IR 05000302/1998004
| ML20249A298 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 06/08/1998 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20249A263 | List: |
| References | |
| 50-302-98-04, 50-302-98-4, NUDOCS 9806160280 | |
| Download: ML20249A298 (60) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No:
50-302 License No:
DPR-72 Report No:
50-302/98-04 Licensee:
Florida Power Corporation Facility:
Crystal River 3 Nuclear Station Location:
15760 West Power Line Street Crystal River, FL 34428-6708 Dates:
March 22 through May 9, 1998
. Inspectors:
S. Cahill, Senior Resident Inspector T. Cooper, Resident Inspector S. Sanchez, Resident Inspector B. Crowley, Reactor Inspector, Sections M1.2: M2.1 H. Miller, Reactor Inspector Sections El.1: E8.2 -
E8.4: E8.8 - E8.10 S. Ninh, Project Engineer, Sections 08.1 - 08.3 L. Stratton, Physical Security Specialist. Sections S3.1: S8.1 M. Thomas, Reactor Inspector, Sections E8.1: E8.5 -
E8.7 F. Wright. Senior Radiation Specialist, Sections R1.1
- R1.3: R3.1: R7.1: R8.1 - R8.2
' Approved by:
R. Schin, Acting Chief, Projects Branch 3 Division of Reactor Projects Enclosure 2 fD 302
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EXECUTIVE SUMMARY Crystal River 3 Nuclear Station NRC Inspection Report 50-302/98-04 This integrated inspection included aspects of licensee operation:.
engineering, maintenance, and plant support.
The report covers a 7-week period of resident inspector inspection: in addition, it includes ~the results of announced inspections by regional inspectors, a regional physical security specialist and a regional radiation specialist.
Ooerations A short turbine generator outage on April 3, 1998. was well
planned and executed and a thorough post-outage critique was conducted to further im] rove performance. This was considered indicative of the improvement t1e licensee has made in scheduling and coordination between departments (Section 01.1).
A weakness was identified for several examples of poor licensee
recognition of Technical Specification Limiting Conditions for 0)eration requirements and informal tracking of the associated actions.
T1e administrative requirements for this function were scattered throughout various and overlapping procedures and the individual accountability for tracking and compliance was not clear (Section 01.2).
The licensee issued a detailed set of 10 site 1998 Performance Goals
that effectively captured their most important broad performance issues.
Goals included creation of a Supervisory Development Program to ensure common senior management ex)ectations and methods were understood, an overhaul of the Procedure C1ange Process to address disorganized and inefficient methods, consistent Plant Benchmarking Expectations, and improving Clear Management Performance Expectations. The inspectors concluded the licensee was very effective at identifying and promulgating their broad programmatic problems.
Final implementation of the licensee goals would effectively address several previously documented inspector and licensee concerns (Section 01.3).
A Non-Cited Violation (NCV 50-302/98-04-01) was identified for an
example of poor implementation of design change assumptions that resulted in the failure to monitor and detect pressure of backup air to the atmospheric dump valves that fell below equipment design basis limits. lhe cause of the problem was similar to previously reported problems with identifying and implementing design change assumptions (Secuvo 03.1).
The inspectors concluded that Operations' routine processes and their
administration were a weakness. The inspectors noted that Operations processes weaknesses' had been contributing causes for a large portion of previous licensee and NRC identified problems.
Problems included
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routine log reviews, implementation of short-term guidance, and
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recording of equipment out of service (Section 03.2).
The Required Action Log role and guidance was unclear. The inspector
identified that it was inappropriately used for Technical Specification compensatory action tracking, was not on operators' turnover sheet checklist.to be reviewed, and was poorly integrated with other.
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processes.
The administration of the log and attention to detail were al,so poor and the process-appeared to inconsistently overlap other
'llcensee programs. (Section 03.2).
The inspector concluded the Operability Concerns Resolution (OCR)
process and nonconforming condition Deficiency Report (DR) process were-technically sound and complied with regulatory guidance in NRC Generic Letter'91-18.
Safety expectations were clear and conservative (Section l
03.3).
Administrative implementation of the OCR and DR programs by Operations
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was poor. The inspector identified that:
there was not a consistent way of im]lementing compensatory actions: there were errors in the OCR log, tracting of OCRs was unclear procedurally and was unfamiliar to many licensee personnel: an old Short Term Instruction was active and I
renewed although it conflicted with a Deficiency Report Justification for Continued Operations evaluation; and Precursor Cards were not promptly initiated to address some of these problems after they were identified (Section 03.3).
l Human performance errors caused an operability test of an emergency
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diesel generator to be suspended due to an incorrect valve alignment restoration-following a coolant change-out.
Other operator human performance errors were indicative of )oor procedure usage and-
-questioning of abnormal conditions. T1e ins)ector concluded that the-
aggregate of these errors indicated that altlough human errors and attention to detail have improved from past observations, they remain valid concerns for the licensee. Operator's questioning of some of the discrepancies was marginal and therefore failed to preclude earlier detection of the problems (Section 04.1).
While accompanying a 3rimary plant operator on shift rounds, the
inspector concluded tlat the operator's knowledge of plant systems, equipment history, and ongoing work and activities was very good.
However, the operator was not knowledgeable of )lant expectations for treatment of contaminated area boundaries, whic1 was an example of management expectations not being effectively promulgated (Section 04.2),
The reviews of the Nuclear Quality Assurance auditor remain focused on
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app opriate areas and they have identified notable issues with tracking-of lant equipment status and configuration control, similar to NRC fin ings, and several' problems with the licensee's control of spare material storage. However, they have had difficulty defending their findings to licensee management and their ownership of their findings
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has been inconsistent as evidenced by delayed or inaccurate corrective i
actions by line organizations. They continue to perform good assessments of the licensee's performance (Section 07.1).
The new Corrective Action Review Committee was an effective and prompt
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-licensee initiative to address previously reported problems with inconsistent and weak apparent cause evaluations.
Trending of items in the corrective action system was not a fully developed program but was evolving adequately per licensee plans already in place (Section 07.1).
Maintenance Maintenance activities were adequately performed and documentation was
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good.. Procedures were in place and were being conscientiously followed by qualified maintenance personnel.
Interface between maintenance and operations personnel was good (Section M1.2).
Applicable foreign material exclusion controls, measuring and test
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equipment controls, post maintenance testing requirements, and quality control hold points were being accomplished in accordance with requirements (Section M1.2).
