ML20069E061: Difference between revisions

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                                                                                      ._..            e USNRC REOlON ':
Al i AN Ti.t u C R."~M Carolina Power & Light Company g        g AW . 43 H. B. ROBINSON STEAM . ELECTRIC PLANT POST OFFICE BOX 790 HARTSVILLE, SOUTH CAROLINA 29550
                                                  ' MAR    4 1983 Robinson File No:      13510E.                        Serial: RSEP/83-286 Mr. James P. O'Reilly Regional Administrator U. S. Nuclear Regulatory Commission Region'II 101 Marietta Street, N. W.
              ~ Atlanta, . Ceorgia 30303 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT No. 2 DOCKET NO. 50-261 LICENSE NO. DPR-23 RESPONSE TO NRC INSPECTION REPORT 82-42
 
==Dear Mr. O'Reilly:==
 
Carolina Power and Light Company (CP&L) has received and reviewed the subject report and provides the following response.
A.-  S_everity Level IV Violation (IER-82-42-02-SL4)
Technical Specification 3.1.2.d requires that the overpressure protection system be operable whenever Reactor Coolant System (RCS) temperature is below 350 F and the RCS is not vented to containment.
Contrary to the above, as of December 12, 1982, the overpressure protection system has not met operability requirements since system installation in 1978, due to 'a non-conservative pressure transmitter calibration error affecting both trains of protection. As a result, the overpressure protection system was incapable of meeting its design basis requirements during all _ periods of required operability.
: 1. Admission or Denial of the Alleged Violation Carolina Power and Light Company acknowledges the alleged violation.
KO    ohhPDR
 
y r" y
  '~ q~ ~'' .,* Lett:r t].Mr. J: mea P. O'RJ111y.
Ser'ici: RSEP/83-286 P;312 '                                                                              ;
: 2. Reason for the Violation
                            - Lt -1978, when the Low Temperature Overpressure Protection (LTOP)
                            . system was installed, an incorrect value was assigned to the "zero adjust" which compensates for the reference leg height in the calibration of the LTOP pressure. transmitters. Since the narrow range pressurizer pressure transmitter and the LTOP pressure trans-mitter use the same pressurizer reference leg, it'was erroneously assumed that the narrow range "zero adjust" could be used for the LTOP "zero adjust." This; resulted in a.non-conservatively low bias on the LTOP pressure transmitters.
3.~  Corrective Steps Which Have Been Taken and Results Achieved The LTOP pressure transmitters imve been properly calibrated, and their calibration sheets, which are now controlled in the Plant Operating Manual (POM), have been corrected.
The modification control procedure was reorganized in 1982 and now. requires that the calibration sheets be implemented into the POM as part of the modification process.
: 4. Corrective Steps Which Will Be Taken To Avoid Further Violation
                                                                                          ~
All safety-related instruments that have .been added to or altered
                            ' by modifications will be reviewed to ensure that the appropriate information' is contained on their respective calibration sheet in the Plant Operating' Manual.
: 5. Date When Full Compliance 'Will Be Achieved The appropriate instruments will be identified by August 1,1983. The review of calibration sheets for the identified instruments should be completed within two months following the identification of the ins trume nt s.
B.    ,S,everity Level IV Violation (IER-82-42-03-SL5)
Technical Specification 6.5.1.1.1 requires that procedures be established, implemented, and maintained meeting the requirements of Appendix A of Regulatory Guide 1.33 Revision 2 and addressing surveillance and test activities of safety-related equipment. Maintenance Instruction-4, Cal-ibration Program, implements these requirements for calibration of the pressure transmitters required for proper operation of the low temperature overpressure protection system.
x
 
