ML14191A920

Forwards Summary of 880330 Enforcement Conference Re Design Basis Problem Involving Safety Injection Pump Availability. Meeting Beneficial & Provided Better Understanding of Insp Findings,Enforcement Issues & Status of Corrective Actions

ML14191A920
Person / Time
Site:	Robinson
Issue date:	04/25/1988
From:	Grace J NRC/IE, NRC/RGN-II
To:	Utley E Carolina Power & Light Co
References
NUDOCS 8805030354
Download: ML14191A920 (34)

Text

APR 2 5 1988 Docket No. 50-261 License No. DPR-23 Carolina Power and Light Company kLAFfN:

Mr. E. E. Utley Senior Executive Vice President Power Supply and Engineering and Construction P. 0. Box 1551 Raleigh, NC 27602 Gentlemen:

SUBJECT:

ENFORCEMENT CONFERENCE

SUMMARY

(NRC INSPECTION REPORT NO. 50-261/88-03)

This letter refers to the Enforcement Conference held at our request on March 30, 1988.

This meeting concerned activities authorized for your H. B. Robinson facility. The issues discussed at this conference related to a design basis problem involving safety injection pump availability. A summary, a list of attendees, and a copy of your handout are enclosed.

It is our opinion that this meeting was beneficial and has provided a better understanding of the inspection findings, the enforcement issues, and the status of your corrective actions.

We are continuing our review of these O issues to determine the appropriate enforcement action.

In accordance with Section 2.790 of the NRC's "Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosures will be placed in the NRC Public Document Room.

Should you have any questions concerning this letter, please contact us.

Sincerely, G2f~

RACE J.

Nelson Grace Regional Administrator

Enclosures:

1. Enforcement Conference Summary

2. List of Attendees

3.

Handout cc w/encls:

(See page 2) 8805030354 880425 PDR ADOCK 05000261 DCD

Carolina Power and Light Company 2

APR 25 1988 cc w/encls:

W P. Beatty, Jr., Vice President Robinson Nuclear Projects Department iJK E. Morgan, Plant General Manager b

w/encls:

'C Resident Inspector DRS Technical Assistant Document Control Desk State of South Carolina R

RII RH RI RII PFredrickson:tj DVerrelli L yes Gibson GJen ins MErt 04/11/88 04/ C /88 04/,

1 A/8 8 04/. /88 04/2/88 04/ /88

ENCLOSURE 1 ENFORCEMENT CONFERENCE

SUMMARY

The Regional Administrator opened the meeting by expressing disappointment in an apparent lack of aggressiveness by the licensee to:

(1) followup on NRC findings from the Safety System Functional Inspection conducted during the Spring 1987, and (2) self initiate a program to reconstitute the design basis for the Robinson plant. A more aggressive approach might well have resulted in the licensee independently identifying the deficiency of the Safety Injection (SI) pumps not meeting single failure criterion rather than just making an effort to respond to NRC questions.

The licensee began their presentation, using Enclosure 3, with a review of the original, revised, and final design of the SI system.

The final design and licensing bases (1970) predated the present standards as identified in 10 CFR 50, Appendix A (General Design Criteria), ANSI and IEEE Standards, and Reg. Guide 1.6.

The licensee then reviewed the operating history and the chronology of events that led up to the identification of the design deficiency. The presentation included a discussion by the licensee of operator actions that could be initiated to prevent core damage.

The NRC staff expressed concern that the licensee's mitigating circumstances would rely on operator actions using non-safety related equipment.

.With respect to the timeliness of corrective action, the licensee presented a sequence of events for the January 28-30, 1988 time frame, in order to demonstrate that management actions were prudent, conservative, decisive and timely. The licensee did not agree that a violation of Criterion XVI of Appendix B had occurred.

The licensee's presentation was concluded by outlining corrective actions.

This included completed actions, interim actions for returning the unit to full power operation, and longer term efforts to reconstitute the design basis for the Robinson facility.

The Regional Administrator closed the meeting and stated that due consideration

.would be given to the licensee's presentation in determining NRC enforcement action.