Preventive maintenance (PM) and surveillance requirements for the fire
protection equipment for the 4160V switchgear were being met (Section M1.2).
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J A weakness was. identified because of a discrepancy between PM Procedure e
PM-275 requirements, and the implementing PM Control sheet and work request for the Auxiliary Feedwater Pump FWP-7 Backup Power Supply MTDG-1 (Section M1.2).
Improved material condition was noted in the areas where the plant
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coatings project had been completed, such as' the intermediate building and the upper levels of the turbine building (Section M2.1).
In areas that had not yet been cleaned and re-coated, such as the sea
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water room and the lower level of the turbine building, there was some
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evidence of corrosion and deterioration of equipment and supports-(Section M2.1).
The licensee has established an improvement plan for the maintenance
function at.the plant. -While stilI in the early stages of
. implementation, the plan appears to be thorough, defining the weak areas i
and systematically addressing the targets to be implemented to address-the weaknesses (Section M6.1).
Many of the licensee goals for the maintenance performance indicators
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have either been met or displayed sustained positive trends, i
demonstrating improvement in the implementation of the maintenance program.
Final assessment will depend on the licensee's completion of the plan and sustained improvement in the various areas (Section M6.1).
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The development of an accurate schedule and adherence to it were
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significant licensee management priorities. Schedule adherence and planning implemented by the new 12 week rolling schedule had improved coordination of work between licensee departments.
Enaineerina Engineering had provided good support to maintenance for resolving
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issues and concerns with sizing of overload heaters for motor operated valves the thermography for monitoring a step-up transformer hot spot, the replacement of the Integrated Control System power su) ply, and the resolution of the GE 10 CFR Part 21 for SMB control switcles (Section E1.1).
A Non-Cited Violation (NCV 50-302/98-04-02) was identified for an
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example of poor implementation of a revised calculation. The problem resulted in the reactor coolant pump lube oil collection system being incapable of collecting all four reactor coolant pumps' lube oil as required (Section E1.2).
The licensee had effectively determined the cause for premature failures
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of rupture disks in their containment penetration expansion chambers as inadequate vendor interpretation of their purchase specification.
Their investigation was thorough and methodical and resolved the design concerns. As a contingency action, they proactively performed an operability assessment on chambers that had not experienced problems (Section E2.1).
A Violation (VIO 50-302/98-04-03) was identified when it was determined
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that the licensee did not comply with the requirements of their corrective action program.
FSAR discrepancies identified in an interoffice correspondence were not processed in accordance with compliance procedure CP-111 (Section E8.1).
The inspector identified that the licensee completed the needed
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corrective action, so LER 50-302/96-10-00 is closed.
However, the final corrective actions to address potential throttle valve blockage were not verified by the licensee to ensure they were successful and they were not delineated or tracked in the licensee's corrective action and commitment tracking systems.
This was considered an example of poor
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corrective action and commitment closure (Section E8.11).
Plant Sucoort The inspector concluded that although the chemistry activities were
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performed in accordance with procedures and in each case the desired results were obtained, a lack of attention to detail in the chemistry l
procedures was observed (Section R1.1).
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Overall, the plant water chemistry for primary and secondary water e
systems was being maintained well below the a]plicable Technical Specifications and procedure limits (Section 11.2).
No adverse trends were identified in the Annual Radiological Effluent
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l Report and all effluents were well within limits (Section R1.3).
. Radioactive waste and radioactive material shipping papers were properly
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completed (Section R3.1).
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Documentation and corrective actions for Health Physics and Chemistry e
related program problems were adequate and improving. A lower threshold l
for initiating items in the corrective action system was observed and
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developed corrective actions were more comprehensive (Section 7.1).
l Records reviewed by the inspector reflected that the licensee was in
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l compliance with 10 CFR 73.56(e) security regulations and implementing l
procedures for appeal rights of individuals denied unescorted security l
access (Section S1.1).
The inspector determined that additional administrative duties assigned
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to Secondary Alarm Station operators did not impede their responsibility to monitor the alarm response activities of the Central Alarm Station (Section 52.1).
Botn passive and active barriers of the Vehicle Barrier System were in
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place and operational as required by the Physical Security Plan (Section I
E2.2)
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Per 10 CFR 50.54(p)(1), a Violation (VIO 50-302/98-04-04) was identified when Revision 13 of the Physical. Security Plan decreased the effectiveness of the security plan (Section S3.1).
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Report Details
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Summary of Plant Status The plant began the inspection period in Mode 1 at 100% rated thermal power.
The plant remained at full power o)eration until April 3, 1998, when power was reduced to approximately 18% and t1e main turbine generator taken off line to perform corrective maintenance.
The turbine was placed back on line April 4, 1998 and 100% power was achieved later that day.
The plant remained at 100%
power for the remainder of the report period.
I. Operations
Conduct of Operations 01.1 General Comments (71707)
Using Inspection Procedure 71707, the inspectors performed routine reviews of plant operations which included shift turnovers, response to emergent problems, log reviews, observations of operator rounds, coordination meetings, and equipment tracking and operability determinations.
Significant observations are discussed in subsequent paragraphs.
The licensee removed the turbine generator from service on April 3.1998 to perform repairs to a main step-up transformer bushing, a condensate pump motor brush, a waterbox screen, and to install a tem)orary power supply in the Integrated Control System (ICS).
None of t1ese repairs individually required the unit shutdown but the licensee elected to remove the unit from service based on the aggregate risk of any of the item worsening and causing an unplanned forced outage. The inspectors observed that the outage scope was controlled to limit it to only these items and it was scheduled in detail. Accountable teams were assigned for each of the items on the schedule.
This planning resulted in the outage progressing very closely to the schedule and the unit returning to service on schedule, even though some late-identified and emergent items related to the originally scoped items had to be included in the schedule. The licensee conducted a thorough post-outage critique and identified items to improve performance even further. The inspectors considered the licensee *s outage performance to be an example of good planning and execution that is indicative of the improvement the licensee has made in scheduling and coordination between departments.
01.2 Poor Consideration and Trackina of Technical Specification Requirements a.
Insoection Scone (71707 and 61726)
The inspector reviewed the details surrounding five licensee-identified instances where entry in to appropriate Technical Specification (TS)
Limiting Conditions for Operation (LCO) and actions were either not
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recognized and implemented or not logged. The instances occurred during routine surveillance testing and maintenance activities.
b.