E    ~
Letter to.Mri J:me] P. O'ROilly
          ' 8e rial *: RSEP/83-286
: Pag 3 3 E
Contrary to the above, as of December 12, 1982, adequate procedures had not been established controlling the calibration of the low temperature overpressure protection system pressure transmitters in that the zero adjustment was incorrectly specified, resulting in transmitter output being non-conservatively low.
: 1. Admission or Denial of the Alleged Violation Carolina Power and Light Company acknowledges the alleged violation.
: 2. Reason for the Viola tion JThe reason for this violation and the corrective steps taken and to be taken are identified as those stated in the response to Violation "A" ab ove .
C. _ Severity Level V Violation (IER-82-42-0-SL5)
Technical Specification 6.5.1.1.1 requires that procedures be implemented which meet the requirements of Appendix A to Regulatory Guide 1.33, Revision 2. Administrative Instructions Section 5 and Engineering Procedure 5.0 implement these requirements with respect to procedural compliance and 91 ant modification control and require that modification implementing procedures be followed or appropriately revised and reviewed.
Contrary to the above, during periods of fuel movement on December 26-28, 1982, these procedures had not been implement.ed in that the following requirements of Modification 633, Attachment 17, Fuel Shuffle Procedure, were not met:
(1) The spent fuel pit water level was less than the minimum allowed.
(2) The boron dip samples were not being performed.
(3) The Fuel Handling Procedure 3.0, Table 3.4 log sheet was not utilized to record appropriate spent fuel pit parameters.
: 1. Admission or Denial of the Alleged Violation Carolina Power and Light Company acknowledges the alleged violation.
: 2. Reason for the Violation i
Fuel Handling procedure FT-3 is used by Operations to move fuel during refueling outages. Because FT-3 contained the information necessary to ensure a safe fuel shuf fle, Fr-3 was referenced in Attachment 17 to J
 
K.i  . .f Lettcr;tb Mr. JJames P.[OfReilly 7~  tericit RSEP/83-286 y          P ga 4 L                      ,
(Modification'633. IFf-3 contained some' steps that would be unique to fuel movement only;during refuelins outages and not during this modification.n These were' steps such as:
(1) : referring to the SRO and manipulatior operator in containment, (2) the handling of polyethylene wrappers on new fuel in the new fuel handling building, and (3) thel use of checkoff sheets tha't covered both the containment and ~the spent fuel pit (SFP) .
However, Modification 633 failed to delineate which portions of the IPf-3 were applicable. - Therefore, only those conditions in FT-3; believed by those performing this operation to be pertinent . to the fuel swement in the SFP, were observed and                                            ,
adhered to as per the reference in Attachment 17 of Modifi-cation 633.' It was -believed that the pertinent steps in FT-3 had .been followed and that the three steps cited in the violation were not pertinent and, therefore, did not necessarily apply to Attachment 17 of Modification 633.
: 3. Corrective Steps Which Have Been Taken and Results Achieved Movement of Spent Fuel in the SFP was stopped until a special procedure (SP-456) was implemented which included all necessary requirements of the fuel shuf fle without referencing other procedures.      SP-456 included a required SFP level, SFP bcron samples, and checkoff list, which included appropriate SFP parameters.
In the performance of SP-456, a personnel error in procedural compliance resulted in a discrepancy of the documented SFP level. This resulted in disciplinary' action with the individual involved. . In addition, the Manager of Operations & Maintenance
                          - met with each operating shif t to emphasize the necessity of                                            '
procedural compliance and the importance of quality operation.
                -4.-      Corrective Steps Which Will Be Taken to Avoid Further Violation The steps described above should prevent further violation of not strictly adhering to referenced procedures.
: 5. Date When Full Compliance Will Be Achieved Ibil compliance has been achieved.
 
'a * * :4 * .Lett:r to Mr. Jane] P. C'Reilly                                    ,
f'  ~ Bericit RSEP/83-286                                                                =
7r P;:ga 5                                                                  -
              .If you have any questions concerning this response, please contact my
            - staf f or me.
Very truly yours, R. B. Starkey, Jr.
General Manager H. B. Robinson S. E. Plant CLW:FMC:JMC/bs .
cc:  R. C. DeYoung                                                                  ,
O e
t p-  --}}

Revision as of 23:27, 7 August 2020

Responds to NRC 830202 Ltr Re Violations Noted in IE Insp Rept 50-261/82-42.Corrective Actions:All safety-related Instruments Added or Altered by Mods Will Be Reviewed to Ensure Correct Info Is on Calibr Sheet
ML20069E061
Person / Time
Site: Robinson Duke Energy icon.png
Issue date: 03/04/1983
From: Starkey R
CAROLINA POWER & LIGHT CO.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20069E059 List:
References
RSEP-83-286, NUDOCS 8303210379
Download: ML20069E061 (5)
v • d • e


Text

. .

t . _~,.

