3F0685-05, Responds to Violations Noted in Insp Rept 50-302/85-08. Corrective Actions: Operation Section Implementation Manual Will Be Reviewed & Revised to Remove All Instructions Re Plant Safety or Regulatory Compliance

Responds to Violations Noted in Insp Rept 50-302/85-08. Corrective Actions: Operation Section Implementation Manual Will Be Reviewed & Revised to Remove All Instructions Re Plant Safety or Regulatory Compliance

ML20127A201
Person / Time
Site:	Crystal River
Issue date:	06/06/1985
From:	Westafer G FLORIDA POWER CORP.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
3F0685-05, 3F685-5, NUDOCS 8506210047
Download: ML20127A201 (5)

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3 Florida Power C OR POR ATION June 6,1985 3F0685-05 Dr. 3. Nelson Grace Regional Administrator, Region II Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, GA 30323

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 IE Inspection Report No. 85-08

Dear Sir:

Florida Power Corporation provides the attached as our response to the subject inspection report. This response has been delayed as described in our memos dated May 10 and May 24,1985.

Sincerely, o

G. R. Westafer Manager, Nuclear Operations Licensing and Fuel Management AEF/feb Attachment 8506210047 850606 PDR ADOCK 05000302 O PDR ZEo l ap GEN ERAL OFFICE 3201 Thirty-fourth Street South e P.O. Box 14042, St. Petersburg, Florida 33733 e 813-866-5151

FLORIDA POWER CORPORATION

RESPONSE

INSPECTION REPORT 8508 VIOLATION 85G8-01 Technical Specification 6.8.2.b requires procedure changes to be reviewed by qualified interdepartmental interdisciplinary reviewers as specified in Administrative Procedures and to be approved by the responsible superintendent or manager prior to implementation.

In addition, Technical Specification 6.8.2.d requires procedures to be reviewed on a periodic basis as set forth in Administrative Procedures.

Contrary to the above:

a. On January 31,1985, a change made to the Operations Section Implementation Manual (OSIM) was implemented without the approval of the responsible superintendent.

b. As of February 8,1985, the periodic two year review of the OSIM as required by Administrative Procedure AI-500, Conduct of Operations, had not been performed.

This is a Severity Level V Violation (Supplement I).

FLORIDA POWER CORPORATION POSITION Florida Power Corporation (FPC) agrees with the stated violation that a change to the Operations Section Implementation Manual (OSIM) was not properly controlled and that a required two year review of OSIM was not properly performed and documented.

APPARENT CAUSE OF VIOLATION The apparent cause of this violation was an unintentional change in the purpose and scope of OSIM from a document that included only FPC administrative requirements to one that provided management philosophy and guidance in a variety of areas, including some which involved Plant safety.

CORRECTIVE ACTIONS OSIM will be reviewed and revised to remove all instructions which involve Plant safety or regulatory compliance. These instructions will be incorporated in an Administrative Instruction which is reviewed and approved in a manner consistent with the requirements of Technical Specifications 6.8.2.b and 6.8.2.d.

ACTION TAKEN TO PREVENT RECURRENCE The corrective actions described above are sufficient to prevent recurrence.

DATE OF FULL COMPLIANCE The applicable instructions will be moved to an Administrative Instruction by August 30,1985.

)

VIOLATION 85 08-02 Technical Specification 3.7.4.2 requires two independent Decay Heat (DH) seawater loops to be operational when the plant is in operating modes 1 through 4.

Procedure OP-404 directs the operation of .the DH Removal System and specifies in para

-(ES)normal graph 11.0 of this standby modeprocedure of th, nuthe val a lineup Seawater thatThis System. provides valve the Engineered lineup Safeguards requires the seawater train isolation valve to the discharge canal, RWV-40, and the discharge line cross connect valves, RWV-32 and RWV-33, to be open.

Contrary to the above:

a. On February 22,' 1985, an improper procedure change to OP-404 resulted in RWV-40 being closed for approximately 94 hours0.00109 days <br />0.0261 hours <br />1.554233e-4 weeks <br />3.5767e-5 months <br />.

b. As found on February 22, 1985, procedure OP-404 was inadequate in that the requirement to have both cross connect valves (RWV-32 and RWV-33) open defeated the independent status of the DH seawater loops. As a result, two independent DH seawater loops were not available for the duration of the last operating cycle which extended from July 1983 through March 11,1985.

This is a Severity Level IV Violation (Supplement I).