Observations and Findinas On February 7. 1998. while performing Surveillance Procedure (SP) 358A.
Operations Engineered Safeguards (ES) Monthly Automatic Logic Functional Test #1, operators did not recognize and enter the TS four hour action statement for LCO 3.6.3 on Containment Isolation Valves.
It was a)plicable when air valves were opened to supply test air pressure to-tle reactor building pressure switches. The licensee identified the oversight on February 16. 1998.. and initiated precursor card.(PC) 98-1069 to perform an apparent cause investigation and identify corrective actions. The licensee verified that the valves were open much less that the required four hours of the LC0 and were independently verified closed upon com)letion.
The LC0 action requirement was to isolate the penetration witlin 4 hours4.62963e-5 days <br />0.00111 hours <br />6.613757e-6 weeks <br />1.522e-6 months <br /> so the inspector confirmed it was not violated. The licensee determined the SP had recently been revised due to a modification and didn't clearly delineate the new applicability of the TS LC0 when aligning the test air.
It also contained an error in a Caution note stating the TS requirements were only applicable in Mode 4 versus the required Mode 1 through 4.
The corrections to the SP were verified com)lete by the inspector. The licensee also promulgated details of t1e incident to all operators via an Operations Study Book (0SB) entry. The inspector noted that the aforementioned modification was a significant Restart Item to correct previous noncompliance with TS 3.6.3.
The details of the modification and its TS implications were well promulgated during the outage and should have been recognized by the operators.
'On March 3. 1998, operators were performing a portion of procedure SP-
'358B. Operations ES Monthly Automatic Logic Functional Test #2, and again did not recognize and enter an LCO action statement when an ES channel for containment isolation was placed in bypass. The LC0 for TS , 3.3.7 required declaring the affected containment isolation valves i
inoperable or placing them in a fail safe position within one hour of l
putting an ES channel in bypass. The error was detected by the Nuclear
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Shift Manager (NSM) but not until one hour and 11 minutes had elapsed.
The switch was taken out of bypass. the operators retroactively declared the affected valves inoperable for the previcus 11 minutes, and PC 98-l-1319 was initiated to investigate and identify corrective action. The
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inspector noted that only eight valves were affected which were not already closed and therefore in their fail safe position.
Declaring i
them inoperable required entry into TS 3.6.3 for containment isolation
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valves. The operators had previously recognized this as applicable and
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entered the requirement at the beginning of the test.
It allowed 4
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hours prior to taking action to isolate each containment penetration.
Consequently. no physical action was required to be done that had not l
been taken. The involved operators again attributed the oversight to the lack of a specific note in the SP procedure step text directing them to the TS requirement prior to placing the switch in test.
Licensee
management took issue with this excuse and reiterated their expectation j
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that licensed operators are expected to recognize equipment TS applicability regardless of whether cautionary notes were present. The inspector also determined that TS 3.3.7 was clearly referenced as an applicable LCO in the reference section-of procedure SP-358B.
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corrective actions, the licensee also promulgated details of this problem via an OSB entry and posted comments against the SP to add a note in the step text alerting the operator of the pending TS implications.
On February 28, 1998, while performing procedure SP-340F, Makeup Pump 1C and Valve Surveillance, operators placed raw water valve (RWV) 150 in test but did not recognize doing so could require entry into LCO action l
statement condition A for TS 3.7.9 and 3.7.10.
RWV-150 recirculates a
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)ortion of the normal seawater supply after it has been heated by the iuclear Services Closed Cycle Cooling System (SW) heat exchangers to control SW system temperature above a minimum of 80 F.
Placing it in test disabled the interlock that would close the valve following a start of safety-related raw water pumps (RWP) 2B or 3B. The failure of RWV-150 to close on an emergency actuation of these pumps would result in elevated seawater supply temperatures in the B train, potentially rendering the B train of RW incapable of removing the necessary amount of heat and requiring entry into LC0 3.7.9 for RWP-28 and LCO 3.7.10 for RWP-38. The oversight and lack of guidance in procedure SP-340F was questioned by a member of the oncoming Operations crew and PC 98-1264
. was initiated to perform an investigation. The licensee subsequently determined on March 24, 1998, that the disabling of the RWV-150 interlock. rendered the RW system susceptible to a single failure, determined TS requirements were applicable, and initiated PC 98-1660 to do a root cause. The LC0 action statements each required the turbine-driven emergency feedwater pum) (TDEFP) and flowpath be verified operable within one hour and t1e associated RW train be restored to i
operable within 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />. The licensee determined that RWV-150 was only in test for five hours and that the TDEFP and flowpath were operable because during the time RWV-150 was in test for procedure SP-340F, the operators were also in LCO 3.5.2 for an inoperable train of the i
emergency core cooling system.
LC0 3.5.2 also contained the exact same
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aforementioned action to verify the TDEFP. which the operators had
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com) lied with and logged.
Consequently the ins)ector considered this
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l pro)lem was only a failure to recognize applica)ility of TS requirements, not a failure to take the required actions and L
verifications.
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Two more examples involved logging and tracking of a TS LC0 entry.
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April 20, 1998, control complex heating coil AHHE-4B was removed from service and entry into TS LC0 3.7.18 Control Complex Cooling. Condition B was entered in the NSM turnover sheet and Equipment Out of Service
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.(005) log, but not in the NSM or Control Room Operator's narrative log as required by the licensee's 0)erations Instruction (01) 07. Control of Ecuipment and System Status.
T1e licensee subsequently determined that AFHE-4B was not subject to TS 3.7.18 requirements and the LC0 entry was done in error because the work schedule listed AHHE-4B as required by-TS. On April 15. 1998, reactor building (RB) air handling fan (AHF) 1B.
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was removed from service and the LCO entry was also not logged in the
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narrative logs as well as the NSM turnover sheet or 00S 109 The Nuclear Shift Supervisor (NSS) was focused on the potential effect on RB temperature and delayed hanging the clearance after he had authorized it, until he was sure the work was ready to commence. Consequently he diri not log it when it was hung.
The inspector's review of the personnel statements for the licensee's investigation of this event revealed several process problems that contributed to all of the aforementioned events.
First, the delay from the NSS authorization to the hanging of the tags for this last example indicates the lack of a standardized process and time for entering the LC0 clock times. The NSS didn't want to enter the LCO when the tags were authorized because AHF-1B was still in service but the actual hanging of the tags recuired no further NSS involvement to ensure the LCO was formally enterec.
