ML20005B652
| ML20005B652 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 06/09/1981 |
| From: | Baynard P FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20005B630 | List: |
| References | |
| CS-81-130, NUDOCS 8107080490 | |
| Download: ML20005B652 (5) | |
Text
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..O June 9,1981 M.o =
3-0-3-a-2 co oa u CS-81-130
- 3-061-02 Mr. J. P. O'Reilly, Director Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission 101 Marietta St., Suite 3100 Atlanta, GA 30303
Subject:
Docket No. 50-302 License No. DPR-72 Ref: RII: T.F.S.
50-302/81-05
Dear Mr. O'Reilly:
We offer the following response to the violations listed in the referenced inspection report.
NOTIGE OF VIOLATION A.
10 CFR Part 50, Appendix B, Criterion X1 requires that testing required to demonstrate that systems will perform satisfactorily in service is performed by written test procedures which incorporate the requirements and acceptance litaits contained in applicable design documents.
The licensee's Quality Preoram, as delineated in Section 1.7.6.1.7.V requires test procedures to iacorporate or reference the require-ments and acceptance limits contained in applicable design and pro-curement documents.
Contrary to the above, procedure SP-501, Halon System Functional Test, was found to be inadequate to verify operability of the cable spreading room Halon System, in that the procedure did not contain adequate instructions for use of the test equipment and data evalua-tion as delineated in the test equipment technical manual.
A.
Response: We agree with th violation and offer the following:
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Notice of Violation Ref: PII: T.F.S. 50-302/81-05 Page 2
- SP-501 was deficient in that it was written to functionally test the Halon System and it lacked specifics that could have resulted in an invalid test when used by an inexperienced technician.
- SP-501 had previously been reviewed by several staff members, Pro-fessional Loss Control Inc., and NRC inspectors, but had not been reviewed against the Fenwal Instruction Manual. At the time of this inspection there was not an approved copy of this Manual in the Plant Technical Library. The discrepancies in SP-501 had gone un-noticed until a copy of the Manual that was part of the Fenwal Test Kit was used as a reference.
- When the deficiencies in SP-501 became apparent, a Nuclear Plant Engineer and the Nuclear Fire Protection Specialit; were assigtad to correct these deficiencies.
SP-501 has been reviewed and revised to incorporate the latest requirements of the Fenwal Instruction Manual.
SP-501 was successfully performed and the Halon System was found to be operable and it was returned to service.
- A properly reviewed copy of the Fenwal Instruction Manual has been plsced in the Plant Technical Lfkrary and Administrative Procedure AI-400 has been revised to require that the latest revision to the Manufacturer's Instruction Manual be reviewed each time the applicable SP is reviewed.
We feel that full compliance has been achieved.
B.
Technical Specification 6.11 requires procedures prepared to meet the requirements of 10 CFR Part 20 to be adhered to for all activities in-volving personnel radiation exposure.
Radiological. Control Procedure RP-101, Radiation Protection Manual, para-graph 4.8, Use of Protective Clothing, requires protective clothing to be worn as specified on the Radiation Work Permit (RWP) when in a Radiation Control Area (RCA).
Radiological control procedure RP-106, Radiation Work Permit Procedure, paragraph 5.8, RWP Procedural Cyclc, requires personnel to log their name and TLD number on the "RWP Authorized Personn2l Radiation Exposure Log" to assist in radiation exposure control.
Contrary to the above, at approximately 9700 hours0.112 days <br />2.694 hours <br />0.016 weeks <br />0.00369 months <br /> on March 30, a per-son was observed within a RCA without all the protective clothing on the RWP.
In addition, this same person was not logged on the "RWP Authorized Personnel Radiation Expocure Log".
I
Notice of Violation Ref: RII:
T.F.S 50-302/81-05 Page 3 B.
Response: The violation is correct as stated and the individual conccrned readily admitted that he was aware of the procedural re-quirements.
This individual has not been involved in frequent or flagrant radiological violations.
The actions to be taken, as stated in the inspection repert, have been completed except for the revision of RP-101 to include an enforcement policy that will identify and remove from the RCA access, persistent RWP violators. This revision will be implemented by July 15, 1981 and full compliance will be achieved.
C.
Technical Specification 3.7.1.2 requires both the steam driven and motor driven emergency feedwater pumps to be operable when in opera-tional modes 1, 2, or 3.
Technical Specification 4.7.1.2 requires surveillance to be performed on th; steam driven emergency feedwater pump within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after enter-ing Mode 3.
Surveillance Procedure SP-349-Emergency Feedwater System Operability Demonstration, requires in step 6.3.7 tha* the control switch for the steam driven emergency feedwater pump stop valve (ASV-5) be placed in the " Auto" position as part of the pump's return to standby status.
Contrary to the above, at 0929 hours0.0108 days <br />0.258 hours <br />0.00154 weeks <br />3.534845e-4 months <br /> on April 17, with the plant in Mode 3 operationc and following completion of surveillance procedure SP-349 at approximately 0830 hours0.00961 days <br />0.231 hours <br />0.00137 weeks <br />3.15815e-4 months <br />, the steam driven emergency feed-water pump (EFP-2) was not operable in that the turbine stop valve (ASV-5) was not in the " Auto" position.
C. Response:
The stated violation has been acknowledged by the issuance of Licensee Event Report 81-025/03L-0. The violation is attributed to the inadequacy of SP-349 to force acknowledgement of completion of all required actions.
Surveillance Procedure SP-349 has been revised to provide signoffs for the steps required in Section 6.
Full com-pliance was achieved on May 26, 1981 when revision 25 to SP-34f aas issued.
Please he advised that NRC inspection 81-05 was received by Florida Power Corporation Nuclear Operations on May 26, 1981,and the inspection report was dated May 15, 1981. This differential of eleven (11) days subtracts from the twenty-five (25) day limit for the response to reach the regional office.
It is requested that consideration be given to allaw the response to reach the regional office within twenty (20) days of receipt, or within twenty-five (23) days of the date of the report, whichever is later.
Notice of Violation Ref: RII:
T.F.S. 50-302/81-05 Page 4 Should there by further questions, please contact us.
Very truly yours, FLORIDA POWER CORPORATION If 1/
Patsy Y. Baynard Nucle 5r Plant Manager Manager Nuclear Support Services JC/rc 1
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STATE OF FLORIDA COUNTY OF PINELLAS P. Y. Baynard states tnat she is the Manager, Tuclear support Services, of Florida Pcwer Carporation; that she is authorized on the part of the said company to sign and file with the Nuclear Regulatory Comission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of her knowledge, information and belief.
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. LJ P.(/YU3ayna dv Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 9th day of June, 1981.
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Nota $ Public Notary Public, State of Florida at Large, My Commission Expires:
W E, State of FI.,ide at %
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