IR 05000302/1986013

SALP Rept 50-302/86-13 for Nov 1984 - Mar 1986

ML20206K036
Person / Time
Site:	Crystal River
Issue date:	06/19/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20206K034	List: IR 05000302/1986013 ML20206K029 ML20206K036
References
50-302-86-13, NUDOCS 8606270398
Preceding documents:	ML20215J685 (17 October 1986)
Download: ML20206K036 (41)

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June 19, 1986  !

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ENCLOSURE SALP BOARD REPORT

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U. S. NUCLEAR REGULATORY COMMISSION

REGION II

I SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE INSPECTION REPORT NUMBER 50-302/86-13 FLORIDA POWER CORPORATION CRYSTAL RIVER UNIT 3 NOVEMBER 1, 1984 THROUGH MARCH 31, 1986  ;

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8606270398 860619 PDR ADOCK 0S000302 O PDR

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2 Introduction

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The Systematic Assessment of Licensee Performance (SALP) program is an integrated NRC staff effort to collect available observations and data on a i periodic basis and to evaluate licensee performance based upon this informa-tion. The SALP program is supplemental to normal regulatory processes used to determine compliance with NRC rules and regulations. The SALP program is intended to be sufficiently diagnostic to provide a rational basis for allocating NRC resources and to provide meaningful guidance to licensee management to promote quality and safety of plant corstruction and operatio An hRC SALP Board, composed of the staf f members listed below, met on May 27, 1986, to review the collection of performar.ce observations and data to assess licensee performance in accordance with guidance in NRC Manual Chapter 0516, " Systematic Assessment of Licensee Performance." A summary of the guidance and evaluation criteria is provided in Section II of this repor This report is the SALP Board's assessment of the licensee's safety performance at Crystal River Unit 3 for the period November 1, 1984, through March 31, 198 SALP Board for Crystal River Unit 3:

L. A. Reyes, Acting Director, Division of Reactor Projects (DRP) RII (Chairman)

A. F. Gibson, Director, Division of Reactor Safety, RII D. M. Collins, Acting Director, Division of Radiation Safety and Safeguards, RII D. M. Verrelli, Chief, Reactor Projects Branch 2, DRP, RII H. Silver, Project Manager - Crystal River, PWR Project Directorate #6, NRR G. E. Edison, Deputy Project Director, PWR Project Directorate #6, NRR T. Stetka, Senior Resident Inspector, Crystal River, DRP, RII Attendees at SALP Board Meeting:

J. A. Hind, Director, Division of Radiation Safety and Safeguards, RIII S. A. Elrod, Chief, Reactor Projects Section 2C, DRP, RII K. D. Landis, Chief, Technical Support Staff (TSS) DRP, RII S. Guenther, Project Engineer, Reactor Projects Section 2C, DRP, RII J. K. Rausch, Reactor Engineer, TSS, DRP, RII T. C. MacArthur, Radiation Specialist, TSS, DRP, RII B. Mozafari, Project Manager, PWR Project Directorate #6, NRR J. E. Tedrow, Resident Inspector, Crystal River, DRP, RII

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j II. Criteria

! Licensee performance is assessed in selected functional areas depending on whether the facility has been in the construction, preoperational, or operating phase during the SALP review period. Each functional area l represents an area which is normally significant to nuclear safety and the environment and which is a normal programmatic area. Some functional areas may not be assessed because of little or no li zensee activity or lack of meaningful NRC observation Special areas may be added to highlight significant observation '

One or more of the following evaluation criteria was used to assess each functional area; however, the SALP Board is not limited to these criteria and others may have been used where appropriat Management involvement in assuring quality Approach to the resolution of technical issues from a safety standpoint

Responsiveness to NRC initiatives Enforcement history Operational and construction events (including response to, analysis of, and corrective actions for)

i Staffing (including management)

' Training and qualification effectiveness Based upon the SALP Board assessment, each functional area evaluated is classified into oneiof three performance categorie The definitions of these performance categories are:

Category 1: i Reluced NRC attention may be appropriat Licensee

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management attent. ion and involvement are aggressive and oriented toward i nuclear safety; iicensee resources are ample and effectively used such that a high level of performance with respect to operational safety or j construction quality is being achieve Category 2: NRC ittention should be maintained at normal level ,

Licensee management attention and involvement are evident and are J concerned with nuclear safety; licensee resources are adequate and are reasonably effective such that satisfactory performance with respect to l operational safety or construction quality is being achieve Category 3: Both NRCx and licensee attention should be increase Licensee management agtention or involvement is acceptable and considers nuclear safety, but weaknesses are evident; licensee resources appear to be .3 trained or not effectively used such that minimally satisfactory performance with respect to operational safety or construction quality is being achieve The functional area being evaluated may have some attributes that would

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place the evaluation in Category 1, and others that would place it in either Category 2 or 3. The final rating for each functional area is a composite i

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of the attributes tempered with the judgement of NRC management as to the significance of individual iten The SALP Board may also include an appraisal of the performance trend of a functional area. This performance trend will only be used when both a definite trend of performance within the evaluation period is discernible

, and the Board believes that continuation of the trend may result in a change of performance level. The trend, if used, is defined as:

Improving: Licensee performance was determined to be improving near the I close of the assessment perio Declining: Licensee performance was determined to be declining near the close of the assessment perio III. Summary of Results A. Overall Facility Evaluation

The Crystal River Facility was effectively managed and has achieved a l satisfactory level of operational safety. The licensee continued to i

exhibit a strong maintenance program and has improved deficiencies J identified during the last SALP assessment period in the surveillance

) are However, general weaknesses were noted in the areas of procedural

adherence and adequacy, the review and approval process for making 1 changes to plant procedures, the control of contract personnel, i training and qualification effectiveness, and securit In addition, while still satisfactory, a weakening and declining trend was noted in j the area of radiological control The licensee has initiated a program to address the procedural adherence issue. Reports of recurrent procedural noncompliance receive

] high level management review to determine the root cause of the problem

, and to assess the adequacy of corrective actions. The long-term

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results of this program are not readily apparent and its overall effectiveness cannot be judged at this time. Based on the findings during this assessment period, management involvement in these areas should continue and is recommended.

I j The licensee continues to have problems with procedural adequacy both i

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area, the licensee has attempted to clarify these requirements by ;

I revising the administrative instruction governing the review and l l approval of changes to plant procedures and by constructing writer's 1 i guides for departmental procedures. The licensee has also implemented a training summary sheet to accompany revisions to administrative and

compliance procedures in an attempt to minimize misunderstanding of

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these revisions. The licensee should continue its efforts to improve I performance in this are I

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l Actions taken to improve control of contractor personnel include a t training program in modification procedure usag To strengthen this area, the licensee needs to pursue this program and increase the monitoring of contractor activitie Regarding the licensee's security program, the recurring finding of breached vital area barriers remained a weakness during this SALP period. We understand that frequent surveys of the barriers have been directed by plant management in an attempt to correct this recurring i

violatio The licensee has audited its security program and found numerous other items which need to be corrected or upgraded to meet

! regulatory commitment Diminished radiological control of work practices was evidence of a ,

weakening of the overall radiation protection progra Problem areas observed were typified by failure to implement existing radiation

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protection procedures or use of procedures that inadequately

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implemented regulatory requirements. The nature and frequency of inspection findings were indicative of insufficient plant management review, involvement and support for this functional are B. The performance categories for the current and previous SALP period in j each functional area are as follows:

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i Functional Area October 31, 1984 March 31, 1986 Plant Operations 2 2 Radiological Controls 2 2 Maintenance 1 1

! Surveillance 3 2 Fire Protection Not Rated 2 Emergency Preparedness 2 2

Security and Safeguards 3 3

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Outages Not Rated 2 l

l Quality Programs and Administrative 2 3

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Controls Affecting Quality l l

Licensing Activities 2 2  ;

Training and Qualification Not Rated 3 l Effectiveness i i

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IV. Performance Analysis l A. Plant Operations

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1. Analysis

During this evaluation period, inspections of plant operations were performed by the resident and regional inspection staff Major operational decisions were made at a management level adequate to assure appropriate supervisory involvement. Plant operations were generally conducted in a conservative manner to ensure plant safety. An example of this conservative approach to operations included the decision to shut down the plant af ter an increase in unidentified reactor coolant system leakage was observed even though license conditions allowed continued plant operatio ; Overall control of plant operations was satisfactory. In September

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1985, plant operators responded effectively to a failed reactor coolant system pressure transmitter, thereby preventing a reactor trip and minimizing the resultant pressure transient to which the plant was subjecte Three notable instances of inadequate control of plant operations

! were observe The first instance occurred whtle the reactor was shut down in August 1985, when operators reset an initiating

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whether the actuation was necessar Since the actuation signal

! was valid, this action resulted in another automatic actuation of j this system. The second instance occurred in November 1985, when

, a reactor trip occurred when transferring control of the main

feedwater system while conducting a plant shutdow Inadequate corrective action for a feedwater control valve problem identified during a previous post-trip review, combined with operator error, j resulted in insufficient feedwater flow to the steam generator and -

{ a high pressure reactor trip. The third instance occurred while the reactor was shut down in December 1985, when an operator error

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in not bypassing the reactor coolant pump (RCP) power monitor trip j

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resulted in a reactor protection system actuation causing a group of control rods to drop into the cor !