._.. e USNRC REOlON ':

Al i AN Ti.t u C R."~M Carolina Power & Light Company g g AW . 43 H. B. ROBINSON STEAM . ELECTRIC PLANT POST OFFICE BOX 790 HARTSVILLE, SOUTH CAROLINA 29550

' MAR 4 1983 Robinson File No: 13510E. Serial: RSEP/83-286 Mr. James P. O'Reilly Regional Administrator U. S. Nuclear Regulatory Commission Region'II 101 Marietta Street, N. W.

~ Atlanta, . Ceorgia 30303 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT No. 2 DOCKET NO. 50-261 LICENSE NO. DPR-23 RESPONSE TO NRC INSPECTION REPORT 82-42

Dear Mr. O'Reilly:

Carolina Power and Light Company (CP&L) has received and reviewed the subject report and provides the following response.

A.- S_everity Level IV Violation (IER-82-42-02-SL4)

Technical Specification 3.1.2.d requires that the overpressure protection system be operable whenever Reactor Coolant System (RCS) temperature is below 350 F and the RCS is not vented to containment.

Contrary to the above, as of December 12, 1982, the overpressure protection system has not met operability requirements since system installation in 1978, due to 'a non-conservative pressure transmitter calibration error affecting both trains of protection. As a result, the overpressure protection system was incapable of meeting its design basis requirements during all _ periods of required operability.

1. Admission or Denial of the Alleged Violation Carolina Power and Light Company acknowledges the alleged violation.

KO ohhPDR

y r" y

'~ q~ ~ .,* Lett:r t].Mr. J: mea P. O'RJ111y.

Ser'ici: RSEP/83-286 P;312 '  ;

2. Reason for the Violation

- Lt -1978, when the Low Temperature Overpressure Protection (LTOP)

. system was installed, an incorrect value was assigned to the "zero adjust" which compensates for the reference leg height in the calibration of the LTOP pressure. transmitters. Since the narrow range pressurizer pressure transmitter and the LTOP pressure trans-mitter use the same pressurizer reference leg, it'was erroneously assumed that the narrow range "zero adjust" could be used for the LTOP "zero adjust." This; resulted in a.non-conservatively low bias on the LTOP pressure transmitters.

3.~ Corrective Steps Which Have Been Taken and Results Achieved The LTOP pressure transmitters imve been properly calibrated, and their calibration sheets, which are now controlled in the Plant Operating Manual (POM), have been corrected.

The modification control procedure was reorganized in 1982 and now. requires that the calibration sheets be implemented into the POM as part of the modification process.

4. Corrective Steps Which Will Be Taken To Avoid Further Violation

~

All safety-related instruments that have .been added to or altered

' by modifications will be reviewed to ensure that the appropriate information' is contained on their respective calibration sheet in the Plant Operating' Manual.

5. Date When Full Compliance 'Will Be Achieved The appropriate instruments will be identified by August 1,1983. The review of calibration sheets for the identified instruments should be completed within two months following the identification of the ins trume nt s.

B. ,S,everity Level IV Violation (IER-82-42-03-SL5)

Technical Specification 6.5.1.1.1 requires that procedures be established, implemented, and maintained meeting the requirements of Appendix A of Regulatory Guide 1.33 Revision 2 and addressing surveillance and test activities of safety-related equipment. Maintenance Instruction-4, Cal-ibration Program, implements these requirements for calibration of the pressure transmitters required for proper operation of the low temperature overpressure protection system.

x

E ~

Letter to.Mri J:me] P. O'ROilly

' 8e rial *: RSEP/83-286

Pag 3 3 E

Contrary to the above, as of December 12, 1982, adequate procedures had not been established controlling the calibration of the low temperature overpressure protection system pressure transmitters in that the zero adjustment was incorrectly specified, resulting in transmitter output being non-conservatively low.

