3F0890-02, Responds to Violations Noted in Insp Rept 50-302/89-14. Corrective actions:short-term Instruction Issued to on-duty Operators Emphasizing Conditions Necessary to Perform Procedural Steps W/O Presence of Procedure
| ML20248B318 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 08/04/1989 |
| From: | Widell R FLORIDA POWER CORP. |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| 3F0890-02, 3F890-2, NUDOCS 8908090186 | |
| Download: ML20248B318 (3) | |
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August 4, 1989 3F0890-02 U. S. Nuclear Regulatory rwnminaion Attention:. Wnnr=1t Control Desk Washington, D.' C.
20555
Subject:
C*;stal River Unit 3 Docket No. 50-302 Operating License DPR-72 Inspection Report 89-14
Dear Sir:
Florida Power Corporation (FPC) provides the attached as our response to the subject Inspection Report.
Should there be any questions, please contact this office.
Yours very truly, I,-.) _
f Rolfb.Widell Director, Nuclear Operations Site Support WIR: mag Att.
Ac: Regional Administrator, Region II Fenior Resident Inspector S
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6908090186 890804 l
PDR ADOCK 05000302 8
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FDC POST OFFIOE BOX 219
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FLORIDA POWER CORPORATION l
INSPECTION REPORT 89-14 I
REPLY TO NOTICE OF VIOLATION
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VIOLATION 89-14-01 Technical Specification 6.8.1 requires written procedures to be established, implemented, and maintained as recommended in Appendix A of Regulatory Guide 1.33, Novem~ er,1972. Appendix A of Regulatory Guide 1.33 recommends general I
o plant operating procedures for plant heatup and procedures for operation of the pressurizer spray control system.
It also recommends administrative procedures on adherence to procedures. Administrative Instruction AI-400E, Performance and Transmittal of ' Procedures, Revision 1,
requires.that j
operators have procedures present when performing them, except for routine actions that are frequently repeated and where the operators are familiar with the procedure content.
1.
Contrary to the above, operators failed to have procedures present for performing actions that were not routine to them. At about 0015 on May 28, 1989, operators initiated pressurizer spray from Decay Heat Removal to degas the Reactor Coolant System.
The operators had not performed these actions before and were not familiar with the procedure content.
This contributed to the May 29 overheating of Emergency Feedwater piping and its containment penetration and to subjecting the A steam generator to unanalyzed thermal stresses.
2.
Contrary to the above, general plant operating procedure OP-202, Plant Heatup, Revision 80, was inadequate in that it did not adequately address using pressurizer spray control to degas the reactor coolant system while in Mode 5, with no reactor coolant pumps operating. There were no steps, conditions, cautions, or limits to prevent heating the Emergency Feedwater piping and its containment penetration beyond design limits or to prevent subjecting the A steam generator to unanalyzed thermal stresses. As a result, at about 0500 on May 29, 1989, these conditions occurred.
This is a Severity Level IV violation (Supplement 1).
RESPONSE
Florida Power Corporation (FPC) accepts the violation. This violation was identified by FPC and has been reported in accordance with 10 CFR 50.73 as LER 89-18.
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APPARENT CAUSE OF VIOLATION
- 1) - Administrative guidance and management controls to permit ' performance
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of procedural steps without presence of procedures were weak and not L
sufficiently understood 'by the operators performing the evolutions.
The operators were aware it was a routine evolution a'nd felt th-administrative procedure permitted them to do it without the pro M ure in hand.
- 2) Personnel involved with operations of auxiliary pressurizer spray and the writing of applicable procedures failed to recognize effects of this unusual system interaction.
CORRECTIVE ACTION
- 1) A short-term instruction was issued to on-duty plant operators which emphasized and clarified the conditions which must be satisfied to perform procedural steps without the presence of a procedure.
2)
Instructions were issued to Operations supervisors emphasizing the need to consider the effects of unusual plant conditions and observe applicable precautions when o;,erating the plant in unique situations which occur during shutdown and startup conditions.
DATE OF FULL COMPLIANCE
- 1) Full compliance was achieved on June 1, 1989 when the short-term instruction was issued to the Operations personnel.
- 2) Full compliance was achieved on June 9,1989 when the above instructions were issued.
ACTION TAKEN TO PREVENT RECVRRENCE 1)
FPC will conduct a review, with the assistance of INP0, of the administrative guidance and management controls used to govern operator actions without procedures present.
This review will focus on plant shutdown conditions. Additional corrective actions, as a result of this review, will be implemented appropriately.
2)
Procedure OP-202, Plant Heatup, will be revised to provide adequate guidance to degas the Reactor Coolant System with no reactor coolant pumps operating. Other procedures which may be applicable will also be i
reviewed and necessary changes identified.
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