3F0594-15, Responds to NRC Re Violations Noted in Insp Rept 50-302/93-16.Corrective Action:Developing an Operations Study Book Entry

Responds to NRC Re Violations Noted in Insp Rept 50-302/93-16.Corrective Action:Developing an Operations Study Book Entry

ML20069D072
Person / Time
Site:	Crystal River
Issue date:	05/27/1994
From:	Beard P FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F0594-15, 3F594-15, NUDOCS 9406020226
Download: ML20069D072 (6)

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l l Florida Power CORPORATION l

ST U S May 27, 1994-3F0594-15 l

l U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555

Subject:

Notice of Violation - Revised Response

[ NRC Inspection Report No. 50-302/93-16

Reference:

A. NRC to FPC letter, 3N1293-40, dated December 30, 1993 I B. FPC to NRC letter, 3F0194-08, dated January 14, 1994 l C. NRC to FPC letter, 3N0294-04, dated February 10, 1994 l D. FPC to NRC letter, 3F0394-08, dated March 10, 1994 j E. NRC letter to FPC, 3N0594-01, dated May 2, 1994

Dear Sir:

Florida Power Corpnration (FPC) provides the attached revised response concerning the Notice of Violation identified in reference C. There were some statements in the NRC reply (reference E) to our initial response where our judgement differs. FPC does not consider it productive to continue to attempt to resolve these disagreements within the framework of the Enforcement Process. A key disagreement involves our plant specific example of using PSA insights. This generic issue is currently being addressed by the NRC and the industry. As active members of the NEI Regulatory Threshold Working Group, we are working to support the industry's part of the resolution of this issue. The NEI "PSA

, Application Guidelines" are currently scheduled to be issued late this year. The related NRC Policy Statement is being developed on a similar schedule. We believe this Policy Statement and the Guidelines will form the essential tools necessary to address this issue. i l

l Thus, we have accepted the violations previously denied and are taking action to address them. In one case, we are making the change encouraged by the NRC and in the other we have a schedule for doing so. Attachment 1 provides the revised a . . . ,

O .n eL G .Li CRYSTAL RIVER ENERGY COMPLEX: 15760 W Power Uno St Crystal River, Florida 34428-6708 604) 795-6486 A Florida Progress Company 9406020226 940527

! PDR ADOCK 05000302 ,, gI l Q PDR

' Nuclear Regulatory Commission

3F0594-15 l c

Page 2 of 6 response to the violations we previously denied. Also included in Attachment 1 ,

is a response to your request for a more definitive action plan.  ;

1 We appreciate the frank discussion we have had on these issues and are confident I our differing professional judgments can and will be resolved. In this regard l we will schedule a meeting with the NRC staff. j Sincerely,

/

. M. Beard, Jr.

Senior Vice President Nuclear Operations PMB/RLM/PVF cc: Regional Administrator, Region II NRR Project Manager Senior Resident Inspector

4 Nuclear Regulatory Commission ATTACHMENT 1 i 3F0594-15

,Page 3 of 6 FLORIDA POWER CORPORATION NRC INSPECTION REPORT NO._50-302/93-16 REPLY TO A NOTICE OF VIOLATION RESTATEMENT OF VIOLATION 50-302/93-16-01 (examples 1.a. and 1.b. )

A. 10 CFR 50, Appendix B, Criterion V, requires, in part, that activities affecting quality shall be prescribed by documented ' instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

1. Contrary to the above, on December 11, 1993, several Emergency Operating and Abnormal Operating Procedures were inadequate as evidenced by the following examples:

a. Emergency Operating Procedure 03, " Inadequate Subcooling Margin," did not contain appropriate guidance to mitigate ,

small break loss of coolant accident- with loss of all high pressure injection.

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b. Emergency Operating Procedure 14, Enclosure 6, could not be performed as written because the procedure did not direct the 2 operator to open Valve CXV-358.

ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Florida Power Corporation (FPC) accepts both Violations.

REASON FOR THE VIOLATION _

l.a. FPC evaluated the event in terms of risk (probability & consequences) and determined that adequate guidance for the only risk significant sequence should be provided in the Station Blackout procedure.

1.b. When E0P-14 was written, CXV-358 was the closest source of demineralized water, and CXV-358 is but one option available to the operator. It was part of a reasonably routine evolution and posed no difficulty to the operators observed by the NRC or others with which we have discussed it.

We also acknowledge that the procedure did not direct the opening of MSV-524, or provide the other specific actions listed in the enclosure to reference E. Again, we considered these to be within the normal knowledge and skills of operators.

CORRECTIVE ACTIONS TAKEN AND THE RESULTS ACHIEVED 1.a. Initial actions included developing an information aid for the operating staff to make them aware of SBLOCA without HPI events. As an interim action FPC is developing an Operations Study Book entry to discuss this in mere detail until final resolution is achieved. FPC will resolve this issue following the conclusion of the B&W Owners Group Operator Support Committee meeting, currently scheduled for August,1994. This meeting will also address the results of the recent generic technical guideline validation efforts conducted at the CR-3 site specific simulator.

