3F0185-15, Suppls Response to NRC Supplemental Re Violations Noted in Insp Rept 50-302/84-09.Continues to Deny Existance of Violation Based on Procedure Adherence. Event Considered Isolated Incident

Suppls Response to NRC Supplemental Re Violations Noted in Insp Rept 50-302/84-09.Continues to Deny Existance of Violation Based on Procedure Adherence. Event Considered Isolated Incident

ML20127G946
Person / Time
Site:	Crystal River
Issue date:	01/25/1985
From:	Westafer G FLORIDA POWER CORP.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20127G897	List: 3F0185-15, Suppls Response to NRC Supplemental Re Violations Noted in Insp Rept 50-302/84-09.Continues to Deny Existance of Violation Based on Procedure Adherence. Event Considered Isolated Incident IR 05000302/1984009
References
3F0185-15, 3F185-15, NUDOCS 8505210180
Download: ML20127G946 (3)

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Power C O n P O n a F e O as January 25,1985 3F0185-15 Mr. 3. P. O'Reilly Regional Administrator, Region II Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, GA 30323 j

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 IE Inspection Report No. 84-09, Supplemental Response 2

Dear Sir:

I Florida Power Corporation provides the attached as our supplemental response to the subject inspection report and your supplemental response dated December 26, 1984.

Sincerely, '

e P/

G. R. Westafer  !

Manager, Nuclear Operations Licensing and Fuel Management RMB/feb Attachment 8505210100 850417 gDR ADOCK 05000302 PDR G EN ERAL OFFICE 3201 Thirty-fourth Street South e P.O. Box 14042, St. Petersburg, Florida 33733 e 813-866-5151

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FLORIDA POWER CORPORATION SUPPLEMENTAL RESPONSE 2 INSPECTION REPORT 84-09 VIOLATION 84-09-04 Technical Specification 6.8.1.c requires adherence to procedures involving surveillance and test activities. Surveillance procedure SP-317 provides the instructions for performing a Reactor Coolant System (RCS) leakage check.

Procedure steps 6.4.1 through 6.4.3 require data to be recorded on Enclosures 1 and 2 at the end of-the data collection interval consisting of at least eight hours of.

steady state operation. The procedure then requires that the data from Enclosure I and Enclosure 2 provide input for the RCS leakage calculation performed on data sheet Enclosure 3.

Contrary to.the above, on March 6,1984, data from Enclosure 1, completed at approximately 1:00 p.m. and representing only six hours of steady state operation, was used to compute the RCS leakage with data from Enclosure 2 that was completed at 4:00 p.m. The Enclosure 2 data represented eight hours of steady state operation.

This is a Severity Level IV violation (Supplement 1).

NRC Supplemental Response With regard to Violation 84-09-04, we still conclude that you have missed the root cause of this ' violation. Your supplemental response discusses the need in your procedure to allow boration or deboration during the eight hour data taking period to accommodate variation in core burnup (c.g., the ad_ vent of Xenon burnup) so that variations in reactor power, reactor coolant system (RCS) temperature, etc., can be minimized. While your procedure ~1n Section 4.2 requires such activities to be -

minimized, it does not prohibit these activities. We agree with your assessment that such activities are in accordance with your procedure. We do not agree, however,' that the securing of data taking at 1:00 p.m. on Enclosure I and the securing of data taking at 4:00 p.m. on Enclosure 2 and then using the resultant data to compute the RCS leakage on Enclosure 3 is in accordance with your l _ procedures. Good engineering practice dictates that data recorded for use in a final calculation, that may be subject to change during the data run, should cover the same time interval to assure that all data variations are captured in the calculation. During the three hour period (: e., from 1:00 p.m. to 4:00 p.m.) when the reactor coolant drain tank (RCDT) leven change was not being recorded, unexpected level variations could have occurred resulting in a different RCDT inventory change value with a resultant different RCS final leak rate value. It appears that the data runs specified in Enclosures I and 2 should be accomplished in

- the same time frame as intended by procedure Sections 6.4.1 through 6.4.3 to ensure an accurate RCS leakrate determination had been performed. Based upon our review of your supplemental response, NRC continues to assert that a violation for failure to follow SP-317 did occur.

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FLORIDA POWER CORPORATION SUPPLEMENTAL RESPONSE o .

It is very difficult, if not impossible, to present a disagreement with a position  :

without appearing argumentative which is certainly not our intent. We, however in l

- this instance, feel that in some way we have failed to present our case in such a manner as to convince you that.we are not in violation.7We also feel that it is in

'NRC's interest as well as our own to attempt once again to coherently present our position for your consideration. This issue might best be resolved by telephone or a meeting.

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I While fully understanding your position and argument regarding violation 84-09-04 presented above, we continue to deny existance of a violation based on procedure

. adherence and respectfully offer the following justification for this denial.

By your assessment, presented above, you agree that we were in compliance with our procedure in deborating the RCS during this performance of SP-317 (a practice we both agree should be minimized and one which we make every. effort- to

. observe). With respect to your position regarding " good engineering practice", we

? wholly agree with the need for accuracy, but we firmly deny that the data intervals used in this single example constitute a violation of our procedure or a deviation -

from routine calculational accuracy.

To : assume-.that average leakage to the RCDT would suddenly change without operator recognition, during the time between 1:00 p.m. and 4:00 p.m., such as to make a significant impact on computational accuracy, throws the technical basis Jfor the 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> interval allowed between calculations in doubt. If we are given credit to recognize such changes between required calculations, there is no basis to

' assume we could not recognize the presence of such a change between the hours of 1:00.and 4:00 p.m.

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We,,therefore, submit that while good engineering practice may be in. question, in your. view, it does not support a violation based on failure to follow procedure. 'In -

our' view, this event is an isolated incident on which we disagree regarding calculational accuracy and engineering judgment. :

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