ML20205P736

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Discusses Design Changes After Receipt of Ol.Exam of Sample Field Requests Revealed That 42 Design Changes Issued After Sys Operation Date.Completion of Remaining Field Change Requests Will Be Completed by 870415
ML20205P736
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 03/18/1987
From: Watson R
CAROLINA POWER & LIGHT CO.
To: Grace J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
HO-870384-(), HO-870384-(0), NUDOCS 8704030357
Download: ML20205P736 (2)


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y HARRIS NUCLEAR PROJECT P. O. Box 165 New Hill, NC 27562 MR 181987 File Number:

SHF/10-10000

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Letter Number: HO-870384 (0) l Dr. J. Nelson Grace United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 2900)

Atlanta, CA 30323 HARRIS NUCLEAR PROJECT DOCKET NO. 50-400 LICENSE NO. NPF-63

Subject:

Design Changes after Receipt of Operating License (OL) l

Dear Dr. Grace:

l l

A site nonconformance report (NCR) has been written stating.that.

l construction phase design changes were written against plant i

systems which had been declared operational.

Upon review of the problem, CP&L has determined that controls were in place to limit design changes after issuance of OL.

Construction phase design changes (Field Chat.ge Requests /FCRs) l were allowed to be used until the system affected was declared

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operational. Following the operational date, operational phase l

design changes (Plant Change Requests /PCRs) were required.

FCRs l

usually were not fully reviewed for operational impact prior to signout since they_were design issued prior to the system becoming operational.

l An examination of a sample of 215 of approximately 800 FCRs 1

approved for implementation after the issuance of the OL-revealed 42 that were design issued after the system operation date and may not have received a full review for operational impact. These 42 have now been reviewed for the following:

1)

Operations and Maintenance Procedures Impact 2)

Training Programs Impact 3)

Pre-Operational Testing Impact 4)'

Safety Review B704030357 870318 PDR ADOCK 05000400 P

PDR MEM/HO-8703840/ PACE 1/OSI lD ww

Dr. J. N:Ison Gracs Page 2 Two of the 42 were determined to have a minor procedural impact.

In both instances, setpoints were changed on non-safety related systems such that the existing setpoint or limit was more conservative than the new one.

No other impacts were found.

CP&L is now in the process of reviewing the remaining FCRs resolved after issuance of OL to determine if other similar instances exist. Based on the insignificance of the findings so far, CP&L does not believe the situation to be reportable. CP&L will provide a complete analysis when all reviews are complete and make a final declaration of reportability at that time.

Completion of this review is scheduled for April 15, 1987. We will inform you of any delays that may occur.

In the interim, CP&L has further restricted the use of FCRs with the intent of completely eliminating them as soon as the last plant system is declared operational.

This correspondence supercedes letter HO-870381 (0) sent March 16, 1987. Please also note that this previous letter was incorrectly identified as a 30-Day Special Report, when in fact it was not sent to comply with any particular NRC reporting requirement. CP&L regrets the error.

Very truly yours, 0$ $b R. A. Watson Vice President Harris Nuclear Project RAW:AH:sdg cc: Messrs.

B. Buckley (NRC-RII)

C. Forehand L. I. Loflin C. Maxwell (NRC-SHNPP)

C. A. Meyer J. L. Willis l

MEM/HO-8703840/PAGE 2/0S1