ML20136E858

Responds to NRC Re Violations Noted in Insp Rept 50-302/96-20.Corrective Actions:Required Action 3.4.3.C Was Entered & Fracture Analysis Was Performed

ML20136E858
Person / Time
Site:	Crystal River
Issue date:	03/07/1997
From:	Cowan J FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
NUDOCS 9703130351
Download: ML20136E858 (5)

Text

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Florida Power CORPORATION o mina soane March 7, 1997 i 3F0397-04 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555-0001

Subject:

Notice of Violation (NRC Inspection Report No.50-302/96-20)

NRC to FPC letter, 3N0297-02, dated February 5, 1997

Dear Sir:

In the subject Inspection Report, Florida Power Corporation received a Notification of Violation. Please accept this correspondence as our response.

1 Sincerely, MOQ  ;

J. P. Cowan Vice President Nuclear Production JPC/RLM cc: . Regional Administrator, Region II NRR Project Manager Senior Resident Inspector I

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. 'U.-S. Nuclear Regulatory Commission Page 2 of 5 3F0397-04 q

j FLORIDA POWER CORPORATION 4 NRC INSPECTION REPORT NO. 50-302/96-20 REPLY TO A NOTICE OF VIOLATION I

f VIOLATION 50-302/96-20-01 l Technical' Specification (TS) 3.4.3, Reactor Coolant System (RCS) Pressure and Temperature-(P/T) Limits, requires that at all times, RCS pressure, RCS

temperature, and RCS' heatup and cooldown rates shall be maintained within the

limits specified in the Pressure Temperature Limits Report (PTLR).

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Contrary to the above, on January 11, 1996, during unit cooldown, the RCS cooldown l-rate was allowed to exceed the limits specified in the PTLR for agproximately one

hour. Specifically, the cooldown" rate was not decreased from 25 F per half-hour

' to less than 10 F per hour at an .RCS temperature of 150 F as measured by the decay heat cooler outlet temperature, as required by the PTLR curve' entitled, ~ Reactor Coolant System Pressure-Temperature Limits for Cooldown for First 15 Effective Full Power Years (EFPY).

ADNISSION OR DENIAL 0F THE ALLEGED VIOLATION l

Florida Power Corporation (FPC) accepts the violation. l REASON FOR VIOLATION The cause of this event is personnel error in that the procedure was misinterpreted-and the Decay Heat (DH) Cooler outlet temperature was not used to determine the transition temperature for the more restrictive cooldown rate limit. DH Cooler outlet temperature is the most conservative indicator of the reactor pressure vessel temperature change. The operating crew mistakenly decided that Reactor.

Coolant System bulk fluid temperature should be used. The training of the operators was not specific enough to ' preclude' the misinterpretition. Another ,

contributing factor was insufficient corrective actions from a 1983 event where the l actual calculation of the cooldown rate used the DH Pump suction temperature j instead of the DH Cooler outlet temperature. The corrective action from the previous event, revision of surveillance procedure SP-422, RC System Heatup and l J

Cooldown Surveillance, was not sufficient to preclude the wrong temperature from

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being used to determine the transition temperature for the more restrictive cooldown rate limit.

CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED The RCS temperature was stable when the event was discovered. ITS_ Required 1.

Action 3.4.3.C was entered and a fracture analysis was performed. The evaluation was performed and showed that required safety margins had been met throughout the entire transient. FPC concluded, based on the results of the evaluation, that CR-3's reactor vessel had maintained 7.dequate structural integrity and continued normal operation was acceptable. As a result, ITS Required Action 3.4.3.C was exited on January 17, 1996 at 2148 hours0.0249 days <br />0.597 hours <br />0.00355 weeks <br />8.17314e-4 months <br />.

2. The unacceptable performance by the operating crew was discussed with the

. crew by the Operations Manager. Licensed operators were trained that DH Cooler outlet temperature is to be utilized to determine transition temperature for the more restrictive cooldown rate limit.

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• U. S. Nuclear Regulatory Commission Page 3 of 5 3F0397-04 3 .- Short Term Instruction (STI)96-004 w'as issued January 17, 1996 to clarify.

the requirements regarding use of DH Cooler outlet temperature for-

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. determining RCS.teoperature relative'to cooldown rate limits when the decay heat system is operating with no RC pumps operating. STI 96-004 remained in

effect until a revision to Surveillance Procedure SP-422,'RC System Heatup r and Cooldown Surveillance was issued that clearly indicated which temperature i to use when determining the applicable RCS Cooldown Rate Limit. Revision 27  !

to SP-422 included this information and was issued on April'27, 1996. J 4 ~

4. The guidance provided to operators in response to Request for Engineering

j. Assistance (REA) 93-0667 has been reviewed and expanded upon. REA 93-0667 1

was. initiated after CR-3's March,1993 event involving an RCS cooldown which exceeded technical specification requirements. It provided guidance on

limits for swapping from one DH Removal system train to the other DH Removal

train. Specific guidance was provided after the 1996 event to ensure brief-temperature drops that occur when swapping DH trains are. fully addressed.

