ML20207J378
| ML20207J378 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 12/23/1986 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Wilgus W FLORIDA POWER CORP. |
| References | |
| NUDOCS 8701080423 | |
| Download: ML20207J378 (3) | |
See also: IR 05000302/1986031
Text
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DEC 2 31986
orida Powe. uorporation
ATTN: Mr. W. S. Wilgus
Vice President Nuclear Operations
P. O. Box 14042, M.A.C. C-2-M
St. Petersburg, FL 33733
Gentlemen:
SUBJECT: NRC REPORT NO. 50-302/86-31
Thank you for your response of November 25, 1986, to our Notice of Violation
issued on October 31, 1986, concerning activities conducted at your Crystal River
facility.
We have evaluated your response to violation example
"b",
and found
that it meets the requirements of 10 CFR 2.201.
We will examine the
implementation of your corrective actions during future inspections.
We have reviewed your response to violation example "a" and have concluded, for
the reasons presented in the enclosure to this letter, that the violation occurred
as stated in the Notice of Violation.
Additionally, as requested in our Notice
of Violation of October 31, 1986, we request your response document your efforts to
correct the discrepancy between your Final Safety Analysis Report (FSAR)
description of your normal mode of operation of the cooling water systems that
cool safety related equipment and your present mode of operating these systems.
Therefore, in accordance with 10 CFR 2.201 please resubmit your response to the
Notice of Violation example "a".
We appreciate your cooperation in this matter.
Sincerely,
\\s\\
.
J. Nelson Grace
Regional Administrator
Enclosure:
Staff Assessment of
Licensee Response
cc w/ enc 1:
S P. F. McKee, Director, Nuclear
j Plant Operations
VR. C. Widell, Manager, Nuclear
Operations Licensing and Fuel
Management
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VNRC Resident Inspector
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Document Control Desk
State of Florida
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DEC 2 31986
ENCLOSURE
STAFF ASSESSMENT OF LICENSEE RESPONSE
INSPECTION REPORT 50-302/86-31
Restatement of Violation Example a
Technical Specification (TS) 6.8.1.
requires the impicmentation of written
procedures for those activities recommended in Appendix A of Regulatory
Guide 1.33, November 1972 and for surveillance activities of safety related
equipment.
Regulatory Guide 1.33, Appendix A,
recommends procedures and/or written
instructions for log entries.
Administrative Instruction AI-500, Conduct of Operations, Section 2.1.6 requires
all TS action statements entered or exited be noted in the Nuclear Shift
Supervisor's log.
Contrary to the above:
During the periods when two independent emergency cooling subsystems were not
,
available from 3:10 a.m., on August 27,1986, until 6:25 p.m.,
on August 28,
1986; from 7:00 a.m., until 7:22 p.m., on September 3,1986; from 6:00 a.m., on
September 6,1986, until 6:11
p.m., on September 8,1986; and from 2:25 a.m.,
until 4:35 a.m., on September 10, 1986, no log entries were made in the NSS log
for entry into the applicable TS action statement.
Summary of Licensee's Response
FPC does not concur with example "a"
of the stated violation in that the
placement of all Make Up Pump (MVP) Cooling on Nuclear Services Closed Cycle
Cooling Water (SW) was not interpreted by FPC to be a violation of independence
'
during the time frame cited in the violation; and therefore no entry into an
action statement would have been made.
Following notification of concerns by the resident inspector, FPC Site Licensing
reviewed the configuration and provided a written evaluation that SW-only cooling
did not violate independence.
Further discussion between FPC management, Site
Licensing, and the NRC resident determined SW-only cooling was less preferable
l
than SW and Decay Heat Close Cycle Cooling Water (DC) cooling.
The Operations staff was notified of the more stringent guidelines for
maintaining Make Up Pump independence.
Plant procedures are being modified to
ensure at least one MVP is aligned to DC cooling.
FPC will enter the Technical
Specification Action Statement if all makeup pumps are aligned to SW-only
cooling.
NRC Evaluation of the Licensee's Response
'The NRC staff has carefully reviewed the licensee's response and has concluded
that the licensee did not provide any additional information that was not already
considered in determining the occurrence of the violation. The licensee contends
that SW-only cooling to the MVP's was not recognized as violating the
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DEC 2 31986
Enclosure
2
independence requirement for these pumps and therefore no entry into an action
statement was required.
The Final Safety Analysis Report (FSAR) describes the cooling water supply lineup
to the MVP's in sections 9.5.2.1 (SW) and 9.5.2.2 (DC). These descriptions state
in part that the cooling water supply to MVP-1A and MVP-1C is the DC system
(MVP-1A from the "A" train of DC and MVP-1C from the "B" train of DC) and that
MVP-1B is normally cooled by the SW system. Although subsequent NRC commitments
made by the licensee in June 1979, have altered the normal cooling water alignment
to these pumps, independence of the MVP's is maintained by supplying SW to MVP-1A
and MVP-1B while maintaining a separate and independent DC cooling water source
to MVP-1C.
When cooling water to the MVP's was aligned in a condition that was
cutside of that described in the FSAR such that independent cooling water was not
supplied to the MVP's (all three MVP's aligned to the same SW cooling water
source), entry into the applicable action statement was appropriate and this
entry should have been logged in the NSS log.
This fact was not recognized by
the licensee.
Maintaining the independence of cooling water supplies to the MVP's was discussed
between -the licensee's operations personnel and management and the NRC Resident
Inspector on September 8, 1986.
During this meeting, licensee representatives
acknowledged the need to maintain two separate cooling water flow to this
configuration.
Nevertheless, on September 10, 1986, the MVP's were once again
all aligned to the same cooling water source (SW) and no entry into the
applicable action statement was logged in the NSS log.
NRC Conclusion
For the above reason, the violation occurred as stated.