ML20137T031

Notice of Violation from Insp on 970112-0222.Violations Noted:Licensee Failed to Prescribe Quality Related Clearance Tagging Activities Into Appropriate Procedure That Compliance Procedure 115 Nuclear Plant Tags

ML20137T031
Person / Time
Site:	Crystal River
Issue date:	03/24/1997
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20137S969	List: ML20137S964 ML20137T031 ML20137T046
References
50-302-97-01, 50-302-97-1, NUDOCS 9704150297
Download: ML20137T031 (3)

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NOTICE OF VIOLATION Florida Power CorporationDocket No. 50-302 Crystal River Unit 3 License No. DPR-72 Coring NRC inspections conducted on January 12 through February 22. 1997.

violations of NRC requirements were identified. In accordance with the

" General Statement of Policy and Procedure for NRC Enforcement Actions." NUREG 1600, the violations are listed below:

A. 10 CFR Part 50. Appendix B. Criterion V. Instruction. Procedures and Drawings requires in part, that activities affecting quality shall be prescribed by documented procedures of a type appropriate to the circumstances.

Contrary to the above, as of February 6. 1997, the licensee failed to prescribe quality related clearance tagging activities into an appropriate procedure in that Compliance Procedure 115. Nuclear Plant Tags and Tagging Orders. Revision 73 was inadequate because it did not require local tagging of valves or components and gagging of air-operated valves for red tag clearances. This inadequacy resulted in a valve being repositioned while under a red tag clearance.

This is a Severity Level IV Violation (Supplement 1).

B. Technical Specification 5.6.1.1 requires, in part, that procedures be implemented covering activities as recommended in Regulatory Guide 1.33.

Appendix A. Revision 2. dated February 1978. Appendix A recommends administrative procedures to cover the authorities and responsibilities for safe o)eration and shutdown, procedure adherence and temporary change metlod. The licensee implemented the above Appendix A recommendations. in part, through Procedure AI-500. Conduct of Operations and 01-09. Operations Procedures. 01-09 requires that activities will be performed in accordance with approved instructions.

The licensee's modification functional test procedure. Modification i Approval Record 96-10-05-01. Test Procedure-1. Attachment A. states that after the emergency diesel engine has been stopped for at least 15 ,

minutes, but not more than 20 minutes, steps 4.6.30 through 4.6.34 l should be performed. Step 4.6.30 tri)s the fuel racks, which should  ;

prevent an inadvertent diesel start w1ile rolling it with air. '

Contrary to the above, on February 1. 1997, a non-licensed plant operator failed to follow instructions contained in licensee procedure Modification Ap3roval Record 96-10-05-01. Test Procedure-1. Attachment A for restoring t1e emergency diesel generator EDG-1A following the functional test. Specifically, several steps, including 4.6.30, were not completed as required, resulting in an unplanned start of the emergency diesel generator.

This is a Severity Level IV Violation (Supplement 1). >

C. Technical Specification Surveillance Requirement 3.7.13.1 requires that the licensee verify the fuel storage pool water level is 2156 foot plant 9704150297 970324 PDR ADOCK 050003o2 G PDR

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datum once per.7 days during movement of irradiated fuel assemblies in ]

the fuel storage pool. '

Contrary to the above. between August 1994 and November 1996, on five .

occasions during irradiated fuel movement, the licensee failed to  :

perform a valid surveillance test, in that instruments. SF-1-LT1 and SF- ,

1-LT2, used to verify fuel storage pool water level, were not within -l their allowable calibration intervals. Subsequent calibrations revealed ,

that SF-1-LT1 was outside the acceptance criterion and could not be  !

calibrated within it, and SF-1-LT2 was found with a significant zero offset, but was able to be calibrated within acceptance criteria. 1

. This is a Severity Level IV Violation (Supplement 1).

D. 10 CFR 50. Ap)endix B. Criterion III. Design Control. requires measures that assure tlat the applicable regulatory requirements and design basis for-safety-related components are correctly translated into specifications, drawings, procedures, and instructions. When this translation is accomplished through calculations, the measures must  ;

assure ihat the assumptions and data used in performing the calculations  ;

are justpied and correct.

1- Contrary to the above, as of February 22. 1997, the licensee's measures  :

did not assure that the applicable regulatory requirements and design i basis for safety-related components would be correctly translated into j specifications; drawings, procedures. and instructions. The design assumptions for Auxiliary Building temperatures used in the r Environmental and Seismic Qualification Program Manual (ESOPM) and in ,

instrument loop uncertainty setpoint calculations were not properly >

translated into procedures for calibration of the instruments, the  ;

Engineering Design Basis Document or the Final Safety Analysis Report.  !

Additionally, there were no 3rocedures for ensuring that the Auxiliary '

Building temperatures would ]e maintained within the ranges assumed by the ESOPM and the instrument setpoint loop uncertainty calculations.

This is a Severity Level IV violation (Supplement 1).  !

E. 10 CFR 50. Appendix B. Criterion XVI recuires that measures shall be  !

established to assure that conditions acverse to quality such as  !

deficiencies and nonconformances are promptly identified and corrected. ,

This requirement is implemented by Florida Power Corporation Oe311ty i Program Section 1.7.1.16. Corrective Action.  :

Contrary to the above. since December 1993, deficiencies and j nonconformances were identified in safety related cables but were not  !

corrected. Calculation E91-0020 identified deficiencies or  !

nonconformances with safety-related cables MTL-117. AHC-656 and MTL-67 l

~but as of February 14. 1997. they had not been corrected. l This is a Severity Level IV violation (Supplement 1). l l

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3 l Pursuant to the provisions of 10 CFR 2.201. Florida Power Corporation is  :

hereby required to submit a written statement or explanation to the U.S. .

Nuclear Regulatory Commission. ATTN: Document Control Desk. Washington. DC l 20555, with a copy to the Regional Administrator. Region II and a copy to the NRC Resident Inspector, at the Crystal River facility, within 30 days of the l date of the letter transmitting this Notice of Violation (Notice). This reply  ;

should be clearly marked as a " Reply to a Notice of Violation" and should include for each violation: (1) the reason for the violation or, if  ;

contested, the basis for disputing the violation. (2) the corrective steps i that have been taken and the results achieved. (3) the corrective steps that  !

will be taken to avoid further violations, and (4) the date when full i com)liance will be achieved. Your response may reference or include 3revious i docceted corn spondence. if the correspondence adequately addresses tie required response. If an adequate reply is not received within the time  :

specified in this Notice, an order or demand for information may be issued as  :

to why the license should not be modified. sus) ended, or revoked, or why such other action as may be proper should not be ta(en. Where good cause is shown.  ;

consideration will be given to extending the response time.

Because your res)onse will be placed in the NRC Public Document Room (PDR) to '

the extent possi)le, it should not include any personal privacy 3roprietary.

or safeguards information so that it can be placed in the PDR wit 1out i redaction. If personal privacy or proprietary information-is necessary to  !

provide an acceptable response, then please provide a bracketed copy of your >

response that identifies the information that should be protected and a redacted copy of your response that deletes such information. If you request withholding of such material, you must s)ecifically identify the portions of j your response that you seek to have withield and provide in detail the bases for your claim of withholding (e.g., explain why the disclosure of information will create an unwarranted invasion of personal privacy or provide the information required by 10 CFR 2.790(b) to support a request for withholding confidential commercial or financial information). If safeguards information is necessary to provide an acceptable response, please provide the level of protection described in 10 CFR 73.21.

Dated at Atlanta, Georgia this 24thday of March 1997