ML20070N270

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Responds to NRC Re Violations Noted in IE Insp Rept 50-302/82-24.Corrective Actions:Personnel Instructed to Verify That Consumable Working Copy Procedure Current Before Using
ML20070N270
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 12/22/1982
From: Baynard P
FLORIDA POWER CORP.
To: James O'Reilly
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML20070N250 List:
References
NUDOCS 8301250457
Download: ML20070N270 (2)


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December 22,1982

  1. 3F-1282-21 Mr. 3. P. O'Reilly Regional Administrator, Region II U. S. Nuclear Regulatory Commission Office of Inspection & Enforcement 101 Marietta Street, Suite 3100 Atlanta, Ga. 30303

SUBJECT:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 IE Inspection Report No. o2-24

Dear Mr. O'Reilly:

Please find enclosed Florida Power Corporation's response to Ir.spection Report 82-24, dated November 22,1982.

Very truly yours, 0AjyDAck Afy br. P. Y. Baynard Assistant to Vice President Nuclear Operations PGH/ mig Enclosure l

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Document Control Desk U. S. Nuclear Regulatory Commission Washington, D. C. 20555 8301250457 830105 gDRADOCK 05000302 PDR General Office 32o1 Thirty-fourth Street South a P O Box 14042. St Petersburg. Fionda 33733 e 813-866-5151

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t INSPECTION REPORT 82-24 VIOLATION Technical Specification 6.8.1 requires the use of current written procedures covering the activities listed in Appendix A of Regulatory Guide 1.33, November,1972.

Regulatory Guide 1.33 requires a preventative maintenance schedule for equipment lubrication; and procedure PM-133, Equipment Lubrication Procedure, Revision 8, provides such a schedule.

Contrary to the above, at approximately 1500 on October 6,1982, an outdated revision of PM-133 (Revision 4) was used to add oil to the "B" Makeup Pump.

This is a Severity Level V Violation (Supplement I).

RESPONSE

(1)

FLORIDA POWER CORPORATION'S POSITION: Florida Power Corporation agrees with the violation. While performing surveillance on the Make-up Pumps, an outdated reference procedure was used to verify that the correct oil was added to Make-up Pump B.

(2)

DESIGNATION OF APPARENT CAUSE: This violation was caused by personnel error coupled with inadequate administrative controls dealing with the issuance of updated procedures.

Prior to October 6,1982, only select locations received controlled procedures. When a copy of a procedure was needed in an area other than one of the select locations, the procedure was checked out as a consumable working copy using a procedure log. When a procedure was revised, the approved revision was sent to those select locations.

Consumable working copies that had been checked out within the past thirty days (of the revision date) were also sent the appropriate revision.

In this case, the procedure, PM-133, was inappropriately being used as a permanent reference copy and, as such, had been checked out for more than thirty days. Thus, PM-133 was not updated as it should have been.

t (3)

IMMEDIATE CORRECTIVE ACTIONS: Personnel were instructed to verify that, prior to using a consumable working copy of a procedure, the procedure is current.

l On November 1,1982, the distribution list for permanent working copies was increased to include all areas that previously had used consumable working copies as reference i

l copies.

(4)

LONG TERM CORRECTIVE ACTIONS: Florida Power Corporation has determined that the immediate corrective actions are adequate.

(5)

DATE OF FULL COMPLIANCE: On November 1,1982, Florida Power Corporation was in full compliance.

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