3F0896-21, Advises That Util Revising Completion Schedule & Program Content for Plant EOP Enhancement Program

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Advises That Util Revising Completion Schedule & Program Content for Plant EOP Enhancement Program
ML20117F159
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 08/26/1996
From: Beard P
FLORIDA POWER CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F0896-21, 3F896-21, NUDOCS 9609030338
Download: ML20117F159 (2)


Text

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Florida l Power CORPORATION l

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August 26, 1996 3F0896-21 1

U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C. 20555-0001

Subject:

E0P Enhancements

Reference:

FPC to NRC letter, 3F0296-02, dated February 1, 1996

Dear Sir:

This letter is to advise the NRC that Florida Power Corporation (FPC) is revising the completion schedule and the program content for the Crystal River Unit 3 (CR-3) Emergency Operating Procedures (E0P) Enhancement Program. As we stated in the reference letter, the E0P Enhancement Program is receiving a high priority within FPC. We currently have six operators and engineers working en this effort full time, in addition to support from operating crews and engineering personnel on an as-needed basir to validate and verify procedures, perform technical reviews, and resolve t?chnical questions. The plan described in the reference letter contained a fairly optimistic and aggressive schedule which we have been following, but other emergent issues which affect E0Ps have impacted that plan.

FPC commits to completion of the CR-3 E0P Enhancement Program by March 31, 1997 rather than September 30, 1996. Our reasons for this extension and program content change are provided below.

First, the Enhanced E0Ps were going to be issued b.v September 30, 1996. This date was selected to allow one cycle of Licensed Operator Requalification training before and after the E0Ps were issued, and prior to the annual exams for the operators. The schedule did not account for emergent E0P revisions occurring during Refuel 10. Plant analyses and modifications associated with resolving Small Break LOCA issues resulted in numerous changes to the E0Ps during the outage. This diverted our efforts on the Enhancement Program and we were unable to maintain the previous schedule. Although the overall scheduled completion is being delayed, we emphasize that FPC made numerous substantial improvements to

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U. S. Nuclear Regulatory Commission 3F0896-21 Page 2 the E0Ps earlier than we originally planned. Also, we want to ensure adequate I training of our licensed operators which is an essential element to the success l of this program. The next opportunity to provide comprehensive training on the enhanced E0Ps will be Cycle 1 of requalification training which begins in January 1997.

Second, we are canceling the part of the program which creates a " Plant Specific j Step Bases" document. This should not be confused with the Plant Specific Technical Guidelines (PSTG). Crystal River Unit 3 had previously developed an extensive " Cross-Step" document that compares the B & W Technical Bases Document (TBD) to our E0Ps. As we discussed in the reference letter, FPC had intended to validate setpoints and steps. The setpoint validation effort was completed as originally intended. However, during this effort, we realized that many steps were validated by virtue of the setpoint they contain. Thus, completing the setpoint document resulted in validation of many plant specific steps. Further validation of the remaining plant specific steps is no longer considered j necessary from a technical point of view. '

l Sincerely, b

P. M. Beard, Jr. 1 Senior Vice President Nuclear Operations PMB/JWT/ GAB l l

xc: Regional Administrator, Region II Senior Resident Inspector NRR Project Manager