The plant underwent a refueling and extensive modification outage in which major new equipment was installed. Extensive operator

training on these plant modifications was conducted to familiarize i the operators with the new equipment. The plant had several

! minor, short-term maintenance shutdowns following this outag These shutdowns were well planned and coordinate l Eight reactor trips from power operation occurred during the assessment period; seven were caused by equipment failures and one

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by an operator erro All of the trips occurred during the operating period following the 1985 refueling / modification outage and many are attributable to startup problems associated with j equipment modifications. Prior to the refueling shutdown on March 9,1985, the unit had operated since April 26, 1984 without a reactor trip and had a 1984 availability factor of 94.5%. In l January 1986, the plant suffered a reactor trip due to a failed reactor coolant pump shaft and has remained shutdown pending completion of extensive repairs. (See Section V.J for a reactor trip summary).

Operations staffing was adequate. Because there has been little

licensed operator turnover, there has been generally good continuity

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in the level of understanding and implementation of plant procedures

! and practices, j Findings by an NRC training assessment team and performance on NRC

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requalification exams resulted in the necessity to requalify all j licensed operators during the major outage discussed above (see the Training analysis for additional discussion). This necessitated ,

i a sharp increase in overtime for on-shif t operators, which, i

coupled with the retrainirg efforts, had a detrimental effect on

operator morale; however, no detrimental effect was noted on plant operation The plant staff appeared observant of Limiting Conditions for i Operation (LCOs) and was generally conservative in its application I of action statement requirements. However, violations (a), (b) .

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and (d) listed below involve failures to comply with Technical

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Specification (VS) requirements.

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Viciations (c), (e) and (0) identified below involve procedural

! inadequacies and operator failures to comply with procedures. The t l licensee is addressing this weakness by implementing an operations ,

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procedure writing guide to oe used in improving and clarifying i procedure Another part of the procedure improvement program i includes validation of procedure requirements and an actual walkthrough of the procedures. When this program is fully

implemented, it should have a positive effect on plant operation Additionally, the licensee has used senior reactor operators on a

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routine basis to observe performance of operating procedures to i verify procedural adherence and adequacy. This process appears to

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be effective.

l I Violations (f), (h) and (i), listed below pertain to inadequate 3'

review and approval of changes to procedures. Similar violations i related to the procedure change process are identified in the i Surveillance, Outage and Quality Programs analyses. This indicates  !

a lack of familiarity by plant personnel with the administrative l procedure which controls this proces l l

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The conduct of shift turnover meetings continues to be a strong point in plant operation Attendance by other departments is required during these meetings; this has a positive effect on overall plant control and coordination of plant activities. These meetings are held in the control room, and access to this area is restricted during these meeting Control room operations have been and continue to be conducted in an orderly and professional manne Nine violations and two deviations were identified: Severity Level IV violation for failure to take reactor coolant system grab samples after a change in power level as required by Technical Specifications. (84-30) Severity Level IV violation for failure to secure waste gas additions to a radioactive waste gas decay tank when required by Technical Specification (84-33) Severity Level IV violation for failure to have an adequate procedure for valve lineup verification. (85-33) Severity Level IV violation for failure to have an operable emergency diesel generator during core alterations and mode changes as required by Technical Specifications. (85-33) Severity Level IV violation for failure to adhere to the requirements of a reactor startup procedur (85-41) Severity Level IV violation for an improper temporary change to a decay heat removal system operating procedur (86-09) Severity Level IV violation for failure to adhere to the requirements of a procedur (86-0a) Severity Level IV violation for an improper change to the procedure for decay heat seawater system operatio (85-08) Severity Level V violation for making an improper procedure change to the Operations Section Implementation Manual and failure to conduct a periodic revie (85-08) Deviation for failure to maintain the emergency diesel generator air start system pressur (85-21) Deviation for failure to .Taintain the corrective actions taken for a previous violation of a waste gas decay tank Technical Specificatio (85-44)

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, Cor.clusion Category: 2 Board Recommendations Failures to comply with Technical Specification requirements in this area warrant further licensee effort to improve performanc No changes in NRC inspection resources are recommende B. Radiological Controls 1. Analysis During the assessment period, inspections were performed by the resident and regional inspection staffs. This included confirma-tc > j measurements using the Region II mobile laborator In comparison with the previous assessment period, the licensee showed weakening of the radiation protection program. Problems were identified in the positive access control program for high radiation areas (violatiofis d and f), and also in the area of personnel monitoring in which procedures were not adequate to implement good frisking practices (violation a). This area was cited a second time when the licensee's corrective action was found inadequate (violation c). Implementation of the Radiation Work Permit (RWP) program also exhibited deficiencies in that, on two separate occasions, individuals were observed in noncompliance with the protective clothing requirements of the RWP (violations e and i). The RWP program was also found to be procedurally deficient in that adequate controls were not specified for RWP revisions (violation h). Other procedural deficiencies were noted during the assessment period and included such areas as Maximum Permissible Concentration (MPC) hour calculations from ingestion (violation k),

calibration of the whole body counter (violation 1), Offsite Dose i Calculation Manual requirements (violation j) and Technical

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Specification requiren1ents (violation b).

Licerisee management support and involvement in the radiation protection program appeared weak. This was exemplified by the onsite health physics staff's lack of stop work authority when failures to comply with RWP requirements were detected. The health physics technicians and their first line supervisors must go through their management chain to plant management to stop work on a job when the radiological conditions warrant such action. In February 1986, the potential for an unmonitored release from the reactor building was identifie A reactive inspection was conducted at which time it was determined that containment integrity was not established after it was known that an airborne radioactivity problem existed. The failure was attributed to the lack of authority by health physics to require closure of the containment hatches.

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10 The licensee's health physics staffing level was adequat In conjunction with the contract health physics technicians normally maintained onsite, adequate coverage was available for routine operation. The health physics staff was further augmented by additional contract technicians during outage operation The health physics staff turnover was low during the evaluation perio The licensee relied strongly on offsite contractor expertise for such services as dosimetry processing, waste classification and quality assurance auditor During 1985, the licensee developed a formal training and qualification program for radiation protection and chemistry technician A task analysis methodology was utilized in development of these programs and it was anticipated that both programs would be submitted to the Institute of Nuclear Power Operations for certification during 198 The licensee's approach to resolving health physics technical issues was, in general, adequate. In the area of radiological measurements, the licensee's understanding of technical issues and its approach to problem solving was generally adequate; however, problems with measurement controls were noted. Specific conceras included biases in gaseous effluent measurements and disagreement for one nuclide in the NRC's spiked sample analysis progra Corrective action for the latter has not been reviewed at this time. Previous corrective actions for similar matters were adequate and timel The licensee submitted the required effluent and environmental reports during the rating perio Both liquid and gaseous effluents were within limits for total quantities and concentra-tions of radioactive material released and for radiation dose to the maximally exposed individua There were eight unplanned gaseous effluent releases during the second half of 1985, all of which were related to reactor trips. All of these releases were adequately monitored. There were no unplanned liquid releases during the assessment period. As discussed earlier, the potential for an unmonitored release from the reactor building due to maintenance activities occurred late in the evaluation period and has been correcte Plant chemistry and corrosion control compliance has improved since the previous assessment interval even though a serious problem with corrosion product buildup in the steam generators attributed to plant design continued during this perio Significant improvement in the efficiency of the condensate polishing system was achieved, permitting effective implementation of the licensee's water chemistry program. The licensee's ability to implement the program was improved by the acquisition of additional personnel and upgraded instrumentation. The licensee has improved its chemistry program by incorporating the Electric

