ML20003H495

Responds to NRC 810303 Ltr Re Violations Noted in IE Insp Rept 50-302/81-01.Corrective Actions:Temporary Nuclear Tech Spec Coordinator Has Been Relieved & All STS Have Been Reviewed

ML20003H495
Person / Time
Site:	Crystal River
Issue date:	03/26/1981
From:	Richard Bright FLORIDA POWER CORP.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20003H494	List: ML20003H495
References
CS-81-072, CS-81-72, NUDOCS 8105060148
Download: ML20003H495 (5)

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Flor'ichi Power C O 4 PO R a T 60 8s March 26, 1981 File: 3-0-3-a-2 CS-81-072

1. 3-031-25 Mr. J. P. O'Reilly, Director Office of Inspection & Enforcements U. S. Nuclear Regulatory Commission 101 Marietta St., Suite 3100 Atlanta, GA 30303

Subject:

Docket No. 50-302 Operating License No. DPR-72 Ref.: R11:TFS 50-302/81-0.1

Dear Mr. O'Reilly:

We offer the following response to the violations listed in the referenced inspection report.

NOTICE OF VIOLATION A. Technical Specification 6.9.1.9 requires that events leading to operation in a degraded mode permitted by a limiting condition for operation (LCO) be reported to the Regional Office Director within 30 days of occurrence of the event.

Contrary to the above, as of February 2,1981, the following events that resultc:i in operation in a degraded mode were not reported to the Region-al Office Director: .

-Failure of meteorological tower temperature instrumentat6n on October 13, 1980;

-Failure of cable to tunnel sump pumps on November 3,1980; and

-Failure of building spray pump 1A on December 15, 1980.

A. Response: Florida Power Corporation concurs with the violation in regard to two of the three examples stated in the Notice of Violation "A".

-The failure to report the meteorological tower temperature instrumenta-tion failure occurred due to a misinterpretation of the action state-ment requirement of Technical Specification 3.3.3.4. We understand that our interpretation was in error and all future occurrences will be reported via Licensee Event Reports.

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J. P. O'Reilly Ref. R11:TFS 50302/81-01 Page 2 _

- We do not agree with the reportability requirement as stated in the Notice of Violation in regard to the Cable Tunnel Sump Pump failure. We do not consider the failua a of one of two redundant sump pumps to constitute a reportable occurrence. It is our contention that as long as one of the two sump pumps at each end of the tunnel is operable, we meet the requirements of Technical Specification 3.8.1.1.C. A previous determination by an NRC representative led to this interpretation of the Technical Specification.

- The failure to report the inoperability of the Building Spray Pump 1A was a result of a personnel error in that a temporarily assigned person performed the duties of the Nuclear Technical Specifications Coordina-tor. This event has been reported by LER. The permanent Nuclear Tech-nical Specifications Coordinator and the Nuclear Plant Manager have reviewed the Standard Technical Specifications for all plant systems and those persons responsible for reportability requirement of plant events have been advised by management to assume an event is reportable until proven otherwise. We feel that full compliance has been achieved.

B. 10 CFR Part of 20.202 defines a radiation area as any area in which there exists radiation levels that could cause a person within the area to receive a dose rate of greater than 5 millirems per hour or 100 millirems in any 5 consecutive days.

10 CFR Part 20.203 requires such radiation areas to be posted.

Contrary to the above, at approximately 1430 hours0.0166 days <br />0.397 hours <br />0.00236 weeks <br />5.44115e-4 months <br /> on January 26, two areas on the plant berm, not designated as radiation areas and therefare not posted as such, were identified to have radiation doses of up to 7 millirems per hour.

B. Response: Florida Power Corporation concurs with this violation. The two areas addressed in this finding were being modified and permanent j stanchions were being installed. The prior radiation p,osting had been

moved without Chem / Rad notification in order to complete the modifica-l tion. Upon notification of the violation to Chem / Rad by the inspector, l

reposting of the area was accomplished imediately. An immediate meeting i was conducted between the Chem / Rad Manager and the Contract Labor Force Manager to discuss the situation. A comitment was madd by the Contract l Labor Force Manager to reprimand and to instruct the work force of the l necessity to follow the appropriate procedures, and that only Chem / Rad l Department has the authority to move or remove radiation postings. The l

permanent posting is in place and full compliance was achieved on January 26, 1981.

( C. 10 CFR Part 50, Appendix B, Criterion V, requires that activities I affecting quality be accomplished in accordance with procedures.

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3.P.O'Reilly Ref. R11:TFS 50302/81-01 Page 3 The licensee's Quality Program, as delineated in part in Sectf6n 1.7.6.7.1 of the FSAR requires maintenance to be performed in a manner to ensure quality.

