ML20203E066

Discusses Crystal River 3 Apparent Violations Resulting from Performance of Unapproved Test

ML20203E066
Person / Time
Site:	Crystal River
Issue date:	07/27/1995
From:	Curtis Rapp NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Merschoff E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20203B366	List: IR 05000302/1995022 ML20203B362 ML20203B391 ML20203B411 ML20203B426 ML20203B463 ML20203B528 ML20203B549 ML20203B680 ML20203B781 ML20203B804 ML20203B829 ML20203B842 ML20203B850 ML20203B857 ML20203B875 ML20203B894 ML20203B933 ML20203B969 ML20203B983 ML20203C003 ML20203E066
References
FOIA-97-313 NUDOCS 9712160377
Download: ML20203E066 (2)

Text

.B. 8 UNITEo STATES

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July 27,-1995 MEMORANDUM FOR: Ellis W. Herschoff. Director Division of Reactor Projects FROM:- Curtis W. Rapp Reactor Inspector '

Division of Reactor Safety ,

SUBJECT:

CRYSTAL RIVER 3 APPARENT VIOLATIONS RESULTING FROM PERFORMANCE OF t,NAPPROVE0 TEST Having been excluded from the discussions for the above subject, I now am aware that several violations are under consideration. Since I accompanied 01 to' provide technical' support, I reviewed the procedures referenced in support of these proposed violations. Based on my review of the procedures and understanding of commercial nuclear power plant operations, I believe that

-three of the proposed violations have no merit.-

-The. violation for failure to follow procedure OP-402, Makeup and Purification System, does not apply because the operators did comply with OP-402. I reach this conclusion based on the following.

When increasing MUT overpressure, OP-402 specifically states the maximum allowable overpressure is given by OP 1038 Curve 8. The operators

, complied with that guidance and did not exceed the maximum allowable overpressure when initially increasing MUT overpressure.

When changing MUT level, OP-402 does not give any guidance to maintain MUT overpressure.within the limits given by OP-1.03B Curve 8.

There is no precaution or limitation that directs the operators to maintain MUT-overpressure within the limits given by OP-103B Curve D.

liconcluded that OP-402 is _ weak in operator direction or guidance; however, it is not appropriate'to-cite the violation in a manner that holds the operators accountable for procedural weaknesses.

The violation for failure'to comply with procedure-AR-403 PSA H, Annunciator Response,'does-not apply.because the operators did not need to comply with AR-403. I reached this conclusion based on the following.

When c,onducting an evolution it is not necessary or desirable to respond to; alarms generated as a consequence of the evolution. The necessary g21 7 971203 X  : LIAW97- 13; - PDR - 4

actions to bring any parameter back with the allowable limits would be taken when the evolution was completed. Th;s evolution was completed when operators had restored MUT level. MUT overpressure was within the limits of OP-103B Curve 8 when MUT level was restored. I explained this concept during the conference call on this matter.

These alarms are to warn operators when a parameter is outside of the expected steady-state limits and are not valid when in a transient condition.

Considering the fact the operators did not know that OP 103B Curve 8 was a design basis limit, it is unreasonable to have expected the operators to resaond to this alarm. The reason for the operators failure to respond being hig111ghted in the 01 report is to emphasize the overt willfulness of the operators actions.

The violation for exceeding OP-103B Curve 8 is not a violation in and of itself. OP 1038 is not a procedure but contains the administrative limits for the operation of Crystal River 3. Therefore, OP-103 Curve 8 must be referenced within the context of a procedural requirement.,

Based on my review and understanding of commercial nuclear power plant operational practices, I concluded the only valid violation was Al-500, Conduct of Operations, for failing to operate the plant within administrative limits.

It is regrettable that my observations and conclusions were not sought during the preparation of the proposed enforcement action. If you have any questions or comments, I am available to discuss them, cc:

A. Gibson T. Peebles eP. Kellogg 4

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