ML20046C190

Responds to NRC 930701 Ltr Re Violations Noted in Insp Rept 50-302/93-13.C/As:quality Programs Nonconformance Rept Has Been Issued to Address General Concern of Inadequate Sys Configuration Control

ML20046C190
Person / Time
Site:	Crystal River
Issue date:	07/30/1993
From:	Beard P FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F0893-01, 3F893-1, NUDOCS 9308090325
Download: ML20046C190 (3)

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• Florida Power COA 9OMATI0N Crystal River Unit 3 Docket No. 50-302 July 30,1993 3F0893-01 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555

Reference:

1) NRC letter to FPC dated July 1,1993 Notice of Violation - Inspection Report 93-13

Dear Sir:

Florida Power Corporation (FPC) provides the attached as our response to the subject inspection report.

Sincerely, kk

. M.7 Beard, Jr.

Senior Vice President Nuclear Operations EEF: mag Enclosure xc: Regional Administrator, Region II NRR Project Manager l

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PDR ADOCK 05000302 l9 jf l j G PDR b A Florida Progress Company I

FLORIDA POWER CORPORATION

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. NRC INSPECTION REPORT NO. 50-302/93-13 REPLY TO A NOTICE OF VIOLATION VIOLATION 50-302/93-13-01 Technical Specification 6.8.1.a requires the estahlishment and implementation of

• aritten procedures as recommended in Appendix "A" of Regulatory Guide 1.33, November, 1972. Appendix "A" of Regulatory Guide 1.33, November 1972, includes procedures for operation of safety-related systems.

Contrary to the above:

(1) On April 24, 1993, with the reactor in Mode 3, Operating Procedure OP- 1 301, Operation of the Reactor Coolant System, was not properly implemented in that the pressurizer spray isolation valve, RCV-36, was found not to be open. This resulted in degraded capability of the pressurizer spray to reduce reactor coolant system pressure.

(2) On April 29 and 30, 1993, with the reactor in Mode 1, Operating Procedure OP-402, Makeup and Purification System, was not properly implemented in that Makeup Pump 1B was operated for approximately seven and one half hours with less than required recirculation flow because valve MVV-267 was in the closed position during post maintenance testing. This resulted in higher than normal discharge pressure which contributed to damage to the pump's seals. During this time, the Technical Specification requirement for two operable makeup pumps was satisfied by Makeup Pumps IA and 10.

(3) On May 25, 1993, with the reactor in Mode 1, Administrative Instruction, Al-500, Conduct of Operations, was not properly implemented in that annunciator slide link #808 was found in the open position without proper documentation in the Annunciator / Event Point Alarm Defeat Log nor proper labeling with an equipment out of service sticker. This resulted in disabling the alarm for neutron power Smart Automatic Signal Selection System mismatch. This alarm would alert operators to a deviation in the indications associated with neutron power channels relative to each other.

ADNISSION OR DENIAL OF THE ALLEGED VIOLATION Florida Power Corporation (FPC) accepts the Violation.

ILEASON FOR THE VIOLATION (1) The reason for RCV-36 being mispositioned can not be determined. As discussed in the inspection report (93-13, 3.a.1), the root cause was originally considered to be performance of post maintenance testing (PMT) after release of the clearance and alignment of the system by 0P-301.

However, a subsequent review of Health Physics and Security logs revealed that this testing was performed before the clearance was released.

Additionally, the scaffolding accessing this valve was not removed until thirteen days following system alignment, allowing potential manipulation of the valve to that time.

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b The primary cause for the second example is. considered to be a-procedural

.(2)

~ deficiency. MUV-267 was closed during the performance of Surveillance Procedure SP-340C, "MVP-l%, MVP-1B, and Valve Surveillance". When the action to restore MUV-267 was not performed in SP-3400, adequate administrative controls were not in place to assure the valve position would i be restored by other means. ,

(3) The reason for the annunciator . link being opened with . inadequate  !

administrative controls is attributed to personnel error.

CORRECTIVE ACTIONS TAKJN AND THE RESULTS ACHIEVED (1) Although the PMT was found not.to have mispositioned the valve, weaknesses  :

were identified in the performance and documentation of ' the PMT. As a-  !

result, shop personnel have been made aware of the event and potential consequences. Additional guidance has been provided to work package planners to improve communications with Operations during PMT in -similar applications. l (2) Al-500, Conduct of Operations, has been revised to strengthen the followup requirements for those occurrences where procedural steps are not completed. -

(3) An Operations Study Book Entry has been made to enhance operations personnel r awareness of the instructions in AI-500 concerning the removal from-service of annunciator alarms. .

CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS A Quality Programs Nonconformance Report (NCR) has been issued to address the  :

general concern of inadequate system configuration control.

r DATE WHEN FULL CONPLIANCE WILL BE ACHIEVED The initial evaluation of the NCR is expected to be complete by August 30, 1993. .

Other corrective actions may be determined from that evaluation.

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