ML17228A963
| ML17228A963 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 12/14/1994 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17228A962 | List: |
| References | |
| 50-335-94-24, 50-389-94-24, NUDOCS 9412280188 | |
| Download: ML17228A963 (3) | |
Text
NOTICE OF VIOLATION Florida Power 8 Light Company Docket Nos.
50-335 and 50-389 St.
Lucie 1
and 2
License Nos.
DPR-67 and NPF-16 During an NRC inspection conducted on November 6 - December 3,
- 1994, a
violation of NRC requirements was identified.
In accordance with the "General Statement of Policy and Procedure for NRC Enforcement Actions,"
10 CFR Part 2, Appendix C, the violation is listed below:
Units 1
and 2 Technical Specification (TS) 6.8.2 requires that changes to procedures of TS 6.8. l.a shall be reviewed by the Facility Review Group (FRG) and approved by the Plant General Manager prior to use.
Units 1
and 2 TS 6.8.3 states that temporary changes to procedures of TS 6.8. I.a may be made provided that the intent of the original procedure is not altered and that the change is approved by two members of the plant management staff, at least one of whom holds a Senior Reactor Operator's license.
TS 6.8.3 also requires that the temporary change is documented, reviewed by the
- FRG, and approved by the Plant General Manager within 14 days of implementation.
Units 1 and 2 TS 6.8. I.a requires that written procedures shall be established, implemented, and maintained covering the activities recommended in Appendix A of Regulatory Guide 1.33, Revision 2, February 1978.
Appendix A, paragraph 9.a, includes maintenance that can affect the performance of safety-related equipment.
Procedure gI 5-PR/PSL-1; Preparation,
- Revision, Review/Approval of Procedures; Revision 58; paragraph
- 5. 12; states that approved vendor technical manuals that contain sufficient detail and acceptance criteria may be used as procedures.
It requires that technical manuals shall be treated as plant procedures for the purpose of procedure adherence.
Also, it requires that changes to technical manuals received from the vendor shall be reviewed by the FRG and approved by the Plant General Manager.
Contrary to the above, on April 12 - November 16, 1994, the licensee's process for making and using changes to vendor technical manuals was inadequate in that it failed to assure that, prior to implementation or
Examples include:
1.
Procedure gI 3-PR/PSL-l, Design Control, Revision 32, was inadequate in that it stated that a Documentation Change Request (DCR) for an administrative change to a technical manual, that does not require any physical work in the plant, does not require plant review and approval.
As a result, on October 11, 1994, the Nuclear Engineering Department issued DCR 8DCR-SLM-94-043 approving an April 12,
- 1994, vendor-recommended change to technical manual 8770-6251, Velan Valves.
The DCR approved the change for use by the maintenance department without the prior plant review and approval that is required by TS 6.8.2 and 6.8.3.
The change, in part, revised the Enclosure 94i2280i88 94iii4 PDR ADOCK 05000335 8
required torque for the bonnet-to-body bolts for a safety-related valve such as 1-V-3660 from 130 ft. lbs. to 150 ft. lbs.
On November 9, 1994, the licensee's Document Control distributed that change to holders of controlled copies of the technical
- manual, including the maintenance department.
On November 16, the copy of the change from Document Control was put into the maintenance department controlled copy of the technical manual.
Throughout this
2.
Procedure gI 5-PR/PSL-I, Revision 58, was inadequate in that it did not require that, prior to implementation or use, changes to technical manuals shall be reviewed approved as required by TS 6.8.2 and TS 6.8.3.
As a result, on or before September 12, 1994 (prior to the Nuclear Engineering Department approval) and again on November 16, 1994 (after the Nuclear Engineering Department approval),
the above change was put into the maintenance department controlled copy of the technical manual.
On September 12, 1994, the maintenance department used the change in writing Plant Work Order
'PWO) 61/0148.
The PWO required disassembly and reassembly of Unit 1 safety-related valve 1-V-3660 per the technical manual and also specifically required that the bonnet-to-body bolts be torqued to 150 ft. lbs.
On November 15,
- 1994, maintenance personnel torqued the valve bonnet-to-body bolts to 150 ft. lbs. per the PWO.
The technical manual change was not reviewed and approved as required by TS 6.8. 1 and 6.8.3 prior to torquing the bolts to 150 ft. lbs, Valve 1-V-3660, low pressure safety injection and high pressure safety injection pumps'ecirculation to the refueling water tank, is safety-related and receives an automatic signal to close during an accident on a Recirculation Actuation Signal.
3.
Administrative Procedure
- 0010432, Nuclear Plant Work Orders, Revision 72, was inadequate in that it permitted maintenance personnel to deviate from a Plant General Hanager approved technical manual without prior approval as required by TS 6.8.2 and 6.8.3.
Procedure step 8.7.3 allowed deviation from a technical manual (when it "is not invoked, but only used as a reference")
with only a concurrence from a vendor or a maintenance engineer prior to returning the affected equipment to service.
This is a Severity Level IV violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, the Florida Power 8 Light Company is hereby required to submit a written statement or explanation to the U.S.
Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington, D.C.
20555, with a'opy to the Regional Administrator, Region II, and a copy to the NRC Resident Inspector at the facility that is the subject of this notice, 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.
If an adequate reply is not received within the time specified in this Notice, an order or 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 Dated at Atlanta, Georgia this 14thday of De'c.
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