ENCLOSURE 2 LIST OF ATTENDEES Attendance at the Carolina Power and Light -

NRC meeting March 30, 1988, at the Region II office.

Carolina Power and Light Company M. A. McDuffie, Senior Vice President - Nuclear Generation G. P. Beatty, Vice President, Robinson Nuclear Projects Department (RNPD)

R. E. Morgan, Plant General Manager L. I. Loflin, Manager, Nuclear Licensing J. J. Sheppard, Manager, Planning and Scheduling G. D. Shartzer, Senior Engineer, RNPD NRC Region II J. N. Grace, Regional Administrator L. A. Reyes, Director, Division of Reactor Projects (DRP)

D. M. Verrelli, Chief, Projects Branch 1, DRP L. Garner, Robinson Senior Resident Inspector, DRP S. J. Vias, Project Engineer, DRP G. R. Jenkins, Director, Enforcement and Investigation Coordination Staff (EICS)

B. Uryc, Senior Enforcement Coordinator, EICS L. M. Slack, Enforcement and Investigation Coordination Assistant, EICS P. J. Fillion, Reactor Inspector, Division of Reactor Safety NRC -

Headquarters E. G. Adensam, Director/PDII-1/Division of Reactor Projects/Office of Nuclear Reactor Regulation (NRR)

R. Lo, Senior Project Manager, NRR D. Tondi, Section Chief, NRR

ENCLOSURE 3 PRESENTATION TO NUCLEAR REGULATORY COMMISSION ENFORCEMENT CONFERENCE MARCH 30, 1988 0.

INTRODUCT ION

ENFORCEMENT CONFERENCE AGENDA I. INTRODUCTION A. PURPOSE B. SYSTEM CONFIGURATION C. PROPOSED VIOLATIONS II, SAFETY INJECTION SYSTEM DESIGN (RESPONSE TO 261/88-03-04)

A. ORIGINAL DESIGN B,

REVISED DESIGN C, FINAL DESIGN D. OPERATIONAL HISTORY E. CONCLUSIONS III.

POSTULATED SINGLE FAILURE IDENTIFICATION (RESPONSE TO 261/88-03-05)

A. CHRONOLOGY B.

TECHNICAL DIRECTION C. MANAGEMENT DIRECTION D. CONCLUSIONS IV, CORRECTIVE ACTIONS A. COMPLETED ACTIONS B. PLANNED ACTIONS V.

SUMMARY

INTRODUCTION PURPOSE'

1) RESPOND TO TWO PROPOSED VIOLATIONS

2)

PROVIDE INFORMATION REGARDING ORIGINAL SYSTEM DESIGN BASIS

3)

COMMUNICATE DECISION MAKING PROCESS WITH REGARD TO SCENARIO DISCOVERY

4)

COMMUNICATE COMPLETED AND PLANNED CORRECTIVE ACTIONS

Carolina Power & Light Co.

H. B, Robinson Plant Emergency Bus Layout For Safety Injection Pumps offsite offsite power power Bus El Bus E2 I

I I288 a221*

3 298 278

)29C SIP A SIP C EDG A SIP 1 EDG 7

Breaker control from Train A battery 0 - Breaker control from Train B battery Breaker - Open Breaker closed EDG - Emergency Diesel Generator SIP -Safety Injection Pump

INTRODUCTION PROPOSED VIOLATIONS FAILURE TO COMPLY WITH 10CFR50 APPENDIX A CRITERION 35 EMERGENCY CORE COOLING (261/88-03-04)

DESIGN BASIS PER UFSAR TABLE.6.5.2-8:

THREE SAFETY INJECTION (SI) PUMPS PROVIDED.

EVALUATION BASED ON OPERATION OF TWO.

SCENARIOS (1,2,4 & 5) IDENTIFIED WHICH SHOW:

ONLY ONE SI PUMP AVAILABLE. FAILED TO MEET IOCFR50.46 ECCS CRITERIA FAILURE TO COMPLY WITH 10CFR50 APPENDIX B CRITERION XVI CORRECTIVE ACTION (261/88-03-05)

XVI REQUIRES PROMPT IDENTIFICATION OF CONDITIONS ADVERSE TO QUALITY.

