ML20202D730

Notice of Violation from Insp on 970921-1025.Violation noted:10CFR50.59 SE Had Not Been Performed as Required within 90 Days on Wds Piping non-conforming Condition

ML20202D730
Person / Time
Site:	Crystal River
Issue date:	11/24/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20202D727	List: IR 05000302/1997016 ML20202D723 ML20202D730
References
50-302-97-16, NUDOCS 9712050142
Download: ML20202D730 (4)

Text

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NOTICE OF VIOLATION Florida Power Corporation Docket No. 50-302 Crystal River Unit 3 License No. DPR-72 During NRC ins)ections conducted on September 21 through October 25, 1997, violations of 1RC requirements were identified. In accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions." NUREG 1600, the violations are listed below:

A- 10 CFR 50. Appendix B. Criterion 111. requires, in part, that a3plicable regulatory requirements and the design basis, as specified in t1e license application, for those structures, systems and components to which Appendix B applies, are correctly translated into specifications, drawings, procedures and instructions.

(1) The seismic design basis description in the Final Safety Analysis Report (FSAR) Section 5.1.1.1 states, in part, that those structures, components, and systems whose failure might cause or result in an uncontrolled release of radioactivity are designated Seismic Class I. This FSAR section required that the waste gas decay tanks (WGDT) and the associated gas outlet piaing be designed Seismic Class I. The licensee's Enhanced )esign Basis Document (EDBD) also stated that the WGDTs and the associated gas outlet piping were designed Seismic Class I.

Contrary to the above, as of October 24, 1997, the design basis requirements for the WGDT gas outlet piping were not correctly translated into licensee design drawings. in that, design drawing FD-302-691 showed the WGDT gas outlet piping as being designed Seismic Class III instead of Seismic Class I. and the gas outlet piping for the WGDTs was installed Scismic Class III. The design drawings and the installed gas outlet piping ha<e never matched the FSAR seismic design basis description.

(2) The seismic design basis description in FSAR Section 5.1.1.1 ,

states, in part that those structures. components, and systems, whose failure might cause or result in an uncontrolled release of radioactivity, were designated Seismic Class I. FSAR Section 5.1.1.1,i further stated that the liquid outlet piping for 14 radioactive waste disposal system (WDS) tanks (to and including the second isolation valve downstream from each of the tanks and the process piping associated with the reactor coolant drain tank) was designated Seismic Class I. The EDBD also described the liquid outlet piping as being designed Seismic Class I.

Contrary to the above. as of October 24, 1997 design basis requirements for the WDS liquid outlet piping was not correctly translated into licensee design drawings, in that, drawings FD-302-681 and FD-302-691 showed the WDS liquid outlet piping as being designed Seismic Class III inatead of Seismic Class I and the liquid outlet piping for six of fourteen WDS tanks was installed Seismic Class III. The six tanks with Seismic Class III 9712050142 971124 PDR G

ADOCK 05000302 PDR .

NOV 2 liquid outlet piping installed were the miscellaneous waste storage tank, reauor coolant drain tank, three (3) waste gas decay tanks, and the spent resin storage tank. The design drawings and the installed WDS liquid outlet piping have never matched tne FSAR seismic design basis description.

This is a Severity Level IV violation (Supplement 1)

B. Technical S)ecification 5.6.1.1 requires that written arocedures shall be establis1ed. implemented and maintained covering t1e applicable activities recommended in Regulatory Guide 1.33. Revision 2. Appendix A.

February 1978. Regulatory Guide 1.33 Quality Assurance Program Requirements (Operation). Appendix A. paragraph 1.d. includes administrative procedures for procedural adherence.

Licensee Compliance Procedure CP-111. Processing of Precursor Cards for Corrective Action Program. Revision 56, dated February 25. 1997 stated that a 10 CFR 50.59 safety evaluation was required when a non-conforming condition conflicted with the Final Safety Analysis Report (FSAR) description and the condition was not corrected for an extended period of time (greater than 90 days). Precursor card (PC) 97-1515 was writtet.

