ML20062J272

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Responds to NRC Re Violations Noted in IE Insp Rept 50-302/82-09.Corrective Actions:Future License Amends Will Be Circulated Among Personnel.Withdrawal of Violation Re Calibr Procedure Requested
ML20062J272
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 06/25/1982
From: Mardis D
FLORIDA POWER CORP.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20062J250 List:
References
3F-0682-31, 3F-682-31, NUDOCS 8208160316
Download: ML20062J272 (2)


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umi ND : 0 9 Florida Power C O R 70 M A 7 'O N June 25,1982

  1. 3F-0682-31 File: 3-0-3-a-2 Mr. 3. P. O'Reilly, Regional Administrator Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 3100 Atlanta, GA 30303

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 IE Inspection Report No. 82-09

Dear Mr. O'Reilly:

Florida Power Corporation hereby responds to the violations cited in IE Inspection Report 82-09 (dated May 28,1982) for the inspection conducted at Crystal River Unit 3 on March 27 -

April 26,1982.

A. VIOLATION Title 10, Code of Federal Regulations, Part 50.59 requires the licensee to obtain NRC approval prior to a Plant modification that changes a technical specification.

Contrary to the above, on March 3,1982, due to an inadequate Modification Safety i

Evaluation, the licensee approved Modification Approval Record (MAR) 82-1-16 authorizing a modification and completed the modification that changed the time response for the RCPPM's to a value that exceeded the TS limit without prior NRC approval.

This is a Severity Level IV Violation (Supplement I.D.)

RESPONSE

Florida Power Corporation concurs with the stated violation. Plant Modification, MAR 82-1-16, had been reviewed, approved, and partially installed without gaining prior NRC approval. This was a result of the reviewer (s) not being aware of a recent Technical agg Specification change (License Amendment No. 46) which was subsequently discovered to Oma. be in error due to a misunderstanding on our part. It should be noted that neither power o8 operation nor mode change were allowed until NRC approval was granted.

$8 o A brief synopsis of the event will be circulated among all personnel directly involved in

$:c the development of modification packages. Future license amendments will be circulated

@g among personnel directly involved to ensure they are made aware of such changes.

<Q 7

Olc This action will be completed by July 31, 1982.

ruQ CDQ.0 General Office 3201 Thirty. fourth Street South . P O Box 14042. St Petersburg. Floruja 33733 813 - 866 5151 L

c. .,

Mr. 3. P. O'Reilly U. S. Nuclear Regulatory Commission June 25,1982 Page l B. VIOLATION Technical Specification (TS) 6.8.2 requires each procedure delineated in TS 6.8.1 and Regulatory Guide 1.33, 1972 to be reviewed by the Plant Review Committee (PRC) and approved by the Nuclear Plant Manager prior to implementation. Regulatory Guide 1.33 requires procedures for each surveillance test and calibration listed in the TS. TS 4.3.3.3.1 requires functional testing and channel calibration of the triaxial time-history accellographs and triaxial seismic switch.

Contrary to the above, on April 20, 1982, the vendor procedure used to perform the calibration of the triaxial time-history accelographs and triaxial seismic switch was not reviewed by the PRC and approved by the Nuclear Plant Manager prior to implementation.

This is a Severity Level V Violation (Supplement I.E.).

RESPONSE

Florida Power Corporation does not concur with the violation as stated for the following reasons:

a) SP-154, " Functional Testing and Calibration of the Triaxial Time-History Accelographs and Triaxial Seismic Switch" covers those portions of the process required by Technical Specification Surveillance Requirement 4.3.3.3.1. This procedure properly references the vendor procedure as the method by which acceptability is assured. This procedure was subject to appropriate review and approval.

Many, in fact, all surveillance / testing procedures include, by reference or implication, some methodology outside the scope of that procedure. In this case that methodology was a procedure provided by the vendor.

b) The seismic instrumentation is not safety-related, per se, and thus, the interpretation of Regulatory Guide 1.33 (1972) proposed in the violation is considered excessively broad, c) Florida Power Corporation is concerned with how the implied interpretation may impact other activities.

Therefore, Florida Power Corporation requests withdrawal of this item of noncompliance and would further request clarification as to the Commission's position of Regulatory Guide 1.33.

Should there be further questions, please contact this office.

Very truly yours,

- 0O David G. Mardis Acting Manager Nuclear Licensing KW/mtg cc: Document Control Desk L