ML20079J760

Responds to NRC Re Violations Noted in IE Insp Rept 50-261/83-32.Corrective Actions:Until Procedure Revised,Note to Ensure RCS Vent Path Established Prior to Isolating LTOP Entered in Info Book

ML20079J760
Person / Time
Site:	Robinson
Issue date:	12/30/1983
From:	Morgan R CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20079J749	List: ML20079J760
References
RSEP-83-1477, NUDOCS 8401240412
Download: ML20079J760 (2)

Text

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ELECTRIC PLANT POST OFFICE BOX 790 HARTSVILLE, SOUTH CAROL.NA 29550 DE03 01983 Robinson File No: 13510E Serial: RSEP/83-1477 Mr. James P. O'Reilly Regional Administrator i U. S. Nuclear Regulatory Commission l Region II 101 Marietta Street, Suite 3100 Atlanta, Georgia 30303 l H. B. ROBINSON STEAM ELECTRIC PLANT UNIT NO. 2 DOCKET NO. 50-261 LICENSE NO. DPR-23 RESPONSE TO IE INSPECTION REPORT IER-83-32 Dear Mr. O'Reilly Carolina Power and Light Company has received and reviewed the subjret report and provides the following response.

VIOLATION SEVERITY LEVEL 5 (IER-83-32-01-SL5)

Technical Specification 3.1.2.1.d. requires that the overpressure protection system thpli be operable whenever the reactor coolant system temperature is below 350 F and not vented to containment.

Contrary to the above, on November 4,1983, while below 350 F, the over-pressure prctection system was isolated for about two hours without estab-lishing an equivalent vent path to containment.

RESPONSE

1. Admission or Denial of the Alleged, Violation Carolina Power and Light Company acknowledges the alleged violation.

2. Reason for the Violation On November 4,1983, while draining the Reactor Coolant System (RCS) in accordance with General Procedure GP-008, " Draining the Reactor Coolant System," the pressurizer power operated relief valves (PORVs) and their block valves were closed prior to establishing a vent path to containment.

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,[ ' S:ric1 RSEP/83-1477 P ga 2 This condition existed for approximately 15 minutes before the three pressurizer safety loop seal drains were opened. The reactor head vent and the stand-pipe vent used for level indication were not opened until approximately two hours following isolation at the PORVs. The prd) ability of an ovetpressarized condition existing was very small considering the condition of the Plant. g The safety injection (SI) pumps are racked out at a RCS temperature of 350 F.

Sub sequent review of GP-008 indicated that the procedure inadequately addressed the proper sequence to follow when establishing a vent path to containment prior to isolating the PORVs.

3. Corrective Steps Taken Until the appropriate procedures are revised, a note to ensure that a RCS vent path is estJ)11shed prior to isolating the LTOP has been entered in the Operating Supervisors Directive and Information Book, which is reviewed by the Shif t Foreman and Shif t Technical Supervisors.

4. Corrective Steps Which Will Be Taken to Avoid Further Violation An appropriate procedure change will be made to GP-008 to clarify to the operators that the LTOP caanot be isolated until another RCS vent path is estd>11shed. The inspector's concecn about providing an equivalent capacity flow path is also being considered.

5. Date When Full Compliance Will Be Achieved Full compliance is achieved. The appropriate procedure change will be made to GP-008 by Fdaruary 3, 1984.

If you have any questions concerning this response, please contact my staf f or me.

Very truly yours,

,/et R. E. Morgan General Manager H. B. Robinson S. E. Plant CLW: FMG:JFB/ac

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