3F0287-21, Ro:On 870112,6-month Interval for Containment Air Lock Type B Tests Found Exceeded Due to Inconsistencies Between Tech Specs & App J.Caused by Failure to Recognize Dual Sources of Requirements.Test Schedule Revised & Tech Spec Changed

Ro:On 870112,6-month Interval for Containment Air Lock Type B Tests Found Exceeded Due to Inconsistencies Between Tech Specs & App J.Caused by Failure to Recognize Dual Sources of Requirements.Test Schedule Revised & Tech Spec Changed

ML20211Q057
Person / Time
Site:	Crystal River
Issue date:	02/23/1987
From:	Eric Simpson FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F0287-21, 3F287-21, NUDOCS 8703030005
Download: ML20211Q057 (2)

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Power C OnPOR AT TON February 23, 1987 3F0287-21 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 10 CFR 50, Appendix J Compliance

Dear Sir:

The enclosed report describes a licensee identified noncompliance with 10 CFR 50, Appendix J requirements for containment air lock testing. This report is submitted voluntarily by Florida Power Corporation.

Sincerely, E. C. Simpson Director, Nuclear Operations Engineering and Licensing AEF/feb Enclosure xc: Dr. J. Nelson Grace Regional Administrator, Region II Mr. T. F. Stetka Senior Resident Inspector Soo 5 NO Q2 6 / 1 GENERAL OFFICE: 3201 Thirty-fourth Street South + P.O. Box 14042 + St. Petersburg, Florida 33733 + (813) 866 5151 A Florida Progress Company

r NONCOMPLIANCE WITH 10 CFR 50 APPENDIX J EVENT DESCRIPTION Since initial fuel loading Crystal River Unit 3 (CR-3) has scheduled Surveil-lance Procedure SP-181, Containment Air Lock Test (Semi-annual), to comply with Technical Specification (TS) 4.0.2 which states:

"Each Surveillance requirement shall be performed within the specified time interval with:

a. A maximum allowable extension not to exceed 25% of the surveillance inter-val, and

b. A total maximum combined interval time for any 3 consecutive tests not to exceed 3.25 times the specified surveillance interval ."

This specification provides allowable tolerances for performing surveillance activities beyond those specified in the nominal surveillance activities interval. These tolerances are necessary to provide operational flexibility because of scheduling and logistical considerations.

On January 12, 1987, while discussing a technical specification change request, it was determined that "at 6-month interval s" in paragraph III.D.2.(b).(i) of Appendix J to 10 CFR 50 required testing at periods not to exceed 6 months.

Because of inconsistencies between Appendix J and Technical Specifications, CR-3 has exceeded the 6-month interval requirement for Type B test of the containment air locks required by Appendix J.

Crystal River Unit 3 was in Mode 5 (Cold Shutdown), at the time this requirement was identified.

This report is being voluntarily submitted.

CAUSE The cause of this non-compliance is failure to recognize dual sources of requirements for SP-181 which were not identical (Technical Specifications and Appendix J).

CORRECTIVE ACTIONS The containment air locks Type B test schedule will be changed to ensure the surveillance interval does not exceed 6 months.

A change to Technical Specification 4.6.1.3 to exclude the applicability of surveillance interval extension in Specification 4.0.2 is in progress.

SAFETY ANALYSIS The tolerance values provided by Technical Specification 4.0.2 taken either individually or consecutively over 3 test intervals, are sufficiently restrictive to ensure the reliability associated wi th the surveillance activity is not significantly degraded beyond that obtained from the nominal specified interval .