ML19254E598

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Responds to NRC Re Violations Noted in IE Insp Rept 50-302/79-30.Corrective Actions:Rod Drop Time Determined by Open Visicorder Chart Speed & Subsequently Verified
ML19254E598
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 10/05/1979
From: Stewart W
FLORIDA POWER CORP.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19254E597 List:
References
CS-79-285, NUDOCS 7911010551
Download: ML19254E598 (2)


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3 October 1979 0$

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Powe,r 3-o-3-a-2 CS-79-285 t e -o u i.

Mr. J.

P. O'Reilly, Director Docket No. 50-302 Office of Inspection & Enforcement Licensee No. DPR-72 U.S. Nuclear Regulatory Comm1ssion Ref:

RII:RCS 101 Marietta St.,

Suite 3100 50-302/79-30 Atlanta, GA 30303

Dear Mr. O'Reilly:

We offer the following response to the apparent Iter:s of Noncompliance in the referenced inspection report.

NOTICE OF VIOLATION A.

As required by Technical Specification 3.1.3.4, individual safety and regulating rod drop times ' rom the fully withdrawn position shall be verified to be less than, or equal to, 1.66 seconds from power inter-ruption at the control rod drive breakers to 3/4 insertion (257.) prior to proceeding to Mode 1 and 2.

Contrary to the above, Mode 2 was entered on July 29, 1979, although rod drop data, obtained on July 27, 1979 could not be verified to meet the 1.66 second time requirenent, since no tin.ing marks appeared on the oscil-log aph paper used in the measurements.

Alternate verification of the acceptability of tod drop time results was not performed until August 8, 13, and 14, 1979.

A.

Response

To ensure acceptabili*y, the original rod drop time as per Surveillance Procedure SP-102, " Control Rod Drop Time Test", relied upon the visicorder chart speed foc determining rod drop time.

A subsequent verification 'f chart drive accuracy determined tne acceptability of the rod drop tim.

results.

Surveillance Procedure S'-102 has been revised to require a 60 hertz timing-signal reference trace be present on the visicorder oscillograph paper. The presence of this timing trace will adequately verify rod drop time, meeting the acceptance criteria of Technical Specification 3.1.3.4.

Full compliance has been achieved.

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7 B.

As required by Technical Specification 6.8.1, as implemented by the Crystal River Plant Operating Quality Assurance Manual Control Document, AI-400, written procedures shall be established, implen.ented, maintained, and followed step-by-step.

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.t Notice of Violation - Responses J. P. O'Reilly Page 2 B.

Continued:

Contrary to the aforemantioned, on July 27, 1979, the reactor coolant loop RTD normalization constants, as calculated by the IBM-5100 RTD Normalization Routine, were not input into the IBM-5100 Heat Balance 11 routine as required by step 12, Enclosure 1 of PT-100 prior. to the first heat balance taken at approximately 15% FP per PT-120.

The constarts were not properly input into the computer software until August 6, 1979 at a power level of 75%,

B.

Responne:

A review of PT-100, Controlling Procedure for Pre-critical Testing, in-dicated that the method of changing the RTD Normalization Constants as not addressed. To avoid further noncompliance, PT-100 has been revised to clarify the method for inputting the constants into the IBM-5100 Normalitation Routine, and concerned perronne) have been instructed as to its requirements.

Full compliance has been achieved.

Should there be further questions, please contact us.

Very truly yours, FLORIDA POWER CORPORATION d...-O ru6ou W. I'. Stewart Nuclear Plant Manager Manager, Nuclear Operations JC/rc 1283

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