ML20205Q021

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Special Rept Re Site Nonconformance Rept Concerning const- Phase Design Changes Written Against Plant Sys Previously Declared Operational.Sample of 215 of 800 Field Request Changes Revealed 2 Minor Procedural Impacts.Review Ongoing
ML20205Q021
Person / Time
Site: Harris Duke Energy icon.png
Issue date: 03/16/1987
From: Watson R
CAROLINA POWER & LIGHT CO.
To: Grace J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
HO-870381-(O), NUDOCS 8704030429
Download: ML20205Q021 (2)


Text

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Carolina Power & Light Company g g ag d

HARRIS NUCLEAR PROJECT MAR 161987 File Number:

SHF/10-10000 Letter Number:

HO-870381 (0)

Dr. J. Nelson Grace United States Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 2900)

Atlanta, GA 30323 HARRIS NUCLEAR PROJECT UNIT 1 DOCKET NO. 50-400 LICENSE NO. NPF-63 NRC 30-DAY SPECIAL REPORT

Subject:

Design Changes after Receipt of Operating License (OL)

Dear Dr. Grace:

A site nonconformance report (NCR) has been written stating that construction phase design changes were written against plant 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 Change Requests /FCRs) were allowed to be used until the system affected was declared operational. Following the operational date, operational phase design changes (Plant Change Requests /PCRs) were required. FCRs usually were not fully reviewed for operational impact prior to signout since they were design issued prior to the system becoming operational.

An examination of a sample of 215 of approximately 800 FCRs 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 8704030429 870316 PDR ADOCK 05000400 S

PDR f

MEM/H08703810/Page 1/0S1 l0 %

q Dr.'J. Nelson Crace

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Page 2 March 16, 1987 Two of the 42 were determined to have a minor procedural impact.

-In both instances, set points were changed on non-safety related systems such that the existing set point 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.

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.

Very truly yours, l

R. A. Watson Vice President Harris Nuclear Project RAW /AH/sig cc:

Mr. B. Buckley Mr. C. Forehand Mr. L. Loflin Mr. G. Maxwell (NRC-SHNPP)

Mr. G. Meyer Mr. J. Willis l

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