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Power Research Institute (EPRI) guidelines int; its chemistry procedures. The licensee is also actively involve:i in the develop-ment of the once through steam generator (OTSG) water slap technology and is conducting research on chemical cleaning of OTSG A weakness discussed in the last SALP report, that of chemistry personnel failing to adhere to radiochemistry procedures, appears to have been corrected as evidenced by the absence of violations in this are Personnel exposures during 1985 were approximately 646 man-rem, which was a large increase over the 46 man-rem reported in 198 This is explained by the fact that a major refueling, maintenance, and modification outage was conducted in 1985 while no significant outages took place in 1984 (94.5 percent unit availability). The collective dose was higher than the average (425 man-rem) for similar PWR facilities, but is not significant considering the scope of outage work perforced in l'J8 The licensee began tracking contaminated areas of the facility in October 1985, when approximately 21,000 square feet of the plant were maintained as contaminated. By January 1, 1986, the contami-nated area had been decreased to 12,500 square feet which corresponded to approximately 18 percent of the auxiliary buildin The licensee had initiated action to increase its contamination control effort by dedicating a full time, six man crew to decontamination work. This decontamination program has increased plant accessibility and has improved plant housekeepin During 1985, the licensee made 43 shipments of radioactive waste consisting of 17,643 cubic feet of waste containing 4,595 curies of activity. This is more than the national average of 11,653 cubic feet shipped by other utilities with similar facilities, but is not significant considering the scope of outage work perforced in 1985. Approximately 2,646 cubic feet of solid waste remained onsite at the end of the assessment perio Fourteen violations were identified: Severity Level IV violation for inadequate procedure to assure implementation of the whole body frisking progra l (85-12) Severity Level IV violation for failure to take grab samples when a radiation monitoring instrument was inoperable as required by Technical Specification (85-33) l Severity Level IV violation for failure to perform personnel frisks and instrument checks. (85-34)

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12 Severity Level IV violation for failure to post and barricade a High Radiation Are (85-41) Severity Level IV violation for failure to follow the protective clothing requirements of a Radiation Work Permi (85-41) Severity Level IV violation for failure of a worker to possess a monitoring device to continuously indicate dose rates in a High Radiation Area. (86-06) Severity Level IV violation for failure to perform surveys necessary to evaluate an airborne radioactivity release to unrestricted areas and evaluate the radiological hazards that could be present during hydrolasing activitie (86-11) Severity Level IV violation for inadequate procedure for Radiation Work Permit revision (86-11) Severity Level -IV violation for failure to wear appropriate protective clothing in a contaminated are (85-44) Severity Level IV violation for failure to adhere to the requirements of the Offsite Dose Calculation Manua (85-29) Severity Level V violation for failure to maintain an adequate procedure to calculate MPC hours for cases of radioactive material ingestio (85-34) Severity Level V violation for failure to have approved, written procedures for calibration of the whole body counting syste (85-05) Severity Level V violation for failure to properly label containers of radioactive materia (85-12) Severity Level V violation for failure to post documents as-required by 10 CFR 19.1 (85-12)

One additional, apparent Severity Level IV violation was proposed for failure to provide reasonable assurance that radioactive waste was properly classifie (86-06). The licensee has contested this citation, and the matter is under review by the NR . Conclusion Category: 2 Trend: Declining

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. Board' Recommendations Based on the observed declining trend, increased licensee manage-

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ment attention is needed to address and correct the weakening program. The NRC should increase its inspection resources to monitor progress in this are C. Maintenance Analysis During this evaluation period, inspections were conducted by the resident and regional inspection staff The maintenance program continued to be strong. High management involvement in maintenance planning and practices was eviden First line supervisors and maintenance personnel generally indicated a high awareness for procedural adherence. There was one violation in the area of procedural adherence and one violation

, involving procedural adequacy. To minimize these occurrences, the licensee has instituted a procedure rewrite program for this department designed to remove human factors errors in reading these procedures, thereby improving procedural adequacy and adherence. This program was nearly complete at the end of this evaluation perio '

In most areas the licensee's approach to the resolution of technical issues continued to be soun Subsequent to the RCP shaft failure in January 1986, all the RCP shafts were tested and evaluated for possible degradatio The licensee decided to replace all the RCP rotating assemblies despite the absence of hard evidence that all the shafts were indeed flawed. Other plant equipment was promptly. repaired or replaced when degradation was

. indicated by the predictive maintenance progra The use of predictive maintenance analysis is a continuing strength of the licensee's program. This program utilizes oil and vibration analyses on mechanical equipment and infrared analysis on electrical equipment, and is beginning to use the Motor Operated Valve Analysis and Testing System (M0 VATS) to determine operability of I motor operated valves. These techniques have enabled the licensee to predict degrading trends in equipment performance and effect repairs before equipment failure occurs. The licensea is evaluating the use of a raliability centered maintenance program to further increase the reliability of plant equipment. This program utilizes machinery history data and the frequency at which components fail in an effort to anticipate component failure If added, this program would further strengthen the maintenance progra An inspection conducted to evaluate the licensee's actions in response to Generic Letter 83-28 revealed that maintenance l

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activity and pon-maintenance testing were adequate to ensure reactor trip system reliabilit Two violations were identified: Severity Level IV violation for failure to adhere to a maintenance procedure while installing control rod drive motor tube (85-29) Severity Level IV violation for failure to have an adequate preventive maintenance procedure for conducting diesel generator insulation resistance check (86-09) Conclusion Category: 1 Board Recommendations No changes in the NRC's inspection resources are recommende D. Surveillance Analysis During this assessment period, inspections of surteillance testing activities were performed by the regional and resident inspection staffs. The surveillance testing program and calibration control program were also reviewed by the regional inspection staf Considerable inspection effort has been devoted to this area as a result of the previous SALP ratin The licensee's surveillance testing and calibration control program was generally well established and implemente Scheduling and completion of surveillances have been -within Technical Specification time limits and have received adequate management attentio Selected survefilance test procedures appeared well writte Several aspects of surveillance testing have been improved by the licensee during this assessment period. The plant's engineering and technical services groups have made definite progress in revising and clarifying surveillance procedures using writer's guides. This has greatly increased operator and technician understanding and compliance with surveillance test procedure The licensee's procedure adherence review plan has also helped to increase the awareness of plant personnel to procedural complianc Surveillance and maintenance procedures have been revised to require the recording of actual calibration dates for measuring and test equipment (M&TE) thus providing acknowledgment by the L__._ ,

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person performing the test that calibrated equipment is being use The licensee has improved and updated the installed instrumenta-tion calibration program, which is now a useful tool in tracking and scheduling instrument calibrations. While there are some

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problems with the computer data base, the improvement of this program has strengthened this area considerabl Violation (a) indicated an improper change to a surveillance procedure. This issue is similar to that discussed in the Operations analysis and is indicative of an inadequacy in the administrative procedures governing the control of these change Violation (c) involved a failure to perform surveillance testing when required and violation (b) identified a failure to adhere to the requirements of a procedure. The number of violations of this type has decreased substantially since the previous SAL Surveillance procedures used during the refueling process to confirm proper operation of systems disturbed during refueling or to confirm core design parameters were generally lacking in guidance on data collection and analysi Consequently, the quality of some data was poo Procedural inadequacies included insufficient data and log sheets necessary to record test observations, inconsistency between procedures, inadequate statistical bases for data rejection criteria, and inadequate definition of terms and data sources to be used in equations. The licensee had recognized this problem prior to the inspection and had begun to develop the procedure writer's guide to address the problem Four violations were identified: Severity Level IV violation for an improper change to an emergency diesel generator surveillance procedur (85-21) Severity Level IV violation for failure to adhere to a surveillance procedure while conducting nuclear services seawater system hydrostatic testin (85-26) Severity Level IV violation for failure to perform a surveillance test of the source range neutron flux monito (85-29) Severity Level V violation for an inadequate meteorological system surveillance procedur (84-34) Conclusion Category: 2 l