FLORIDA POWER CORPORATION POSITION

a. Florida Power Corporation denies that an improper procedure change resulted in RWV-40 being closed for 94 hours0.00109 days <br />0.0261 hours <br />1.554233e-4 weeks <br />3.5767e-5 months <br />.

Two documentation methods are available to Operations personnel when it becomes necessary to align valves differently from that required by a procedure:

1. Issue a clearance per CP-ll5, In-Plant Equipment Clearance and Switching Orders.

2. Make a temporary change to an existing procedure.

Both of these methods provide adequate assurance that valves will be aligned properly in the special lineup and realigned properly when the system is no longer needed in the special lineup. Both of these methods also provide assurance that a special lineup receives adequate review prior to implementation. In this occurrence, Operations personnel repositioned RWV--

-40 using an equipment clearance order in accordance with CP-ll5.

Additionally, a Short Term Instruction (STI) was issued to Operations personnel for information and to explain the reason for this change in valve lineup.

The various valve lineups either in ops or indicated on flow diagrams do not nor were they intended to constitute required lineups but are based on assumed plant status. The ops generally deal with initial valve lineup for appropriate mode ascension or other indicated conditions. The flow diagrams generally reflect " normal" positions. In either case, valves may be repositioned to adjust to changing plant conditions without requiring a procedure or drawing change.

b.- Florida Power Corporation denies that OP-404 was inadequate or that it allowed the independent status of the DH seawater loops to be defeated. FPC understands that the DH seawater piping was not designed or intended to be operated with the discharge pipes isolated from each other. FSAR Section

. i

9.5.2.1.2 which states, in part, "The following cases generally cover the safeguards against the major contingencies anticipated....Two full size redundant 48 inch discharge pipes with piping and valving arrangements inside the building to route the water discharged from the nuclear services and decay heat services heat exchangers to either or both of the discharge pipes" supports this contention. (Emphasis added.) Also FSAR Section 9.5.2.2 states, in part, " Seawater is circulated from each of the decay heat services seawater pumps through separate supply lines and decay heat closed cycle heat exchangers, and discharged to the two 48-inch discharge pipes."

In order to prevent future misinterpretation of this Technical Specification, FPC will propose a change to the wording of the Technical Specification to clearly describe the design of the decay heat seawater discharge piping consistent with the FSAR.

VIOLATION 85-08-07 Technical Specification 6.8.3 allows temporary changes to be made to refueling procedures provided that the intent of the original procedure is not altered and that the change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's (SRO) license.

Contrary to the above, on February 8,1985, a temporary change was made to refueling procedure FP-304 and the change was not approved by two members of the plant management staff, at least one of whom holds an SRO license.

This is a Severity Level V Violation (Supplement 1).

SUPPLEMENTAL INFORMATION:

In Inspection Report 85-11, the inspector cited a similar example to this event involving OP-209, " Plant Cooldown" on March 9,1985. Resident Inspectors T. Stetka and 3. Tedrow cited another example of this problem (85-21) related to SP-354A, " Emergency Diesel Fuel Oil Quality and Diesel Generator Monthly Test" on May 14,1985. They requested that FPC address this example along with those mentioned above.

FLORIDA POWER CORPORATION POSITION .

Florida Power Corporation agrees that current guidance has allowed improper procedure changes to occur through the use of "N/A" (not applicable) on procedure sign-offs, and that corrective action is required to reduce confusion and prevent repetition of these occurrences.

APPARENT CAUSE OF VIOLATION Plant personnel currently mark procedural steps "N/A"(not applicable) in accordance with step 4.3.3 of our Administrative Instruction AI-400, " Plant Operating Quality Assurance Manual Control Document (POQAM)" which states in part:

4.3.3 . .. Steps not performed because of system condition or other basis for inapplicability shall be marked "N/A" and explained by the Responsible Section Superintendent / Supervisor or his designee.

Exercising action under this criteria clearly calls for a judgement on the part of the workers and supervisors. Wherever such judgement must be made there is opportunity for error.

CORRECTIVE ACTION FPC will provide improved guidance to Operation's personnel on the use of "N/A" and the temporary procedure change process. A directive regarding this topic will be issued by the Nuclear Operations Superintendent.

CORRECTIVE ACTION TO PREVENT RECURRENCE Changes to our Administrative Instructions will also be considered and will be implemented where appropriate to clarify the use of "N/A" and temporary procedure changes.

DATE OF FULL COMPLIANCE Full compliance will be achieved by July 31,1985.