1. Admission or Denial of the Alleged Violation Carolina Power and Light Company acknowledges the alleged violation.
2. Reason for the Viola tion JThe reason for this violation and the corrective steps taken and to be taken are identified as those stated in the response to Violation "A" ab ove .

C. _ Severity Level V Violation (IER-82-42-0-SL5)

Technical Specification 6.5.1.1.1 requires that procedures be implemented which meet the requirements of Appendix A to Regulatory Guide 1.33, Revision 2. Administrative Instructions Section 5 and Engineering Procedure 5.0 implement these requirements with respect to procedural compliance and 91 ant modification control and require that modification implementing procedures be followed or appropriately revised and reviewed.

Contrary to the above, during periods of fuel movement on December 26-28, 1982, these procedures had not been implement.ed in that the following requirements of Modification 633, Attachment 17, Fuel Shuffle Procedure, were not met:

(1) The spent fuel pit water level was less than the minimum allowed.

(2) The boron dip samples were not being performed.

(3) The Fuel Handling Procedure 3.0, Table 3.4 log sheet was not utilized to record appropriate spent fuel pit parameters.

1. Admission or Denial of the Alleged Violation Carolina Power and Light Company acknowledges the alleged violation.
2. Reason for the Violation i

Fuel Handling procedure FT-3 is used by Operations to move fuel during refueling outages. Because FT-3 contained the information necessary to ensure a safe fuel shuf fle, Fr-3 was referenced in Attachment 17 to J

K.i . .f Lettcr;tb Mr. JJames P.[OfReilly 7~ tericit RSEP/83-286 y P ga 4 L ,

(Modification'633. IFf-3 contained some' steps that would be unique to fuel movement only;during refuelins outages and not during this modification.n These were' steps such as:

(1) : referring to the SRO and manipulatior operator in containment, (2) the handling of polyethylene wrappers on new fuel in the new fuel handling building, and (3) thel use of checkoff sheets tha't covered both the containment and ~the spent fuel pit (SFP) .

However, Modification 633 failed to delineate which portions of the IPf-3 were applicable. - Therefore, only those conditions in FT-3; believed by those performing this operation to be pertinent . to the fuel swement in the SFP, were observed and ,

adhered to as per the reference in Attachment 17 of Modifi-cation 633.' It was -believed that the pertinent steps in FT-3 had .been followed and that the three steps cited in the violation were not pertinent and, therefore, did not necessarily apply to Attachment 17 of Modification 633.

3. Corrective Steps Which Have Been Taken and Results Achieved Movement of Spent Fuel in the SFP was stopped until a special procedure (SP-456) was implemented which included all necessary requirements of the fuel shuf fle without referencing other procedures. SP-456 included a required SFP level, SFP bcron samples, and checkoff list, which included appropriate SFP parameters.

In the performance of SP-456, a personnel error in procedural compliance resulted in a discrepancy of the documented SFP level. This resulted in disciplinary' action with the individual involved. . In addition, the Manager of Operations & Maintenance

- met with each operating shif t to emphasize the necessity of '

procedural compliance and the importance of quality operation.

-4.- Corrective Steps Which Will Be Taken to Avoid Further Violation The steps described above should prevent further violation of not strictly adhering to referenced procedures.

5. Date When Full Compliance Will Be Achieved Ibil compliance has been achieved.

'a * * :4 * .Lett:r to Mr. Jane] P. C'Reilly ,

f' ~ Bericit RSEP/83-286 =

7r P;:ga 5 -

.If you have any questions concerning this response, please contact my

- staf f or me.

Very truly yours, R. B. Starkey, Jr.

General Manager H. B. Robinson S. E. Plant CLW:FMC:JMC/bs .

cc: R. C. DeYoung ,

O e

t p- --

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