ML20010J161
| ML20010J161 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 08/25/1981 |
| From: | Cross W FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20010J142 | List: |
| References | |
| 3-081-23, 3-81-23, CS-81-193, NUDOCS 8109290651 | |
| Download: ML20010J161 (9) | |
Text
,
t Kb
[dds5c)ffddfhl, 4
$ pod g
g G;,4hy NW)>
\\
3!
? l. 2 :.
cea*
C O n p o s a t e o se August 25, 1981 File: 3-0-3-a-2
- 3-081-23 CS-81-193 Mr. J. P. O'Reilly, Director Office of Inspection & Enforcements U. S. Nuclear Regulatory Comission 101 Marietta St., Suite 3100 Atlanta, CA 30303
Subject:
Docket No. 50-302 Operating D aense No. DPR-72 Ref.: R11:TFS 50-302/81-11
Dear Mr. O'Reilly:
We offer the following response to the violations listed in the referenced inspection report.
Technical Specification 6.8.1 requires written procedures to be established and implemented covering applicable activities recomended in Appendix "A" of Regulatory Guide 1 33 Regulatory Guide 133, Appendix A, Section H.2 requires written pro--
cedures for each surveillance test listed in the Technical Specifi-cation.
Technical Specification 4 3 3.6, Table 4 3-7 requires a monthly channel check on the pressurizer power operated relief valve (PORV) and code safety valve position indicators.
Contrary to the above, as of June 25, 1981, a procedure had not been approved and implemented, and monthly channel checking had not been performed on the PORV and code safety valve position indicators.
8109290651 810922 1 PDR ADOCK 05000302!
O PDRJ Gener=' Office 3201 inirty fourtn street soutn. P O. Box 14042 St. Petersburg. Florida 33733 e 813-866-5151
NRC Notice of Violation August 25, 1981 Page 2 A.
RESPONSE
Florida Power Corporation concurs with the above stated violation and offers the following:
The delay in producing an adequate surveillance procedure was a result of long resolution time for determination of proper parameters and not recog-nizing the urgency of the situation.
It could not be readily determined what instruments constituted primary detectors, back-up detectors, or if such instruments had been installed.
During the ensuing investigation of this problem, the CHANNEL CHECK (s), as defined in STS 1.10, were per-formed on numerous occasions.
Corrective steps have been taken by the TecMical Specifications Coor-dinator to assure that future amendments to Technical Specifications are dealt with in a more timely manner.
Future compliance will be accom-plished through the personal effort of the Coordinator to guide implemen-tation from start to finish for associated new surveillances.
At this time, full expliance has been achieved.
B.
Technical Specification 6.5.2.8 requires the Nuclear General Review Committee (NGRC) to review the following items:
- a. The safety evaluations for 1) changes to procedures, equipment or systems and 2) tests or experiments completed under the provision of Section 50.59, 10 CFR 50, to verify that such actions did not con-stitute an unreviewed safety question.
- b. Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.
- c. Proposed tests or experiments which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.
- d. Proposed changes in Technical Specificaticas or this Operating
- Liceuse,
- e. Violations of codes, regelations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance.
- f. Significant operating abnormalities or deviations from normal and e%pected performance of plant equipment that affect nuclear safety.
I
- g. Events requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> written notification to the Commission.
- h. All recognized indications of an unanticipated deficiency in some aspect of design or operation of safety-related structures, systems, or components.
- 1. Reports and meetings minutes of the Plant Review Comittee.
s NRC Notice of Violations August 25, 1981 Page 3 Cont?ary to the above, cMring the period of April 30, 1981, through May 23, 1981, the NGRC assigned individual NGRC members of one-man subcom-mittees to accomplish these reviews.
The results of these one-man sub-comittee reviews were then presented to the full NGRC in a samarized form consisting of titles of the items reviewed and lacking any details for comittee review, therefore eliminatird the review of item details by members with expertise in other disciplines.
B.