DELAY IN IDENTIFYING SCENARIOS 2,4, & 5

SAFETY INJECTION SYSTEM DESIGN

SAFETY INJECTION SYSTEM ORIGINAL DESIGN - PRELIMINARY SAFETY ANALYSIS REPORT (PSAR) STAGE (1966-1967)

1) Two AUTO START PUMPS

2) ONE INSTALLED SPARE PUMP

3)

ONE SI PUMP REQUIRED TO MITIGATE DESIGN BASIS ACCIDENT (DBA)

REVISED DESIGN -

PSAR To FSAR (1967-1970)

1)

WESTINGHOUSE MODELS EVOLVED

2)

Two SI PUMPS REQUIRED TO MITIGATE DESIGN BASIS ACCIDENT

3)

DESIGN REVISED TO AUTO START SWING BUS PUMP -

BACKFIT

4)

SINGLE FAILURE AND TRAIN SEPARATION CRITERIA CONSIDERED IN DESIGN REVISION A) CONCEPTS OF SINGLE FAILURES AND TRAIN SEPARATION WERE IN EVOLUTION B) LITTLE DOCUMENTATION OF INTERPRETATION

SAFETY INJECTION SYSTEM INAL DESIGN-FSAR/OPERATING LICENSE (1970)

1)

THREE AUTO START PUMPS -

THIRD PUMP ON SWING BUS

2)

DESIGN REVIEWED BY AEC -

CONCERNS OVER INTERLOCK ADEQUACY TO PREVENT PARALLELLING Two EMERGENCY DIESEL GENERATORS (EDGs) - 9/10/69 MEETING WITH LAINAS/SULLIVAN/TEDESCO ET AL. FSAR QUESTION VE -

9/17/69

3)

DESIGN FOUND ACCEPTABLE BY AEC - 5/20/70 LETTER MORRIS TO COLBY FOWARDING 5/18/70 SER

SAFETY INJECTION SYSTEM DESIGN BASIS

1) k DESIGN CRITERIA NOT PRESENTLY AVAILABLE

2) PRESENT GENERAL DESIGN CRITERIA (GDC),-ANS AND IEEE STANDARDS, AND REG. GUIDE 1.6 PUBLISHED AND APPROVED AFTER ROBINSON LICENSED (71-74)

3)

TRAIN SEPARATION AND SINGLE FAILURES (AS CONCEIVED IN THE 1966-1970 TIMEFRAME) WERE CONSIDERED. FSAR STATES THAT SYSTEM WAS DESIGNED AGAINST ACTIVE SINGLE FAILURES.

4) W, CP&L, AND AEC ACCEPTED 1970 DESIGN

SAFETY INJECTION SYSTEM OPERATING HISTORY

1) PRIOR TO 5/87 NO MODIFICATIONS AND NO EVALUATIONS ASSOCIATED WITH SWING BUS WERE IDENTIFIED. (FLOW REVISIONS BASED ON PRE OP TESTING INCORPORATED INTO ANALYSIS IN 8/70)

2)

SSFI ASKED QUESTIONS ABOUT SWING BUS BUT NOT ABOUT "B" SI PUMP - 5/87

3) 1/14/88 REQUEST FOR ADDITIONAL INFORMATION (RAI) FROM NRR O

~

4) 1/28 - 1/29/88 SINGLE FAILURES IDENTIFIED

5) CP&L TOOK VERY CONSERVATIVE INTERPRETATION OF TECHNICAL SPECIFICATION 3.0.