Secondly, the NSS indicated that the NSM was aware of the LC0 and would have logged it if notified. However, the inspector noted that the narrative log is shared between the NSS and NSM and either individual could have logged the LCO. The individual accountable to make the log
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entry is not delineated in licensee procedures. Thirdly, the NSS l
indicated the LCO was not entered in the 00S log by the reactor
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omrators because the duration was expected to be less than one shift.
T11s was allowed per the 00S Log guidance in procedure 01-07. but the inspector considered it an unclear practice, with a significant potential for omission for items extending beyond a shift.
It also caused the inspector to question who was responsible and accountable for tracking the LCO: the NSM, NSS, or reactor operator. Although not clearly delineated in any licensee procedure, most operators considered the NSM, the most senior operator on shift, to be responsible.
The inspector considered this a dilution of responsibility and too high a level of accountability.
To independently confirm the problems, the inspector reviewed the logging and tracking of a routine SW pump 1A outage on April 23. The inspector noted that the 00S Log and NSM narrative log both logged LC0 entry at 4:11 a.m. but the control board operator log did not mention entering the LCO and the auxiliary building operator log indicated the LCO was entered at 4:45 a.m.
All three operator narrative logs recorded that the pump was available when it was restarted at 7:13 p.m., but only the 00S Log and NSM narrative log recorded that the LC0 was exited at 10:35 p.m.
The inspector's review of the licensee's processes revealed that a l
formal and dedicated process for tracking LC0 actions did not exist.
The licensee accomplished the function in other processes such as logs, turnover sheets and equipment out of service tracking.
The licensee was reviewing their process deficiencies and considering broad corrective actions in their investigation of these problems, c.
Conclusions The inspectors concluded that these TS recognition and tracking errors raised two concerns.
First, they were indicative of some operator TS l
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applicability knowledge weaknesses.
Secondly, they indicated that the licensee's LC0 tracking process was poor and informal.
Several near-misses of TS LCO requirements, which were fortuitously able to be determined, post-event, to be in compliance, indicated the weakness in LCO tracking. The inspector determined that administrative LCO tracking requirements were not detailed and were scattered throughout various and overlapping Operations Instruction procedures.
The accountability for tracking and compliance was not clear. The licensee's recognition of TS LCO requirements and tracking of the associated actions were considered a weakness.
01.3 Plant Performance Goals a.
Scone (71707. 40500)
The inspector reviewed the 1998 Performance Goals issued by licensee senior plant management in March, 1998.
b.
Observations and Findinas The licensee issued the Performance Goal listing to succinctly capture several broad initiatives and targets that affected several site groups.
Each of the 10 goals contained a detailed description, desired results, and measurement tools to assess progress. The inspectors have observed that the licensee had previously committed resources to the goals and several of them had progressed significantly. A detailed implementation plan was being further developed by the licensee at the time of the inspector's review.
Some of the noteworthy goals are as follows:
1.)
" Creation of a Supervisory Development Program" was instituted to ensure common senior management expectations and standard methods of implementation were understood at all levels of licensee supervision.
2.)
" Procedure Change Process" was considered disorganized and inefficient by the licensee. There was a lack of formal processes
to verify revisions or changes.
The licensee's project entails a
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complete process improvement and establishment of a consistent procedure hierarchy.
3.)
" Bench marking" with other plants needed to be formalized by issuing consistent department expectations and developing specific
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target areas to assess at other plants. The inspectors have l
observed that the licensee routinely references other plants for problem resolution but the amount and frecuency of personnel trips to other plants had tapered off at the enc: of the outage.
4.)
Development promulgation, and constant revalidation of clear management " Performance Expectations." The licensee and inspectors have observed a contributing cause to inconsistent personnel performance was occasionally poorly communicated expectations.
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Additional goals included On-line Work Controls Process Implementation which is discussed further in Section M6.1. Individual Development and Succession Plans, a complete overhaul of the Clearance Tagging Process, Cost Control Initiatives, a Strategic Plan for Radwaste Storage and l
Shipping, and an overall Facilities Upgrade.
The inspectors observed
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that the licensee's goals targeted appropriate problem areas and were sufficiently self-critical.
Implementation of many aspects was contained in each department *s' individual improvement plans.
c.
Conclusions The licensee issued a set'of 10 site problems as 1998 Performance Goals that effectively captured their most important broad performance issues.
The inspectors concluded the licensee was very effective at identifying and promulgating their broad programmatic problems.
Final implementation of the licensee goals would effectively address several previously documented inspector concerns.
Operations Frocedures and Documentation-03.1 Atmosoberic Dumo Valve (ADV) Backuo Air Sucolv Bottle Pressures low a.
Insoection Scooe (71707)
The inspector reviewed the circumstances of a licensee-identified problem with backup air supply bottles to the once-through steam generator (OTSG) atmospheric dump valves (ADV) that were found below the minimum required pressure.
b.
Observations and Findinas Final Safety Analysis Report (FSAR) section 14.1.2.9.5.2 states that the backup air supply system is capable of operating the ADVs for four hours on the loss of the normal site air' system supply due to a station power blackout. A licensee calculation was )erformed to support Modification -
Approval Record (MAR) 96-07-09-01 whic1 changed the backup bottles from nitrogen to air due to breathing air system cross-connection concerns.
This calculation assumed the minimum required air bottle pressure to
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achieve the four hour requirement would be 1500 psig and that bottles would be replaced prior to dropping below 1650 psig. However, this new-requirement was not translated.into the routine o rator logging requirements. in Surveillance Procedure (SP) 300, rating Daily
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Consequently, the SP-300 log on y recorded pressure downstream of a pressure regulator, as it had done before the modification, and verified it was maintained between 91 and 99 psig. On March 10, 1998, a licensee Operations individual on a plant tour identified that although supply )ressure to the ADVs was between 91 and l
99 psig supply pressures from t1e bottles were 660 psig and 1100 psig respectively for the two air bottle banks to the two ADVs. The licensee attributed the problem to be poor implementation of the MAR requirements.
The inspector considered this similar to previous
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problems with the MAR process sup)orting accurate plant configuration control changes, as discussed in 4RC Inspection Report (IR) 50-302/98-01. As a short term corrective action.. the licensee had implemented an Operations-Impact Review Checklist as part of the MAR process. They were also incorporating the aspects of this problem into already ongoing improvements in the MAR process to address previous problems. The inspector verified the licensee immediately corrected procedure SP-300 to contain the correct logging and bottle replacement guidance.
