ML20136E402

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Forwards Allegation Evaluation Rept Which Summarizes Review & Independent Insp of Failure to Adhere to Administrative Steps in Closure of Plant Action Requests When Licensee Rushed Corrective Action Program Change.W/O Insp Repts
ML20136E402
Person / Time
Site: Saint Lucie  NextEra Energy icon.png
Issue date: 09/14/1996
From: Landis K
NRC (Affiliation Not Assigned)
To: De Miranda O, Mcnulty W
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II), NRC OFFICE OF INVESTIGATIONS (OI)
Shared Package
ML17229A261 List: ... further results
References
FOIA-96-485 NUDOCS 9703130202
Download: ML20136E402 (4)
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UNfTED STATES

. [p miooq'o# NUCLEAR REGULATORY COMMISSION

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September 14. 1996 MEMORANDUM FOR: William J. McNulty. Director Office .of Investigations Field Office Oscar DeMiranda. Senior Allegation Coordinator.

Enforcement and Investigation Coordination Staff N[

FROM: Kerry D. Landis. Chief Reactor Projects Branch 3 Division of Reactor Projects (/

SUBJECT:

RII-96-A-0124 - FAILURE TO ADHERE TO ALL ADMINISTRATIVE STEPS IN CLOSURE PROCESS OF ST. LUCIE ACTION REQUESTS (STARS) WHEN LICENSEE RUSHED THEIR CORRECTIVE ACTION PROGRAM CHANGE.

The Division of Reactor Projects performed a review and independent inspection of tnis concern. Our inscection regarding this matter has been completed and our findings are' cocumented in the enclosures to .this memorandum. Enclosure 1 is the Allegation Evaluatjon Report which summarizes the findings, and the inspection results are documented in Enclosure 2. NRC Inspection Report Nos.

50-335/96-11. ana 50-389/96-11. paragraph 07.1.

Based on the information provided. we were able to substantiate the allegation. One non-cited violation was identified (NCV 335.389/96-11-02.

"Fa11ure to Obtain Originator's Concurrence During STAR Closecut").

This conclude's the staff's activities regarding this matter. This allegation is considered closed. If you have any questions, please contact me.

Enclosures:

1. Allegation Evaluation Report
2. Inspection Report Nos.

50 335/96-11 and 50-389/96-11 ,

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'i PDR FOIA BINDER 96-485 PDR g i

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& LEGATION EVALUA' TION REPORT ALLEGATION RII-96-A 0124 g FAILURE TO ADHERE TO ALL ADMINISTRATIVE STEPS IN CLOSURE PROCESS' 0F ST. LUCIE ACTION REQUESTS (STARS) WHEN LICENSEE RUS!!EO THEIR ,

CORRECTIVE ACTION PROGRAM CHANGC.

FLORIDA POWER AND LIGHT ST LUCIE NUCLEAR PLANT DOCKET NOS. 50 335 AND 50-389  !

CONCERN: .The confidential source provided the following concern:  ;

FAILURE TO ADHERE TO ALL ADMINISTRATIVE STEPS IN CLOSURE PROCESS OF ST.. l LUCIE ACTION REQUESTS (STARS) WHEN LICENSEE RUSHED THEIR CORRECTIVE'

' ACTION PROGRAM CHANGE. FOR EXAMPLE. PERSONNEL DID NOT OBTAIN APPROVAL 0F.THE ORIGINATOR PRIOR TO CLOSURE OF STAR DOCUMENT. ,

DISCUSSION: Our.inso'ection regarding this matter has been' completed and our +

findings are documented in NRC Inspection Report Nos. 50-335/96-11. and 50-389/96-11. paragraph 07.1. as follows:

-07.1 OA Audit Reoort Concernino The STAR /PMAI Conversion Process (40500)  ;

a. Scope f-

. In April. the Condition Report (CR) process superseded the existing St.

Lucie Action Request (STAR) process for documenting adverse conditions.

