IR 05000302/1984009

Forwards Summary of 850315 Mgt Meeting W/Util in Region II Ofc Re Violations Noted in Insp Rept 50-302/84-09. Violation for Failure to Follow Procedure SP-317 Did Occur. Attendance List Encl

ML20127G892
Person / Time
Site:	Crystal River
Issue date:	04/17/1985
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Wilgus W FLORIDA POWER CORP.
Shared Package
ML20127G897	List: 3F0185-15, Suppls Response to NRC Supplemental Re Violations Noted in Insp Rept 50-302/84-09.Continues to Deny Existance of Violation Based on Procedure Adherence. Event Considered Isolated Incident IR 05000302/1984009
References
NUDOCS 8505210171
Download: ML20127G892 (4)

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APR 171985 c

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Florida PowerfCorporation ATTN: Mr. W. S. Wilgu Vice President Nuclear Operations P. O. Box 14042,'M.A.C. H-2 St. Petersburg, FL 33733-

Gentlemen

L SUBJECT: REPORT NO. 50-302/84-09 l

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Your supplemental response 'of January 25, 1985, to our Notice of Violation issue on April 19, 1984, which concerns _ activities conducted under NRC Operating

License No. DPR-72, provides additional ' justification for your continued denial

- of Violation-84-09-04. This citation deals with failure to follow the procedure used in' determining reactor coolant system leakag In your response, you sug-gested 'a meeting with the Region II staff.'in order to resolve this longstanding issue. The Regional staff consented to such a management meeting, and the_ meeting was held in the NRC Region II Office on March 15, 1985. During this meeting, you presented your position _ and bases for your denial of the . existence of a violation

- based upon procedural adherence. The details of the meeting are provided -in Enclosure 1 and a list of attendees at the meeting is shown in Enclosure 'It is our opinion _ that the meeting was beneficial in that it provided both parties an opportunity to discuss our points 'of view as they relate to the occurrence of the subject violatio We have further considered the bases for your dental of the violation and con-

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cludeithat tha . violation for failure to follow Procedure SP-317 did occur since strict compliance with Step 6.4 of that procedure would have required that'

hourly identified reactor coolant system leak rate data be taken for an addi-tional three hours. The NRC acknowledges that this.particular occurrence was of l minor safety significanc However, there are many other instances when . a ;

failure _ to adhere to procedure could place the unit in an unsafe. condition. Many times situations arise~ where ' operations personnel are placed under a stressful condition in which poor -judgement - could _ be exercised if procedures are not followed. Therefore, the NRC must insist upon meticulous procedural compliance for all activities affecting the quality of safety-related functions. We note that.there is an acceptable method-in place'which provides for a temporary chang to a procedure when required. This method should have been utilized rather than-deviating- from. the written procedur l

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' Florida Power Corporation 2

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In accordance with Section 2.790 of. NRC's " Rules of Practice," Part 2, Title 10, Code of Federal Regulations, a copy of this letter and enclosures will be placea in the NRC's Public Document Roo

Sincerely, L ist 5. A lsen G ace ,

J. Nelson Grace l Regional Administrator Enclosures: Meeting Summary j- Meeting Attendees t

cc w/enCls:

E. M. Howard, Director Site Nuclear Operations

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P. F. McKee, Nuclear Plant Manager G. R.- Westafer, Manager

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Nuclear Operations Licensing and Fuel Management bec w/encls:

NRC Resident Inspector-Document Control Desk State of Florida RII f RII RII i

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, APR 17 EGS

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ENCLOSURE 1  :

MEETING SUMMARY

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s On March 15, 1985, representatives of Florida Power Corporation (FPC) met with [

the NRC, at FPC's request, in the NRC Regional Office in Atlanta, Georgia. The topic of discussion was Violation 84-09-04, which was cited for failure to follow -

surveillance procedure SP-317 when ' determining reactor coolant system (RCS) -

leakag _

FPC showed how identified and total RCS hourly leak rate data is used to deter- I

mine the unidentified RCS leak rate, "after at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> of steady state operation," as stated in Step 6.4 of SP-317. The licensee explained that in the . l-

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case of cited Violation 84-09-04, the unidentified leak rate wap determined.from , y idertified leak rate data that was taken from 0500 to 1300 (8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />) and from s total leak rate data that was taken from 0500 to 1600 (11 hours1.273148e-4 days <br />0.00306 hours <br />1.818783e-5 weeks <br />4.1855e-6 months <br />). FPC stated a that due to deberation evolutions (0900,1200, and 1500), the total RCS hourly leak rate data was taken for three additional hours to assure conservatis Additionally, although the taking of both identified and total RCS leak rate' data

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is generally started and stopped at the same time, FPC felt that Step 6.4 of I SP-317 did not prohibit the taking of identified and total leak rate data at different times. Also, FPC pointed out that had the average identi- -

fied RCS leak rate changed during the three hours where such data was not recorded, the calculated unidentified RCS leak rate would have been more ,

conservative since the total RCS leak rate would have had to increase as wel .

The NRC informed FPC that data collection for surveillance tests is expected to be contemporary, coincident, and coterminous unless specified to the contrar Accordingly, compliance with Step 6.4 would have dictated that the hourly

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identified RCS leak rate data be taken for an additional three hours (1400 to ,

1600) as well. The staff acknowledged that this particular occurrence was.of minor safety significance but reminded FPC that meticulous procedural compliance is important and must be adhered to. It was further pointed out.that methods for -

temporarily changing procedures are available to the operators should they be "

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FPC was told that the final NRC decision on this matter would be made known to -

them in a future lette _

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APR 171985 l

L ENCLOSURE 2 i l

MEETING ATTENDEES

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.NRC Attendees: J. N. -Grace, Regional: Administrator

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P. R.- Bemis,. Director, Division of Reactor Safety (DRS)

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- L. Brownlee, Chief, Reactor Projects Branch 2, Division of ( Reactor Projects (DRP)

V. W. Panciera, Section Chief, DRP F. Jape,.Section Chief, DRS

T. F. Stetka,- Senior Resident Inspector, DRP P.'T. Burnett,. Reactor _ Engineer, DRS R.- E. Carroll,' Project Engineer,~DRP J. E. Tedrow, Resident Inspector, DRP

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Licensee: Attendees: P. F..McKee, Plant Manager G. L.-Boldt, Nuclear Operations Manager K.'R. Wilson, Supervisor, Site Nuclear Licensing ,

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G. P. Hebb, Nuclear Shift Supervisor j

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