IR 05000325/1988014

Advises of Results of Evaluation of 880603 Denial of Violation Noted in Insp Rept 50-325/88-14.Violation Occurred as Stated.Response Describing Reasons for Violations & Actions Planned or Taken Requested.Evaluation Encl

ML20205M726
Person / Time
Site:	Brunswick
Issue date:	10/27/1988
From:	Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Utley E CAROLINA POWER & LIGHT CO.
References
NUDOCS 8811030259
Download: ML20205M726 (3)

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w .,. un Carolina Power and Light Company ATTN: Mr. E. E. Utley Senior Executive Vice President Power Supply and Engineering and Construction P. O. Box 1551 Raleigh, NC 27602 Gentlemen:

SUBJECT: REPORT NOS. 50-325/88-14 AND 50-324/88-14 We have completed our evaluation of your June 3,1988, response to our Notice of Violation issued on May 5,1988, concerning activities at your Brunswick facilit After careful review of the basis for your denial of Violation 50-325/88-14-01 and consultation with the Office of Nuclear Reactor Regulation, we have concluded, for the reasons presented in the enclosure to this letter, the violation occurred as stated in the Notice of Violation. Therefore, pursuant to 10 CFR 2.201, please submit to this office within 30 days of the date of this letter, a written statement describing the reasons for the violation, the corrective steps which have been taken and the results achieved, corrective steps which will be taken to avoid further violations, and the date when full compliance will be achieve In accordance with Section 2.790 of the NRC's "Rules of Practice." Part 2 Title 10. Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Roo The response directed by this letter is not subject to the clearance proce-dures for the Office of Management and Budget issued under the Paperwork Reduction Action of 1980. Pub. L. No. 96-51 Sincerel Original Signed by Charles W. Hehl /for Luis A. Reyes, Director Division of Reactor Projects Enclosure:

Evaluation of Violation Denial ec w/ encl:

R. B. Starkey, Jr., Manager Brunswick Nuclear Project J. L. Harness Plant General Manager State of North Carolina bec w/ enc 1: (See page 2)

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ENCLOSURE EVALUATION OF VIOLATION DENIAL l

The cited violation (50-325/88-14-01) involved an inadvertent reactor coolant system (RCS) heatup of about 90 degrees (120*F to 210'F) over a 1.75 hour8.680556e-4 days <br />0.0208 hours <br />1.240079e-4 weeks <br />2.85375e-5 months <br /> period in which the reactor vessel pressure and shell temperature were not

- determined as specified by Technical Specification (TS) 3.4.6. Your denial of the violation is based on two points: (1) you believe that the associated TS bases refers to RCS temperature changes during startup and shutdown, not while in cold shutdown; and (2) there is no technical concern, as the temperature /

pressure cerves do not apply when the reactor vessel is vente Although not recognized as part of the TSs in 10 CFR 50.36, the bases section does provide a general understanding / reason for TS requirements. The basis applicable to TS 3.4.6 indicates that the pressure / temperature limits set forth in the TS are to assure that stresses induced by heatup and cooldown operations are bounded to protect the reactor vessel and its associated component In essence, the intent of the TS is to require monitoring plant conditions such that pressure / temperature limits meet the fracture toughness requirements in Appendix G, 10 CFR Part 50.Section I of Appendix G, 10 CFR Part 50, indicates that its requirements are necessary to provide adequate margins of safety during any condition of nomal operation, including anticipated operational occurrences and system hydro!,tatic tests, to which the pressure boundary may be subjected over its service lifetim Accordingly, this is not just a concern during startup and shutdown as you portray in your response; in fact, the specified TS applicability is "at all times".

1 As the affected Wit was in a conostion recognized by the TS (i.e., recently shutdwn, vented, and cooldown established to prevent RCS heatup from decay heat), TS surveillance tequirement 4.4.6.1.1 requires that reactor vessel shell temperature ind reactor vessel pressure be determined to be within the limits at least once per 30 minutes. We agree, in part, that the inadvertent heatup event resulted in no technical concern, in that the TS specified heatup rate was not exceeded and pressure / temperature limits were not reached becaute the plant remained depressurized. However, your operations staff had n0 confirma-tion that the reactor vent path remaincu established / effective and hence pressure / temperature limits maintained, since pressure and temperature were not being monitore Based on the above, it is the NRC's position that the pressure / temperature monitoring requirements associated with TS 3.4.6 are applicable during cold shutdown. We, therefore, find that your denial is not ' Ttified and the viola-tion occurred as stated.

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