ML20024F686
| ML20024F686 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 08/18/1983 |
| From: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Wilgus W FLORIDA POWER CORP. |
| References | |
| NUDOCS 8309090577 | |
| Download: ML20024F686 (2) | |
See also: IR 05000302/1982029
Text
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AUG 181983
Florida Power Corporation
ATTN: Mr. W. S. Wilgus
Vice President Nuclear Operations
P. O. Box 14042, M.A.C. H-2
St. Petersburg, FL 33733
Gentlemen:
SUBJECT:
INSPECTION REPORT N0. 50-302/82-29
This refers to your letter dated March 11, 1983, in response to a Notice of
Violation sent to you by our letter dated February 11, 1983.
In our letter of
April 13, 1983, we acknowledged receipt of your response and informed you that we
are evaluating the response for acceptability. We have evaluated your response
and do not agree with you that the issuance of these violations is inappropriate.
With regard to Violation A, we do not agree that this violation be classified as
licensee identified and that a citation is not appropriate. As stated in the details
of NRC Report 82-29, the deficiency was first identified by your own Quality Programs
audit on April 9,1982. On April 15, 1982, your technical staff issued and the Plant
Review Committee (PRC) approved a change to procedure SP-355 which added Technical Specification (TS) 4.3.2.1.1(5.a) and (5.d) to section 1.2.
This change demonstrated
that the staff and the PRC had performed a review and had presumed that these TS
requirements were being accomplished while in fact they had not been accomplished.
When, on October 6, the TERA Corporation made a similar finding that TS requirements
4.3.2.1.1(5.a) and (5.d) were not covered by SP-355, the staff responded that these
requirements were addressed by procedure sections 1.1 and 1.2.
It appears that the staff had sufficient notification that a deficiency existed
and that the staff did not perform an adequate technical review when the proce-
dure change was made on April 15.
Your response that the corrective actions for the previous two violations
(Reports 81-19 and 81-23) could not have prevented this deficiency is not
correct. These reports identified inadequate testing of TS mandated surveillance
requirements. Your failure to identify the root cause of these violations (i.e.,
an inadequate review of all TS surveillance requirements) has resulted in this
violation. We believe that to prevent further violations of this type an
ambitious review of the technical adequacy of all your surveillance procedures as
they relate to TS surveillance requirements will have to be undertaken.
We, therefore, conclude the issuance of a citation for Violation A is
appropriate since enforcement policy does not permit credit for self identified
noncompliances when the corrective action is inadequate to prevent recurrence.
With regard to Violation B, we do not concur with your response to this viola-
tion. You stated that the Operations Section Implementation Manual (OSIM) does
not require logging of " repeat routine items which have no safety significance or
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AUG 181983
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little' operational importance." While we do not disagree with the intent of
this statement, we cannot agree that entry into a Technical Specification (TS)
action statement is a " routine" event that has "no safety significance." Entry
into TS action statements are significant safety events which must be logged to
insure that members of that shift and subsequent shifts are aware of plant
status.
You further stated "that the Shift Supervisors Log is a redundant log to other
operational logs" and that the Equipment Out-of-Service (EOS) Log indicated that
the equipment required by Specification 3.1.2.1 was out-of-service." While the
(EOS) log did indicate that both BAST's were out of service, the log did not
indicate that valves DHV-34 and DHV-35 were isolated nor that the BWST was out of
service, therefore this log, by itself, would not have alerted operators to the
fact that they were in an Action Statement.
We do not agree with your position that the OSIM is not subject to audit.
Regulatory Guide 1.33 requires an administrative procedure that delineates log
entry practice. Your procedure AI-500 makes the following statement regarding
log entries:
"Two logs are to be kept:
the Shift Supervisors' Log, a narrative
log of significant plant events; and the Operators' log, a chronological account
of plant manipulations." This statement, by itself, provides insufficient
direction for making log entries.
Your procedure then goes on to say "Each shift
will comply with log entry and review practices detailed in the OSIM." Since the
OSIM becomes the Ocument that provides the necessary direction for making log
entries, it is considered to be an auditable and enforceable document under the
regulations.
Your letter of February 10, 1983 does not provide the information required by
10 CFR 2.201. Accordingly, please submit a written response to this office
within 20 days of your receipt of this letter which provides the information
required by 10 CFR 2.201.
Should you have any questions concerning this letter, we will be glad to discuss
them with you.
Sincerely,
James P. O'Reilly
Regional Administrator
CC:
G. R. Westafer, Manager
Nuclear Licensing and
Fuel Management
E. M. Howard, Director,
Site Nuclear _ Operations
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