5. A Technical Specification interpretation was developed regarding the use of Average Reactor Coolant Temperature values given in ITS Table 1.1-1 for defining MODES. This interpretation addresses which indications are used-i when the decay heat system is operating with no RC pumps operating.

4 l 6. Revision 97 to operating procedure OP-404, Decay Heat Removal System, was i

. issued on February 23, 1996, to ' provide _ guidance to the operators' for

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calculating the effective cooldown utilizing DH: Cooler outlet temperature. ,

CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS i-Operators were trained on this event during Cycle 3 training conducted June 24 .

. through July 30,-1996. Followup training will be provided by incorporating lessons learned from this event into the appropriate lesson plan by July 31,.1997.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED FPC is in full compliance.

VIOLATION 50-302/96-20-02 l- - Technical Specification (TS) 5.6.1, Procedures, requires that written procedures i

be established,. implemented, and maintained for the recommendations in Regulatory

Guide (RG) 1.33, Revision 2, Appendix A, February, 1978. RG 1.33, as implemented l- by TS 5.6.1, requires that administrative procedures be established for control of t procedure review and approval.

AI-4000, New Procedures and Procedure Change Processes, Revision 17, requires that.

if interfacing department's actions or procedures will be impacted, then the

. interfacing department must. perform a qualified review. AI-4000 requires that all

qualified reviewers of a procedure are to verify conformance to AI-402B, Procedure j Writing (Except for Abnormal and Emergency Operating Procedures).

$ Contrary to the above, the licensee failed to review Procedure PM-191, Main .

Turbine / Generator, 'Feedwater Turbine Layup adequately, in that all departments i impacted by the procedure did not perform qualified reviews and that conformance to Procedure AI-402B was not verified for all sections of the procedure.

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.U. S. Nuclear Regulatory Commission Page 4 of 5

'3F0397-04 l ,

, ADNISSION OR DENIAL 0F THE ALLEGED VIOLATION ,

. Florida Power Corporation (FPC) accepts the violation.

I REASON FOR THE VIOLATION .

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FPC has eyaluated the incident and identified two root causes and one contributing cause that led to the violation. l l The first root cause was a failure to properly implement AI-400C, New Procedures i and Procedure Change Processes. In addition, the procedural needs of Operations l

!. were not addressed as required by AI-402B, Procedure Writing (except for Abnormal l

and Emergency Operating Procedures). The AI-400C procedure review process in

existence at the time of the violation relied upon the department specific 1

qualified reviewer to obtain the required technical reviews necessary to properly l implement the procedure. In the case of PM-191, Main Turbine / Generator, Feedwater Turbine Layup, the departments performing the reviews failed to recognize that an I&C technical review was necessary in addition to the maintenance department c qualified review. This does not meet the FPC expectation for consistent procedure

. . development.

FPC agrees that the expectation for multi-disciplined reviews was necessary. The l qualified reviewers did not meet this expectation in assuming a single signature by maintenance satisfied the minimum requirements of AI-4000.

. The contributing cause was a weakness in AI-400C, Revision 17. This revision did "

! not specify the need for multi-disciplined reviews, even if within a department.

i The second root cause was a failure to assign a single point of accountability to l ensure PM-191 was properly developed, scheduled and' implemented within a timely manner. l C0RRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED l

'} This event root cause was discussed with engineering personnel who performed the qualified review of PM-191. An engineering document was distributed to Technical

Support personnel stressing the -importance of obtaining appropriate reviews to ,

procedures requiring multi-disciplined maintenance' implementation.

r A single point of accountability was assigned to ensure timely implementation of

, the procedure, the procedure was reviewed and then successfully implemented.

I CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS AI-400C will be revised to provide additional guidance on obtaining appropriate i

technical reviews when more than one end-user department is required for

implementation of the procedure.

FPC management expects that a single point of accountability will be assigned j responsibility for complex or multi-disciplined evolutions.

A maintenance department document is being developed for distribution to

maintenance personnel stressing the importance of multi-disc 11pline procedure

! reviews. This action will be completed by March 31, 1997.

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U. S. Nuclear Regulatory Commission Page 5 of 5

- 3F0397-04 Date When Full Como11ance Will Be Achieved

. FPC believes that with the exception of AI-400C revision that it is in' full i compliance. FPC will provide additional guidance on this aspect of the procedure review process. This will be included in revision 19 to AI-4000 scheduled to be implemented by. April 15, 1997.

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