6) PLACED UNIT IN COLD SHUTDOWN 1/29 -

1/30/88

SAFETY INJECTION SYSTEM MITIGATING CIRCUMSTANCES SUBSEQUENT EVALUATIONS HAVE SHOWN

1) ONE SI PUMP SATISFACTORY FOR STEAM LINE BREAKS FOR 0-100% POWER (EVENT TURNED BY DOPPLER & MITIGATED BY AFW FLOW)

2) ONE SI PUMP SATISFACTORY FOR LARGE BREAK Loss OF COOLANT ACCIDENTS (LBLOCA) FOR 0-100% POWER WITH FQ i-2.26 (SI FLOW INSIGNIFICANT COMPARED To ACCUMULATORS AND RHR FLOW)

3) ONE SI PUMP SATISFACTORY FOR SMALL BREAK Loss OF COOLANT ACCIDENTS (SBLOCA) FOR 0-100% POWER DOWN TO L-3" BREAK

4) ONE SI PUMP SATISFACTORY FOR SBLOCA FOR 0-60% POWER FOR ANY BREAK -

THEREFORE, ONLY CONCERNED WITH SMALL SPECTRUM OF BREAKS (1-3") IN 60-100% POWER RANGE

5) No SI PUMPS ARE REQUIRED FOR FIRST 20 MINUTES OF SBLOCA NOTE:

NO OPERATOR ACTION ASSUMED

SAFETY INJECTION SYSTEM MITIGATING CIRCUMSTANCES (CONT'D)

ONGOING EVALUATIONS EXPECTED TO SHOW

1) ONE SI PUMP OR NONE SATISFACTORY FOR ALL LBLOCA WITH FQ

2.32 (BEST ESTIMATE PEAK CENTERLINE TEMPERATURE 1000 0F)

2) ONE SI PUMP SATISFACTORY FOR SBLOCA FOR ANY BREAK SIZE UP TO 80% POWER (BEST ESTIMATE ANALYSIS WOULD SHOW SATISFACTORY RESULTS TO -

100% POWER USING ONLY SAFETY GRADE EQUIPMENT WITH NO CREDIT FOR OPERATOR ACTION)

3) RISK OF CORE DAMAGE FROM SINGLE FAILURE LEADING TO

.-f ONLY ONE SI.PUMP AVAILABLE EXPECTED TO BE 4 10 /REACTOR YEAR.

RISK ASSOCIATED WITH SWING BUS CONCEPT TWO DECADES BELOW THAT.

SAFETY INJECTION SYSTEM MITIGATING CIRCUMSTANCES (CONT'D)

OPERATOR ACTIONS WHICH WOULD HAVE PREVENTED CORE DAMAGE

1) AFTER VERIFYING ECCS EQUIPMENT ACTUATION AND OPERATION A) START CHARGING PUMP(S)

B) DUMP STEAM USING STEAM DUMPS OR S/G PORVS TO COOL REACTOR COOLANT SYSTEM (RCS)

2) AFTER VERIFYING NO TUBE LEAK A) MONITOR CRITICAL.SAFETY FUNCTION STATUS TREES (CSFSTs)

IF THERMOCOUPLES >11000, GO TO FUNCTIONAL RECOVERY PROCEDURE C.1 B) RAPID DEPRESSURIZATION OF S/G TO COOL REACTOR COOLANT SYSTEM C) IF UNSUCCESSFUL, USE PRESSURIZER PORVs TO DEPRESSURIZE PRIMARY

3) ABOVE ACTIONS WOULD MITIGATE ACCIDENT AND ARE BASED ON NRC REVIEWED WOG GENERIC EMERGENCY OPERATING PROCEDURES

SAFETY INJECTION SYSTEM CONCLUSIONS

1) SCENARIOS WERE IDENTIFIED ON 1/28 AND 1/29 WHICH INVALIDATED FSAR SINGLE FAILURE STATEMENTS CONCERNING TWO SI PUMPS AVAILABLE BASED ON TODAY'S INTERPRETATION

2) ORIGINAL DESIGN AND REVIEWS DID NOT IDENTIFY SCENARIOS OR DID NOT CONSIDER THEM AS CREDIBLE, W, CP&L, AND AEC ACCEPTED DESIGN