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16 Board Recommendations

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Management attention in improving surveillance procedures has resulted in definite progress in this are No changes in the NRC's inspection resources are recommende E. Fire Protection Analysis During the assessment period, inspections were conducted by the regional inspection staff in the areas of fire prevention and protection and the status of the licensee's implementation of their commitments regarding the safe shutdown requirements of 10 CFR 50, Appendix The licensee has issued procedures for the administrative control of fire hazards within the plant, for the surveillance and maintenance of the fire protection systems and equipment, and for the organization and training of a plant fire brigad These i procedures were reviewed and found to meet the NRC's requirements and guideline The inspectors reviewed the licensee's implementation of the fire protection program and administrative controls. General house-keeping and control of flammable materials were satisfactory. The fire protection extinguishing and detection systems were found to be serviceable. Organization and staffing of the plant fire brigade met the NRC's guidelines. The training and drills for the

brigade members met the frequency specified by the procedures and the NRC's guideline The Appendix R review performed by the licensee identified numerous cable interaction discrepancies, fire barrier discrepancies and open or unprotected fire barrier penetrations throughout the plant. However, fire vatch patrols were posted in

accordance with the Technical Specification A subsequent regional Appendix R fire protection team inspection was conducted on July 29 - August 2, 1985. Findings generally coincided with the licensee's findings and included such issues as incomplete installation of cable raceway fire barriers, incomplete fire door modifications, inadequate interior fire hose stations, incomplete review of emergency lighting and communications for remote safe plant shutdown, and incomplete operator procedures and training for safe plant shutdown in the event of a fire. These items were typical of findings at other facilities and were not identified as enforcement issues since, at the time of the inspection, the plant's Appendix R fire protection program was not yet required to be in place or implemented. The licensee's corrective actions for these findings were scheduled to be

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completed near the end of this assessment period and have not been reinspecte The annual fire protection / prevention audit, the 24 month QA fire protection program audit by offsite organizations and the triennial audit by an outside fire protection organization required by the Technical Specifications were reviewe These audits were conducted within the specified frequency and appeared to cover all of the essential elements of the fire protection program. The licensee

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had implemented corrective action on discrepancies identified by the audit In general, the management involvement and control in assuring quality in the fire protection program was adequate as evidenced by the issuance and effective implementation of fire protection procedures that meet the NRC requirements and guidelines.

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During the Appendix R fire protection team audit, the licensee's engineering staff and their consultants displayed a clear understanding of the fire protection issue The licensee '

responded to NRC initiatives by implementing the Appendix R requirements or requesting exemptions where necessar The fire protection staff positions are adequately identified and authorities and responsibilities are define Personnel appear qualified for their assigned duties. The licensee has a limited fire protection technical staff and made extensive use of consultants for inost of the Appendix R analysis effor Frequent overtime was required to accomplish work activities. However, some improvement 4 has been seen during the assessment period with the hiring of an additional technical staff membe No violations or deviations were identified.

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Category: 2 Board Recommendations The size of the onsite fire protection staff appears marginal and there is some concern whether adequate technical expertise will remain onsite in the long ter Licensee management should take measures to ensure that the staff's size and technical expertise remains adequat No changes in the NRC's inspection resources are recommended.

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t F. Emergency Preparedness Analysis

During the assessment period, inspections were performed by the

. regional and resident inspection staffs. These included observa-I tion of an annual emergency preparedness exercise and one routine inspectio The routine inspection and exercise evaluation indicated that the onsite emergency organization was effective in dealing with

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simulated emergencie Adequate staffing of the etergency response facilities was demonstrate Corporate management appeared to be ccamitted to maintaining an effective emergency

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response program, and was directly involved in the annual exercise and several subsequent critique Personnel assigned to the emergency organizations were cognizant of their emergency response roles, and, with the exception of dose assessment personnel during i the exercise, were adequately trained in the required areas of

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emergency response (See additional discussion below).

Evaluation of the annual emergency preparedness exercise disclosed that the following essential elements for emergency response were acceptable: emergency classification; notification and communica-

! tions; public information; shift staffing and augmentation; emergency preparedness training; emergency worker protection; post-accident measurements and instrumentation; changes to the emergency preparedness program; and annual quality assurance audits of the plant and corporate emergency planning program The exercise demonstrated that the plan and procedures could be effectively implemented in the areas of communications, accident i assessment, and exposure control . The licensee also demonstrated

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an adequate working relationship with offsite emergency support organizations. The licensee has been responsive to NRC initiatives

regarding correction of identified weakness and suggested program improvement

The exercise evaluation disclosed an adverse finding in the area

! of dose assessment. The dose assessment / projection values calculated and recorded by the Emergency Operations Facility (EOF)

differed significantly from those calculated by the Technical

Support Center (TSC), and neither facility's rasults agreed with the simulated radiological releases and accident parameters defined in the exercise scenario. The differences between the projected offsite doses calculated by the TSC and EOF caused unnecessary delays in event classification and protective action i recommendation The licensee committed to conduct a detailed l review of the TSC and E0F dose assessment computer programs and

manual calculations in an effort to resolve the apparent ;

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discrepancies. No violations were issued for actions during the exercis During routine inspection interviews, walkthroughs and observa-tions, the licensee's emergency response personnel demonstrated the following capabilities: prompt and effective classification of hypothetical emergency events; implementation of appropriate action to control the plant casualty; prompt notification of State, local and offsite organizations; appropriate protective action recommendations; and controlled management of field monitering teams. The inspection disclosed a violation related to the emergency operating procedure for seismic event With the exception of dose assessment performance, the routine inspection and annual exercise evaluation indicated that the onsite emergency organization was effective in dealing with simulated emergencie One violation was identified:

Severity Level V violation for failure to provide an adequate procedure regarding timely reactor shutdown in the event of an earthquak (85-18) Conclusion Category: 2 Board Recommendations No changes in the NRC's inspection resources are recommende G. Security and Safeguards Analysis During the evaluation period, inspections were conducted by the resident and regione) inspection staff The NRC Regulatory Effectiveness Review was also conducted during this evaluation perio The licensee has adequately staffed its contract site security organization, and has trained and equipped its security shif ts in an appropriate manner to meet the requirements of its Physical Security Plan. This was evident during an unannounced security contingency drill conducted during the early morning hours which required the security force to respond to a scenario involving an intruder. Liaison with offsite response forces was also apparent, and included onsite familiarization with the facilit .

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The licensee's program for maintaining a current Physical Security Plan has been adequate. However, the last revision to the Plan, Revision 4, dated November 1, 1985, contained several changes which were determined by NRC Region II to be inconsistent with the provisions of 10 CFR 50.54(p). These changes decreased the overall effectiveness of the Security program as reflected in current commitments to the NR Reports of Safeguards Events submitted as required by 10 CFR 73.71 were accurate and timely. The reports received during this SALP l evaluation period suggest that the age and design of the security

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equipment and systems require excessive repair and maintenance, necessitating compensatory security measure As noted in the previous SALP, the licensee has been auditing its security program to identify hardware and equipment deficiencies which will require improvements to meet the commitments contained in its Plan. This effort has resulted in the finalization of a schedule for installing an improved protected area intrusion detection system, a new security perimeter fence, and a standby compute The licensee

has met with the NRC Region II security staff to update milestones in this equipment upgrade and to make improvements to its Pla '

The Regulatory Effectiveness Review identified several deficiencies.

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The licensee's audit program had previously identified many of

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those daficiencies and was addressing corrective action While this audit effort is to the licensee's credit, it has resulted in the finding of failures to meet regulatory require-ments and long-standing licensee commitment The licensee has continued to experience serious and repetitious

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, failures to maintain vital area barrier This trend was identified in the previous SALP report and resulted in the

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licensee taking minimal corrective measure In that SALP period a Civil Penalty of $50,000 was issued for failure to maintain vital area barriers. The current Severity Level III violation, and proposed $100,000 Civil Penalty, involves a degraded vital area barrier which was identified and reported by the licensee.

However, the Region II inspection of this recurrence revealed that an inadequate compensatory measure was taken by the licensee and that the barrier violation had existed for an unacceptably long i time. It should be noted that the violation is cited as one Severity Level III with five examples of regulatory noncompliance, including an inadequate investigation of the incident, and the failure of non-security personnel to perform their security-

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related duties. The proposed escalated enforcement action was i issued on April 16, 1986, after the close of this SALP evaluation period. As of the date of this report, the licensee has responded to this violation requesting partial mitigation of the Civil Penalt This request is being reviewed by the NRC. Vital area

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barrier integrity is the single most pressing security issue 4 requiring management attentio Four violations were identified: Severity Level III violation for a breached vital area barrie (86-02). The licensee's request for partial mitigation of the proposed $100,000 Civil Penalty is being evaluate l Severity Level IV violation for inadequate communications I with local law enforcement agencie (85-35) i i Severity Level IV violation for failure to control access to the protected are (85-35) Severity Level IV violation for an inadequate assessment capabilit (86-10)

I Conclusion Category: 3

, Board Recommendations Increased licensee and NRC management attention is necessary in this functional are H. Outages 1 Analysis During this evaluation period, inspections of refueling

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activities, outage management, major plant modifications and

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post-outage startup testing were performed by the regional and

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resident inspection staffs. The regional staff also reviewed the

design change program; inservice inspections (ISI) of safety-

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related components and associated piping, supports, and snubbers; j inservice testing (IST) of pumps and valves; welding; nondestruc-tive testing; and work associated with the failure of the reactor coolant pump (RCP) shaft A refueling and extensive plant modification outage commenced in

March 1985, and was completed in August 1985. Major licensee activities during the outage included an inservice inspection of the reactor vessel, inspection and replacement of reactor core i barrel bolts, completion of NUREG 0737 required items including the installation of an emergency feedwater initiation and control (EFIC) system, and completion of Appendix R fire protection requirements including the installation of a new remote shutdown panel. Another major,- but unplanned, plant outage commenced in

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January 1986, to replace the rotating assemblies on all four reactor coolant pumps. This outage was still in progress at the end of this assessment period.

