3F0690-19, Responds to Deviations Noted in Insp Rept 50-302/90-15. Corrective Actions:All Reg Guide 1.97 Category 1 Instruments on Main Control Board Marked & Engineered Safeguards Matrix Indicating Lights Arranged in Unique Array

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Responds to Deviations Noted in Insp Rept 50-302/90-15. Corrective Actions:All Reg Guide 1.97 Category 1 Instruments on Main Control Board Marked & Engineered Safeguards Matrix Indicating Lights Arranged in Unique Array
ML20055C934
Person / Time
Site: Crystal River Duke energy icon.png
Issue date: 06/25/1990
From: Beard P
FLORIDA POWER CORP.
To:
NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
RTR-NUREG-0737, RTR-NUREG-737, RTR-REGGD-01.097, RTR-REGGD-1.097 3F0690-19, 3F690-19, NUDOCS 9007020052
Download: ML20055C934 (3)


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. Power:

CO R POR AT ION

. June 25, 1990 1 3

3F0690-19 U. S. Nuclear Regulatory Commission b Attention:^-Document Control Desk Washington,'D C. 20555-

Subject:

- Crystal River Unit 3 <

Docket No. 50-302 Operating License No. DPR-72 Inspection Report 90-15

Dear Sir:

Florida Power Corporation (FPC) provides the attached as our response to the

' deviation identified in the above inspection report.  !

If you' have any questions regarding this' subject, please contact this office.

Sincerely, P. M.' Beard, Jr.

Senior.Vice President Nuclear Operations WLR: mag Enclosure xc: Regional Administrator, Region II

. Senior Resident Inspector 9007020052 900625 ,

DR . ADOCK 0500 4 2 73O/

. GENERAL OFFICE: 3201 Thirty fourth Street South

  • P.O. Box 14042

(813) 866 5151 l A Florida Progress Company

~

FLORIDA POWER CORPORATION INSPECTION REPORT 90-15 REPLY TO NOTICE OF DEVIATION DEVIATION 90-15-01 In _ Florida Power Corporation submittal, "NUREG 0737, Supplement 1, Regulatory Guide 1.97", transmitted March 21, 1988, they committed to comply with Regulatory Guide (RG) 1.97, " Instrumentation for Light-Water-Cooled Nutlear Power Plants to Assess Plant and Environs Conditions During and Following an Accident", unless specific exceptions were described.

One of the design criteria stipulated in RG 1.97 states: Types A, B, and C instruments designated as Categories 1 and 2 should be specifically identified with a common. designation on the control panels so that the operator can easily discern that they are-intended for use under accident conditions.

Contrary to the above, Crystal River 3 does not have the stipulated common designation of instruments on the control panels, and exception was not ,

taken to this design criteria in any submittal. The March 21, 1988, '

submittal indicates the plant was in compliance with RG 1.97 at the time of the submittal.

FLORIDA POWER CORPORATION RESPONSE APPARENT REASON FOR THE DEVIATION

'FloridaPowerCorporation(FPC)hasdiscussed,withtheNRC,ourposition regarding symptom-oriented procedures and our desire - not to have the stipulated common designation of instruments on the control panels.

However, FPC did not take exception to this requirement when the submittal, describing FPC's conformance to RG 1.97, was made. As identified in the Inspection Report, the NRC has decided that specific identification _of instruments is required at Crystal River Unit 3 and, as stated: "This applies to Category 1 variables only".

CORRECTIVE ACTION l FPC has completed marking the RG 1.97 Category 1 instruments on the Main l Control Board. All Category 1 indicating lights are contained in. the u Engineered Safeguards (ES) matrix section of the Main Control Board. The ES matrix indicating lights are arranged in a unique array and have a unique color. All lights in the array are qualified to RG 1.97 L

requirements. The operators are trained to know the ES matrix indicating L lights are qualified and are to be used under accident conditions. Since l the ES matrix lights meet the intent of the Regulatory Guide (the operators can easily discern that they are intended to be used under accident conditions), no additional marking is required.

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DATE OF FULL CONPLIANCE Full compliance was achieved on June 22, 1990.

ACTIONS TAKEN TO PREVENT RECURRENCE 1.

FPC normally documents exceptions to regulatory positions. -The above deviation represents an isolated incident and no further corrective action.

is considered necessary.

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