ML20127A229
| ML20127A229 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 05/10/1985 |
| From: | Morgan R CAROLINA POWER & LIGHT CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| RNPD-85-1003, NUDOCS 8506210063 | |
| Download: ML20127A229 (3) | |
Text
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CP&L Carolina Power & Light Compyy O *, { 2 g vs ROBINSON NUCLEAR PROJECT DEPARTMENT POST OFFICE BOX 790 HARTSVILLE, SOUTH CAROLINA 29550 MAY 10 L%S Robinson File No:
13510E Serial:
RNPD/85-1003 Dr. J. Nelson Grace, Regional Administrator United States Nuclear Regulatory Commission Region II 101 Marietta Street, N. W., Suite 3100 Atlanta, Georgia 30323 l
H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 f
DOCKET NO. 50-261 f
LICENSE NO. DPR-23 REGION II INSPECTION REPORT 85-11
)
Dear Dr. Grace:
Carolina Power & Light Company has received and reviewed the subject report.
Item 7 of the report discusses the basis for the violation of design control procedures. CP&L does not view the violation as being the result of inadequate procedures as indicated in item 7, but rather as a result of improper interpretation of the procedures. The following response addresses the violation in this respect. Although the procedures are considered adequate, additions and changes will be made as part of the ongoing Plant Operating Manual rewrite effort. Specifics of some of these changes are discussed in the text of this response.
SEVERITY LEVEL IV VIOLATION, RII-85-11-01-SL4 10CFR50, Appendix B, Criterion III states, in part, " Design changes, including field changes, shall be subject to design control measures commensurate with those applied to the original design..."
Technical Specification 6.5.1.2.1 requires that a safety analysis be prepared for all modifications that affect nuclear safety. The analysis shall include a written determination of whether or not the modification is a change in the facility as described in the FSAR, involves a change to the Technical Specifications, or constitutes an unreviewed safety question as defined in 10CFR50.59(a) (2).
8506210063 B50510 PDR ADOCK 05000261 O
~CE~o I N
L;ttIr to Dr. J. N;1 con Gr:c3 Stric1:RNPD/85-1003 Page 2 Contrary to the above, on February 9,1985, the licensee modified three safety-related breaker settings, including one protecting the "A" emergency diesel generator fuel oil transfer pump, without:
(1) such changes being suject to design control measures commensurate with the original design; and (2) performing a safety analysis prior to implementing the changes.
RESPONSE
1.
Admission or Denial of the Alleged Violation CP&L acknowledges that a violation of not following established procedures occurred.
2.
Reason for the Violation A survey of motor feeder breaker trip settings for 480 volt safety-related loads was conducted following the R-21 Radiation Monitor motor circuitry problem (LER-85-008). As a result of the survey, the "A" Emergency Diesel Generator Fuel Oil Pump, R-20 and R-21 radiation monitor vacuum pumps motor feeder breakers were replaced with similiar breakers having a lower trip setpoint to provide protection for the motor starters. These replacements were justified and documented as part of an Engineering Evaluation and installed under a maintenance work request. This procedure resulted in a technically evaluated change to the Plant but did not document the two party safety reviews required by Technical Specification Section 6.5.1.2 for modifications which affect nuclear safety.
The cause of the violation was the improper determination that the replacement with a similiar breaker of proper trip setpoint was not a change to the original design basis. This determination, which is made by Engineering Management, resulted in the documentation of the change using the Engineering Evaluation Process, rather than a Plant Modification. The Engineering Evaluation, by procedure, does not require all the controls necessary to implement design changes. Had the breaker changeout been determined to be a design change, the Modification or Temporary Repair procedure would have been used. Both of these procedures require 10CFR50.59 safety reviews and other necessary controls for implementation of design changes. The breaker replacement was viewed as a " Replacement in Kind" since it involved only reducing the amperage range within which the breakers could operate to provide adequate protection to the equipment. This reducing of trip setpoints changed the design operating limits and, therefore, should have been properly identified as a "setpoint change" which requires using the Modification procedures.
The Engineering Evaluation involved two technical reviews, a QA review, as well as, management reviews and approvals. The two technical reviewers were certified as nuclear safety reviewers qualifying them for performing 10CFR50.59 reviews. Additionally, the event including the replacement was i
reviewed by the Plant Nuclear Safety Committee in session prior to startup from the outage during which the event occurred.
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L:tt r to Dr. J. Nalcon Greca Scrial:RNPD/85-1003 Page 3 3
Corrective Steps Which Have Been Taken 1.
10CFR50.59 Safety Reviews were performed and documented on the Engineering Evaluation which justified the breaker replacements.
2.
Additional emphasis is being placed on the determination of whether equipment replacements constitute Modifications. This emphasis is applied during the management review process prior to approval of Engineering Evaluations.
3 The management involved with Engineering Evaluation reviews have received training to prevent future misinterpretations of the Modification procedures.
4.
Corrective Steps Which Will Be Taken The procedure which controls Engineering Evaluations will be revised to include provisions for 10CFR50.59 safety reviews to be performed when required.
The guidance currently provided in Plant procedures to determine whether a Modification, Temporary Repair, or Engineering Evaluation is involved is considered adequate. However, as a routine part of the ongoing Plant Operating Manual rewrite, enhancements to this procedure will be considered. The details of this event will be included as these enhancements are considered.
5.
Date When Full Compliance Will Be Achieved Full compliance will be achieved by August 31, 1985 If you have any questions concerning this response, please contact Mr. David C. Stadler at (803) 383-4524 extension 2363 Very truly yours,
((/2@-
R. E. Morgan General W ager H. B. Robinson S. E. Plant CLW:vf/C-1206 cc:
H. E. P. Krug Document Control Desk