Preparations for refueling and refueling procedures were found to l be adequat Fuel handling activities were observed to be i generally acceptabl Compliance with Technical Specifications l and adherence to refueling procedures were observed to be

! acceptabl Violation (c) relates to a failure to adhere to the i

requirements of a refueling procedure and violation (f) involves a failure to adhere to the requirements of a Technical Specification during refueling operation Overall control and planning for major outages is a strengt Pre-outage planning and preparations were commenced months before the scheduled shutdown and included the start of modification preparations in the field. This resulted in a significant amount of work around operating equipment in the plant; the fact that no i plant trips occurred demonstrated good control over personnel, i The Nuclear Outage and Modificatien Department was restructured such that the Outage Manager reports directly to the Vice-President for Nuclear Operations; the effectiveness of this restructuring cannot be judged at this tim The use of outage planning meetings is also noted as a strength of this program. These meetings were held twice daily to schedule activities and resolve conflicts during the outag Another strength in this area is the verification of job comple-tion. This process verifies the satisfactory completion of individual jobs which together comprise an entire modification before the functional testing for the modification is performe Walkdowns of the installed modification are performed with '

interdepartmental personnel to further identify problems before functional testing.

The net effect of these activities was the timely completion of all planned modifications near the scheduled outage completion date.

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The overall control and planning of outages of short duration was

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also a decided strength. Even for outages of short duration, the j work is properly planned with regard to scope, repair parts and work procedures.

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Some problems were identified in the engineering verification i process for changes in design. This problem concerns the extent l of management's involvement in ensuring the adequacy of completed designs. Numerous errors in Engineering Instructions associated l

with completed designs were identified in the field. One apparent l

problem was identified in connection with a design change to the

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i l safety-related makeup and purification system. A second example

! involved the inadequate design of the EFIC system level detectors, which contributed to numerous spurious system actuations after the 1985 refueling outag These activities involved the use of engineering design contractors and the apparent lack of management control over their activities and are symptomatic of a concern

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expressed in the previous SAL i To prevent recurrence of such problems, the licensee has initiated

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program enhancements providing for systam walkdowns prior to and

during the detailed design proces The main purpose is to

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establish and maintain continuous commbnication between the

! design office and site personnel. The development and implementa-j tion of the enhanced design change progra'n should improve the (

licensee's management involvement in assuring quality, i

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! Additional weaknesses exhibited in the modification area involved

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procedural adherence. Several violations listed below involve noncompliance with and adequacy of plant modification procedure Of these, violations (a), (b), (d) and (e) involved contractor

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personnel. This continuing contractor problem does not appear to

have improved. The licensee is attempting to address these issues i with the procedural adherence review program. Additionally, the licensee has started 1 training program for contr<ct workers in

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which modification procedures are addressed.

1 i i The licensee's administrative controls of the welding program were

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relatively weak as evidenced by inadequate procedures' for control

of filler metal, unauthorized use of welding procedJres, and

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improper transfer of welder performance qualificatios records.

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These deficiencies resulted, in part, from the licensee!s decision to cancel the contract with a service organization ar.d assume responsibility for administratior of the welding program. This

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task was undertaken prior to making adequate preparations for implementing the program, e.g., hiring qualified personnel and

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writing an adequate welding program manual for implementing the program. Following NRC identification of these deficiencies, the licensee took appropriate measures to rectify the situatio In January 1986, following the failure of the "A" reactor coolant i

pump shaf t assembly the regional staff performed two inspection The inspection effort included observation of the pump disassembly and nondestructive examination of the broken and replacement shaft The staff found that licensee personnel involved in the-l failure investigation and pump repair were fully qualified. Also, as discussed in the Maintenance analysis, management appeared to be supportive of the site's engineering decisions, t One violation listed below involved an improper change to a

, refueling procedure. This issue is similar to that discussed in j the Plant Operations analysi ;

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Eight violations were identified:

a .. Severity Level IV violation for failure to adhere to the requirements of a modification procedure and for inadequate control of scaffolding. (85-16) Severity Level IV violation for failure to follow a welding procedur (85-17) Severity Level IV violation for failure to adhere to the requirements of a refueling procedur (85-19) Severity Level IV violation for failure to follow a welding procedur (85-23) Severity Level IV violation for failure to adhere to the requirements of a modification procedure for anchor bolt torquin (85-26) Severity Level IV violation for failure to adhere to Technical Specification requirements for source range reactor flux monitor operability during fuel handlin (85-27) Severity Level IV violation for an inadequate emergency feedwater pump modification procedur (85-42) Severity Level V violation for an improper change to a refueling procedur (85-08)

One additional, apparent Severity Level IV violation involved a failure to verify the adequacy of a design change to the makeup and purification syste (86-01). This violation is being contested by the license . Conclusion Category: 2 3. Board Recommendations There are continuing problems involving the control of contractor personnel and procedural adequacy and compliance in the design change area. Licensee attention is needed to address and correct these weaknesses. No changes in the NRC's inspection resources are recommended.

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I, Quality Programs and Administrative Controls Affecting Quality Analysis During this assessment period, routine inspections were performed

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by the resident and regional staffs. The following specific areas were reviewed by the regional staff during this period: QA program; audits; offsite support staff; QA/QC administration;

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procurement; receipt, storage, and handling; and tests and experiment In addition, the resident and regional staffs reviewed the implementation of the measuring and test equipment (M&TE) calibration progra The annual QA program review was conducted concurrent with a l review of the QA audit program and the offsite support staff.

i Several problems were identified in the audit areas. In general, audit findings were significant and in-depth but they were not always resolved in a timely manner. Violations were identified for failure to document a disagreement between the audited and auditing organization and the failure to provide appropriate

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criteria for elevating unresolved QA audit findings to upper management. The licensee has initiated programmatic enhancements to assure that conditions adverse to quality are promptly correcte Further discussion > of the QA audit program, as it relates to specific functional areas, are found in the Fire Protection, ,

Security and Safeguards, and Training analyse While the

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licensee's ' Appendix R reviews and fire protection audits were successful in finding program deficiencies, the same is not true in the training are Numerous significant training program deficiencies remained undetected by the licensee. until they were found by an NRC training assessment tea The licensee is credited with finding hardware and commitment deficiencies in the security area, but corrective actJons have not always been timely and some long-standing commitments remain unfulfille The offsite support staff generally fulfilled its mission, however, several weak areas were identifie The interface and communication between corporate and site groups was poor, particularly between licensing and site complianc A review of the plant's snubber surveillance program by a regional inspector revealed that QA audits had not been performed in this a ret, within the two years preceding the inspectio Some j surveillance records were found to be incomplete and some were

illegible; they were, in general, not well maintained and were

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difficult to retriev A violation was issued for failure to adequately document numerous snubber visual inspections.