RESPONSE
FPC disagrees in part with the listed violation and offers the following point-by-point information on method and scope of NGRC review activities both present and as proposed:
ai lhe safety evaluations for changes to procedures have been reviewed by a one-member subccmittee and reported to the full NGRC by listing the procedure number and revision number reviewed.
This member utilized the technical expertise of other members and/or other personnel know-ledgeable in the specific content of a given change as questions arose during the review process.
The reviews were performed on all proce-dure changes, rather than just those under 10 CFR 50.59.
FPC now proposes to modify this review activity by assigning a three (3) member subcommittee to perform the review on those under 10 CFR 50.59 This will utilize additional expertise of other disciplines to provide diverse viewpoints to the review process.
The subcommittee will meet regularly to perform these reviews.
The subcomittee will continue to report the written results of the review to the full Com-mittee and the subcomittee reports and questions /coments by other members will continue to be discussed during full NGRC meetings.
The safety evaluations for changes to equipment and systems were being reviewed by a one-member subcommittee for all changes, not just thoso under 10 CFR 50.59 Written reports were sutmitted to the full NGRC listing tne change numbers and revision number and date.
FPC has already modified this review activity by 1) receiving the change documentation on stendard distribution when issued for field I
implementation rather than waiting for empletion docmenta 1on.
This provides a more timely review.
- 2) The suMommittee reviewer provides l
a written description of all changc:s for distribution to and review by all other NGRC members.
This augments the review process by allowing l
the full spectra of technical expertise on NGRC to participate.
l I
l
NRC Notice of Violation August 25, 1981 Page 4 FPC now proposes to further improve this review by assigning a three (3) member subcomittee to perform this review, thereby achieving interdisciplinary review benefits within the detailed review process.
The subcomittee will meet as a group to perfonn this review.
he subcommittee's written report to the full NGRC will include the safety evaluations for those changes empleted under 10 CFR 50.59 for further review by all NGRC members, thus providing the multidisciplinary tech-nical review enempassing the entire expertise of the NGRC.
he subcommittce reports and questions by other members will be discussed during NGRC meetings.
- b. See Item "a" above.
- c. See Item "a" above.
- d. Proposed changes to Technical Specifications or this Operating License together with written safety analyses have always been provided for review to all NGRC members and discussed fully at full Committee meetings.
FPC disagrees with the inclusion of this item in the violation.
- c. Violations of coden, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance have always been reviewed by the NGRC.
Examples are: 1) LER's are distributed to all members for review;
- 2) Audit Findings are reviewed by at least three (3) members of the NGRC; 3) NCOR's are reviewed by a minima of two (2) members; 4) NRC Site Inspection Reports are distributed for review by all members.
FPC disagrees with the inclusion of this item in the violation, but does plan to improve this review area as follows:
FPC now proposes to enhance its review in this area by performing a Plant Staff review of all Cmpliance Audits, QA Audits and Cmpliance Activity Reviews to identify procedural or Technical Specification violations, which would then be reported to and reviewed by the NGRC.
Audits will be distributed to all members for review of the Findings and Corrective Actions, and subconmittee reviews of Audits will continue to be performed and reported to the NGRC.
- f. The NGRC has always reviewed significant operating abnormalities or deviations through its review of LER's, NCOR's, etc.
he NGRC has reviewed sme but not all Unusual Operating Event Reports j
(U0ER's).
Standard distribution is now implemented, and all will be reviewed.
FPC disagrees with the inclusion of this item in the violation,
- g. Events requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> notification to the Commission have always been reviewed by the NGRC.
Initial reports have been distributed, and all members receive for review the resulting LER.
NRC Notica of Violation August 25, 1981 Page 5
- h. The NGRC performs multifaceted reviews in the area of recognized indications of unanticipated deficiencies.
FPC disagrees with the inclusion of this item in the violation.
- 1. All reports and meeting minutes of the Plant Review Comittee (PRC) are reviewed by the NGRC.
