ML17340B157

Ack Receipt of Util s & Full Payment of Civil Penalty Proposed in NRC

ML17340B157
Person / Time
Site:	Turkey Point
Issue date:	05/04/1981
From:	Thompson D NRC OFFICE OF INSPECTION & ENFORCEMENT (IE)
To:	Robert E. Uhrig FLORIDA POWER & LIGHT CO.
References
EA-81-022, EA-81-22, NUDOCS 8105110020
Download: ML17340B157 (17)

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UNITED STATES NUCLEAR REGULATORY COMMlSSlON WASHINGTON, D. C. 20555 MAY P 'I":Bl Docket No. 50-250 EA-81-22 Florida Power and Light Company ATTN:

Mr. Robert E. Uhrig Vice President - Advanced Systems and Technology P.O.

Box 529100 Miami, FL 33152 Gentlemen:

This will acknowledge the receipt of your two letters dated April 20,

1981, and the enclosed check in the amount of Forty Thousand Dollars in full payment of the civil penalty proposed in the NRC letter dated February 18, 1981.

Sincerely, Dudley pson, Director Enforcement and Investigations Office of inspection and Enforcement cc:

Harold Reis, Esq.

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Stock Form 1114 October 1967 Title 7, GAO Manual 1114-106 0 BILL FOR COL'LECTION~

BillNo.

U. 'S.

Nuclear Pegulatory Commission (Delsarsmens or Establishment and Bureau or Office)

Mashin toni, DC 20555 (Address)

PA2'EA:

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Florida Power and Light Company P.O.

Box 529100

JLiami, FL 33152 Date April 23, 1981 This billshould br rrlurned by lhr payer soifh his remiffarscr.

SEE IrYSTRUCTIOKSBOLO)V.

Date DESCRIPTION Quantity Unit Price Per-Amount 4/23/81 Full payment for Civil Penalty fol'ocket No. 50-250, in response to Notice of Violation dated

-'February 18, 1981; 8l)0,00

.00 AMOUNTDUE THISBILL,,S 40 9 000.00 This is not a receipt INSTRUCTIDIIIS Tender of payment of the above bill may be made in cash, United States postal money order, express money order, bank draft, or check, to the office indicated.

Such tender, when sn any other form than cash, should be drawn to thc order of the Department or Establishment and Bureau or Officc indicated above.

Rcccipts will bc issued in all cases where "cash" is received, and only upon request when remittance is in any other form. Iftender of payment of this bill is other than cash or United States postal money order, the'receipt shall not become an acquittance until such tender has been cleared and thc amount rcccived by the Department or Establishment and Bureau or Offfce indicated above.

Failure to receive a receipt for a cash payment should be promptly reported by thc payer to the chief administrative officer of the bureau or agency,mentioned above.

U. S. GOVERNMENT MTINGOFHCE: Isit 0 - 552-290

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+If'LORIDA POWER & LIGHTCOMPANY April 20, 1981 L-81-173 Mr. Victor Stello,. Director Office of Inspection and Enforcement U.

S. Nuclear Regulatory Commission Washington, D.

C.

20555 Re:

Turkey Point Unit 3 Docket No. 50-250 10 CFR 2.205

Response

to Notice of Violation Dated Februar 18, 1981

Dear Mr. Stello:

In accordance with 10 CFR 2.205, Florida Power and Light Company submits this response to your letter and Notice of Violation of February 18, 1981.

Our reply pursuant to 10 CFR. 2.201 has been provided separately as requested.

We disagree with the severity level assigned to the speci'fic violation.

We also consider the fine to be inappropriate.

This and other regulatory matters were discussed with Messrs.

De Young, O'Reilly, and Lewis during their visit to Florida Power and L'ight on April 7, 1981.

While we consider this enforcement action inappropri'ate, our interest is in resolving the concerns in an expeditious manner and in enhancing our cooperative efforts to.ensure continued safe operation of our nuclear plants.

Accordingly, while we request that you reconsider the severity level, we have decided to not pursue the matter further and we agree to pay the fine.

A check for

$40,000 is enclosed.

Sincerely yours, Robert E. Uhrig Vice President Advanced Systems and Technology REU/RAK/gw Enclosure cc:

Mr. J.

P. O'Reilly Harold F. Reis, Esquire PEOPLE... SERVING PEOPLE

FLORIDA POWER 8 LIGHTCOMPANY April 20, l981 L-81-174 Mr. Victor Stello, Director Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission Washington, D.C.

20555

Dear Mr. Stello:

Re:

Turkey Point Unit 3 Docket No. 50-250 10 CFR 2.201

Response

to Notice of Violation dated Februar 18, 1981 The attachment to this letter contains Florida Power 5 Light Company's reply to your letter and Notice of Violation of February 18, 1981 as required by 10 CFR 2.201.

Our reply pursuant to 10 CFR 2.205 has been provided separately as requested.

Very truly yours, ert E. Uhri g Vice President Advanced Systems and Technology REU/RAK/mbd Attachment cc:

Mr. J.P.

O'Rei-lly, Region II Harold F. Reis, Esquire PEOPLE... SERVING PEOPLE

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Turkey Point Unit 3 Oocket No. 50-250 10 CFR 2.201

Response

to Notice of Violation dated February 18, 1981 Page 1

ATTACHMENT Fi ndi nci:

10 CFR 50.54(k) states that an operator or senior operator licensed pursuant to Part 55 of this chapter shall be present at the controls at all times during operation of the facility.