1.b. No immediate corrective actions were required for this example.

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.. Nuclear Regulatory Commission ATTACHMENT 1 i 3F0594-15 1

,Page 4 of 6

CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS 1.a. The development of a controlled E0P cross-step and deviation document, and

! coordinating Owners Group efforts to determine the best location to place l

! the related mitigative actions, are adequate measures to prevent j recurrance.

1.b. E0P-14, Enclosure 6 will be revised to provide more definitive pre-analyzed course of actions for operators to provide a flow path such as 4

opening valves and removing vent caps (addressing all of the examples in 3

your May 2, 1994 letter).

DATE WhEN FULL COMPLIANCE WILL BE ACHIEVED

, l 1.a. All procedure changes will be completed by October, 1994.

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1.b. The procedure revision will be completed prior to restart from Refuel 9, currently scheduled for June 6,1994.

j RESTATEMENT OF VIOLATION 50-302/93-16-05 (example 3. )

1 E. Technical Specification 6.8.1 required, in part, that written procedures

shall be established, implemented and maintained covering the applicable j procedures recommended in Appendix "A" of Regulatory Guide 1.33, November, 1972.

j Regulatory Guide 1.33 listed various safety-related administrative i activities including Procedure Review and Approval.

4 I Al-402C, "E0P Verification and Validation Plan," . required that the j originator of the procedure verification designate independent reviewers to perform enclosure 2 of the procedure (Evaluation Criteria for Procedure 1 Verification).

Contrary to the above, on December 11, 1993, the licensee had not j performed verifications and validations on 14 Emergency Operating Procedures in accordance with the procedural requirements of Al-402C as

evidenced by the following example

i j 3. Emergency Operating Procedure 14, Enclosure 6, "0TSG Blowdown i Lineup," was not adequately validated. Step 1.1.1 of Al-402C Enclosure 4 required that the procedure contain sufficient information to perform the specified actions. The procedure 1 could not- be performed as written because the procedure did

, not direct the operator to open Valve CXV-358.

ADMISSION OR DENIAL 0F THE ALLEGED VIOLATION FPC accepts the Violation.

BEASON FOR THE VIOLATION As discussed in responses to Violation 50-302/93-16-01, example 1.b. above, the procedure was purposely written to allow any source of water to be used and this step was considered to be within the knowledge and skills of operators. We agree that our validation process warranted improvement.

h ' -- Nuclear Regulatory Commission ATTACHMENT 1 3F0594-15

.Page '5 of 6 CORRECTIVE ACTIONS TAKEN AND THE RESULTS ACHIEVED l

The Verification and Validation Procedure has been revised to improve methods for l performing such tasks.

CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS

1 E0P-14 will be revised to be more definitive on operator action required to provide a flow path such as opening valves and removing vent caps.

1 DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED i The E0P-14 procedure revision will be completed prior to restart from Refuel 9, currently scheduled for June 6,1994. As noted above, the verification and l validation procedure has been revised and is being used on all E0P revisions. I j RE0 VEST FOR A MORE DEFINITIVE E0P ACTION PLAN

! A specific Action Plan was developed and transmitted to the NRC by reference B.

j The current status of each action is as follows:

ACTION STATUS

}' 1. ASSEMBLE TEAM TO DISCUSS MILESTONES, COMPLETE I RESPONSIBILITIES, ACCOUNTABILITIES AND LOGISTICS.

2. UPDATE, REVIEW AND APPROVE THE UPDATE AND REVIEW 1 DEVIATION DOCUMENT USING GTG REV. 7. COMPLETE. APPROVE BY I RESTART I (JUNE 6, 1994) '

3. REVISE AND APPROVE E0P WRITER'S GUIDE. SECOND REVISION IN PROGRESS

4. REVISE AND APPROVE E0P VERIFICATION AND COMPLETE VALIDATION PLAN. l S. REVISE ABNORMAL PROCEDURES (APs) TO COMPLETE CORRECT VALID DEFICIENCIES.

6. PERFORM SAFETY EVALUATIONS (50.59) ON COMPLETE ALL EXISTING E0Ps AND SAFETY-SIGNIFICANT GTG DEVIATIONS.

7. PERFORM VERIFICATION ON ALL E0Ps. COMPLETE

8. PERFORM VALIDATION AS NEEDED ON E0Ps. COMPLETE

9. REVISE E0Ps TO CORRECT VALID NRC COMPLETE BY RESTART DEFICIENCIES. (JUNE 9, 1994) 10 PERFORM QUALITY PROGRAMS EVALUATION. COMPLETE BY RESTART (JUNE 6, 1994) 4

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. 1 Nuclear Regulatory Commission ATTACHMENT 1 3F0594-15 Page 6 of 6 LONG TERM ACTIVITIES:

As a result of the verification and validation performed on the E0Ps,' a number of discrepencies and comments were documented. Most consist of format and detail inconsistencies. However, several indicate the need to either further revise the E0Ps or develop casualty type (or abnormal) procedures to cope with .certain events or co itions. FPC is currently developing t follow-on. action plan to manage this , Ic.'t. ,

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