ML20011D355
| ML20011D355 | |
| Person / Time | |
|---|---|
| Site: | Crystal River |
| Issue date: | 12/01/1989 |
| From: | Ebneter S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Wilgus W FLORIDA POWER CORP. |
| Shared Package | |
| ML20011D356 | List: |
| References | |
| EA-89-172, IEIN-87-066, IEIN-87-66, NUDOCS 8912270038 | |
| Download: ML20011D355 (5) | |
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DEC 01989 7
Docket No. 50-302-~
' License: No.: DPR-72 :
EA 89-172-Florida. Power Corporationi
. : Mr. W. S. Wilgus m.
Vice President Nuclear Operations ATTN:1 Manager, Nuclear 0perations
.. Licensing P. O. Box 219-NA-P.I'
. Crystal River, FL 32629:
Gent' lemen:
SUBJECT:
NOTICE OF VIOLATION AND PROPOSED IMPOSITION OF CIVIL PENALTY
$50,000-
-(NRC INSPECTION REPORT NOS. 50-30P/89-200 AND 50-302/89-24) 1This: refers to the Nuclear Regulatory Commission (NRC) team inspection conducted
.-on April 24 - May 5, 1989, and the inspection conducted by the Senior Resident iInspector on September.7-8,- 1989, at the Crystal River facility. The team inspection included'a review of vendor interface and procurement of items
- used in safety-related applications. - The latter inspection included a review 1
of circumstances regarding instal.lation of an improper impeller in raw water j
(pump (RWP)l2B.
The reports documenting these inspections were sent-to you by letters dated
~
Augusti14, 1989 and September 18, 1989. As a result of these inspections, significant. failures to comply with NRC regulatory requirements were identi-fied and accordingly,.NRC' concerns relative to the inspection findings were s
. discussed in an' Enforcement Conference held on September 28, 1989. The letter summarizing this Conference was sent to you on October 16, 1989.
The violation described in the-enclosed Notice of Violation and Proposed m
Imposition of. Civil ~ Penalty (Notice) involved failures to assure that items and components procured and installed in safety-related systems were suitable for
.such applications-and' met appropriate standards of quality. Many items,
' including ASCO solenoid valves and molded case circuit breakers, which were
-procured-as commercial grade components, were installed in safety-related
' systems'without adequately evaluating.their suitability for such applications.
the material ~ qualification form (MQF)g. items to safety-related status through In some. cases, this involved upgradin process without adequately establishing traceability.to the original equipment manufacturer. Additionally, even though
- NRCzInformation Notice 87-66 specifically alerted licensees.to the problems of cpgrading commercial grade Agastat relays, improper upgrading of such relays
.had been performed at your facility.
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4 t 8912270038 891201 1!-
LPDR ADOCK 05000302 l
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Florida Power Corporation Procurement problems at your facility were not limited to upgrading of commercial
- graQ items. - A raw water pump replacement impeller was procured as a safety-related component, but Florida Power Corporation's quality assurance program failed to detect that the vendor provided an impeller with five vanes rather than the required seven vanes.
Your staff had a subsequent opportunity to
. identify that defect, but failed to do so because the post-maintenance test of RWP-2B operability was not adequately conducted.
Consequently, the plant was operated for about seven weeks during which the pump was not capable of performing its intended safety function.
Consideration was given to issuance of separate violations for the failure to adequately test the pump and for the failure of that pump to be able to perform as required. However, the enclosed Notice focuses on the root cause of that and the other problems, which is a weak procurement program and as discussed below the civil penalty has been adjusted to reflect the added significance provided by the raw water pump example.
To emphasize the importance of implementing an effective procurement and dedication program for commercial grade components, and assuring that purchased safety-related components are suitable fcr their intended use, I have been 3
authorized, after consultation with the Director, Office of Enforcement, and the DepRy Executive Director for Nuclear Materials Scfety, Safeguards, and-Operations Support, to issue the enclosed Notice of Violation and Proposed Imposition of Civil Penalty in the amount of $50,000 for the violation described in the enclosed Notice.