Technical Specification 6.8.1 requires that written procedures and administrative pol'icies be established, implemented and maintained that meet or exceed the requirements and recommendations of Section

5. 1 and 5.3 of ANSI N18.7-1972, Appendix "A" of USNRC Regulatory Guide 1.33; this includes plant operating pr ocedures.

Plant Operating Procedure 0103.2, Responsibilities of Operators On-Shift and Maintenance of Operating Logs and

Records, states in Section 5.3.3 that the Nuclear Control Center Operator (NCCO) shall have an unobstructed view of and access to the control panels, including instrumentation displays and alarms.

He shall not leave the Surveillance Area (Figure 1) for any non-emergency reason: without obtaining a

qualified relief.

Section 5.3.4 states that a single operator shall not assume the NCCO responsibility for both units at the same time unless so di rected and such action is in compliance with Technical Specification 6.2.2 or is necessitated by emergency conditions.

Contrary to the above, at about ll:45 a.m.

on January 29, 1981, the NRC Resident Inspector observed Turkey Point Unit 3 operating, at full power without an operator present at the controls.

The assigned Unit 3 operator was in a room behind the Unit 4 instrument panels which precluded visually monitoring the Unit 3 reactor conditions.

The room, although open to the control room, is outside the surveillance area specified in Plant Operating Procedure 0103.2.

A qualified relief had not been obtained and an operator leaving the surveillance area was not necessitated by an emergency condition, nor was the Unit 4 operator di rected to assume NCCO responsibilities for both units.

~Res ense:

(1-1)

(1-2)

(1-3)

FPL concurs with the finding, however, as discussed in our reply pursuant to 10 CFR 2.205, we, take exception to the severity level classification.

The reason for the violation was that the Nuclear Control Center Operator (NCCO) did not adhere to the procedural requirement to obtain a relief prior to leaving the surveillance area.

As corrective action:

(1)

The surveillance area has been re-defined and permanent red colored floor tiles have been installed to outline the surveil lance area boundary.

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Turkey Point Unit 3 Docket No. 50-250 10 CFR 2.201

Response

to Notice of Violation dated February 18, 1981 Page 2

(2)

Changes have been made to Administrative Procedure 0103.2, Responsibilities of Operators On-Shift and Maintenance of Operating Logs and Records, which redefined the proper procedure which must be taken by the NCCO in order to leave the surveillance area.

The third NCCO, on shift is now required to normally stay in the surveillance area and to verbally notify and obtain acknowledgment from each operator with unit responsibility prior to leaving the surveillance area.

(3)

(4)

(5)

A name display system has been implemented that positively identifies the operator who has unit responsibility.

In order to transfer unit responsibility from one operator to

another, the name display must be changed by the oncoming operator as part of his turnover acknowledgement.

All operators have been instructed in writing of their responsibilities.

Plant management has begun a program of random visits to the Control Room at unannounced intervals.

During. these visits, the management will verify that the licensed operators are continuing to perform their duties in a

professional manner.

(1-4)

We will also take the following long and short term corrective actions to avoid similar problems in the future.

Short term; (2)

(3)

(4)

The surveillance area boundaries will be redefined by April 30, 1981 to fully meet the intent of Regulatory guide 1.114 as discussed at the management meeting with Ihf personnel.

FP&L Management will conduct meetings with Licensed Operators by May 31, 1981 to emphasize the importance of this issue, to provide guidance on compliance with the Regulatory Guide, and to discuss management enforcement actions that wi,.ll be taken should further deficiencies occur.

Movable rope or chain barriers will be iplaced at appropriate openings to the surveillance area boundaries by May 15, 1981 to give a more physical means of identifying the surveillance area and to limit access to this area by non licensed personnel.

Plant management will conduct meetings with Licensed Operators to discuss Operator concerns, management

policies, and Operator safety responsibilities.

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Turkey Point Unit 3 Docket No. 50-250 10 CFR 2.201

Response

to Notice of Violation dated February 18, 1981 Page 3

Long term:

(1)

A human factors engineering study of the Control Room layout will be conducted by January 1, 1982.

(2)

The Nuclear Watch Engineer's office will be modified by January 1,

1982.to allow him to see the control panels while in his office.

(3)

Other physical changes will be made to permanently re-locate such items as water fountains, chart lockers, bookcases and coffee pots in short term item 1, above.

This will be accomplished by January 1, 1982.

Immediate corrective action was taken on January 29, 1981, in response to the violation.

Additional corrective action,

'escribed in 1-3 above, was taken between January 30, 1981 and February 13, 1981.

Additional short and long term cor-rective action to enhance compliance will be completed by the dates provided with each item in 1-4 above.

A'

STATE OF FLORXDA"

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)

COUNTY OF 'DADE

)

ss Robert E. Uhrig, being first duly sworn, deposes and says:

That, he is a Uice President of Florida Power 6, Light Company, the Licensee herein; That he has executed the foregoing document;

.that the state-ments made in this said document are true and correct to the best of his knowledge, information, and belief, and that he is authorized to execute the document:

on behalf.of said Licensee.

Robert E. Uhrig Subscribed and sworn to before me this Q

day of NOTARY PUHLXC, it and for the county of Dade, State of Florida Notery 'PUbgc, Stste of Ronde et Lerge lyly Commis 'on:Expires October 38,.1983

. Ny COmmiSSiOn eXpirCS:

Bonded thru Msynsrd

.Bonding Agency