March 17. 1997, describing piping in the radioactive waste disposal system (WDS) which conflicted with the FSAR seismic design basis description.

Contrary to the above, as of October 24, 1997, a 10 CFR 50.59 safety evaluation had not been performed as required within 90 days on the WDS piping non-conforming co' Jition. Over 200 days had passed since PC 97-1515 was written.

This is a Severity Level IV violation (Supplement 1).

C. Technical Specification (TS) 5.6.2.3. Offsite Dose Calculation Manual (0DCM) states, in part, that the ODCM shall contain the controls for maintaining the doses to members of the public from radioactive ef fluents as low as reasonably achievable. These controls include monitoring, sampling, and analysis of radioactive liquid and gaseous effluents.

TS 5.6.2.3 further states that licensee initiated changes to the 00CM shall be documented and records of reviews performed shall be retained.

This documentation shall contain sufficient information to support the change, together with the appropriate analyses or evaluations justifying the changes.

ODCM surveillance requirement 2.17.1 states that the quantity of radioactive material in each waste gas decay tank (WGDT) shall be determined to be within the limit (less than or equal 39.000 curies, considered as Xenon 133) at least once per 7 days whenever radioactive materials are being added to the tank. and at least once per 24 nours during primary coolant system degassing operations. The NP.C stated in its review of this surveillance requirement (NRC Safety Evaluation

NDV 3 Report EGG-PHYS-6171), that this surveillance was acceptable since the WG)T was sampled at the frequency required during degassing.

Contrary to the above as of October 24. 1997, the licensee was not complying with TS 5.6.2.3 for the following instances:

The quantity of radioactive material in each WGDT was not being determined as specified by ODCM surveillance requirement 2.17.1.

Per licensee surveillance procedure SP-730. Explosive Gas and Storage Tank Monitoring Chemistry Surveillance Program, the licensee was sampling the makeup tank (MUT) instead of the WGDT in order to satisfy the ODCM surveillance requirement for determining the radioactivity in each WGDT.

The licensee had not performed a 10 CFR 50.59 safety evaluation to ,

sup) ort the change for sampling the MUT instead of the WGDT as the metlod for determining the radioactivity in each WGDT.

This is a Severity Level IV violation (Supplement 1).

Pursuant to the provisions of 10 CFR 2.201. Florida Power Corporation is hereby required to submit a written statement or explanation to the U.S.

Nuclear Regulatory Commission. ATTN: Document Control Desk. Washington. DC 20555, with a copy to the Regional Administrator. Region II, and a copy to the NRC Resident inspector, at Crystal River, within 30 days of the date of the letter transmitting this Notice of Violation (Notice). This reply should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation or if contested, the basis ,

for disputing the violation. (2) the corrective steps that have been taken and the results achieved. (3) the corrective steps that will be taken to avoid further violations, and (4) the date when full compliance will be achieved.

Your response may reference or include previous docketed correspondence, if the correspondence adeyuately addresses the recuired response. If an adequate reply is not received within the time specifiec in this Notice, an order c' demand for information may be issued as to why the license should not be modified, suspended, or revoked. or why such other action as may be proper should not be taken. Where good cause is shown consideration will be given to extending the response time.

Because your res)onse will be placed in the NRC Public Document Room (PDR). to the extent possi3le, it should r.3t include any personal privacy. 3roprietary, or safeguards information so that it can be placed in the PDR wit 1out redaction. If personal privacy or proprietary information is necessary to provide an acceptable response, then please provide a bracketed copy of your response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must s)ecifically identify the portions of your response that you seek to have withielo an. provide in detail the bases for your claim of withholding (e.g. , explain why the disclosure of information '

will create an unwarranted invasion of personal privacy or provide the I

n

j t10V 4 information required by 10 CFR 2.790(b) to support a request for withholding confidential comercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Atlanta. Georgia this 24thday of flovember 1997

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