ML20082L483
| ML20082L483 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 11/03/1983 |
| From: | Morgan R CAROLINA POWER & LIGHT CO. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20082L473 | List: |
| References | |
| RSEP-83-1342, NUDOCS 8312050514 | |
| Download: ML20082L483 (3) | |
Text
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. wy Carolina Power & Light Company H. B. ROBINSON $fkAh- -,, s : m r wS k,a.P h U
EC I POST OFFICE BOX 790 HARTSVILLE, SOUTH CAROLINA 29550 NOV 3 1983 Robinson File No:
13510E Serial:
RSEP/83-1342 Mr. James P. O'Reilly Regional Administrator U.S. Nuclear Regulatory Commission Region II 101 Marietta Street, N.W.
Atlanta, Georgia 30303 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT 2 DOCKET NO:
50-261 LICENSE NO:
DPR-23 INSPECTION REPORT IER-83-024
Dear Mr. O'Reilly:
Carolina Power and Light Company has received and reviewed the subject report and provides the following response:
A.
IER-83-24-07-SL5 Technical Specificatione 6.5.1.1.1.c requires that written procedures be established for surveillance and test activities of safety-related equipment. Technical Specification definition 1.6.3 requires that a channel calibration include the channel functional test pursuant to Technical Specification 4.1.1 surveillance requirements.
Contrary to the above, as of August 15, 1983, adequate calib ration procedures had not been estah !'.shed in that functional testing was not required prior to returning calibrated safety-related channels to service. This resulted in containment pre:ssure channels being returned to service af ter calibration on March 8 and 14,1983, without performance of channel functional testing.
8316050514 831116 PDR ADOCK 05000261 G
"hstter to Mr. James P. O'Reilly e
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Serial: RSEP/83-1342 Page 2
Response
1.
Admission or Denial of the Alleged Violation Carolina Power and Light Company acknowledges the alleged violation.
2.
Reason for the Violation For the past twelve years, loop calibrations were performed during refueltag outages.
The subsequent functional testing was performed as p' rt of the surveillance test which was scheduled prior to Plant startup.
To relieve the workload during refueling outages, those " calibrations" that could be performed at power were rescheduled throughout the year. The normally scheduled " functional" test (bi-weekly, monthly) was believed adequate to satisfy the functional test requirement.
Two (2) instances were identified where the Containment pressure channels were calibrated at power and were functionally tested two (2) days later in one instance, and ten (10) days later in the second.
In both instances, the functional testing was the norma 11f scheduled bi-weekly surveillance test.
In both instances, the instrumentation passed the functional test. However, as a clarification of the require-ment, CP&L was informed that the " functional" test had to be an integral part of the calibration and completed prior to putting the loop back in service.
3.
Corrective Steps Taken and Results Achieved The work request which directs the technicians to perform the "At Power" calibration will also direct the technician to perform the functional test prior to returning the instrument to service.
4.
Corrective Steps Which Will Be Taken to Prevent Further Violations The corrective action taken above will ensure full compliance until the appropriate calibration procedure revisions are made.
These calibration procedure revisions will be scheduled as part of the already initiated Plant Operating Manual rewrite project as committed to in the Long Term Improvement Program.
5.
Date When Full Compliance Will Be Achieved Full complisuce has been achieved with the performance of functional tests following instrument calibration and prior to returning the instrument to se rvice. The Maintenance portion of the Plant Operating Manual rewrite is currently scheduled to be completed by the end of 1984.
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RSEP/83-1342 Page 3 B.
IER-83-24-05-SLS r
Technical Spec
- fication 6.5.1.1.1.a. requires that written procedures be established and implemented which caet the requirements of Appendix A of USNRC Regulatory Guide 1.33, Revision 2, with respect to procedures for post-maintenance testing of safety-related equipment.
Plant Maintenance Instruction - 1, Maintenance Administration Program, and the Corporate Quality Assurance Program also require procedures that satisfy ANSI N18.7-1976 paragraph 5.2.7.
Contrary to the dbove, as of August 10, 1983, procedures were not estab lished and implemented for the performance or, ast-maintenance testing of test switches associated with the reactor safeguards circuitry.
Response
1.
Admission or Denial of the Alleged Violation a
Carolina Power and Light Company acknowledges the alleged violation.
2.
Reason for the Violation The Plant staf f did not recognize that the surveillance test following the replacement of the test switches did not test all the functions of the switch.
The switch is replaced in its " test" position and is tested in the test position. However, a continuity check is not made with the switch in its normal position.
3.
Corrective Steps Taken and Results Achieved A satisfactory continuity check was made of the safeguards test switch in its normai position.
4.
Corrective Steps to be Taken to Avoid Further Violation The appropriate procedures will be revised or new procedures written to ensure all functions of these switches are tested.
In the interim, l
Work Requests for testing these switches will contain a note to contact the I&C Foreman for post-maintenance testing if the switch is replaced.
5.
Date When Full Compliance Will Be Achieved The appropriate procedures will be revised by March 31, 1984.
If you have any questions concerning this response, please contact me or my staff.
Very truly yours,
$b Clw R. E. Morgan General Manager H. B. Robinson SEG Plant CLW:FMG:JMC/ta cc:
R. C. DeYoung (1)
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