In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1989)
(Enforcement Policy), the violation described in the enclosed Notice has been categorized as a Severity Level 111 violation. The base value of a civil penalty for a Severity Level III violation is $50,000. The escalation and mitigation factors in the Enforcement Policy, vere considered.
Fifty percent mitigation of the base civil penalty is warranted because of your prompt and extensive corrective actions, including reverification of procurement packages, procedure revisions, and replacement of the material qualification form (MQF) process with processing per EPRI guidelines.
In considering past performance, we balanced negative factors, such as the SALP 3 rating in the engineering category and the recent escalated enforcement associated with environmental qualification, with our assesment that you have developed a good overall quality assurance program and racognition of active participation in industry initiatives in this area, and conclude that neither escalation nor mitigation is warranted for this factor. With respect to multiple examples, in this case, the civil penalty has been escalated 50 percent in recognition of the added significance of an example in which a replacement part, the raw water pump impeller, was not only of indeterminate quality but was demonstrably unsuitable for its application.
You are required to respond to this letter and should follow the instructions specified in the enclosed Notice when preparing your response.
In your re-sponse, you should document the specific actions taken and any additional actions you plan to prevent recurrence. After reviewing your response to this Notice, including your proposed corrective actions and the results of future inspections, the NRC will determine whether further NRC enforcement action is necessary to ensure compliance with KRC regulatory requirements.
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Florida Power Corpo. ation DEC 011989 In accordance with section 2.790 of the NRC's " Rules of Practice," Part 2 Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room.
The respoases directed by this letter and enclosed Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980 Public Law No.96-511.
Should you have any questions concerning this letter, please contact us.
Sincerely, Original Signed By J 1.. Milhoan Stewart D. Ebneter Regional Administrator 4
Enclosure:
Notice of Violation and Proposed Imposition of Civil Penalty cc w/ encl:
Gary L. Boldt Vice President, Nuclear Production Florida Power Corporation P. O. Box 219-SA-2C
. Crystal River, FL 32629 P. F. McKee, Director Nuclear Plant Operations Florida Power Corporation P. O. Box 219-NA-2C Crystal River, FL 3?:*9 R. C. Widell, Director Nuclear Site Support Florida Power Corporation P. O. Box 219-NA-21 Crystal River, FL 32629 A. H. Stephens General Counsel Florida Power Corporation MAC - A5D P. O. Box 14042 St. Petersburg, FL 33733 cc w/ encl cont'd:
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t Florida Power Corporation MC011989 o
cc w/enci cont'd:
kY Attorney General Department of Legc1 Affairs c'
The Capitol Tallahassee.-FL 32304 Jacob Daniel Nash Office of Radiation Control
' Department of Health and Rehabilitetive Services 1317 Winewood Boulevard Tallahassee, FL 32399-0700 Administrator Department of Environinental Regulation Power Plant Siting Section State of Florida 2600 Blatr Stone Road Tallahassee, FL 32301 i
State Planning and Development Clearinghouse Office of Planning and Budgeting Executive Office of the Governor The Capitol Building c
-Tallahassee, FL 32301 Chairman Board of County Commissioners Citrus County 110 N. Apopka Avenue Iverness, FL 36250 Robert B. Borsum Babcock and Wilcox Company Nuclear Power Generation Division 1700 Rockville Pike, Suite 525 Rockville, MC 20852-1631 State of Florida 1
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HThompson. DEDS JMTaylor, DEDR JLieberir.an, OE
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SEbneter, RII JGoldberg, OGC TMurley, NRR JPartlow, NRR -
DRS Technical Assistant i
Enforcement Coordinators L
R1, RII, Rlli, RIV. RV Resident Inspector I
'FIngram,GPA/PA BHayes. 01 EJordan, AE00 MMalsch, OlG OE:ES OE:Chron OE:EA A
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State of Florida GJohnson, RM Document Control Desk NRC Resident Inspector U.S. Nuclear Regulatory Commission 15760 W. Power Line Street Crystal River, FL 32629 0
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