ML20078N014
| ML20078N014 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/09/1983 |
| From: | Westafer G FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20078M941 | List: |
| References | |
| 3F-0983-09, 3F-983-9, NUDOCS 8310250374 | |
| Download: ML20078N014 (4) | |
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83 SEP 13 A9: 05 Fkuida Power C C R 8 0 R A T e 0 as September 9,1983 3F-0983-09 Mr. James P. O'Reilly Regional Administrator, Region II Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlant.1, GA 30303
Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 IE inspection Report No. 82-29
Dear Mr. O'Reilly:
Enclosed is Florida Power Corporation's (FPC's) Supplemental response to Inspection Report 82-29 dated February 10,1983.
Concerning Violation A, FPC is providing an explanation that leads us to conclude that no corrective actions need be planned. A supplemental response to Violation B is also enclosed.
Sincerely, A
G. R. Westafer Manager Nuclear Operations Licensing and Fuel Management Attachment AND/feb xc:
Document Control Desk U.S. Nuclear Regulatory Commission Washington, D.C. 20555 8310250374 831013 PDR ADOCK 05000302 O
PDR General Office 3201 Thirty-fourtn street soutn. P O. Box 14042. St. Petersburg FWda 33733 813-866 5151 l
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FLORIDA POWER CORPORATION SUPPLEMENTAL RESPONSE INSPECTION REPORT 82-29 September 9,1983 A.
VIOLATION TechnMal Specifications 4.3.2.1.1 requires a channel functional test of the Engineered Safety Feature Actuation System (ESFAS) instrumentation channels listed in Table l'.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 lice:. sing) 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 Reports 50-302/81-19,81-23, and 32-05.
A.
RESPONSE
Florida Power Corporation (FPC) maintains our position with regard to this item which we identified in our follow-up to a prompt report dated December 13, 1982.
Your answer to our initial response seems to be based on a misunderstanding of a Quality Programs Surveillance report dated April 9,1982. That report was part of an extensive effort in which we had just begun to develop a computerized data base cross referencing regulatory requirements with implementing procedures.
The method used to develop the data base was to allow a contractor (TERA) to develop a first cut of requirements and implementing documents. Any mismatches in these two data sets were called " variances".
This term was intentionally chosen to distinguish it from non-conformances. The Technical Specification portion of this effort ideatified 26 " variances", one of which is the subject of this discussion.
Quality Programs and the Plant Staff viewed this program's development with differing priorities. Thus, as a mechanism to upgrade the priority, Quality Programs issued QPSR 82-VAH-04 on April 9,1982. It did not indicate thet any of these items were, in fact, non-conformances.
If it had, it would have required a written response in 30 days, meeting our Quality Program requirements for such responses.
It simply requested the plant to respond as to when they would be able to resolve the data base variances. On May 2,1982, the Manager of Site QA closed the QPSR with the following comments (reprinted in their entirety):
The subject QPSR was written to encourage more timely investigation of potential Technical Specifications implementation deficiencies. Investigation of the items referenced in the report has been completed and the plant has determined that compliance to the identified requirements has never been compromised. Some administrative measures (procedure revisions) are being in.plemented to specify where the requirements are being satisfied, but follow-up of these measures is beyond the scope of the report and will be pursued in routine Program Control System activities.
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The investigation conducted by the Plant is considered adequate to resolve the concerns documented by the repart. No further action is required.
- As can be seen, both Nuclear Operations and Quality Programs were satisfied that the items were covered and that only a " paperwork" hole had been identified and closed.
As you noted, a procedure change to Sections 1.1 and 1.2 of the ESFAS procedure resulted from this review. This portion of our procedure (s) is reserved for cross-referencing. No technical requirements is contained therein. Thus, the PRC review of the change was " housekeeping"in nature.
The bottom-line is that both FPC and the NRC would have hoped that such deficietcies would have been identified during QPD audits, routine procedure reviews or, more importantly, during their development. However, as discussed in great detail in our prompt report follow-up, there existed considerable differences of opinion on what IEEE-279, Technical Specifications, and other requirements meant in this area. In December of 1982, FPC began firmly establishing a position on IEEE-279, et al, and discovered that Standard Technical Specifications, as modified for CR-3, were not. based on an ESFAS design similar to our own. This l
problem was promptly reported ~ and has been aggressively pursued since its identification.
FPC considers ' it quite possible that any two organizations with staffs of professional people will, on occasion, come to differing interpretations _ of highly technical requirements. In fact, our efforts to develop a complex data base tracing all requirements to their implementing document (s) is indicative of a very positive management commitment in this area. Nevertheless, as noted in our December letter, we had begun "several months ago" the action you requested in your letter of August 18,.1983, i.e., "an ambitious review of the technical adequacy of all surveillance procedures".
You also.noted that corrective actions on previously identified violations could have prevented this -violation and, thus, this was a recurrent problem. FPC does not l'
. agree. The root cause of each of these violations differs substantially, and your generalization (inadequate review of all TS surveillance requirements) was not mentioned in your notices of violation or our response (s). The root cause of the violation in IR 81-19 was the definition of analog versus bistable channels, not any oversight of Technical Specification requirements. The root cause of the violation in IR 81-23 was the technically defensable position that RTD's do not drift and were, therefore, allocated an assumed error versus a measured one. Again, no oversight was involved.
B.
VIOLATION Technical Specifiction 6.8.1 requires adherence to written procedures required by
' Appendix A of Regulatory Guide 1.33, November,1972. Appendix A of Regulatory
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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 J
comply with log entry practices detailed in the Operations Section Implementation Manual (OSIM).
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'e OSIM Section Ill.E.3 requires that the Shift Supervisor's Log include all Technical Specification Action Statements that were entered and/cr 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 and no log entry was made to signify this event.
This is a Severity Level V Violation.
B.
RESPONSE
(1) ~
FPC Position:.FPC concurs that failure to note in Shift Supervisor's log the entry into an action statement violated the Operations Section Implementation Manual (OSIM) which implements AI-500.
(2)
Designation of Apparent Cause:
As noted in our previous response, the position expressed above was not that held by FPC heretofore. Personnel, in accordance with other OSIM requirements, concluded that such log r otation was of no safety significance considering current ' plant conditions.
(3) - Immediate Corrective Actions: As noted in our previous response, personnel have been instructed to record all entries inte action statements regardless of plant conditions.
(4)
Long Term Corrective Actions:
The immediate correction actions are considered adequate to prevent recurrence.
(5)
Date of Full Compliance: October 1,1983.
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