICES
CP&L'S PERSPECTIVE
-
IDENTIFIED BY CP&L AS PART OF SURVEILLANCE PROGRAM
-
POTENTIAL DEFICIENCY PROMPTLY EVALUATED
-
REPORTABILITY DETERMINATION VALID
BACKGROUND
-
CP&L IDENTIFIED TAPED SPLICES DURING MARCH 1986
SURVEILLANCE
-
SIMILARITY ANALYSIS INDICATED QUALIFIED
-
QUALIFIED TAPED SPLICES REPLACED WITH QUALIFIED
RAYCHEM SPLICES
-
NOT REPORTABLE SINCE QUALIFIED AS NOTED
-
SIGNIFICANCE DOCUMENTED BY INTERNAL MEMORANDUM
-
JCO NOT REQUIRED SINCE DISCOVERED AND CORRECTED
PRIOR TO POWER OPERATION
ROOT CAUSE
-
INSTALLED BY MODIFICATION PRIOR TO EQ PROGRAM
DEVELOPMENT
-
INADEQUATE MODIFICATION REVIEW
CP&L CORRECTIVE ACTIONS
-
QUALIFIED TAPED SPLICES REPLACED WITH QUALIFIED
RAYCHEM SPLICES
-
MODIFICATION REVIEW PERFORMED
-
INSTRUMENTATION INSPECTIONS
MIS:87-4282(18)
Enclosure 3
19
INADEQUATE QUALIFICATION OF TAPED SPLICES (87-10-07)
(CONTINUED)
SAFETY SIGNIFICANCE
-
SIMILARITY ANALYSIS SHOWED TAPED SPLICES WERE
ACCEPTABLE
SUMMARY
-
DEFICIENCY IDENTIFIED BY CP&L
-
DEFICIENCY EVALUATED FOR REPORTABILITY AND
SIGNIFICANCE
-
DEFICIENCY CORRECTED PROACTIVELY
-
SPLICES REPLACED WITH RAYCHEM FOR CONSERVATISM
-
JCO NOT REQUIRED SINCE PLANT IN OUTAGE
MIS:87-4282(19)
Enclosure 3
20
PROGRAM IMPROVEMENTS
ENVIRONMENTAL QUALIFICATION REQUIREMENTS HAVE BEEN
EVOLVING CONTINUOUSLY
H. B. ROBINSON PROGRAM HAS CHANGED IN ANTICIPATION OF
AND IN RESPONSE TO CHANGING REQUIREMENTS
MOST RECENT INSPECTION BROUGHT FORTH LATEST
PERSPECTIVES FOR ENSURING SAFE OPERATION
CP&L IS TAKING ADVANTAGE OF THE NEW PERSPECTIVE WE HAVE
GAINED TO FURTHER ENHANCE AN ALREADY ESTABLISHED EQ
PROGRAM
COMPLETED
-
CLEAR ACCOUNTABILITY AT SITE
-
EQUIPMENT WALKDOWNS AND RESULTANT CHANGES
-
ADDITIONAL PROCEDURAL GUIDANCE
-
TRAINING
ONGOING
-
SYSTEMATIC REVIEW OF QUALIFICATION DOCUMENTS
-
CONTINUE TO MONITOR INDUSTRY
-
ENHANCE PROCEDURES
-
ADDITIONAL TRAINING
MIS:87-4282(20)
Erclosure 3
21
PROGRAM ASSESSMENT
EQ PROGRAM MEETS REQUIREMENTS OF 10CFR50.49
MASTER LIST OF EQUIPMENT ACCURATE AND COMPLETE
EXTENSIVE AUDITS AND SURVEILLANCES
POTENTIAL DEFICIENCIES EVALUATED PROMPTLY AND
CONSISTENTLY REPORTED IN A TIMELY MANNER
PROMPT CONSERVATIVE APPROACH TO IDENTIFIED DEFICIENCIES
-
RAYCHEM SPLICES
-
TEAM FINDINGS
.
JCO DEVELOPMENT
EQUIPMENT CHANGES
EQUIPMENT WALKDOWNS
.
DOCUMENT REVIEWS
-
TESTING INFORMATION
.
PLANT SHUTDOWN
a EQUIPMENT CHANGES
.
EXTENSIVE DATA
COMMITMENT TO CONTINUED REVIEW AND IMPROVEMENT
MIS:87-4282(21)