ML20128L721
| ML20128L721 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 06/21/1985 |
| From: | Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Wilgus W FLORIDA POWER CORP. |
| References | |
| NUDOCS 8507110432 | |
| Download: ML20128L721 (3) | |
See also: IR 05000302/1985007
Text
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JUN 211985
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:
REPORT NO. 50-302/85-07
Thank you for your response of May 7,1985, to our Notice of Violation issued on
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April 8, 1985, concerning activities conducted under NRC License No. DPR-72.
We have reviewed your response to the violation and have concluded, for the
reasons presented in the enclosure to this letter, that the violation occurred as
stated in the Notice of Violation.
Therefore, in accordance with the require-
ments of 10 CFR 2.201, please resubmit your response to the Notice within 30 days
of the date of this letter.
The response directed by this letter and the enclosure are not subject to the
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clearance procedures of the Office of Management and Budget issued under the
Paperwork Reduction Act of 1980. PL 96-511.
Should you have any questions concerning this letter, please contact us.
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Sincerely.
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Original signed by D. Vorrelli
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Roger D. Walker, Director
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Division of Reactor Projects
Enclosure:
Staff Evaluation of Licensee
Response
cc w/encI:
-E. M. Howard, Director
Site Nuclear Operations
vP. F. McKee, Nuclear Plant Manager
vG. R. Westafer, Manager
Nuclear Operations Licensing
and Fuel Management
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State of Florida
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ENCLOSURE
STAFF EVALUATION OF LICENSEE RESPONSE DATED MAY 7, 1985
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You make the following statement in your denial:
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Following an unplanned reactor trip, printouts of computer monitored data are
used to evaluate the cause of the reactor trip and the response of plant safety
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systems. The results of the evaluation are documented in " Restart After Reactor
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Protection System Actuation" which is Enclosure 16 of the Operations Section
Implementation Manual. AI-1100 does require that Enclosure 16 be collected,
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stored, and maintained as Quality Assurance Records. Therefore, FPC disagrees
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that printouts of the computer monitored data constitutes records of facility
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operation and as such are not required to be stored and maintained as Quality
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Assurance Records.
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For all reactor trips FPC has collected, stored, and maintained the computer
printouts but not as Quality Assurance Records.
FPC does agree that treating
these computer printouts as Quality Assurance Records would be beneficial.
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Accordingly, the computer printouts for recent (1983 and later) reactor trips
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have already been includej in our quality files.
FPC intends to treat future
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reactor trip computer printouts as Quality Assurance Records.
Our contention is that the printouts of your computer systems constitute records
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of facility operation, in that they are the essential source of information used
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to conduct a meaningful review and analysis of your plants transient response.
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As such, the p(rintouts constitute a record of facility operation under TechnicalTS
Specification
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five years.
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Section 1.7.1.17 of your Quality Program (QP) identifies records required to be
retained by TS as Quality Assurance Records.
However, Administrative Instruction
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(AI)-1100, which implements QP 1.7.1.17, omits any reference to TS required
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records as Quality Assurance Records.
Consequently, Al-1100 fails to fully
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implement the Quality Program.
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It is acknowledged that Enclosure 16 of the Operations Section implementation
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Manual, " Restart After Reactor Protection System Actuation," provides an evalua-
tion of the computer printouts and is retained as a Quality Assurance Record.
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However, a review of several Enclosure 16 evaluations revealed that this sumany
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provides only indirect testimnny of adequate plant response,
it is not a docu-
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ment which by itself, essists in comparing the transient event with known or
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expectedpIantbehavior.
It simply documents that supervisory personnel were
satisfied that the plant responded as designed.
Proof to this affect can only
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come from an analysis of the source documents; the computer printouts upon which
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Enclosure 16 is based.
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Enclosure
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In summary, we are satisfied that the required initial reviews and analyses of
the computer printouts have been performed by your staff prior to returning the
reactor to power operation.
However, the ability to independently assess the
transient hinges on the availability of the computer printouts.
Such an indepen-
dent assessment may be required subsequent to reactor startup either by your
safety review group or, as occurred during Inspection b5-07, by members of the
NRC staff.
To assure that the printouts will be a'.ailable for future use or
review, their custody must be remanded to your Recos is Management Department for
prntected storage, as required by Section 1.7.1.17 of the FPC Quality Program and
Since Administrative Instruction No. AI-1100 did not address the
above requirements, which resulted in data used in post trip review analysis not
being properly collected, stored, and maintained, constitutes the violation as
stated in the Notice of Violation.
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