ML20071L251
| ML20071L251 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 03/11/1983 |
| From: | Westafer G FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20071L235 | List: |
| References | |
| 3F-0383-16, 3F-383-16, NUDOCS 8305270503 | |
| Download: ML20071L251 (4) | |
Text
.
$%S3NN9 v u' men o
v. 419 ASsi#
d3 tus 15 Aie 1j Fkwida Power C 0 A P o n a T e o se March 11,1983
- 3F-0383-16 Mr. 3. P. O'Reilly Regional Administrator, Region 11 U. S. Nuclear Regulatory Commission Office of Inspection & Enforcement 101 Marietta Street N.W., Suite 2900 Atlanta, GA 30303
SUBJECT:
Crystal River Unit 3 Docket No. 50-392 Operating Licer.se No, DPR-72 IE Inspection Report No. 82-29
Dear Mr. O'Reilly:
Enclosed is Ficrida Power Corpot ation's response to Ir+pection Report 82-29 datad February 10,1933.
Cancerning your request that Florida Power Corporation describe actions taken or plannen to improve the effectiveness of our management control systems, we consider the present management control systems to be effective. The prompt report follow-up letter, dated
~
December 23, 1982, indicated that there were no apparent generic implications concerning our management control systems. Thus we do not anticipate any changes to these systems as a result of this Inspection Report.
Sincerely,
/
G. R. Westafe Manager Nuclear Licensing and Fuel Management PGH/ caw Enclosure cc:
Document Control Desk U. S. Nuclear Regulatory Commission Washington, D. C. 20555 8305270503 830413 DR ADOCK 05000302 PDR G
Office 3201 in.rty-fourin street south. P O Box 14042, st. Petersburg. Florida 33733 813-866-5151
FLORIDA POWER CORPORATION RESPONSE INSPECTION REPORT 82-29 February 10,1983 A. VIOLATION Technical Specifications 4.3.2.1.1 requires a channel functional test of the Engineered Safety Feature Actuation System (ESFAS) instrumentation channels listed in Table 4.3-2. Table 4.3-2, items 5.a and 5.d, require a monthly channel functional test of the manual initiation of the Reactor Building Isolation function of ESFAS.
Contrary to the above, during the period from January 28,1977 (initial plant licensing) until December 12, 1982, portions of the manual initiation portion of the Reactor Building Isolation function of ESFAS, had not been tested.
This is a Severity level IV Violation. Related cited violations which address the area of failure to perform required surveillance testing are identified in NRC Inspection Raports 50-302/31-19,81-23, and 32-05.
& RESPONSE Florida Power Corporation agrees that until December 12, 1982, portions of the manaal initiaticn portion (f the Reactor Building Isolation function of ESFAS, had not beea performed (as was reilected in the Florida Power Corporation prompt report dated December 12, 1982).
Ficrida Power Corp? rat?on, however, considers this a licensee identified finding for the followm reasons and in accordance with the published Enforcement Policy (47 I-R M87) u nsiders tssuance cf this as a v'clation laappropriate:
(1)
This surveilluace testing deficiency was identified by Florida Power Corporation as a resuit of a detailed review of our Licensing basis with regard to Engineered Safeguards testing.
Based on this review, a prompt report was filed on December 13,1982.
(2)
This is a Severity Level IV incident.
(3)
A prompt report was filed on December 13, 1982, identifying this surveillance inadequacy. In addition, an Executive Summary, dated December 23,1982, was submitted as a detailed follow-up to the prompt report.
(4)
Corrective actions will be concluded within a reasonable period of time.
The deficiency identified in Quality Programs Surveillance Report (QPSR) 82-VAH-04 and by TERA Corporation, dated October 6,1982, did not address the technical adequacy of the surveillance requirement. Rather, these reports were questioning whether a procedure for each surveillance requirement existed for the purpose of developing a Licensing Commitment data base. Discussions with the personnel associated therewith (Florida Power Corporation and TERA) reconfirmed that they had neither looked for nor noted any technical inadequacies. Procedures which were heretofore considered adequate were, in fact, in place.