Although this problem resulted in a non-complianu with the station blackout design requirements, it was licensee identified, was promptly and effectively corrected, and the root cau.se was a problem similar to one the licensee was actively working to correct.
Consequently, it is being identified as Non-Cited Violation NCV. 50-302/98-04-01. Failure to Implement Design Change Assumptions Results in Noncompliance with Equipment Station Blackout Design Requirements.
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Conclusions A non-cited violation was identified for an example of poor implementation of design change assumptions that resulted in failure to monitor and detect pressure of backup air to the atmospheric dump valves that fell below equipment design basis limits. The cause of the problem was similar to previously reported problems with identifying and implementing design change assumptions.
03.2 Doerations Process Problems a.
Insoection Scooe (71707)
As a result of discrepancies noted during review of poor Technical
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Specification LC0 tracking discussed in Section 01.2, the inspector reviewed the implementation of several Operations administrative processes for adequacy.
b.
Observations and Findinas
Several exam)les of poor control of administrative requirements were identified t11s period by the inspector.
NSM narrative logs did not consistently record NSS shift reliefs.
Several operations procedure data packages could not be located when requested by the inspector.
Some original copies were found inappropriately attached to Operations Investigations Reports but one surveillance procedure original copy
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never could be located.
The inspector identified that PCs had not been
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generated for previous examples of known missing Operations procedure I
packages. The cognizant individual was not aware of the requirement to generate a PC for those problems due to insufficient management oversight.
As discussed in subsequent Section 03.3, several discrepancies were also observed in the Operability Concerns Report log.
As discussed in Section E8.15. final guidance from engineering on l~
operabr j and procedural actions to be taken for various ambient tempera Jre effects on emergency diesel radiator coolant was issued by Operations as a Night Order. While of minimal safety significance, it
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is an example of poor Operations administrative control because it is contrary to Operations Instruction (OI) 06, Shift Orders, which states that Night Orders are to be used only for administrative guidance.
PC 98-2117 documented a licensee-identified problem where repositioning of spare electrical breakers, due to an Operating Procedure revision that implemented an alignment change, was not effectively completed.
The inspector noted that this process problem with positioning plant equipment when alignment procedures change was previously noted in IR 50-302/98-01 and therefore still not effectively fixed.
After reviewing the circumstances of a non-safety related backup station air bank that was found low out of specification on pressure due to minor fitting leaks, the inspector questioned the trending capability of operator's log readings. Trending capability was poor in that only two data points were available for viewing in the licensee's com)uterized log 3rogram.
Inspector interviews with operators revealed tlat a change in tie program software several months prior had made the ability to view several logged data points for a single parameter very cumbersome during reviews.
Consequently, operators logging readings and supervisors reviewing logs were not adequately reviewing a large enough sample to detect slow trends in parameters. This problem was recognized by operators but their requests for resolution were not collated and channeled through management effectively to obtain the desired correction to the software.
The inspector also observed numerous inconsistencies with Operations recording of equipment deficiencies. Operations Instruction 01-07.
Control of Equipment and System Status, loosely established a framework for dispositioning degraded equi) ment but as previously discussed in Section 01.2, it made recording _COs optional if expected duration was less than one shift.
Non-TS equipment was tracked inconsistently on watch station lists as well as numerous overlapping sections of turnover sheets and morning status reports.
The inspector observed that recorded equipment was inconsistent between each list, even for watch stations
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such as the NSS and control board o)erator in the same physical location.
The inspector expected t1em to track virtually identical equipment but tha agreement between their two lists was approximately 50L Items were tracked on some lists as emergent problems while not at all on others, indicating guidance and expectations for the tracking of
. equipment problems by Operations was unclear.
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Operations-Instruction (01) 40, Required Action Log (RAL), was a process intended to track items such as equipment on accelerated testing frequencies and equipment needed for a different operating Mode when
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shutdown.
However, the inspector observed discrepancies between the
increased frequency testing list maintained by the Inservice Testing
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f group and the RAL. The inspector also noted that the licensee implemented a separate Restart Mode Restraint List process during the recent plant outage that ap) ears to have superseded the Mode tracking aspects of the RAL.
The RA_ also specifically stated it was not intended for TS LCO action tracking but the inspector noted the RAL i
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contained 31 day valve position verification actions for two containment
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l penetrations declared inoperable.. This was further indication of the licensee's lack cf a formal LC0 tracking process as discussed in Section
l 01.2. because a process for tracking these recurring actions did not exist. The inspector also noted that the RAL was not listed on the o)erators' turnover review item checklist, it did not coordinate with t1e 01-7 00S Log process, and it was poorly cross referenced to other site processes such as the Inservice Inspection program, work request, i
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.and surveillance scheduling.
It also did not contain any dates making determination of the age of any item difficult. The inspector concluded the RAL overlapped and was redundant with other systems and its role and guidance needed revision.
l These examples provide numerous data points which are indicative of poor-administrative controls and process problems in Operations. The licensee confirmed the poor administrative controls at the end of the report period when Operations management reviewed many of the same i
references the inspector did. They issued PC 98-2392 to perform an i
apparent cause determination and implement corrective action. The inspector observed Operations management reenforcing expectations for better administrative performance immediately afterwards.
c.
Conclusions The inspectors concluded that Operations' routine processes and their administration of them Mre a weakness. The inspectors noted that Operations process weaa. esses had been contributing causes for a large portion of previous licensee and NRC identified problems.
Problems included routine log reviews. implementation of short-term guidance, and recording of equipment out of service.
The Required Action Log role and guidance was unclear.
The inspector identified that it was inappropriately used for Technical Specification compensatory action tracking, was not on operators' turnover sheet checklist to be reviewed, and was poorly integrated with other processes. The administration of the log and attention to detail were also poor and the process. appeared to inconsistently overlap other licensee programs.
03.3 00erability Determination and Nonconformance Resolution Proarams a.
Insoection Scoce (71707)
In response to previous concerns with Operations and Engineering interfaces and operator misconceptions regarding the overlap between operability and degraded equipment problem resolution processes, the inspector reviewed the licensee's Operability Concerns Resolution (0CR)
3rocess as delineated in Compliance Procedure (CP) 150. Identifying and 3rocessing Operability Concerns, and Nonconforming Condition Disposition process as delineated in CP-111. Processing of Precursor Cards in the Corrective Action System. Enclosure 1. Deficiency Report (DR)
Instructions. The inspector reviewed several completed issue reports
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from each of these processes and verified regulatory guidance in NRC Generic Letter (6L) 91-18 was met.
b.
