ML20062J409

Responds to NRC Re Violations Noted in IE Investigation Rept 50-261/82-03 on 820111-0226.Corrective Actions:Verification Made to Ensure That Curves in Reactor Vessel Would Not Result in Nonconservative Operation

ML20062J409
Person / Time
Site:	Robinson
Issue date:	07/24/1982
From:	Starkey R CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20062J373	List: IR 05000261/1982003 ML20062J370 ML20062J409 ML20062J421 ML20062J438
References
RSEP-82-1281, NUDOCS 8208160358
Download: ML20062J409 (3)

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.A j hTl Carolir}a Power & Light Company Nb . ROBINSON STEAM ELECTRIC PLANT POST OFFICE BOX 790 HARTSVILLE, SOUTH CAROLINA 29550 JULZ *1se Robinson File No: 13510E Serial: RSEP/82-1281 Mr. James P. O'Reilly Regional Administrator USNRC Region II 101 Ma rie t ta S t ree t , N. W.

Suite 3100 Atlanta, Georgia 30303 H. B. ROBINSON STEAM ELECTRIC PLANT, UNIT NO. 2 DOCKET NO. 50-261 LICENSE NO. DPR-23 RESPONSE TO IE INSPECTION REPORT 82-03

Dear Mr. O'Reilly:

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

Infraction IER-82-03-01 Technical Specification 6.9.2.a requires the licensee to report to the NRC, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br />, discovery of conditions not specifically considered in the

safety analysis report or Technical Specifications that require remedial

! action or corrective measures to prevent development of an unsafe condition.

Contrary to the above, within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> of receipt of a letter dated April 4, 197 7, from Southwest Research Institute, the licensee did not report to the NRC conditions in the safety analysis report or Technical Specifications.

The conditions rela ted to radiation embrittlement of the reactor vessel. It required consideration of remedial action, modification of heatup and cooldown limitations, to prevent development of an unsafe condition.

1. Admission or Denial of the Alleged Infraction CP&L acknowledges the alleged infraction.

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.. u Le tter to Mr. James P. O'Reilly Shrial: RSEP/82-1281 Pa ge 2

2. Reason for the Alleged Infraction The informa tion wa s not reported to the NRC nor was it incorporated in the Technical Specifications due to an administrative error.

The event , which was discovered by CP&L personrel, was repot ted following discovery of the error via LER-81-33 da ted January 11, 1982. This event occurred several years ago and is believed the result of a unique set of circumstances rela ted to re-assignment of responsibility for coordina tion of this project of f-site. It is, therefore, considered to be an isola ted event.

3. Corrective Steps Taken A ve rifica tion wa s made to ensure tha t the existing cerves, although slightly in error, would not result in non-conserva tive ope ra t ion. This verification indicated that the current curves would be conserva tive for a plant life greater than ten ef fective full power years (current plant life is approxima tely 7.3 EFPY) .

With respect to the administrative error, major changes have been made to administrative practices rega rding of f-site coordinated projects since 197 7, and an increased awareness of the sta tus of these activities has resulted. Procedures used to request technical assistance from other departments within the Company require tha t as a minimum, correspondence shall include the project coordinator, the Plant Cencral Manager as well as other appropriate Section Managers for distribution.

In addition, a Regula tory Compliance Subunit was established on site in 1981. This subunit provides a central point of focus for all H. B. Robinson regula tory ma tters, which should further prevent this type of event from recurring.

l l 4. Corrective Steps Which Will Be Taken t

I During the 1982 refueling outage a surveillance capsule was removed from the reactor vessel. Upon completion of the analysis of this capsule, a Technical Specifica tion change containing the revised curves and the revised reactor vessel ma terial surveillance calcula tions will be submitted to the NRC.

5. Da te When Full Compliance Should Be Achieved Results of the examinations of the surveillance capsule and l

upda ted hea tup and cooldown curves will be reported to the i NRC within 90 days of the completion of the examination.

The examina tion is scheduled to be comple ted in September, 1982.

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Letter to Mr. James P. O'Reilly

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• Serial: RSEP/82-1281 Page 3

6. Assessment of the Corrective Action Requested by the Transmittal Le tte r Company policies and procedures' implemented, since the event, regarding of f-site coordinated projects have been effective in ensuring that plant personnel are aware of information provided by personnel outside the Company and that pertinent data is promptly acted upon.

If you have any questions regarding this response, please contact me.

Very truly yours, b l (l( ,

R. B. Starkey, Jr.

General Manager H. B. Robinson SEG . Plant CW/bs i

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