IR 05000302/1996009

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-302/96-09

ML20147E328
Person / Time
Site:	Crystal River
Issue date:	02/11/1997
From:	Jaudon J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Beard P FLORIDA POWER CORP.
References
NUDOCS 9702180293
Download: ML20147E328 (3)

Text

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February 11, 1997 Florida Power Corporation Crystal River Energy Complex Mr. P. M. Beard, Jr. (SA2A)

Sr. VP, Nuclear Operations ATTN: Mgr., Nuclear Licensing 15760 West Power Line Street Crystal River, FL 34428-6708 SUBJECT: NRC INTEGRATED INSPECT!ON ttEPORT 50-302/96-09 NOTICE OF VIOLATION

Dear Mr. Beard:

Thank you for your response of November 4,1996, to our Notice of Violation (NOV)

issued on October 4,1996, concerning activities conducted at your Crystal River 3 reactor facility. As noted in our acknowledgement letter of November 27,1996, your denial of Violation 50-302/96-09-05 was under review.

We have completed our review of your response to Violation 50-302/96-09-05 and the additional information provided. After careful consideration of the basis for your denial of the violation and the supplemental information, we have concluded, for the reasons presented in the following discussion, that the violation occurred as stated in ;

the Notice of Violation. Therefore, in accordance with 10 CFR 2.201(a), please l submit your reply within 30 days of the date of this letter.

Your response to this NOV should include corrective actions to assure that design inputs reference all applicable design information, that applicable design requirements are clearly articulated in the design documentation, and that design requirements are translated into procedures in accordance with 10 CFR 50, Appendix B, Criterion Ill.

l Violation 50-302/96-09-05 cited certain design requirements that were not correctly translated into procedures. Specifically, Modification and Approval Record (MAR)

95-01-07-01 changed the design of valve MUV-64 from a disabled, air operated valve (locked in the open position) to a manual, gear driven, chain operated valve, without issuing procedure changes to reflect the intended use and operation of the valve.

Your letter dated November 4,1996, denied the violation due to the stated belief that use of MUV-64 was not necessary to mitigate any design basis event and was not part of the design basis as defined in 50.2.

However, this position was not consistent with the description of design input as detailed in the " Design input Record" of the MAR. The MAR design requirements were in paragraph 1 of the " Design input Record", and stated in part:

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"REA 94-1308 (ref.15) evaluated the potential of adding a chainwheel to the ,

manual handwheel of the air operator for better access in the manual mode, since it may be necessary to quickly stroke this valve closed in certain accident scenarios with the new higher MU tank hydrogen gas pressures (certain Appendix R fires, keeping the MU Tank level indication on scale post-LOCA, rapid boration, etc. ....."

This design requirement was not translated into a procedure which specified how, when, under what conditions, etc., the valve was to be closed. Consequently, the violation stands. '

Additionally, MAR 95-01-07-01 failed to incorporate all applicable reference design and licensing basis criteria into the design input for the modification. Specifically, MUV-64, which is located between the Makeup Tank (MUT) and the suction of the Makeup Pumps (MUPs), was designed to close automatically on an engineering ,

safeguards (ES) actuation. To avoid inadvertent closure and pump damage, in 1983, !

you planned and requested staff approval for a design modification to remove the ES !

signal for Valve MUV-64 and eliminate its auto closure. By letter dated August 22, 1984, the NRC found your proposed design modification to be acceptable. The staffs acceptance was based partially on the operators' ability to shut the valve manually within a certain time period and the effects of mixing low-concentration borated water in the borated water storage tank during the manual action to close the valve. Accordingly, the use of MUV-64 as described in your submittals and our August 22,1984, letter form the design and licensing basis for CR3. Although this letter was referenced in the MAR package, the requirements therein were not included in the " Design input Record" as design and licensing bases. ,

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10 CFR 50, Appendix B, Section ill, Design Control, requires establishing appropriate measures to assure that applicable reaulatory reauirements and the design basis, as defined in Section 50.2 and as specified in the license apolication, for those structures, systems, and components to which this appendix applies are correctly !

translated into specifications, drawings, procedures, and instructions. j We appreciate your cooperation in this matter.

Sincerely

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0lE E N, M BY  !

OSSP.JMSON l

Johns P. Jaudon, Director )

Division of Reactor Safety l

Docket No. 5A302 License No. uPR-72 cc: (See page 3)

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FPC 3 cc: Gary L. Boldt, Vice President  !

Nuclear Production (SA2C) Bill Passetti l Florida Power Corporation Office of Radiation Control l Crystal River Energy Complex Department of Health and i 15760 West Power Line Street Rehabilitative Services .

Crystal River, FL 34428-6708 1317 Winewood Boulevard l Tallahassee, FL 32399-0700 l B. J. Hickle, Director i Nuclear Plant Operations Joe Myers, Director ,

(NA2C) Division of Emergency Preparedness l Florida Power Corporation Department of Community Affairs Crystal River Energy Complex 2740 Centerview Drive  ;

15760 West Power Line Street Tallahassee, FL 32399-2100 Crystal River, FL 34428-6708 Chairman L. C. Kelley, Director (SA2A) Board of County Commissioners Nuclear Operations Site Support Citrus County Florida Power Corporation 110 N. Apopka Avenue Crystal River Energy Complex inverness, FL 34450-4245 15760 West Power Line Street Crystal River, FL 34428-6708 Robert B. Borsum J Framatome Technologies R. Alexander Glenn 1700 Rockville Pike, Suite 525 Corporate Counsel Rockville, MD 20852-1631 Florida Power Corporation MAC - ASA Distribution -

P. O. Box 14042 K. Landis, Ril St. Petersburg, FL 33733-4042 L. Raghavan, NRR B. R. Crowley, Rll Attorney General G. Hopper, Ril Department of Legal Affairs PUBLIC The Capitol Tallahassee, FL 32304 NRC Resident inspector U.S. Nuclear Regulatory Commission 6745 N. Tallahassee Road Crystal River, FL 34428 j nr rirr pff nos pff not pf f 900 i M

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