3F0388-11, Responds to Violations Noted in Insp Rept 50-302/87-40. Corrective Actions:Clearances Reviewed for Compliance w/30- Day Certification,Engineered Safeguards Actuation Reset & Power Restored to Required Electrical Distribution Busses
| ML20153B504 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 03/16/1988 |
| From: | Ken Wilson FLORIDA POWER CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 3F0388-11, 3F388-11, NUDOCS 8803220200 | |
| Download: ML20153B504 (4) | |
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Florida Power C0RPOPATI0N March 16, 1988 3F0388-11 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C.
20555
Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License DPR-72 Inspection Report 87-40
Dear Sir:
i Florida Power Corporation provides the attached response to NRC Inspection Report 87-40.
Should there be any questions, please contact this office.
Very truly yours, db K. R. Wilson Manager, Nuclear Licensing WLR: mag Att.
xc:
Dr. J. Nelson Grace Regional Administrator, Region II Mr. T. F. Stetka Senior Resident Inspector
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8803220200 880316 PDR nDOCK 05000302 A Florida Progress Company Q
FIORIDA INR ONFORATICH RESKNSE INSPECTICH REKRP 87-40 VIOIATICE 87-40-01 TS 6.8.1.a requires the inplementation of written procedures for those activities r-rxled in Appenilx "A" of Regulatory Guide 1.33, November 1972.
Regulatory Guide 1.33, Appendix "A",
Section A.3 r-nds procedures for equipment control, and Section C.19. (2) I-nds procedures for operation of the onsite AC electrical system.
Conpliance procedure CP-115, In-Plant Equipraent Clearance and Switching Orders, specifies in step 4.2 that equipnent clearances which remain active for greater than 30 days must be certified every 30 days to visually verify the clearance tags are legible, attached to the correct equipnent, and that camponents are in their specified position.
Operating procedure OP-703, Plant Distrihition System, step 5.18.10 requires that the Engineered Safeguards (ES) 4160v ES Bus 3A undervoltage interlocks be bypassed prior to deenergizing this bus, Contrary to the above; a.
As of Decerber 7, 1987, seventeen equipnent clearances active for greater than 30 days did not have the required certification perfonned.
1 b.
On October 14, 1987, the 4160v ES Bus 3A was deenergized without bypassing the associated urxlervoltage interlocks.
This action resulted in an inadvertent actuation of the ES system.
This is a Severity Invel IV violation (Supplement I).
RFSKNSE i
Florida Power Corporation (FPC) accepts the violation.
Part "B"
of this violation was identified by FPC and has been reported in accordance with 10 CFR 50.73 as LER 87-21.
Apparent Cause of Violation a.
The cause of the violation was the result of the clearance holders not realizing the 30-day certification period had been exceeded.
b.
The cause of the violation was personnel error:
the control board operator failed to use the procedure for deenergizing a 4160v ES bus.
Basically, the evolution involves unloading the 480v ES bus 3B using a dead bus transfer technique, shifting the necessary 4160v loads from the 4160v ES bus 3A to the 4160v ES bus 3B and finally deenergizing the 4160v bus 3A.
In subsequent discussions, the personnel stated the reason they did not use the procedure was because they thought all steps had
n.
previously been acocmplished with the ex ption of opening the single off-site feeder breaker 3205 to the 4160v ES bus 3A.
A review of the procedure subsequent to the event revealed that prcper procedure usage would have prevented the transient.
Corrective Action a.
The clearances were reviewed for ocmplian with the 30-day rtification.
Those needing rtification were either certified or released, The Dv3 neered Safeguards Actuation was reset, and power was restored to 1
b.
the required electrical distribution busses.
Date of Full Otmoliance a.
Full ocmpliance was achieved by Der 21, 1987, when the identified clearances had either been certified or released.
b.
Full ocupliance was achieved on October 14, 1987, when the plant electrical distribution was restored to normal.
Action Taken to Prevent Recurrence a.
Distribution of the notification of open clearance has been revised to enocupass individuals more closely associated with the clearance holder.
A memorandum was issued to the individuals re iving the daily clearance printout and area managers to emphasize clearance holder responsibilities, b.
The personnel involved have been counseled with regard to the infortance of following plant procedures, particularly the use of operating procedure j
OP-703 (Plant Distribution System) whenever performing evolutions involving major electrical buses.
The cirmmstances of this event are being reviewed with all operators.
DEVIATION 87-40-03 In a letter to the NRC frca Florida Ibwer Corporation (FPC) dated August 24, 1984, in response to a NRC Confirmatory Order dated February 21, 1984, FPC ocamitted to ccmply with the requirements of Regulatory Guide (IG) 1.97.
This letter th-nted, in part, the installation of a high range containment area radiation monitor that has both an inlicating and recording display in the control roca.
Contrary to the above, as of November 23, 1987, the high range containment area radiation monitor does not have a recording display in the control rocn.
RESIOEE Reasons for the Deviation The reason for this deviation was the failure of responsible personnel to identify the need for upgrading the recording for the high range containment area radiation monitor for Reg. Guide 1.97 requirements.
s e
Discussion Apparently, the oversight occurred because of the timing of two emplex but related design projects, that Ming NUREG 0737 issues and PG 1.97 requirements.
Although the existing (pre NUREG 0737/PG 1.97) Radiation Monitor had a recording function, the inputs to both projects failed to remgnize that the recording function did not meet all requirements nor that the additional high range radiation monitor installed as part of the NURB3 0737 project would not include a qualified recording function.
This most likely resulted frun the NUREG 0737 project being initiated around 1981 and continuing for a number of years.
RG 1.97 study was cxmpleted in 1984 and had many overlapping areas.
Neither one of the projects recognized the failure to record frun a qualified sensor.
l Corrective Steps Taken to Avoid Rirther Deviation Upon discovery by FIC enployees of the non-conformnce, an NCOR and a Field Change Notice to install a recorder with Reg. Guide 1.97 requirements was initiatal.
The recorder has been installed to fulfill the Reg. Guide requirement.
Bared on the above discussion no further corrective actions are necessary.
Date Corrective Action Oroleted Corrective action was ccrapletcd on December 28, 1987, when the recorder on BM3-29 was declared opazeble.