ML20236S145

Responds to 980206 Memo from W Rogers Which Documented Errors Identified in Staff SE for Amend 163 to Crystal River Unit 3 FOL

ML20236S145
Person / Time
Site:	Crystal River
Issue date:	07/17/1998
From:	Hebdon F NRC (Affiliation Not Assigned)
To:	Rogers W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
NUDOCS 9807240153
Download: ML20236S145 (1)

Text

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MEMORANDUM TO: Walter G. Rogers, Senior Reactor Analyst Division of R: actor S fety, Rigion 11 FROM: Frederick J.- Hebdon, Director Original signed by_

Project Directorate ll-3

- Division of Reactor Projects - 1/11 Office of Nuclear Reactor Regulation

SUBJECT:

SAFETY EVALUATION REPORT ERRORS IN AMENDMENT 163 TO THE CRYSTAL RIVER OPERATING LICENSE s

in a memorandum to me dated February 6,1998, you documented errors you had identified in the staff's safety evaluation (SE) for Amendment No.163 to the Crystal River Unit 3 operating license. I appreciate your initiative in reviewing this significant amendment and bringing to our

,, attention the errors in the SE As stated in your memorandum, the SE contained a statement that the Emergency Operating

. Procedure (EOP) inspection team confirmed that the draft EOPs used in the simulator validation exercises did not contain substantive, technical differences fmm the proposed final EOPs.

However, the EOP team did not confirm this to be the case and the licensee made substantive revisions to the EOPs as a result of the EOP inspection to address differences between the

,' procedures used in the simulator and the final EOP prncedures. Another error concemed the conclusion that the licensee had demonstrated the ab;lity of the operating crews to perform the actions necessary to mitigate a small break loss of coolant accident with a concurrent loss of

. offsite power. The licensee addressed the concems raised by the EOP team reisted to the ability of the operators to perform these actxms, but this occurred afterissuance of the SE. You also identified two other errors in the SE which did not affect the basis for staff approval of the amendment.

Normal NRR practice is to rely on docketed information in evalusting the acceptability of a license amendment request. Draft information, undocketed information and information obtained via unofficial channels (e.g., telephone calls, FAX, electronically) are normally not acceptable for use in these determinations. The use of preliminary inspection resuks,'as occurred in the case of

. Amendment 163, represents a deviation from our normal practice. Such deviations from our

. normal practice are rare, so administrative controls as you recommended are not deemed to be necessary. However, I agree that if future use of draft inspection results is necessary, greater care should be used to ensure its accarscy. With regard to the errors in the SE for Amendment <

163, since the actions by the licensee support the conclusions made in the SE, no benefit would i

' result from a revision of the SE at this point.

. Again, your interest and initiative in this. matter are greatly appreciated.

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