3) PLANT DESIGNED & LICENSED AGAINST DRAFT APPENDIX A CRITERIA PUBLISHED IN 1967 NOT THE PRESENT APPENDIX A WHICH WAS ADOPTED IN 1971 AND STATED IN THE VIOLATION

4) BASED ON PROBABILITY OF FAILURES, SUBSEQUENT ANALYSIS, AND IN-PLACE EMERGENCY OPERATING PROCEDURES, RISK TO PUBLIC HEALTH AND SAFETY WAS MINIMAL

5) PLANT COMPLIANCE WITH EFFECTIVE GDC WAS REVIEWED AND FOUND ACCEPTABLE IN 1970, DESIGN WAS NOT CHANGED IN 18 YEARS, PLANT IS STILL IN COMPLIANCE WITH ORIGINAL GDC (CRITERION 44) IT WAS LICENSED TO

6) UPON IDENTIFICATION OF POSTULATED SINGLE FAILURES, DESPITE THE LOW.PROBABILITIES INVOLVED, CP&L TOOK DECISIVE ACTION TO PLACE PLANT IN COLD SHUTDOWN

SINGLE FAILURE IDENTIFICATION

SINGLE FAILURE IDENTIFICATION CHRONOLOGY 1/14 NRR ISSUES RAI ON Bus TRANSFER SCHEME FOR "B" SI PUMP (RECEIVED 1/18) - 30 DAY REQUEST 1/22 (FRI)

ONSITE TECHNICAL SUPPORT UNIT BEGINS REVIEW OF RAI AND REQUESTS ASSISTANCE FROM CENTRAL DESIGN ORGANIZATION (CDO) ON ITEM #3, BREAKER COORDINATION 1/25 (MON)

ONSITE TECHNICAL SUPPORT UNIT BEGINS RESEARCH ON ITEM #1, SI PUMP TRANSFER LOGIC 1/27 (WED)

ONSITE TECHNICAL SUPPORT UNIT IDENTIFIED CONCERN OVER LOSS OF BATTERY EFFECTS AND CONFIRMED.EFFECTS WITH CENTRAL DESIGN ORGANIZATION 1/28 (THURS)

AM -

CONCERN RAISED TO OPERATIONS AND REGULATORY COMPLIANCE OVER LOSS OF BATTERY 1625 TO 1700 -

AFTER CONFIRMATION OF BASIS OF TRANSIENT ANALYSIS, PLANT NUCLEAR SAFETY COMMITTEE (PNSC) MET AND AGREED THAT AN UNANALYZED CONDITION EXISTED 1705 -

NRC SENIOR RESIDENT WAS NOTIIED 1740 -

POWER DECREASE INITIATED 10%/HR 1749 -

ONE HOUR NOTIFICATION MADE

PROBLEM STATEMENT

Carolina Power & Light Co.

H. B. Robinson Plant Emergency Bus Layout For Safety Injection Pumps offsite offsite power power Bus El Bus E2 v7)

I I) 185 f

l I

I 88 228 298 279

)29C SIP A SIP C EG A SIP a EDG B 7

B Breaker control from Train A battery

- Breaker control from Train 8 battery Breaker - open Breaker - closed

.EDG - Emergency Diesel Generator SIP -Safety injection Pump

Carolina Power & Light Company H. B. Robinson Plant Normal Emergency Bus Lineup (After Jan 28, 1988) offsite offsite power power Bus Et Bus E2 E )

)

)o

)- o lag 28 228 290 278 29C SIP A SIP C EDG A SIP S EDGi 7 =Breaker control from Train A battery B

Sreaker control from Train I battery Breaker - open Breaker - closed EDOG - Emergency Diesel Generator SIP -Scfety Irlection Pump

1700 -

2330 NEW BREAKER ALIGNMENT IMPLEMENTED ALIGNMENT TESTED OPERATOR TRAINING COMPLETED FOR ONSHIFT PERSONNEL TECHNICAL SUPPORT PERSONNEL SENT HOME FOR SLEEP 2343 -