Observations and Findinos The inspector observed that several im)rovements to each of the processes had been implemented since t7e original concerns were identified.
Improvements in the DR process addressed format and scope problems and plans were in place to remove it from Procedure CP-111 to a more comprehensive new procedure.
Cross-referencing between DRs and OCRs was improved by using PC numbers.
The phrase " Justification for Continued Operation" (JCO) was removed from the DR process and discussed only in the OCR process, which eliminated a frequent point of confusion with operators.
Procedure CP-150 for OCRs had a conservative safety focus and clear expectations guidance.
The inspector noted the two processes didn't synchronize as well as they should and the OCR process role in the corrective action system was not clear, but they had improved from in the past. The licensee was also evaluating further im)rovements to ensure the two processes became smoothly integrated su) routines of the site corrective action program (CAP). An example of the deficiencies were that both processes could initiate compensatory
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actions (CA), and DR CAs were clearly captured in the CAP while OCRs Were not required to be in the CAP system. Tracking by CAP PC number was implied for OCRs but not required.
The licensee's Nuclear Quality Assurance (NQA) auditors had observed 3revious problems Mth the distribution of completed DRs to Operations.
) distribution was changed to be limited and an informal process screened which ones to keep in the NSM office.
The inspector verified that 6 DR j
reports were maintained in the NSM office and that they were a)propriate references for Operations. However, several other completed D1 reports could also be considered appropriate but were screened out by the informal process. The licensee was in the process of formally incorporating the guidance in the DR process.
Training material provided to Operations to address previous operator misconceptions was good to define the DR and OCR processes and roles.
Administrative implementation of these processes by Operations, however, was poor. The inspector observed that Operations does not have a consistent way of implementing compensatory actions or temporary equipment restrictions that these processes could generate. These actions or restrictions were issued in disperate forums such as Night j
Orders, Short Term Instructicas (STI), Operations Study Book entries, or a revision to a pt ocedure. The inspector identified that active STI 98-15 conflicted with an open DR. resolution. The STI stated the closed-cycle service watet (SW) system was ino)erable if the ultimate heat sink
(UHS) supplied b,v the intake canal reacled 92 degrees F, but DR PC 97-8080 had a more conservative limit of 89 degrees F.
The STI was linked to two closed restart issues but had been reissued twice by Operations
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after expiring.
STIs are limited to three month durations but can be renewed.
It was apparent to the inspector that the related restart t
issues, which had long since been superseded by the conclusions of DR PC
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97-8080, had not been referenced when reissuing the STI. Operations quickly removed the STI but did not issue a PC in the corrective action system until several days later when questioned by the inspector.
PC 98-2287 was then issued to perforn,an apparent cause evaluation.
The inspector also identified errors in the OCR log maintained by Operations in the NSM office. OCR 98-07 for an inadvertent addition of
. argon to a core flood tank (CFT), was recorded in the log index as
" fully operable" so a copy of the OCR was not required to be maintained
in the log book. This was essentially equivalent to saying the OCR was closed.
However, the conclusion of the OCR was " operable, not fully qualified" and compensatory actions were recommended to maintain CFT pressure at an administrative limit higher than the normal limit. This determination required the OCR to be maintained in the NSM log book until the degraded condition was resolved ~and the need for compensatory actions was removed.
Again. 0)erations quickly corrected the problem but due to a miscommunication )etween Operations management, a PC was not initiated until several days later when questioned by the inspector.
The inspector identified several other minor OCR log errors contrary to clearly delineated CP-150 administrative log guidance. Tracking of OCRs was alst not well understood by many licensee personnel. The exact status or an OCR was not clearly delineated as open or closed so personnel were ur,';ure as to where and how long an OCR copy should be
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maintained. Guidance was in Procedures CP-111 and CP-150 but it was not i
clear. These misunderstandings were apparent when several licensee personnel had difficulty obtaining a signed copy of an OCR for several days following an inspector's request.
c.
Conclusions The inspector concluded the OCR process and DR process were technically sound and complied with regulatory guidance in NRC Generic Letter 91-18.
Safety expectations were clear and conservative.
However, administrative implementation of the OCR and DR programs by Operations was poor. The inspector identified that: there was not a consistent way of im)lementing compensatory actions; there were errors in the OCR_ log, traccing of OCRs was unclear procedurally and was unfamiliar to many licensee personnel: an old Short Term Instruction was active and renewed although it conflicted with a Deficiency Report Justification for Continued Operations evaluation; and Precursor Cards were not promptly initiated to address some of these problems after they were identified.
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Operator Knowledge and Performance 04.1 fuman Performance Errors - Valve Misoositionino Followino Chanae out of Emeraency Diesel Generator Coolant a.
Insoection Scoce (71707)
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The inspector reviewed the details of an event involving mispositioned valves identified following coolant replacement for emergency diesel generator B (EGDG-1B), and several other minor operating performance
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problems.
b.
Observations and Findinas Following the removal of anti-freeze from EGDG-1B for warm weather operations on March 18. ?998, the licensee performed Surveillance Procedure SP-354B, Monthly Functional Test of the Emergency Diesel Generator EGDG-1B. Approximately one-half hour after the start of the diesel, the building operator reported that the intercooler expansion tank level had dropped approximately 3/8 from an initial level of 3/4 full. Similar occurrences had been noted in the past following filling of the coolant systems.
The control room supervisor decided to continue
loading EGDG-1B while closely monitoring temperatures and levels.
One hour after the start of the diesel, the DIESEL GEN B TROUBLE alarm was received. The building o)erator was notified to investigate. The investigation revealed that t1e intercooler tank was empty.
The o)erators reduced load on EGDG-1B and shut it down within ten minutes of t1e receipt of the alarm. The operator investigated and determined that i
the jacket coolant tank level was high.
Further investigation discovered that jacket cooling water valves DJV-78 and DJV-82 were open, connecting the normally separate jacket coolant and intercooler systems.
j These valves are located on the bottom of the radiators for the jacket
coolant and intercooler systems and were manipulated per Operations Procedure (0P) 707, Operation of the ES Emergency Diesel Generators, during the refill of the coolant systems.
The inspector reviewed Enclosure 10 Diesel Generator Valve Check List.
to procedure OP-707.
The enclosure had a single sign off for opening and closing all valves associated with each radiator.
