ML20210B689

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-302/86-20. Supplemental Response to Violation B Requested.Responses to Violations a & C Acceptable

ML20210B689
Person / Time
Site:	Crystal River
Issue date:	01/26/1987
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Wilgus W FLORIDA POWER CORP.
References
NUDOCS 8702090214
Download: ML20210B689 (5)

See also: IR 05000302/1986020

Text

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Docket No. 50-302

License No. DPR-72

FloridajowerCorporation

ATTN: vfir. W. S. Wilgus

Vice President Nuclear Operations

P. O. Be>: 14042, M.A.C. C-2-M

St. Petersburg, FL 33733

Gentlemen:

SUBJECT: NRC INSPECTION REPORT N0. 50-302/86-20

Thank you for your response of October 8,1986, to our Notice of Violation issued

on September 2, 1986, concerning activities conducted at your Crystal River

facility.

Your responses to Violation examples "a" and "c" have been found to be accept-

able. We will evaluate the implementation of your corrective actions during

future inspections.

After careful consideration of the basis for your denial of Violation example

"b," we have concluded, for the reasons given in the Enclosure to this _ letter,

that the violation occurred as stated in the Notice of Violation. Therefore, in

accordance with the requirements of 10 CFR 2.201, please submit to this office

within 30 days of the date of this letter, a written statement describing steps

which have been taken to correct Violation example "b" and the results achieved,

corrective actions which will be taken to avoid further violations, and the date

when full compliance will be achieved.

The responses directed by this letter and the enclosure are not subject to the

clearance procedures of the Office of Management and Budget issued under the

Paperwork Reduction Act of 1980, PL 96-511.

We appreciate your cooperation in this matter.

Sincerely,

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8702090214 870126 JL

ADOCK 05000302

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J. Nelson Grace

Regional Administrator

Enclosure:

Staff Assessment of Licensee Response

w/ encl:

. F. McKee, Director, Nuclear Plant

I. Operations

C. Widell, Manager, Nuclear

Operations, Licensing and Fuel

Management

bec w/ encl: (See page 2)

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ENCLOSURE

STAFF ASSESSMENT OF LICENSEE RESPONSE

INSPECTION REPORT 86-20

Restatement of Violation 86-20-01, Example b.

-Technical Specification 6.8.1 requires the implementation of written procedures

to -cover those activities recommended in Appendix A of Regulatory Guide 1.33,

November 1972 and the surveillance activities of safety-related equipment.

Regulatory Guide 1.33, Appendix A, recommends procedures and/or written instruc-

tions for: the conduct of a plant startup, cold to hot; the operation of the

emergency core cooling system; and performance of maintenance.

Administrative Instruction AI-600, Conduct of Maintenance, step 4.4.12, requires

that all non-emergency corrective maintenance on plant safety-related equipment

be authorized and documented by an approved Work Request (W/R).

Contrary to the above:

b. On April 8,1986, procedure AI-600 was not implemented in that corrective

maintenance, in the form of a valve packing adjustment, was performed on

valve IAV-90 prior to authorizing and. documenting this maintenance with an

approved W/R.

Summary of Licensee's Response

Florida Power Corporation (FPC) takes exception to example "b" for the following

reasons:

This violation is c: ed against plant procedure AI-600, Conduct of Maintenance

step 4.4.12 which states: "All non-emergency repairs of plant safety-rel'ated

equipment shall be authorized and documented by an approved Work Request in

accordance with CP-113, Handling and Controlling Work Requests and Work Packages.

These repairs shall be performed in accordance with written procedures and work

instructions, and the equipment / system restored to proper configuration for

system operability."

The adjustment of packing on manual valves is not viewed by FPC as a maintenance

repair to equipment but rather as a normally expected routine adjustment, which

is often performed by operations personnel.

It must be emphasized that operators are only allowed to adjust the packing of

manual valves that do not require any post maintenance testing, i.e., valve

stroking or stroke time testing. A review of FSAR (Section 1.7.1.3) and ANSI

N18.7-1976/ANS-3.2, could not reveal any conflict with current FPC practice.

Elimination of the ability of the operator to adjust packing immediately upon

.

., . . .

Enclosure 2 JAN 2 61987

,

discovery can result in increased personnel exposure, increased spread of

contamination and decreased valve / system availability due to resultant increase

in packing replacement. FPC has determined that there is no benefit sufficient

to justify documenting these minor adjustments. As a result of this alleged

violation, FPC has recognized the need to clarify AI-600 concerning FPC's

position on minor valve packing adjustments. .This change will be implemented by

October 31, 1986.

NRC Evaluation

The NRC staff has carefully reviewed the licensee's response and has

concluded that the licensee did not provice any information that was not

already considered in determining that the violation had occurred. The

licensee contends that adjustment of packing on manual valves is not viewed

as a maintenance repair to equipment but rather as a normally expected

routine adjustment, which is often performed by operations personnel.

Additionally the licensee determined that there is no benefit sufficient

to justify documenting these minor adjustments.

• The licensee's ge111ty program, as defined by FSAR Section 1.7, endorses

Regulatory Guide 1.33 and ANSI standard N18.7-1976/ANS 3.2, and states in

part, the quality program complies with the requirements of this guide with

the following clarifications, "Except in emergency or abnormal operating

situations where immediate actions are required to protect the health and

safety of the public, to protect equipment or personnel, or to prevent the

deterioration of plant conditions to a possibly unsafe or unstable level,

maintenance or modification of equipment shall be preplanned and performed

in accordance with approved written procedures. Where approved written

procedures would be required and are not used, the activities that were

accomplished shall be documented after-the-fact and receive the same degree

of review as if they had been preplanned."

ANSI N18.7-1976/ANS-3.2 states: - Section 2.2, Glossary of Terms, states

in part, Maintenance and modification procedures are written procedures

defining the policies and practices by which structures, mechanical,

electrical and instrumentation and control systems, and components thereof

of a nuclear power plant are kept in a condition of good repair or effici-

ency so that they are capable of performing their intended functions. As

used in this standard, these procedures apply to those activities performed

by maintenance or contractor personnel to maintain, repair or modify safety-

related equipment. . . Section 5.2.7, Maintenance and Modifications, states

in part, Means for assuring quality of maintenance and modification activities

(for example, inspections, measurements, tests, welding, heat treatment,

cleaning, nondestructive examination and worker qualifications in accordance

with applicable codes and standards) and measures to document the carformance

thereof shall be established. Additionally, Section 5.2.7.1, Maintenance

Programs, states in part, Planning for maintenance shall include evaluation

of the use of special processes, equipment and materials in performance of

the task, including assessment of potential hazards to personnel and equip-

ment. Additionally, the causes of malfunctions shall be promptly determined,

evaluated and recorded.

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Enclosure 3

The NRC views valve packing adjustments as maintaining and/or keeping

equipment in a condition of good repair and subject to the above require-

ments which include documentation and a written procedure or instruction.

Though the procedure may not require detailed step-by-step delineation, it

should ensure proper methods for packing adjustment and considor equipment

and personnel safety hazards.

NRC Conclusion

For the above reasons, the NRC staff believes that the violation occurred as

stated. The licensee is required by Technical Specification 6.8.1 to implement

written procedures to cover those activities recommended in Appendix A of

Regulatory Guide 1.33, November 1972. Administrative Instruction AI-600, Conduct

of Maintenance, implements the Technical Specification requirements. Addition-

ally, FPC's quality program endorses the requirements of Regulatory Guide 1.33

and ANSI standard N18.7-1976/ANS-3.2. The failure to implement these require-

ments for valve packing adjustments is a violation. ,

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