POWER DECREASE TERMINATED 2345 -

POWER ASCENSION BEGAN 1/29 (FRI) 0535 -

UNIT AT 100%

0730 -

FOLLQWUP INVESTIGATION BEGAN BASED ON MANAGEMENT CONTINUING CONCERNS 1100 -

NRC SENIOR RESIDENT ASKED QUESTIONS ABOUT LOSS OF BATTERY AND EFFECT ON EDG 1325 -

MANAGEMENT DECLARED THAT UNANALYZED CONDITION STILL EXISTED, POWER DECREASE INITIATED 1410 -

ONE HOUR NOTIFICATION MADE 2046 -

HOT SHUTDOWN 1/30 (SAT) 1942 -

COLD SHUTDOWN

SINGLE rAILURE IDENTIFICATION TECHNICAL DIRECTION 1).TECHNICAL SUPPORT UNIT DILIGENTLY PURSUED INVESTIGATION IN RESPONSE To RAI

2) ORIGINAL PROBLEM IDENTIFIED WAS IN THE DC CONTROL POWER (B BATTERY)

3) ORIGINAL FIX WAS AIMED AT DC CONTROL POWER

4) TECHNICAL INVESTIGATION WAS NEVER TERMINATED NOT UNTIL 1/29 DID LOGIC SCHEME BECOME SUSPECT AND INVESTIGATION TURNED TO THAT DIRECTION

5) ONCE LOGIC SCHEME BECOME SUSPECT, THAT 'PROBLEM DILIGENTLY PURSUED

6) ULTIMATELY OVER 50 POTENTIAL FAILURES INVESTIGATED. S SCENARIOS IDENTIFIED WHICH NEEDED DISPOSITION

SINGLE FAILURE IDENTIFICATION MANAGEMENT DIRECTION

1)

MANAGEMENT CONVENED PNSC AND ACTED PRUDENTLY ON 1/28

2) MANAGEMENT ACTED DECISIVELY TO CORRECT DC CONTROL POWER PROBLEM IDENTIFIED ON 1/28

3) MANAGEMENT DIRECTED INVESTIGATION TO CONTINUE ON 1/29

4)

UPON IDENTIFICATION OF LOGIC PROBLEM, MANAGEMENT ORDERED PLANT SHUTDOWN

5)

MANAGEMENT DIRECTION WAS TO TAKE VERY CONSERVATIVE ACTION BASED ON TECHNICAL SPECIFICATION 3.0. LITERAL INTERPRETATION OF T.S. 3.0 WOULD NOT HAVE REQUIRED A PLANT SHUTDOWN BASED ON THE DEFINITION OF OPERABILITY

SINGLE FAILURE IDENTIFICATION CONCLUSIONS

1)

TECHNICAL REVIEW WAS DILIGENT AND TIMELY

2)

MANAGEMENT ACTION WAS PRUDENT, CONSERVATIVE, DECISIVE AND TIMELY AND INVOLVED A VERY CONSERVATIVE INTERPRETATION OF TS. 3.0

3) IDENTIFICATION AND CORRECTION OF PROBLEM WAS PROMPT, AND PRUDENT. TECHNICAL AND MANAGEMENT ACTIONS DID NOT INDICATE ANY VIOLATION OF CRITERION XVI OF APPENDIX B

0 0

CORRECTIVE AcT oNs

CORRECTIVE ACTIONS COMPLETED ACTIONS

1)

ANALYSIS PERFORMED AND SUBMITTED TO NRC WHICH SHOWS OPERATION AT 60% IS JUSTIFIED WITH ONLY ONE SAFETY INJECTION PUMP AVAILABLE (TWO PUMPS AUTO START)

TECHNICAL SPECIFICATION CHANGE APPROVED AND ISSUED BY NRC

2) MODIFICATION 947 COMPLETED WHICH CORRECTS POTENTIAL SINGLE FAILURE CONCERN IN ACTIVATION LOGIC AND INSTALLED REDUNDANT DC UNDERVOLTAGE TRIP CIRCUITRY FOR CROSSTIE BREAKERS

3) MODIFICATION 951 COMPLETED WHICH DELETES AUTO START/

CLOSURE FEATURES FOR "B" SI PUMP AND CROSSTIE BREAKERS

4) CROSSTIE BREAKER ALIGNMENT CHANGED SUCH THAT CROSSTIE BREAKERS ARE NORMALLY OPEN

5)

CROSS DISCIPLINE INVESTIGATIVE TEAM WHICH INCLUDED W FORMED TO ANALYZE PROBLEM.