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In the area of QA/QC administration, the licensee's QA program documents clearly identified the structure of the QA program and the procedures and responsibilities necessary to execute i Methods existed to modify the program to provide increased emphasis on identified problem area The procurement of safety-related equipment and services and the receipt, storage, and handling of materials met regulatory requirements. Procurement documents were complete and accurate, and equipment storage areas were well organized and clea An inspection conducted to confirm the adequacy of the licensee's actions in response to Generic Letter 83-28 (Required Actions Based on Generic Implications of Salem Anticipated Transient Without Scram) revealed adequate management involvement and control to ensure the quality of procedures and work related to reactor trip breaker modifications, testing, and maintenance. The same inspection also verified the adequacy of post-trip data collection and review, however, a violation was identified involving a failure to maintain computer generated post-trip data in a quality manne Administrative controls for tests and experiments were adequately delineated in writin Special tests were performed under the existing test program which meets regulatory requirement There have been substantial improvements in the licensee's M&TE calibration progra No occasions of using non-calibrated equipment were found in this evaluation period. Surveillance and maintenance procedures have been revised to require the recording of actual calibration dates for measuring and test equipment thus providing acknowledgment by the person performing the test that calibrated equipment is being use The storage of M&TE and the follow-up on M&TE found to be out of calibration (either due to equipment drift or damage) was poor; two violations were identified in this are The M&TE storage facilities appeared to be marginal compared to other facilities in Region II. Recordkeeping in this area was also marginal, but adequat The licensee still has problems with procedural adequacy and methods to change procedure The procedural adequacy problem should improve with the implementation of the various procedure writer's guides. The procedure change method problems seem to be caused by the following two factors:

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failure of the licensee to direct personnel to use the Immediate Temporary Change (ITC) for making procedure changes (which complies with the Technical Specifications), and l l

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i an attempt by the licensee to reduce the amount of paper work

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reviewed by the Onsite Review Committe The use of ITCs has increased considerably since personnel have

been instructed to make changes using this method. The procedure

change area is improving and should continue to imorove as manage-

ment continues to stress the use of ITCs and as personnel become more familiar with the process.

l The licensee has made a number of changes to administrative 4 procedures in an effort to reduce the paperwork burden on the Onsite Review Committee. Some of these procedure changes, however, have been too general and have resulted in violation Three violations listed in the Plant Operations analysis and I violation (h) listed below were caused by these administrative l policy change The licensee has further revised these administrative procedures and now appears to have a better understanding of the license requirements. Insufficient time has elapsed to allow judgement of these changes st this tim One additional violation identified in the area of quality

< programs involved a nonconformance, which was written against l discrepant procedures and was documented as complete in the j absence of adequate corrective actions. Two other violations (one

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of which is listed in the Outage analysis) involved inadequate i quality inspection of maintenance activities. These two

violations, in addition to other recent events (as documented in

plant nonconformance reports) involving the failure of QC

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personnel to perform adequate quality inspections, indicate a J

weakness that apparently is being caused by the use of contractor j personnel who receive only minimal training and by the use of

unqualified Quality Control supervisio These violations highlight a continuing problem with the adequacy of and adherence to plant procedures and the inadequate control of contractor personnel. Other examples of procedural weaknessos and inadequate contractor control are identified in other functional areas within this repor Ten violations were identified: Severity Level IV violation for failure to document a ncnconformance regarding a disagreement between QA audit personnel and audited organizational personnel. (85-15)

. Severity Level IV violation for failure to establish criteria

, for escalating QA audit findings. (d5-15)

, Severity Level IV violation for failure to ensure that nonconformances are correcte (85-19)

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28 Severity Level IV violation for failure to properly inspect a maintenance activity for quality and to ensure replacement parts were of the proper quality level. (86-07) Severity Level IV violation for failure to establish suitable environmental conditions for calibration of M&T (85-13) : Severity Level V violation for failure to ensure M&TE out-of-tolerance evaluctions were performed by contractor (85-13) Severity Level V violation for failure to maintain adequate records of activities affecting quality. (85-20) Severity Level V violation for an inadequate procedure to control the review and approval of changes to plant procedure (85-11) Severity Level V violation for failure to report a condition i outside the design basis of the pla (85-44) l Severity Level V violation for failure to properly maintain quality assurance record (85-07) l Conclusion Category: 3 Board Recommendations The licensee has displayed a general weakness in its ability to detect and correct its own prcblems and deficiencies. The licensee's QA organization failed to identify significant deficiencies in the training area and failed to expedite the correction of deficiencies identified in the security are The rating in this area reflects an overall concern regarding the licensee's commitment to quality and not merely the adequacy of the onsite QA/QC staf f. The licensee's inability to exercise adequate control over contractor activities is also a significant Board concer ; Licensing Activities Analysis The licensee's performance was evaluated in the areas of manage-ment involvement, approach to the resolution of technical issues from a safety standpoint, responsiveness to NRC initiatives, and !

reporting and analysis of reportable event .

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l This performance assessment is based on the NRC's evaluation of

the licensee's performance in support of licensing actions that had a significant level of activity during the evaluation period.

i These actions included licensee requests for license amendments

and for exemptions or relief from regulatory requirements, j responses to generic letters, and various submittals of informa-tion for multi plant and TMI item The licensee has maintained or slightly improved the extent and j consistency of management involvement and control since the last j SALP report.

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i Improvements may be illustrated by the improvement in the quality

of significant hazards determinations in license amendment request Management attsntion was most evident, as may be j expected, in more significant or complex issues such as fire i protection and the requested exemption from the existing General i

Design Criterion IV (GDC-IV) requirements related to the

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leak-before-break issue. Periodic updating of FPC's position, status and priority for outstanding issues was also beneficial in

our planning process. On the other hand, the review of the Cycle VI reload report was made more difficult because of late submittal by the licensee and by use of an unreviewed code in the analysi During the Cycle VI reload review, the licensee's attempt to identify issues needed for restart was only partially successful because of changes in these issues which caused some NRC effort on items which subsequently proved unnecessary for restar In general, the approach of the licensee and its contractors to

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resolution of technical issues demonstrated an adequate under-standing of those issues and resulted in sound, timely, viable.

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and conservative resolutions. However, this was not always the case. For example, in the amendment involving natural circulation cooldown, several iterations over a four year period occurred before the issue was resolved. Overall, however, the licensee performed well in this area and improvement is continuin ,

The licensee has taken an active role in owners group activities and in incorporation of plant improvements (e.g., participation in the TS improvement program, redesign of reactor coolant pump l

restraints, and incorporation of EFIC).  ;

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FPC has generally been well prepared and responsive, and has made !

i concerted efforts to resolve issues during the reviews and I discussions in this assessment perio Although, as discussed

! above, the Cycle VI reload report was submitted somewhat late, the

, licensee responded quickly to NRC requests and necessary matters

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were resolved without a delay in restar Response to NRC

requests and initiatives was prompt and effective in the areas of

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improvement of significant hazards determinations and in the exemption request for GDC-I FPC has tried to meet deadlines and notified NRR when deadlines could not be met. Fewer requests for extension to respond to our requests for additional information on some long-standing issues brought about resolutions during this assessment period as wel ! During the report period, Crystal River 3 reported 43 events to the NRC Operations Center as required by 10 CFR 50.72. Four of these events were security-related. Ten of these events involved reactor trips, five of which were from reactor power levels greater than 90 percen During these events, systems generally functioned as expecte Fifteen of the events reported involved engineered safety features (ESF) actuations, of which six included an auto-start of an emergency diesel generator (EDG). Five of the six EDG auto-starts occurred during the performance of maintenance and surveillance activities related to the EDG system Four of these can be attributed to personnel error. These occurrences suggest that the licensee needs to provide better training and procedures for work associated with the EDGs. Five of the reportable events placed the licensee into LCO action statement The licensee has generally been timely and accurate in reporting events, the number of which ha s been about average for the report perio The licensee utilizes contractor personnel to a significant extent in connection with licensing effort FPC personnel appeared to exert adequate control over these support organization In total, staf fing appears adequate to meet the licensing demands.

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FPC has not had delays in the licensing area attributable to inadequate quality or quantity of staf Staff members are well informed and ef fective in their interactions with the NRR staf . Conclusion Category: 2

, Board Recommendations No changes in the NRC's inspection resources are recommende K. Training Analysis A special training inspection was conducted by Region Il personnel at Crystal River during this SALP period. Training areas

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4 inspected included licensed and nonlicensed operator, licensed operator requalification, shift technical advisor, maintenance technician, plant engineer and management, quality control inspector, operational experience feedback, and general employee trainin This inspection indicated a significant- lack of management control over, and attention to, the areas of licensed operator requalification training, the implementation of training commitments, and the accuracy of license applications to the Commission. An investigation was conducted by the Office of Investigation (01) to determine if intent was involved in the misinformation provided to the Commissio, as detailed in 01 Investigation Report No. 2-85-004. The OI investigation confirmed NRC Region II's findings but failed to identify any willful violation of commitments and requirements. Escalated enforcement action is currently under consideration by the NR The inspection report contains multiple examples of potential violations in several areas including failure to implement the NRC-approved requalification training program, potential material false state-ments on license applications and other communications with the Commission, failure to establish or imploment adequate training procedures, and failure to maintain adequate training record In March 1985, the NRC administered a requalification examination to approximately 25 percent of the licensed reactor operators and senior reactor operators at Crystal River. The results of this examination confirmed the inspection findings in the area of requalification training. Only 5 of 17, or 29.4 percent, of the licensed operators passed this requalification examination; the requalification program was consequently judged to be unsatis-factory per NUREG 1021. The licensee divided the remaining licensed personnel who had not passed the NRC examination into two groups for accelerated regt.alification trainin One group received an NRC examination in May 1985 and achieved an 8 percent pass rate, and the second group in July 1985 had a pass rate of 58.8 percen The average of the examinations administered following upgrade requalification training was 71 percent. Based upon these results, the licensee's requalification r program was determined to be deficient pending additional i corrective actions, i

