ML20064L041: Difference between revisions

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Cp&L Carolina Power & Light Company p _- --r,2%e H. B. ROBINSON STEAM ELECTRIC PLANT POST OFFICE BOX 790 HARTSVILLE, SOUTH CAROLINA 29550 JANZ 11983 Robinson File No:    13510E                                Serial:  RSEP/83-83 Mr. James P. O'Reilly Regional Administrator U. S. Nuclear Regulatory Commission                ,
Region II 101 Marietta Street, N. W.        ,                                            w Atlanta, Georgia 30303                                                          _
                                                                                            =,
H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2                4 DOCKET NO. 50-261                                  ,
LICENSE NO. DPR-23                              7
                                                                                                -i RESPONSE TO NRC INSPECTION REPORT 82-37                    p;3
 
==Dear Mr. O'Reill.y:==
 
cr Carolina Power and Light Company (CP&L) has received and reviewed the
!            qubject report and provides the following response.                                      ,
A. Severity Level IV ' Violation - IER-82-37-13-SL4 Technical Specification 6.5.1.1.1 requires that procedures be established and implemented which meet the recommendations of Appendix A of Regulatory Guide 1.33, Revision 2'        . Appendix A
;                requires equipment control and protection procedures for operations and maintenance affecting safety-related equipment. Administrative Ins tructions 11.6 and 4.1, Operating Procedure-7A, and Standing Order-9 implement these requirements. FSAR Section 1.3.4 states that the air start supply is independent for each emergency i                diesel generator.
l Contrary to the above, as of November 9,1982, these procedures had not been adequately established or implemented, in that the diesel generator air start air receiver discharge crossconnect valve was lef t open following activities associated with the "B" I                emergency diesel generator air compressor.
l 8302150093 830210
, PDR ADOCK 05000261 i
Q                  PDR e
 
g '. Letter to Mr. James P. O'Reilly Serial:  RSEP/83-83 Page 2 Respo nse
: 1. Admission or Denial of the Alleged Violation Carolina Power and Light Company acknowledges the alleged violation.
: 2. Reason for the Violation The diesel generator air receiver discharge crossconnect valve was usually controlled at the Auxiliary Operator (AO) level using the A0 logs as the controlling document.
DG-AS-10 was not included on an Operating Work Procedure and, therefore, would not have been included on a clearance of either air compressor / receiver. When either diesel generator air compressors or either air receiver were made inoperable, the Auxiliary Operator opened DG-AS-10 to provide stating air to both diesels and recorded his action into the A0 shift log. In this particular event, an entry on opening valve DG-AS-10 was not made in the A0 shif t log. The valve had probably been opened a few days earlier-when maintenance was performed on "B" emergency diesel air compressor and DG-AS-10 was inadvertently lef t open following this maintenance.
: 3. Corrective Steps Taken and Results Achieved Valve DG-AS-10 was closed immediately as d' rected by the Shif t Foreman. Operations personnel were interviewed to determine why the valve was open. It could not be determined by these interviews why valve DG-AS-10 was opened.
: 4. Corrective Steps That Will Be Taken to Avoid Further Violation Operating Work Procedures on equipment associated with this valve DG-AS-10 are being revised, as necessary, to include D G-A S-10. This will ensure positive control of DG-AS-10 and will properly document its repositioning for maintenance.
The importance of properly documenting the repositioning of safety-related equipment will be discussed with the Auxiliary Ope ra to rs .
: 5. Date When Full Compliance Will Be Achieved Discussions with the Auxiliary Operators will be completed b y Februa ry 28, 1983. The appropriate OWPs will be revised by April 30, 1983.
 
r          .    .
    ''. Letter to Mr. James P. O'Reilly -
g 6
Serial: RSEP/83-83 Page 3 B. Severity Level V Violation    -
IER-82-37-02-SL5 Technical Specification Table 3.5-5, Item 2, requires that a
.            special report be submitted _if one or more of the direct auxiliary I            feedwater flow. indicators becomes inoperable for more than seven days when the reactor coolant system temperature is above 350*F.
i contrary - to the above, as of October 25, 1982, special reports had '
not been submitted for three instances of auxiliary feedwater flow i
indication inoperability occurring in September and October,1982.
.            Response Carolina Power and Light Company ackuswledges the alleged violation.
4            The items CP&L would discuss in a response to this violation have j            been discussed in "Special Report - AN Flow Indication" submitted l            to your of fice on December 16, 1982. Please refer to this Special i            Report for the necessary information.
I Deviation - I ER-82-37-07-DEV CP&L letter GD-28-231, Reactor Vesse1' Overpressure Protection Request for License Amendment, dated January 25, 1978, committed to installation of a low pressure alarm on the backup nitrogen system for the low
;        temperature overpressure protection system.
i l        Contrary to the above, as of November 1,1982, a low pressure alarm had j      not been installed on the backup nitrogen system.
 
===Response===
: 1. Corrective Actions That Will Be Taken A low pressure alarm on the backup nitrogen system for the low temperature overpressure protection system system will be installed during the next refueling outage presently scheduled' to begin in early 1984.
: 2. Corrective Actions Taken to Avoid Further Deviation A review of past correspondence from CP&L to the NRC has been initiated to verify that no additional commitments were missed. A system to audit regulatory commitments has been initiated by the Quality Assurance Group and the Corporate Nuclear Safety Group on site.
 
      . '- Letter to Mr. James P. O'Reilly
* Serial: RSEP/83-83 Page 4
: 3. Date When Corrective Action Will Be Completed The N 7 low pressure alarm will be installed during the next refueling outage.
The review of past NRC correspondence is presently expected to be completed by July,1983. However, the total extent of this review will be determined by the review itself. If additional problems are identified, then the scope of the review will be expanded.
If you have any questions concerning this response, please contact my staff or me.
Very truly your.s, l          fil R. B. Starkey,    r.
General Manager
: 11. B. Robinson SEG Plant CLW:FMG:JMC/bss cc:  R. C. DeYoung 5
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Revision as of 14:33, 31 March 2020

Responds to NRC 821223 Ltr Re Violations Noted in IE Insp Rept 50-261/82-37.Corrective Actions:Valve DG-AS-10 Closed W/Operating Work Procedures to Be Revised by 830430 & Low Pressure Alarm on Backup Nitrogen Sys Installed
ML20064L041
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 01/21/1983
From: Starkey R
CAROLINA POWER & LIGHT CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20064L003 List:
References
RSEP-83-83, NUDOCS 8302150093
Download: ML20064L041 (4)
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