(5)
This could not have been prevented by corrective actions for a previous violation.
a Previous violations which address a failure to perform required surveillance testing are identified in Inspection Reports 81-19,81-23, and 82-05.
81-19 addressed the adequacy of the surveillance procedure to perform the Reactor Building pressure channel monthly functional test including the injection of a simulated pressure signal at the pressure switches. The corrective action was to revise the procedure to induce a simulated pressure signal.
81-23 states that the procedure used to calibrate the RCS outlet temperature did not encompass the sensor channel. The corrective action was to revise the procedure to include the sensor.
82-05 addressed the failure to conduct leak rate testing on specific containment isolation valves. This violation occurred because a change to the Technical Specifications was made without the review of the discipline engineers or supervisors, thus procedures were not revised reflecting the change.
The corrective action was to revise the review cycle of Technical Specifications Changes to include the discipline engineers and supervisera.
In the first two violations, the events concerned only the testing of the sensor.
The subject inadequacy does not address testing the sensors. Thus the corrective actions for these two violations could not have prevented this deficiency.
Finally, IE Report 82-05 only addressed the subject procedure revision with regard to a Technical Specification Change. The subject deficiency did not occur because a procedure revision was overlooked following a Technical Specification Change. Thus, the corrective action for IR 82-05 could not prevent this deficiency.
B. VIOLATION Technical Specification 6.8.1 requires adherence to written procedures required by Appendix A of Regulatory Guide 1.33, November,1972. Appendix A of Regulatory Guide 1.33 requires a procedure for log entries. Administrative Instruction Al-500, Conduct of Operations, requires, in paragraph 2.1.6, that each operations shift comply l
with log entry practices detailed in the Operations Section Implementation Manual l
(OSIM).
l OSIM Section III.E.3 requires that the Shift Supervisor's Log include all Technical I
Specification Action Statements that were entered and/or exited during a shift.
Contrary to the above, during the period of 9:15 a.m. through 8:45 p.m. on December 7, Technical Specification 3.1.2.1 Action Statement was entered and exited i
I and no log entry was made to signify this event.
This is a Severity Level V Violation.
i B. RESPONSE Florida Power Corporation does not concur with this violation, as stated.
The Operations Section Implementation Manual (OSIM) does require that entrance and exit of Action Statements be logged in the Shift Supervisor's Log. It also states, in l
part, "The log need not repeat routine items which have no safety significance or little operational importance."
2 l
J
The Nuclear Shift Supervisor concluded that since it was not possible to perform core alterations or significant positive reactivity changes, entry into the 3.1.2.1 Action Statement had no safety significance and little operational importance. Florida Power
- Corporation agrees with this interpretation and does not consider this event a violation.
Furthermore, FPC does not consider the requirements of the OSIM to be regulatory commitments subject to audit (by our Quality Programs Department) or enforcement (by NRC). The items in OSIM represent administrative and other requirements which exceed regulatory requirements.
Those items, involving Conduct of Operations, necessary to meet such commitments / requirements are detailed in Al-500 itself.
Additionally, it should be noted that the Shift Supervisor's Log is a redundant log to other operational logs. In this case, the Equipment Out-of-Service Log indicated that the equipment required by Specification 3.1.2.1 was out-of-service. Thus Operations personnel were aware that required equipment was inoperable. Because the Equipment Out-Of-Service Log is reviewed during shift turnover, there was little possibility that any oncoming shift would fail to note the entry into the Action Statement. This requirement is considered sufficient to meet requirement 2.2.1.c, " Shift and Relief Turnover Procedures", contained in NUREG-0578 and elsewhere.
To prevent any further interpretation conflicts between your staff and Florida Power Corporation, all Nuclear Shift Supervisors have been instructed to log Action Statements even if it appears that they may not apply, i.
I 3
l J