Based upon the inspection findings and NRC examination results, the licensee has taken corrective actions including a QA audit of l Training Department revisions to training procedures, implementa- l tion of training commitments, revision of record keeping l procedures, and replacement of key training staf These corrective actions have not been inspected in detail to dat To further strengthen operator training, the licensee has implemented the use of a " check operator", who is a full time experienced senior reactor operator, to conduct on-shif t training L

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for licensed and nonlicensed operator This program should produce positive effects in the futur Interviews with licensed personnel and the success rate on NRC !

license examinations indicated that replacement license training ,

was effective. Four reactor operator and seven senior reactor operator replacement examinations were administered during the SALP period. All of the reactor operators passed, and six of the seven senior reactor operators passed for an overall pass rate of 90.9 percen i A review of the training records and license applications for the group of applicants who took NRC license examinations in December 1984, indicated, however, that the licensee had not established adequate measures to ensure that all required training was successfully completed and documented prior to taking the examination These deficiencies were the subject of a Confirma-tion of Action Letter (CAL-50-302/85-02) issued on January 29, '

1985, from the NRC to Florida Power Corporatio The CAL confirmed FPC's commitment to resolve all identified training i deficiencies for the December 1984 license applicants and to .

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recertify their eligibility to take an NRC license examination pursuant to 10 CFR 55.10(a)(6). In a letter to the NRC dated April 4,1985, the licensee stated that the recertification was complete and that the resulting documentation was available for ,

review. A follow-up inspection by Region 11 revealed that the .

I recertification process was inadequate in that the training records still did not support the licensee's contention that the candidates had successfully completed all of the required trainin In summary, the failures to (1) fully implement the requalifica-tion program, (2) conduct valid and regular evaluations of operations personnel, (3) adequately control the preparation and grading of examinations, (4) maintain adequate and readily retrievable training records, (5) provide in-depth QA audits for training records and training program requirements, and (6) to i

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take adequate corrective actions on identified deficiencies, are evidence of a breakdown in the management controls necessary to ensure the performance and qualifications of licensed personnel, i No violations were issued during this appraisal period, however, l proposed escalated enforcement action is pending regarding apparent deficiencies detected in the licensed operator requalification training progra . Conclusion Category: 3 Trend: Improving ,

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l Board Recommendations No changes in the NRC's inspection resources are recommende V. Supporting Data and Summaries  ! Licensee Activities The scope of major outage work at Crystal River Unit 3 was as follows:

Reactor Coolant Pump Rotating Assembly Replacement - The "A" i reactor coolant pump (RCP) shaft failed during power operation on ;

) January 1, 1986. Disassembly of the "A" RCP revealed that the j shaft had sheared; ultrasonic testing of the other three RCP j shafts revealed possible crack indication All four shafts /

J rotating assemblies are being replace The outage was still in

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progress at the end of this SALP perio . NUREG 0737 and Appendix R Fire Protection Items - A new emergency a feedwater initiation and control (EFIC) system and a new remote ;

] shutdown panel were installed.

i j Once Through Steam Generator (OTSG) Water Slap - A water slap '

process was developed and utilized in an attempt to remove sludge l buildup from the OTSG tube support plates. This process proved j only partially successful, i

1 Reactor Vessel Inservice Inspection (!$1) - ISI examinations were j performed in accordance with ASME Boiler and Pressure Vessel Code, i Section XI, 1974 edition, Summer 1975 addenda. Babcock & Wilcox

! completed the examinations under contract to FP . Reactor Core Barrel Bolt Inspection - During the last refueling (Refuel 5) the licensee detected cracking on some lower core barrel bolts; these bolts were subsequently replaced with bolts

composed of a corrosion resistant material. During the refueling conducted during this appraisal period (Refuel 6) the remaining accessible core barrel bolts were replaced.

I , Inspection Activities i The routine inspection program was performed during this period, with j special inspections conducted to augment the program as follows:

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] January 14-18, 1985, in the areas of licensed operator replacement i trainino, requalification training, general employee training, l support engineer training, maintenance training, quality control

[ inspector training, shift technical advisor training, and ;

j management training.

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1 l March 4-8, 1985, to review the licensee's implementation of a program per the requirements of 10 CFR 50.49 for establishing and maintaining the qualification of equipment. The inspection also included evaluations of the implementation of equipment qualifi-l cation (EQ) corrective action commitments made as a result of '

l deficiencies identified in the January 11, 1983, Safety Evaluation l Report (SER) and the October 1,1982, Franklin Research Center  :

l (FRC) and Technical Evaluation Report (TER). l April 29 - May 1,1985, to verify the licensee's actions and  !

documentation regarding recertification of the December 1984, operator license applicants per Confirmation of Action Letter (302/85-02) and Florida Power Company response letter dated April 4, 198 , July 29 - August 2, 1985, in the areas of fire protection and the licensee's actions regarding the implementation of the require-ments of 10 CFR 50, Appendix R, Sections III.G, III.J, III.L. and II . August 22-23, 1985, to review and determine the circumstances of a licensee identified and reported incident relating to alleged unauthorized introduction of firearms into the protected are . January 2-3, and 28,1986, to review the circumstances associated with a physical security event reported by the licensee on December 19, 198 ; January 3-7, 1986, to follow-up on the event involving the failure of reactor coolant pump (RCP) 1A and the subsequent reactor trip on January 1,1986. Areas under review included: an inspector *

review of recorded values of selected plant parameters associated with the event; an inspector review of the licensee's post-trip review; an inspector review of selected plant chemistry data for indication of fuel element failure; and an inspector review of RCP 1A's surveillance, preventive maintenance, corrective maintenance and predictive maintenance program . March 3-13, 1986, to investigate airborne radioactivity concerns and potential airborne radioactivity . released to unrestricted areas as a result of hydrolasing activitie Licensing Activities >

Ouring the evaluation period, licensing activities included requests  !

for license amendments, requests for exemption or relief from regulatory requirements, responses to generic letters, and various submittals of information for multi plant and TMI items. Active issues during this period are classified belo A total of 31 licensing actions were complete ,

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j 1. 58 Plant-Specific Actions (17 completed): Included in this l

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category and used to provide input to this evaluation:

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Emergency and Security Plans i

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Change to Section 3.0.4 Applicability C

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- Fire Protection Exemption Requests j -

Operating Modes for RV Head Seismic Instrumentation

! - ISI Relief Request

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Hydrogen Recombiner Valve Replacement j -

Heatup and Cooldown Curves

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Increase Controlled Leakage Rate r

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Emergency Feedwater Initiation ard Control (EFIC) TS i j -

Cycle VI Reload Report  ;

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ES Actuation Testing

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Dedicated HVAC

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Licensed Operator Requalification Program l

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GDC-4 Exemption Request

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i j 2. 32 Multi-Plant Actions (12 completed): Included in this category ,

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and used to provide input to this evaluation:  !

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Environmental Qualification of Safety-Related Equipment a

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Natural Circulation Cooldown

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Post-Maintenance Testing l

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Post-Trip Review - Data and Information Capability '

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Automatic Actuation of Shunt Trip f TMI (NUREG-0737) Actions (two completed): Included in this ,

category and used to provide input to this evaluation:  ;

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Post-Accident Sampling Modifications NRR/ Licensee Meetings (8) {

) Division Director Status '

Reload Codes l Backfit Issues j Detailed Control Room Design Review

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GDC-4 Exemption Requests (2)

! EFW System Reliability l EFW Event of November 22, 1985 I .