The review of PRC minutes has been per-fomed by a one-member subcomittee with written reports sumarizing meeting minutes and observations of meetings submitted to the full NGRC.
Expanded subcomittee reports were initiated in early 1981 that sumarize fully the contents of the meeting minutes.
Discussion of the reports during full NGRC meetings will continue as before.
Full ccmpliance will be achieved by September 9,1981.
C.
Technical Specification 6.5 specifies the requirements for the review and audit function of the Plant Review Committee (PRC). Specific sections of the Specification require the following:
Specification 6.5.13 requires all alternate members to the PRC to be appointed on a temparary basis in writing by the PRC Chairman and that no more than two alternates serve as voting mesers at any one time.
Specification 6.5.1.5 requires that a quorum of the PRC consist of the Chairman or his designated alternate and four members (two of whom may be alternates).
Specification 6.5.1.6.e requires the PRC to review all violations of Technical Specifications, including those identified by internal audits or NRC inspections.
Contrary to the above, during the period October 14, 1980, through May 10, 1981, the following PRC meetings were conducted without a quorum and without designating alternates for the meeting in writing: 80-41, 80-47, 81-1, 81-2, 81-4 through 81 -3, and 81-18.
Contrary to the above, during the period June 1980, through May 1981, the PRC has not reviewed any Technical Specification violations either identi-fled through internal audits or throt:gh NRC Inspectors.
C.
RESPONSE
- 1. Violation of STS Paragraph 6.5.1 3
" Paragraph 6.5.1 3 requires alternate members of the comittee to be appointed in writing by the PRC chaiman and that no more than two soch alternates shall participate as voting me.mbers in PRC activit.es at any one time.
The inspectors' review of PRC meeting minutes 80-41 through 81-18 indicated that...for meetings 80-41, 80-47, 81-1, 81-2, 81-5, 81-6, 81-7, 81-8 and 81-18... personnel designated as alternstes were not designated by letter identifying what member they were replacing as an alternate.
In addition, the meeting minutes listed numerous personnel as alternates giving the appearance tnat more than t
two alternates participated as voting members in comittee activities."
NRC Notice of Violation August 25, 1981 Page 6 A.
We deny the alleged violation of this technical specification for the following reasons but confirm that inattention to proper docmentation requires imediate corrective action on our part:
1.
Technical Specification 6.5.1 3 states that alternates be appointed in " writing" (not necessarily by " letter" as stated in the NRC finding) by the PRC chairman.
In addi-tion, there is no requirement that such alternates be desig-nated at scrne time in advance of a specific PRC meeting.
Bus, it is our practice and continued intent to designate alternates either by letter or, as a minimum, in the PRC minutes which are reviewed and approved by the PRC Chair-man.
Thus, these minutes when signed by the Chairman constitute " written" approval of alternates.
2.
There is no requirement specified in the Technical Speci-fications to designate for whom an alternate is acting. The PRC meeting minutes list members present, alternates present and members absent.
Every attempt is made to ensure as diverse a background in plant expertise as possible and to assure the diversity intended by the specific designation of membera contained in Article 6.5.1.2.
However, we continue to.11ow some latitude, in this regard, based on specific items reviewed.
3 There is no limit on the number of alternates who may participate in a PRC meeting, only on the number who may vote in a meeting.
It is not our practice to vote on items in the PRC unless there is a dissenting opinion on the adequacy of a specific item.
Such items are then discussed among the members in order to resolve the issue to the satis-faction of all persons present, or a vote is taken and ma-jority rules.
In the case where such voting is done, the presence of a dissenting opinion is logged in the PRC minutes.
Since none of the meetings mentioned in the NRC finding centain evidence of dissenting opinion on PRC review items, there were no voting issues, and the presence of more than two alternates is not material to the outcome.
B.
his violation is denied.
C.
The PRC membership letter has been updated to clarify current members and a minimum of two alternates for each.
D.
No further action is required.
E.
It is oor opinion that full compliance was never compromised.
