3F0988-10, Responds to Violations Noted in Insp Rept 50-302/88-18. Corrective Actions:Nuclear Operations Dept Procedure NOD-17, Design Basis Issue Resolution, Established & Valves Will Be Repaired or Replaced & Reconfigured

Responds to Violations Noted in Insp Rept 50-302/88-18. Corrective Actions:Nuclear Operations Dept Procedure NOD-17, Design Basis Issue Resolution, Established & Valves Will Be Repaired or Replaced & Reconfigured

ML20154L993
Person / Time
Site:	Crystal River
Issue date:	09/16/1988
From:	Widell R FLORIDA POWER CORP.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
RTR-NUREG-1022 3F0988-10, 3F988-10, NUDOCS 8809270019
Download: ML20154L993 (4)

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l Septanbar 16, 1988  !

3F0988-10 ,

U. S. Nuclear Regulatory Ocamission f Attention: Docunent Control Desk +

Washington, D. C. 20555 i

Subject:

Crystal River Unit 3 Docket No. 50-302 i Operatiry License DHL-72 Inspection Report 88-18 Dear Sir Florida Power Corp 3 ration (FFC) prtnides the attached as our responso to the subject inspection report.

During our review of this and other events, FTC has determined that two aspects of 10 CFR 50.72 appear to warrant clarification. We underistard that revisions to NLTE-1022 are ocotamplated Wich should adiress these ,

concerns. In the interim, ITC recpests the Region's concurrence with ,

ITC's interptstation.

1) We one-hour tiporting zwpirinent is the time frame for aootrplishnent ,

of the tiport. At ITC/ Crystal River 3, mkiry the a:tual tiport is the  !

responsibility of the Naclear shift Supervisor on Duty (NssoD). Until  !

this key nonagement positicn if notified, the "clock" cbes not begin.

We process for identifyin] nonxnformnoes and determinirg that design ,

basis or other riporting cbligatictu are involved sust be timely, but  :

no explicit regulatory maniate is contairtd in 10 CIR 50.72 or  !

elsewhere. We ITC position is consistent with guictmco given in the new LDt rule workshcps, a subsequent natiomi meetirg sponsorcx1 by NUS and atten3ed by the Staff, and in various informal interrcgatories. >

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Post oft ce Box 219

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• Teiert.cne 19?O 795.M32 g g A hmas Pr0;?rss Crum <

U. S. Nuclear Regulatory h imaion 3F0988 Septater 16, 1888 Page 2

2) Se definition of "design basis" is not sufficiently clear. We iglicit iglication of a one-hour reporting requin ment ard the explicit exagles given in NURED-1022 igly a sors narrow definition.

F1C suggests that "design basis" be nu m more clearly definod. In the '

interim, TPC will continue to report rather liberally, i.e., we are reporting many events we suspect were interdad to be riported. We ,

believe that a more clear definition and more unifor1a industr/

iglassentatics would have many benefits. W e definition should, in our [

opinion, be related to those structures, syntans, and saw.wa reliad i upon to mitigate design basis events and should iglicitly or i explicitly include same aspect of significance.  ?

I FPC notas that the information prwided herein does not replicate information provided in the a - iated UR or elsewhere. It is intentionally narrwed to issues related to the violations. FTC's j cr/erall program is much brr*iar ard more substantial than the subset prwided.

1 Should there be any questions, please contact this office. i t

, Yours very truly, t

Bolf C. Widell l

' Director, Nuclear 0 petitions Site suport WIR!abq I Att.

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1 xc: Regional Achainistrator, Region II f Senior Resident Inspector l l

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FIIRIIA KDER CKRREATIN IMMK:'HW RERRr s8-18 NEPtr to wrIm or VIotArIm vin 1=Hemi sa-is-ol A. 10 QR Part 50.72(b)(ii)(B) requiries that any event that results in a nuclear plant beirq in a condition that is outside of tA design huis of the plant be reported to the IGC Operations center within one hour.

i Cbntrary to the above, on 14uth 8, 1988, taperatures in the amergency l feedwater punp discharge piping were higher than the design twporature l for this piping and this cordition was not reported to the 14C Operations ,

Center. Birthermre, a recurrera of a similar event on June 19, 1988 kas I not reportal until 11:15 a.m. on June 21, 1988.

1 This is a Severity level IV Viohtien (Surpleinent I) . '

W Florlds Power Corporation (FFC) accepts the violation. FTC has requestod oormrrence with two positions relative to this event in the cover letter provided. ,

Asparmt ha of violaticm l

The cause of this violatics) is failure to have an established screenirg l 1

pt-a to a== in a timely mnner, the impact of prtblem reports that my rtpresent potential "design hssis" issues. [

t 0=Mive Acticn After determining thit the design taperature had bocn exocalcd, the event l was reported per 10 QR50.72(b)(ii)(B) . ,

hta of Mill h1 lance orpliance was achieved 4th the report at 11:15 a.m. on June 21, 1989.

1 hetions_Takari to Prevmt_Focurruice I Nuclear Operations Departnent Procedure 100-17, "Design fusis Issue  !

Resolution", was issual on August 15, 1988. 'Ihis prtcodure establishes  ;

the responsibility and proceso for dispositioning design huis issues.  ;

This pr-a formlizes how the apprtpriata level of mnvycrent and technical expertise will be applial to future design basis issues. Ceples L of NOD-17 were prtnidad to several 1cvels of !GC staff for review and feedback. ,

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,l Viniati m 88-18-02 i B. 10 CFR Part 50, A@endix B, Criterion 16 requires corrective action measures that assurw that nonconformnoes are pzuptly identified ard i j oorrected and that such measures will prevent repetition of these i nonconformances. i

) Section 1.7.1.16 of Florida Powr Corporation's (FTC) Quality Prtgram i requires nonconformnoes to be pluptly identified ard corrected, ard that i

the corrective action taken be sufficient to prwent recurrence of tho ,

nonconformnoe. t i (

) Cbntrary to the abwe, corrective action taken by the licensco to prevent  !

i the occurrarne of excessive temperatures on the emertpency foodvater system pipirq ard a-latai reactor buildirq penetration wri insufficient in prwentirq recurrence of this nonconformnon.

) As a result of this failure to take sufficient corrective action,  !

I excessive surface terperatures m,tered on this pipiry on Docxrber 20, l 1982, Octh 3, 1983, Marth 8, 1988 ani June 19, 1988. We first two events resulted in syste flow instrurentation beiw rudorod incporable.

! We later two events resulted in exceedity the desi,,.. to:Terature for this l pipirg ard reactor building penetration.

r j W is is a Severity level IV Violation (Surplement I).

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! Florida Power Corporation (FTC) accepts the violation.

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] Agparint Onuse of Violatim [

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Repairs of the aplicable valve which had back leakage wre perfomod in -

i 1983 but were not permnently smmmaful at elimimting the tack Imkage.  !

l Replacement of the valve was not considered at that tire. In ad:lition, ,

plant proordures did not monitor back leakage thrugh the valvo.  ;

4 i Ca= xwtive Actim i j  !

! The valves will be Ityeiral or replaced ard roconfiguro1 to facilitate  ;

I testiry. IW-43 ard IW-44 will be adirtssed in ruvisicns to the CR-3 j Pwp and valve Prtgram, t DLtp of Ful1 Omolimag l

i Full crrpliarre will te achieved during the Octcber outage rd.odulcd for  ;

this pirTose. l l t j &ctics Take to Prwet Recurrwre  !

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2e corrective Action abwe ard those outlined in the asscciated IIR 88- l j 14 are sufficient to prevent recurrence.  ;

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