ML20077A820
| ML20077A820 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 06/24/1983 |
| From: | Starkey R CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20077A798 | List: |
| References | |
| RSEP-83-767, NUDOCS 8307220458 | |
| Download: ML20077A820 (4) | |
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H. B. RCBINSCN STEAM ELECIRIC PLANT PCSP CFFICE BOX 79%3 JllN 27 AIO : ?.d HARTSVILLE, sol 7IH CAROLINA 29550 JUN 2 41983 Robinson File No:
13510E Serial: RSEP/83-767 Mr. James P. O'Reilly Regional Administrator U. S. Nuclear Regulatory Comnissicn Region II 101 Marietta Street, N.W., Suite 3100 Atlanta, Georgia 30303 H. B. ROBINSCN STEAM ELECIRIC PLANP, UNIT NO. 2 DOCKEP NO. 50-261 LICENSE NO. DPR-23 RESPWSE 'IO INSPECPICN REPORP IER-83-12
Dear Mr. O'Reilly:
Carolina Power and Light Cmpany (CP&L) has received and reviewed the subject report and orovides the following response.
A.
Severity level IV Violation Technical Specification 6.5.1.1.1 requires that written procedures shall be l
established, inpleented, and maintained that meet the requirments of l
Appendix A of U. S. NBC Regulatory Guide 1.33, Rev. 2.
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Contrary to the above, procedures were not adequately established, inplemented, and maintained in that:
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1.
IER-83-12-01-SL4 System Description (SD)-16, Appendix A, Electrical Distribution Manual, was established, in part, to delineate safety-related instrument bus and DC auxiliary panel loads. As of May 2,1983, Appendix A to SD-16 either did not identify all instrument bus and DC auxiliary panel loads or incorrectly identified load power sources.
8307220458 830715 PDR ADOCK 05000261 Q
Ietter to Mr. James P. O'Reilly Serinl RSEP/83-767 Page 2 2.
IER-83-12-02-SL4 Administrative Instruction 11.12 and Maintenance Instruction-1 were established to satisfy the requirements of ANSI N45.1.2-1973 for examination of work areas to assure cleanness and adequacy of protection of equipnent frcm dirt and fire hazards. As of May 2, 1983, these instructions had not been implenented during circuit nodifications and maintenance conducted since 1980 in safety-related instrument bus cabinets. The potential fire and operability hazards associated with dirt, debris, and paper tags contained in these cabinets were not identified and corrected.
3.
IER-82-12-03-SL4 Operations Wrk Procedure (CWP) HVH-3 was established to control post-maintenance testing of containment air recirculation units. As of April 11, 1983, OWP HVH-3 did not provide adequate formal control of post-maintenance testing methodology with respect to control of containment integrity. 'Ihis lack of formal controls resulted in violation of containment integrity during brief periods of post-maintenance testing associated with containnunt air recirculation unit fan cooler service water leakage.
RESPWSE:
Carolina Power and Light Ompany acknowledges the above violation.
1.
IER-83-12-01-SL4 a.
Reason For 'Ihe Violation Fae of the discrepancies in the Electrical Distribution Minual noted by the inspector were due to modifications that -
have not been closed out and, therefore, changes to the distribution manual have not yet been made. Other discrepancies were due to modifications made years ago which did not identify that a change to the distribution manual was necessary.
b.
Oorrective Steps Which Have Been Taken And Results Aciueved Increased emphasis in this particular area has been placed on closing out old modifications.
Ietter to Mr. James P. 0 % illy Serial RSEP/83-767 Page 3 c.
Corrective Steps Which Will Be Taken 'Ib Avoid Further Violation Old Plant modifications are scheduled to be closed out by February, 1984, h discrepancies in the instrument busses identified in this report should be corrected by Septerrber 30, 1983.
d.
Date When Full Coupliance Will Be Achieved Full coupliance should be achieved in February,1984.
2.
IER-83-12-02-SL4 a.
Reason For 'Ihe Violation h housekeeping statements in MI-1 were intended to apply to cabinets which contained omponents with open contacts that would be affected by the accumulation of dust not necessarily to cabinets such as the safety-related instrument busses which contained sealed conponents.
However, the housekeeping guides in AI-11.12 should have been followed by those individuals who worked in these cabinets as-they should have observed the accumulation of dust and old tags, b.
Corrective Steps Which Have Been Taken And Results Achieved
'Ihe safety-related instrument busses have been cleaned. h inportance of having a positive attitude toward housekeeping so that areas such as identified in this report are cleaned as soon as identified was stressed by the Maintenanco Foremen with those reporting to them.
c.
Corrective Steps Which Will Be Taken To Avoid Further Violation h safety-related instrument busses will be included in our Preventative Maintenance Program to ensure they are inspected and cleaned as necessary during the next refueling outage.
d.
Date When Full Ccmpliance Will Be Achieved h Preventative Maintenance Program will be appropriately revised by the next refueling outage.
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Iettdr to Mr. Jame P. O'Reilly
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Reason For 'It2!'Vio10 tion g
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, c-s %e Operating WorKhu:edure (CWP) contained instructions tg %
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" check for leaks" al.'ers maintenance on the HVH coolers.
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R an effort to inplemeht, this instruction, personnel.wcJe stationed at the HVF oca.ler inlet and outlet valves. %e O
f; outlet valve yas cpened ta prevent jarring the system den
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-3 the Inlet valve was operini. his inplementation of the instruction " check for leaks" was thought to be adequate.
However, based on the. fact that the IMI coolers are a
e considered a contairent boiindary, additional guidance is believedto,beapproprigte.*
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Corrective Steps Which Ea;m-8sen Taken And Re_sults Achieved
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%o'NRC's concern was discussed wjfh the Shift Foremen irmived in taking the system out of service and placing it r
xy backfirdo service. Altprnative rsthods of checking for
.i leaks were also disctyscd.'s x
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Corrective Steps hh'ich Will Be Taken To Avoid Further Violation
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% qs0WP statement "ch ck for leaks" will be expanded to be norehpecific.
In the interim, the Shift Foremen not
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involved will be provided additional gui&nce for " check for leaks" as it applies in this ONP.
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Date When Full Ccmpliance Will Be Achievfd
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Full coupliance will be achieved by SepterrNr 30,19E3, by
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which tine the CWP should be' revised.
In the interir.I, the s
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q' existing procedure, along with additional guidance to be P
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'JL provided to the Shift Foremen, is believad adequate until s,,
l inplementation of a more detailed procechire.
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y If you have any questions concening this report, please contact my staff or me.
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Very truly yours, lb y
R. B. Starkey, Jr.
General Manager
/ H. B. Robinson SEG Plant CLW/bss cc:
R. C. DeYoung s
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