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NRR Site Visits (1)

s I j Site Visit With Commissioner Asselstine l

j Commission Briefings - None i

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i 36 l Schedule Extensions Granted (2)

I Surveillance Interval Extensions Surveillance Capsule Removal Reliefs Granted (6) .

j ISI Relief Requests (6)

i i Exemptions Granted (7)

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Fire Protection (6)

Reactor Vessel Head Vent

) 1 License Amendments Issued (20)

i l 1 Emergency Technical Specifications Changes Issued - None

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l 1 Orders Issued - None

! 1 NRR/ Licensee Management Conferences (2) i

) Investigation and Allegation Review

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{ One major investigation involving concerns about lic.ensed operator

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recertification activities was conducted during this SALP perio Escalated Enforcement Actions Civil Penalties Severity Level III (Supplement III) violation for failure to l afford vital equipment the level of protection specified in the

! Physical Security Plan. A Proposed Imposition of Civil Penalty of

$50,000 was issued on January 10, 1985. FPC denied the violation

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on March 1,1985, and an Order Imposing Civil Penalty was issued l

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on July 29, 1985. This violation was included in the basis for the previous SALP analysis and is listed here for continuit . Orders l As noted in paragraph E.1 abov i Licensee Conferences Held During Appraisal Period Members of the NRC's Committee to Review Generic Requirements (CRGR) visited the Crystal River facility on December 5-6, 198 I An enforcement conference was held on January 15, 1985, to discuss

{ an individual's entry into a locked high radiation area with dose rates of 200 - 1200 R/h f i

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! A management meeting was held on February 1,1985, to discuss the findings identified during the Region II training assessment (reference Inspection Report No. 50-302/85-01) and FPC's corrective action ' A management meeting was held on March 12, 1985, to review the results of the SALP program for the Crystal River facility.

I A management meeting was held on March 15, 1985, to discuss the i NRC and FPC positions regarding ci,ted Violation 84-09-04.

i A management meeting was held on April 3, 1985, to discuss the NRC

administered operator requalification examination and FPC's plans for operator retraining and recertificatio . A management meeting was held on May 15, 1985, to discuss the NRC

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inspection findings documented in Inspection Report No. 50-302/85-22 l concerning the recertification of licensed operator candidates at

! Crystal River . A management meeting was held on July 16, 1985, to discuss a proposed 10 CFR 50.54(p) change to the Crystal River Physical Security Pla . A management meeting was held on July 16, 1985, to discuss the-application of 10 CFR 50, Appendix R at Crystal River and the

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forthcoming Appendix R inspectio '

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10. A management meeting was held on July 18, 1985, to discuss the staffing of Crystal River 3, p'otential procedural problems, and the training required on the recent plant modification ,

11. A management meeting was held on July 31, 1985, to discuss FPC's

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quality assurance program, its management and implementatio ! 12. A management meeting was held on September 6,1985, to discuss FPC's QA review of operator training procedures, as requested in CAL-50-302-85-02, and plans to improve the operator requalifica-tion training progra . An enforcement conference was held on September 13, 1985, to discuss the apparent failure to control personnel and material j access to the protected area of the Crystal River 3 facilit . An enforcement conference was held on January 28, 1986, to discuss failures to comply with NRC regulatory requirements in the area of licensed operator training and an event involving the breach of a vital area barrier.

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G. Confirmation of Action Letters A Confirmation of Action Letter (CAL-50-302-85-01) was issued on January 22, 1985, concerning the removal of a senior reactor operator from licensed duties when an NRC inspector determined during a training audit that the operator had failed the facility-administered annual requalification make-up examinatio . CAL-50-302-85-02 was issued on January 29, 1985, concerning the recertification of licensed operator applicants examined by the NRC in December 1984. FPC also confirmed that it would conduct a QA audit of training procedures and activities and meet with the NRC to discuss the audit result H. Licensee Event Report (LER) Analysis During the evaluation period, 26 LERs were evaluated by the NRC staff to determine event caus The distribution of these events was as follows:

CAUSE NUMBER Component Failure 12 Design , 1 Construction / Fabrication 1 Personnel

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Operating Activity 3

- Maintenance Activity 2

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Test / Calibration Activity 5

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Other Activity 2 TOTAL 26 I. Enforcement Activity FUNCTIONAL NO. OF DEVIATIONS AND VIOLATIONS IN EACH AREA SEVERITY LEVEL D V IV III II I Plant Operations 2 1 8 Radiological Controls * 4 10 Maintenance 2 Surveillance 1 3 I

Fire Protection Emergency Preparedness 1 Security 3 1 l Outages * 1 7

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Quality Programs and 5 5 Administrative Controls Licensing Activities Training *

TOTAL 2 13 38 1 l

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• Additional apparent violations have been proposed as noted in the functional area analyse J. Reactor Trips Ten unplanned trips and six manual shutdowns occurred during this evaluation period. The unplanned trips are l'isted below: August 20, 1985 - This anticipatory reactor trip from 21 percent power was caused by a manually initiated main turbine trip in response to a ruptured 2-inch drain line on the main turbine high pressure crossover lin The drain line was repaired and the reactor was restarted later the same da The same steam line failed again on August 21 because of excessive steam pipe vibrations induced by newly installed, modified turbine governor valves. The plant was placed in cold shutdown on August 22 to repair the steam line and turbine governor valve . August 20, 1985 - This reactor trip from approximately 20 percent power occurred during the restart from the reactor trip described in paragraph J.1 above. The automatic trip was caused by a reactor coolant system high pressure signal which was actuated because of plant temperature and pressure oscillations induced by sluggish feedwater control valve operatio The integrated control system (ICS) was adjusted and the feedwater system was repaired prior to the reactor restart on August 21, September 27, 1985 - The reactor was manually tripped after control rod group number 7 dropped into the reactor core while attempting to transfer a control rod from the auxiliary power supply back to its normal group power supply. A faulty jogging motor in the auxiliary power supply's programmer control assembly caused the entire rod group to drop into the core adding sufficient negative reactivity to shut down the reactor from 13 percent power. The auxiliary power supply was repaired and critical operation was resumed on October . October 9,1985 - The reactor was manually tripped from approxi-mately 96 percent power in response to the inadvertent closure of two main steam isolation valves (MSIVs) for the "B" once through steam generator (OTSG). The MSIVs closed when a personnel error was committed during troubleshocting activity on the emergency feedwater initiation and control (EFIC) system resulting in satisfaction of the two-out-of-four main steam isolation channel trip logic for the "B" OTS Troubleshooting and repair of the EFIC system was completed and critical operation was resumed later the same da ,'

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5. October 26, 1985 - An anticipatory reactor trip from 97 percent power was caused when the main turbine was manually tripped by the operators. An inverter failure had interrupted the primary power supply to the control rod position indication (RPI) system and an improperly adjusted backup power supply resulted in a momentary indication that all control rods were fully inserte The operators responded to this false scram indication by tripping the main turbine in accordance with plant procedures when they observed that it had not automatically tripped. The inverter was repaired and the reactor was restarted on October 2 . November 8, 1985 - The reactor tripped from 95 percent power on a high reactor coolant system pressure signal. A feedwater booster pump tripped causing a plant runback to 55 percent power. This power reduction resulted in less heat transfer from the reactor coolant system thereby increasing its temperature and pressure to the trip setpoint. The licensee could detect no reason for the booster pump trip; the plant was restarted after the pump was satisfactorily teste . November 22, 1985 - The reactor tripped from 18 percent power on a high reactor coolant system pressure signal. A plant shutdown was in progress and the operators encountered difficulties controlling the "A" OTSG level with the startup flow and low load control valves. A low level in the "A" OTSG tripped the EFIC cystem and started the emergency feedwater (EFW) pumps. The cool emergency feedwater caused a slight power excursion and contributed to RCS temperature and pressure oscillations. The operators secured the EFW pumps, but sluggish low load control valve response caused the

"A" OTSG level to decrease again resulting in the reactor high pressure tri . December 3, 1985 - An anticipatory reactor trip occurred from 93 percent power when loss of the "B" 6900 volt unit auxiliary bus deenergized two reactor coolant pumps (RCP-18 and 10). An inspection revealed that a loose wire termination on the RCP-ID breaker created a phase-to phase fault which caused the bus feeder breakers to trip. That and other switchgear connections which were found to be loose were retorqued and the protective relays were functionally tested and found to be satisfactor . December 7, 1985 - An anticipatory reactor trip occurred while the reactor was in the shutdown condition with a group of control rods fully withdrawn. The reactor trip was caused by an operator error while starting and stopping reactor coolant pumps. . _ ;

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10. January 1, 1986 - The reactor tripped from about 92 percent power due to a reactor power to reactor coolant flow mismatc The RCP-1A shaft sheared causing reactor coolant system flow to decrease below the established minimum setpoint for the existing power level. The other reactor coolant pump shafts were subsequently tested and found to contain possible defects. All four RCP shafts are being replaced during the ongoing maintenance outage,

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