NRC Notice of Violation August 25, 1981 Page ?
- 2. Violation of STS Paragraph 6.5.1.5 Paragraph 6.5.1.5 requires each PRC meeting to have a quorum consist-ing of the chaiman or his designated alternate and four members including alternates.
The inspectors' review of PRC Meeting minutes 80-41 throagh 81-18 indicated that quorm requircments were not met for meetings 80-41, 80 87, 81-1, 81-2, 81-5, 81-6, 81-7, 81-8 and 81-18 in that personnel designated as alternates were not designated by letter identifying what member they were replacing as an alternate."
A.
Since the alleged violation is based on the point of designation of alternate members, we deny this violation based on the discus-2 j
sion presented above for STS paragraph 6.5.1 3 B.
This violation is denied.
C.
No corrective action is required.
D.
No corrective action is required.
E.
It is our opinion that full compliance was never compromised.
- 3. Violation or STS Paragraph 6.5.1.6.e
" Paragraph 6.5.1.6.e requires the PRC to investigate all TS violations including an evaluation of the reports issued to prevent recurrence.
Review of the PRC minutes for the period June 1980 through May 1981 indicates that the PRC has not reviewed any TS violations identified by NRC Inspectisu Reports.
In addition, the PRC failed to review a 13 violation identified by an internal quality programs audit (QP Audit 194) conducted in July,1980."
A.
We concur with the above inspection finding in that the majority of potential technical specification violations identified by personnel not assigned as CR-3 plant staff (e.g., USNRC staff, FPC Quality Programs, Insurance Auditors) did not receive formal PRC review if a non-conforming operations report (NCOR) was not originated.
However, each of these items is fomally addressed and resolved, with corrective action, through existing plant procedures.
B.
The reason for this finding appears not to be dee to inadequate plant procedures in that plant procedure CP-111, " Procedure for Docmenting the Reporting and Review of Nonconforming Opera-tions," outlines the method for any person assigned to the plant staff to originate an NCOR describing potential violations of technical specifications.
This procedure coupled with AI-300,
" Plant Review Cormattee Charter," establishes requirements for PRC review of all NCOR's and, hence, all potential technical specifications violations identified in an NCOR.
NRC Notice of Violetion August 25, 1981 Page 8 The existing problem arises from the fact that NRC and FPC qua-lity programs audits are conducted by non-plant staff person-nel.
This problem is cmpounded by a failure to formally assign responsibility for review of these audits, for potential tech-nical specifications violations, to specific plant staff per-sonnel familiar with CP-111.
C.
The corrective action proposed is to revise the plant adminis-trative instructions ( AI's) to fonnally assign responsibility for screening NRC inspections, FPC internal audits, and other quality assurance reports to the QA/QC Cmpliance Department.
This orga-nization will review and identify potential technical specifi-cations violations, frm the above reports, and notify the plant Technical Specifications Coordinator who will be assigned respon-aibility for generation of an NCOR in accordance with CP-111.
These NCOR's will be reviewed as currently required by AI-300.
This requirement has been verbally established by discussion with the cognizant department 'mlager as of this date.
D.
We feel that the corrective action discussed in item C above will avoid further potential non-compliance with this article.
2.
Procedure changes to effect full cmpliance will be implemented by October 15, 1981.
Should there be further questions, please contact us.
Very truly yours, Yh eN
~
fuelear Plant Mandger William A. Cross Manager Nuclear Licensing JC:ji
STATE & FLORIDA COUNTY & PINELLAS W. A. Cross states that he is the Manager, Nuclear Licensing, Nuclear Support Services, of Florida Power Corporation; that he is authorized on the part of said company to sign and file with the Nuclear Redalatory Conmission the information attached hereto; and that all such statements made ann.oatters set forth therein are true and correct to the bes' of his knowledge, information, and belief.
- d. b W. A. Cross Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 25th day of August, 1981.
'AY
(/ Notary Public Notary Public, State of Florida at Large, My Commission Expires: May 29, 1984