The licensee's goal was to have a uniform Nuclear Division Condition ,

Report process to document evaluate. track, and correct conditions of concern to site personnel. During the period 'of transition from STARS

. to CRs the licensee used the newly developed Plant Manager's Action Item -

. (PMAI) tracking system to document any outstanding actions associated with STARS.1This tracking system was implemented in January and was  ;

designed to track action items on a plant wide basis. -During this inspection period the inspector reviewed 0A audit report 96-05. which  ;

evaluated this conversion process. *

'b. . Findings In general, the audit found that STARS whose actions had been completed

were simply closed. For STARS'containing outstanding actions. PMAI's

.were: initiated to track those actions and then the STAR was closed. The . .

audit identified three- findings. The first finding stated that the PMAI procedure lacked adequate guidance and'was impi.emented without first ,

,providing training for the affected_ personnel. The licensee stated that the procedure was being successfully used at Turkey-Point and was--simply i implemented without considering the impact it would have on personnel at. '

St. Lucie who had no. working knowledge of the_ process. The inspector reviewed;AP 0006129. revision 1. "PMAI C,orrective Action Tracking i

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Program." and noted that, since the finding, the procedure had been revised to clarify points of confusion.

The second finding identified that the Corrective Actions department was '

. ~c10$10cf STAR $'without'first receiving concurrence from the initiating department when required. The Corrective Actions department head i admitted that this had occurred but stated that an independent review  :

was substituted for the originator's concurrence, which was the method used by the new CR process. He stated that he had submitted a procedure revision requesting that this requirement be deleted. However, the procedure revision was not approved by OA and the Corrective Actions group was not made aware that the revision had been denied. As a result. the originator's concurrence was not obtained in all cases as required by OI 16-PR/PSL-2. Rev. 4. "St. Lucie Action Report (STAR)

Program." step 5.6.1.B. The licensee's corrective action included discussing procedural compliance requirements with the involved individuals. In addition. the Corrective Action group has been put on distribution for the procedures they normally use. The inspector concluded that the licensee s failure to obtain the originator's signature constituted a violation of the licensee's procedure. However, the inspector noted that the issue was administrative in error. appeared -

. to be limited in scope and impact, and did not impact the actual disposition of the issues described in the affected STARS. Therefore.

this licensee identified and corrected violation is being treated as a Non-Cited Violation. consistent with Sectidn VII.B.1 of the NRC Enforcement Policy (NCV 335.389/96-11-02. " Failure to Obtain Originator's Concurrence During STAR Closeout"). -

The inspector reviewed approximately seventy-five STARS which had been converted to the CR/PMAI process and noted the same deficiency identifi'ed by OA. In addition the' inspector noted several STARS for which final approval by the Plant General Manager (PGM) was provided by someone other than the PGM. STARS 960355. 940428. and 960459 were identified as requiring PGM approval prior to being closed: however, the PGM blank was signed by a member of the Corrective Actions. group not having PGM signature authority. The STARS were closed with the outstanding actions being transferred to the PMAI process. In addition the inspector noted that the majority of the STARS which didn't require '

PGM concurrence had been signed by someone without his authority. The Corrective Actions group head stated that this was not an attempt to i circumvent PGM concurrence, but rather to simply' transfer documentation and closecut to the new process. It would appear that the unauthorized  !

signatures.were simply a result of closing out a large quantity of ,

documents over a short period of time. Although not a violation of i procedural requirements the inspectors felt this action was not prudent.

- This issue was discussed with t1e PGM who stated that it did not meet his expectations either. He stated that he would discuss this with the personnel involved. The inspectors considered this course of action to-  !

be appropriate. .

. The third finding noted that near term corrective actio.ns' associated with three STARS had the due dates extended when converted to PMAls.

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The issues surrounding the three STARS were evaluated and dispositioned upon identification. Additionally, in response to this finding. the affected group reviewed approximately 20% of the nonconforming STARS for closeout adequacy and found no discrepancies.

c. Conclusion The inspector concluded that the OA audit was thorough and contained findings of substance. The responses to the findings by the affected organizations adequately addressed the concerns. One poor practice with regard to the delegation of signature authority was identified.

CONCLUSION:

The inspector concluded that the licensee's failure to obtain the originator's signature constituted a violation of the licensee's prpcedure. However, the inspector noted that the issue was administrative in error, appeared to be limited in scope and impact. and did not impact the actual disposition of the issues descr1 bed in the affected STARS. Therefore, this licensee identified and corrected violation is being treated as a Non-Cited Violation, consistent with Section VII.B 1 of the NRC Enforcement Policy (NCV 335.389/96-11-02. ,

" Failure to Obtain Originator's Concurrence During STAR Closeout"). The l inspector concluded that the OA audit was thorough and contained findings of substance. One poor practice with regard to the delegation of signature authority was identified.  !

l This allegation was substantiated. One non-cited violation was identified.

The responses to the licensee's OA audit findings by the affected organizations adequately addressed the concerns.

This allegation is considered closed.

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