Step 4.15.5.8 stated that when 150 gallons of coolant were added into the radiator.
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then close the valves that were used to fill radiator per Enclosure 10.
There was only a single sign-off for all four radiators in the emergency diesel generators.
The licensee determined that the vague procedure guidance was a contributor to the event. A revision to the procedure has been issueC clarifying exact ste)s to be taken when refilling the various radiatort.
The licensee was una)le to conclusively determine how the valves were left open.
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Additional examples of human performance problems were also identified by the licensee this period.
On the afternoon of April 10. 1998, a main control board steam generator level recorder was turned off and inadvertently left off after replacing a defective pen.
The recorder was noted to be incorrect by almost 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> early the next day at 1:40 a.m. by another operator, when checked as ) art of the board operator's routine daily recorder review.
However, t1e magnitude of the error i
relative to the requirement to check it daily was not questioned by the operator who manually repositioned the recorder paper ahead 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> to align the pen with the correct time. The recorder remained off because the operator did not notice the red power light was extinguished.
A third operator detected the roblem during shift relief later that day at 8:45 a.m., and verified a 1 of the control room recorders were f
working. Another error involved a valve closure step that was missed during the performance of fire pump surveillance procedure SP-365C, Diesel Fire Service Pump, FSP-2B Operability. The valve left open was a
recirculation valve to the opposite fire service tank from the one i
supplying water to the running pump which resulted in transferring half of the pumped water from one tank to the other. The level change caused a low level alarm on the supply tank but operators considered it expected due to the test and did not observe the transfer of water between tanks. The error was caught by a NSS during paaerwork review.
The level change was small and difficult to detect on tie coarse control board indicator and did not result in the tank dropping below minimum required levels.
A second operator was available to perform a peer check of the first operator who should have closed the valve, but did not perform this function due to an erroneous assumption that he would be unable to independently verify subsecuent sections of the SP. These
incidents were indicative of poor procecural usage and poor questioning of abnormal indications.
All of these errors were found by the licensee and did not result in safety significant implications. The licensee aggressively addressed each problem with individual corrective actions and an Operations stand i
down. All of these examples were incorporated into an already in-progress root cause investigation for Operations * human errors under PC 98-0180. This effort incorporated other previous errors and was reflective of licensee management's desire to implement a comprehensive solution to what they perceived as an adverse human performance trend.
The licensee's corrective actions included increasing supervisory i
presence in the field, increased crew ownership and accountability for errors, and reinforcement of expectations. The licensee's investigation had not identified a comon cause for the errors but it was still under management review and specific actions were provided to preclude recurrence of each error. The inspector considered the licensee's response to the problems adequate.
c.
Conclusions
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Human performance errors caused an operability test of an emergency diesel generator to be suspended due to an incorrect valve alignment restoration following a coolant change-out. Other operator human L
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performance errors were indicative of )oor procedure usage and questioning of abnormal conditions. T1e inspector concluded that the aggregate of these error s indicated that human errors and attention to l
detail remain valid concerns for the licensee. Operator's questioning of some of the discrepancies was marginal and therefore failed to preclude earlier detection of the problems.
04.2 Doerator Accompaniment a.
Insocction Scooe fil707)
On April 7,1998, the ins)ector accompanied the primary olant operator (PP0) on shift rounds. T1e inspector was assessing whether the PP0 adhered to procedures, understood ongoing activities, identified plant deficiencies, adequately communicated identified deficiencies to supervision, and followed-up on actions taken.
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b,.0 observations and Findinal The operator was very knowledgeable on plant systems and past history associated with various equipment. The operator understood ongoing activities and observable deficiencies (usually in the form of a deficiency tag) when questioned by the inspector. While the operator was observing makeup pump (MUP) operation. the ins)ector observed the operator reach across a contaminated boundary to s11ne his flashlight on a sightglass.
The operator did not touch or manipulate any components.
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The inspector questioned the operator on the expectation or requirement for treating contaminated area boundaries (CAB). The operator was unsure of the requirement, but after some thought, believed the expectation was to treat a CAB as if a geometric plane ran from the floor to the ceiling at the point where the CAB rope was hung. The
o)erator indicated to the inspector that he would followup with a health
l p1ysics-(HP) technician after rounds were completed.
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L An HP technician was encountered a short while later and asked by the o)erator how to treat a CAB. The HP technician indicated that a CAB
siould be treated as an infinite ) lane running from the floor to the
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l ceiling at the point where the CA3 ro)e was hung. After the PPO completed shift rounds, he informed tie nuclear shift su)ervisor (NSS)
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about the inspector's question. The NSS confirmed the H) technician's
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answer. Several days later an Operations Study Book entry was written
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to ensure all operators were aware of the requirements for treating
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CABS. PC 98-2064 was also written to document the poor radiation work practices.
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Conclusions The inspector considered the primary plant operator's knowledge OT plant systems, equipment history, and ongoing work and activities to be very good. However, the operator's knowledge of plant expectations and
requirements for treatment of contaminated area boundaries was poor and an example of management expectations not being promulgated.
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Quality Assurance in Operations l
07.1 Licensee Self-Assessment Activities a.
Insoection Scone (71707 and 40500)
The-inspectors routinely reviewed various licensee self-assessment activities and corrective action processes which included review of Nuclear Quality Assessments (NOA) surveillance-and audit report findings, review of precursor cards entered in to the corrective action system, and performance of the Corrective Action Review Board (CARB).
b.
Observations and Findinas The inspectors attended the NQA Exit Meeting for their 98-03 audit of
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Materials Controls on April 6,1998. The inspectors observed that the NQA staff still had difficulty defending and discussing their findings when fairly challenged by licensee management.
Licensee management has also exhibited dissatisfaction with the NQA ownership and disposition of their findings. Resolution by line management of several NOA-identified issues has been delayed and licensee senior management expected better ownership by NQA to ensure cc/rective action prioritization and completion. However, the inspector noted from the detailed written descriptions of N0A findings that they had identified relevant issues with tracking of )lant equipment status and configuration control that were similar to t1e previously discussed NRC findings and that they identified several notable problems with the licensee's control of spare material storage. Their activities and reports were generally focused on safety-significant evolutions and processes, they contained relatively balanced findings and enhancements, and they've been observed altering. inspection schedules to observe critical plant evolutions such as the April 3, 1998 outage. The inspector did not identify any significant concerns with NQA activities and concluded they continue to adequately assess the licensee's performance.
