3F0888-17, Forwards Revised Response to Violations Noted in Insp Rept 50-302/88-09.Corrective Action:Permanent Book Marks Placed in Control Room Emergency Operating Procedure

Forwards Revised Response to Violations Noted in Insp Rept 50-302/88-09.Corrective Action:Permanent Book Marks Placed in Control Room Emergency Operating Procedure

ML20153G071
Person / Time
Site:	Crystal River
Issue date:	08/29/1988
From:	Widell R FLORIDA POWER CORP.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
3F0888-17, 3F888-17, NUDOCS 8809080028
Download: ML20153G071 (4)

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Ts F e Cower A P O R At IO N August 29, 1988 3F0888-17 U. S. Nuclear Regulatory Msualon Attention: Document Control Desk Washington, D. C. 20555

Subject:

Crystal River Unit 3 Dockot No. 50-302 Operating License DPR-72 Inspection Report 88-09 Revised Response li

Dear Sir:

Attached please find Florida Ibwer Corporation's (FPC) revised response to Inspection Report 03-09. 'Ibe original response to IFI 88-09-06 was incorrect. A more ccuplete description of the table-top review and precedure walk-throughs is provided try this revision along with several (xiitorial corrections. 'Ihe only changes are on the first three pages; therefore, the thirty-three page (33) attachment is not enclosed.

Should you have any questions, please ocntact this office.

Very truly yours, Rolf C. Widell t

Director, Nuclear Operations Site Support WLR: mag i

Att.

xc: Rogional Administrator, Regicre II Senior Resident Inspector 4

8809080028 880829 PDR ADOCK 05000302 Q PDC Post Office Box 219

• Crystat River, Florida 32629

• Telephone (904) 7953802 A Florida Progress Company s ,

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FimIIR IMER CIRIWATICH RESRMSE INSPECTICH REREP 88-09 IFI 88-09-01 Placekeeping deficiencies were identified during control rocu walk-throughs of the IDPs. Operators typically use loose sheets of paper or their fingers as placekeeping aids. Addit.ionally, when questioned on the problem of placekeeping, the operators indicated that they would remove the iniividual pro dures fr m the notebooks and place then on the desk. This is undesirable, J particularly when one considers that the IDPs are not stapled and can casily became intermixed, separated, or lost. This is an inilcation of a placekeeping deficiency. The licensee has ocamitted to resolve these placekeeping deficiencies.

FIIRIIR IMER CIRIMATICN (FIC MPIW FPC has placed permanent book marks in the Control Rocm Emergency Operating Procedure (EDPs) . FEC has also increased the number of EOP sets in the Ccntrol Rocn to three.

IFI 88-09-02 Currently, the licensoo has no document in place to cross reference operator action points for plant parameters to where they occur in procedures. The licensee has cxxmtitted to implement an EOP cross reference dO::ument.

FPC MPICN FPC agrees an E0P cross refercace document would be beneficial and conmits to inplement the EDP cross referen:e by June 30, 1989.

JFI 88-09-0]

Correction of technical discrepancies contained in IDPs as outlined in Appen-lix B of Inspection Report 88-09.

FFC MUM Referenca Appendix B response for line-for-line item cmments. These l 1 procalural changes will be implementcxl by October 31, 1988, unless otherwise )

stated. This provides time for verification on the simulator.

IFI 88-09-04 Correction of human factors discrepancies contained in IDPs as outlined in Appendix C of Inspection Report 88-16.

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FPC ACTIW Reference Appendix C response for line-for-line iten omments. These procedural changes will be inplemented by Oc+. nhar 31, 1988, unless otherwise stated.

IFI 88-09-05 Cbrrection of labeling discrepancies between E0Ps and panel indications as outlined in Appendix D of Inspection Report 88-09.

FFC ACTIW FPC agrees that omponents should be uniquely labeled and delineation made in the E0Ps should be such to avoid any ambiguity. For this reason Unique Equipnent Identification Numbers (Tag Numbers) are assigned to all equipnent.

These Tag Nunbers used in the EDPs should agree with the Equipnent Labeling used in the plant. 7b ensure this goal is met FPC utilized Quality Program personnel to perform a cxzparison of all EOPs against control board labelim.  !

The ncanenclature discrepancy performed by the inspection team in many cases ccmpared the short functional description used in the E)Ps against the control board labeling. A review of these discrepancies was performed item by item aM the response is detailed in Appendix D. l m 88-09-os Licensee nocds to re-perform EOP table top review and procedure walk-throw 3hs to upgrade the V&V program.

Fm AcrIW Precedures revised as a result of the inspection receivcd a table top review.

The procedures were walked thru in the field by two licensed operatoru not  !

involved in the writing or revising of the procedures. i The procedures receive a mininum of 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> review per year per license holder i at the Power Safety Sinulator. This review is in the form of accident l sinulation. This review is performed by Shift personnel, Licenscd Administrative Staff, and Training Department personnel. Problems encountered by these perranol are forwarded to the Operations Ergineer for resolution Wich nay includo procedure ruvision.

7ho normal training cycle also provides input for procedure inprovement. l Licensed cperators as a minimum are required to review all Emergency Operatirq  !

Procedures cn an annual basis. DiscIrpancies noted are forwarded to the  !

Operations Dgineer for resolution.

As evidenced by the above response, the end user of the procedures reviews the l Emergency operating Preocdures numeruts times throughout the year. l Rh.i.ardations for inprovenent are encouraged. Adntinistrativo procedures are '

in place to provide the operator with a mechanism to ensure his concerns are addressed and that feedback on his suggestions rcmived.

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i Florida Power Corporation believes these mechanisms provide strong usable i procedures and a sense of ownership to the persons that ultimately have to use the procedures.

IFI 88-09-07 Licensee will review SorA training and upgrade if n-mry.

FPC AcrICH

'Ihe training of all ScrAs has been reviewed, by the Nuclear Operations Trainim Department and the Nuclear Safety Supervisor, and found to be adequate. In order to resporx1 to the specific concerns d%3=d in the Inspection Poport, all ScrAs were given a walk-through, on the use of VP-540, Rurback Verification Procedure, and VP-580, Plant Safety Verification Procedure, by a qualified Senior Reactor Operator. These walk-throughs were capleted satisfactorily and '

h = anted. The ScrA 9equalification program provides further assurance that the level of training of all ScrAs is adequate. As of July 29, 1988, each qualified ScrA has spent 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> on the B&W sinulator in Lynchburg, Virginia.

Each qualified SorA also will spend or has spent 120 hours0.00139 days <br />0.0333 hours <br />1.984127e-4 weeks <br />4.566e-5 months <br /> in classrom requalification trainig durim the periods of May 16 through Jtnw 3 or August 1 through August 19, 1988. Successful ccmpletion of these requalification programs will provide conclusive evidence of the adequacy of the trainim of all SorAs.

IFI 88-09-08 Licensee rm% to formlize the program for ongoing evaluation of E0Ps.

E IW3TQEE AI-402, Writers Guido for Abnorml, Verification and Emergency Operating Proccdure does provide an on-goirq EOP evaluation process. This, in a conjunction with the cperator annual EOP review and the biannual sirulator review, is FPC's forml on-goirg 00P evaluation.

IFI 88-09-09 Ru-validation of the 00Ps when the plant specific simulator is operational.  ;

FIC RESIQUE l PTC will re-evaluate its EDPs on its plant specific simulator within one year frta the date the simulator becmes fully operational.

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