Procedures AI-500, Conduct of Maintenance, and CP-113, Procedue for Handling and Controlling Work Requests, accomplish these Quality Program requirements by requiring quality control concurrence on work requests and by requiring that a work request be issued for all maintenance on safety related equipment.

Contrary to the above, Quality Control occurrence was not obtained on wurk requests 20627 dated 12/12/81, 20686 dated 12/15/80, and 20904 dated 1/13/81. Also contrary to the above, on 1/18/81 maintenance activities were conducted on a safety related piece of equipment without issuance of a work request.

C. Response Florida Power Corporation agrees that this violation occurred as described. The violation was due to an error in the Planning Section and an understanding by personnel performing maintenance activities that a work request had, in fact, been written, when in fact, it had not. The Planning Section processes approximately thirty-five (35) work requests per day, and in a five (5) week sampling period only three (3) were dis-covered to be in error. The Quality Control Section has since reviewed the work requests and all QC requirements have been met. A work request has been written to cover the maintenance performed without a work request. The Planning Department has reviewed the applicable sections of Administrative Instruction AI-600 Conduct of Maintenance, and Compliance Procedure CP-113, Procedure for Handling and Controlling Work Requests, and this review has been documented. The Instrument and Controls Super-visor is conducting a review of AI-600 and CP-113 with the I&C techni-cians, and this review will be completed by March 27, 1981 and full compliance will be achieved.

With regard to the request for a description of the corrective actions to be taken to improve the effectiveness of our management control systems, Mr. D. C. Poole, the Nuclear Plant Manager, received additional clarification Mr. Tom Stetka, Crystal River Resident Inspector, that this pertained to the repeated violation for failure to report items as require.d by Section 6.9 of the CR-3 Standard Technical Specifications. ,

r; Of the three instances cited by Mr. Stetka in the report, none'were due to an inadequate management control system. We do acknowledge that the failure to report the failure of the Building Spray Pump 1A was the result of personnel error on behalf of the person temporarily assigned to perform the duties of the Nuclear Technical Specification Coordinator and on behalf of the Nuclear l Plant Manager for not detecting the original failure reportability determination.

As to the failure to report the inoperability of the Meteorological _

Instrumentation which occurred on October 13, 1981, the Crystal River Uni #3 Plant staff had previously interpreted the reporting requirement for ti:fs particular system to be as stated in action statement 3.3.3.4.a. Since the i

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3.P.O'Reilly Ref. R11:TFS 50302/81-01 Page 4 _

system was restored to operable status within the prescribed seven (7) days, no report was required. Following discussions with Mr. Stetka and NRR, we understand that our interpretation was in error.

The third incident cited was the failure to report the failure of the Cable Tunnel Sump Pumps. Specification 4.8.1.1.1.a.2 states, "That the sump pumps in the tunnel containing the DC control feeds to the 230 KV switchgear are opera-ble." It was pointed out to Mr. Stetka that there are two (2) sump pumps in each end of the Cable Tunnel and that only one of the pumps had failed the acceptance criteria. In July of 1979, our plant staff becam concerned over the number reportingofa LER's failure submitted of any one on these of the foursump (pumps

4) pumps) (prior and to this atime requested we were clarifica-tion of the design basis for the pumps. The determination was that one pump on either end of the tunnel was sufficient. Based on this evaluation, and the fact that no specific number of pumps is specified in 4.8.1.1.1.a.2, the Nuclear Technical Specification Coordinator has not considered the failure of a single pump reportable.

Relative to these specific instances, the following actions have been taken:

- The person temporarily assigned to perform the duties of the Nuclear Tech-nical Specification Coordinator has been relieved by the permanent assignee.

- The Nuclear Plant Manager has reviewed the Standard Technical Specifica-tions (STS) for all systems.

- Those persons responsible for evaluation of NCOR's for reportability have been advised by management to assume an event is reportable until proven otherwise; and if doubt exists, report it.

-A change of the STS has been initiated to clarify specification 4.8.1.1.1.a.2.

In summary, Florida Power Corporation's management and thk Crystal River Unit 3 staff intend to operate under a full disclosure policy. Further, each of the above instances was somewhat unique and do not indicate' a generic weakness in cur management control system. .-

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Should there be further questions, please contact us. ,,

Very truly yours, FLORIDA POWER CORPORATION Ronald M. Bri t -

Acting Manager

! Nuclear Support Services Bright (R04)D-1

STATE & FLORIDA COUNTY OF PINELLAS R. M. Bright states that he is the Acting Manager, Nuclear Support Services, of F.lorida Power Corporation; that he is authorized on the part of the said company to sign and file with the Nuclear Regulatory Comission the infonnation attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of his knowledge, information and belief.

M R. M. B(igift Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 26th day of March, 1981.

a ,. .

(/ Notary Public _-

s Notary Public, State of Florida at Large, My Commission Expires: May 29, 1984 e w =- -s 7

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