INVESTIGATIVE TEAM'S ANALYSIS OF POTENTIAL SINGLE FAILURES IS COMPLETE. PRESENT ARRANGEMENT IS SATISFACTORY FOR TWO PUMPS

CORRECTIVE ACTIONS PLANNED ACTIONS

1)

ANALYSIS INITIATED TO JUSTIFY HIGHER POWER LEVEL. (^80%)

WITH ONLY ONE SI PUMP AVAILABLE (2 AUTO START).

EXPECTED COMPLETION -

5/33

2)

TASK TEAM INITIATED TO DESIGN CHANGES TO RESTORE PLANT TO 100% POWER. EXPECTED COMPLETION -

10/88

3) INDEPENDENT REVIEW' TAM CONDUCTING PROBABILITY BASED FAILURE MODES AND EFFECTS ANALYSIS (FMEA) ON SI SYSTEM TO VERIFY INVESTIGATIVE TEAM'S EFFORT AND PROVIDE INPUT To TASK TEAM.

EXPECTED COMPLETION -

4/88

CORRECTIVE ACTIONS PLANNED ACTIONS (CONT'D)

4)

DESIGN BASIS RECONSTITUTION PROJECT UNDERWAY, SYSTEMS IN PROGRESS IN 1983 ARE:

A) SAFETY INJECTION B) AUXILIARY FEEDWATER c) REACTOR SAFEGUARDS AND PROTECTION D) ELECTRICAL DISTRIBUTION E) ELECTRICAL CABLE/RACEWAY THESE SYSTEMS WILL BE COMPLETED IN MID-1989 AND THEN HAVE AN INTERNAL SSFI OR EQUIVALENT REVIEW TO ASSURE CONSISTENCY BETWEEN DESIGN BASIS, OPERATING PROCEDURES AND SYSTEM CONFIGURATION, TEN OTHER SYSTEMS WILL FOLLOW AFTER THESE FIRST FIVE.

SUMMARY

0

SUMMARY

1) ROBINSON SAFETY INJECTION AND ELECTRICAL DISTRIBUTION SYSTEMS WERE DESIGNED, APPROVED AND LICENSED PRIOR TO PRESENT REGULATORY REQUIREMENTS AND GUIDANCE.

REGULATION AGAINST WHICH THE VIOLATION CITED (APP. A, CRITERION 35) IS NOT IN H. B. ROBINSON LICENSING BASIS. W, CP&L AND AEC ALL ACCEPTED THE DESIGN AS IN COMPLIANCE WITH GDC IN EFFECT AT LICENSING AND NO CHANGES WERE MADE IN THE INTERIM.

2) ALTHOUGH THE ORIGINAL DESIGN DID NOT MEET CURRENT GUIDANCE, THE PROBABILITY ASSOCIATED WITH POTENTIAL SINGLE FAILURES WAS SMALL AND OVERALL RISK TO THE PUBLIC WAS MINIMAL.

3) UPON IDENTIFYING THE POSTULATED SINGLE FAILURE, CP&L TOOK PROMPT AND CONSERVATIVE ACTIONS TO PLACE THE PLANT IN A SAFE.

CONDITION. No VIOLATION OF IOCFR50 APPENDIX B IS INDICATED BASED ON CP&L'S RESPONSIVENESS TO THE PROBLEM.

4) CP&

IS AGGRESSIVELY PURSUING CORRECTIVE ACTIONS TO NOT ONLY CORRECT THIS PROBLEM BUT TO ASSURE THE DESIGN ADEQUACY OF ALL IMPORTANT SYSTEMS,