The Corrective Action Program implemented a new Corrective Action Review Connittee (CARC) to address previously reported problems with poor and inconsistent apparent cause evaluations of Level C PCs.
The inspector attended the monthly CARC meeting on April 1,1998, and reviewed the guidance the committee used to assess each PC.
Membership was appropriately distributed amongst site organizations and expectations guidance was clear. The inspector noted that the each CARC member reviewed and graded 6 PCs prior to the meeting, one from each major-licensee department.
The individual grading of the six PCs was discussed at the meeting and the basis for each individuals' grades was discussed. The intent of this review and discussion was to ensure each
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CARC member had a common understanding and implementation of the grading criteria. The inspector observed that the evaluations were critical and i.
fair and the discussions raised a)propriate issues. The value of a committee format was evident by tie varied perspective of the questioning.
Afterwards, the committee members divided up all of the remaining Level C PCs for.the preceding month and graded each one
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individually.
The assessment was then routed back to each apparent cause evaluator and supervisor to provide feedback, Unsatisfactory evaluations were required to be.:Crrected. The inspector concluded the CARC was a beneficial effort and appropriately addressed the weaknesses with Level C PC apparent cause evaluations.
The inspector also reviewed the trending activities and capabilities of the corrective action program.
Although the licensee has started trending cause and event codes per fndically, their trending program is in the initial transition from cogn u.ive trending by managers to computer code trending.
The licensee had several initiatives in progress at the time the inspector reviewed the process such as formalizing the trending 3rogram and soliciting line organization input on which parameters were 3eneficial to trend.
The inspector concluded the licensee's trending process was not fully developed but was evolving adequately under the licensee's plans.
c.
Conclusions The licensee's Quality Assurance auditors' reviews rema * focused on appropriate areas and they have identified relevant issbes with tracking of plant equipment status and configuration control, similar to NRC findings, and several notable problems with the licensee's control of s)are material storage.
However, they have had difficulty defending t1eir findings to licensee management and their ownership of their findings has been inconsistent as evidenced by delayed or inaccurate corrective actions by line organizations. They continue to provide good assessment of the licensee's performance.
The new Corrective Action Review Committee was an effective and prompt licensee initiative to address previous problems with inconsistent apparent cause evaluations. Trending of items in the corrective action system was not a fully developed program but was evolving adequately per licensee plans already in place.
Miscellaneous Operations Issues 08.1 (Closed) IFI 50-302/95-21-02: Modification to The Standby Feedwater Pumo Recirculation Line (92901)
This inspector followup item (IFI) was opened to track the licensee's actions to address Institute for Nuclear Power Operation (INPO)
Significant Operating Event Report (SOER) 93-01, Diagnosis and Mitigation of Reactor Coolant Leakage Including Steam Generator Tube Ruptures. This INP0 SOER 93-01 discussed the contamination of approximately 750.000 gallons of secondary system water as a result of a 240 gallons per minute (gpm) steam generator tube rupture that occurred at Palo Verde Unit 2 in 1993. Without the ability to manage this quantity of water, the turbine building sumps overflowed and about 48.000 gallons went on the turbine building floor.
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In response to INP0 SOER 93-01, the licensee initiated MAR 94-07-06.
Contingency Storage for Rad Waste from Tube Rupture, to provide a path to discharge contaminated water from the feedwater system following a steam generator tube rupture. The modification provided a tee in the Feedwater Pump (FWP)-7 recirculation line to allow water to be diverted to the fire water storage tanks and the turbine building drain tank, SDT-1. However, as a result of further engineering study, the licensee decided to im)lement a new MAR-97-07-10-01 CDT-1/FST-1A Cross-Tie, to address the lip 0 SOER 93-01 issue.
The modification provided a permanent, normally isolated, cross-connection line between Fire Water Storage Tank (FST)-1A and the non-safety related portion of the condensate water system / emergency feedwater system supply header to the Emergency Feedwater Pumps (EFP-1 and EFP-2).
In addition, new valves were installed at existing tank nozzles ors both FST-1A and CDT-l'in i
order to provide the ability to access the tank contents for clean up or sampling purposes, as necessary. This modification accomplished two objectives:
1) it would permit the use of FSTs. If necessary, as a coolant supply to the secondary side of the OTSGs via the EFPs or FWP-7
in a natural circulation cooldown event, without the necessity for temporary equipment and hoses, and 2) it would also permit the use of FST-1A for extra storage volume in an OTSG tube rupture event, if necessary.
Both uses would need operator actions (manual valves at the tanks) in order to implement the features.
The inspector reviewed the licensee's modification package, including the safety assessment and the 10 CFR 50.59 evaluation. The inspector determined that the modification package was appropriately reviewed by cross-discipline engineers, the final design review board, and the plant review committee.
The affected plant drawings and operations procedures were modified to reflect the changes. The inspector concluded that the licensee adequtely addressed the INP0 SOER 93-01 issue. Therefore, this IFI was closed.
08,2. (Closed) LER 50-302/96-09-00: Failure to Re-Attach Instrument Tubina to Seismic Sucoorts After Modification Leads to Goeration Outside Desian Basis (92901)-
On March 27, 1996, while performing a system walkdown inside of the
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reactor building. the licensee discovered that the instrument tubing i
downstream of valve MSV-171 had been removed from its seismic supports, leading to an unsupported length of approximately 17 feet. The tubing had been removed from its supports in 1992 to allow for installation of a work platform, and had inadvertently not been re-attached due to interference with structural members associated with the platform.
The apparent cause for this event was a personnel error and inattention to detail for failure to re-attach the instrument tubing. This issue was discussed in greater detail in IR 50-302/96-03 and was identified as-Unresolved Item (URI) 50-302/96-03-06, Instrument Tubing Supports Removed Without Work Instructions and Not Reinstalled.' After the NRC
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inspector completed review of the event. URI 50-302/96-03-06 was closed
and identified as Non-Cited Violation (NCV) 50-302/96-05-03.
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Based on review of the Licensee Event Report (LER) and the previous NRC i
inspection activities on this issue, the inspector determined that the licensee's corrective actions were appropriately implemented.
Therefore, this LER was closed.
08.3 (Closed) LER 50-302/96-15-00: Personnel Errors Cause Cable Seoaration/ Isolation Concerns Resultino in Ooeration Outside the Desian Basis (92901)
On April 8, 1996, while Crystal River Unit 3 (CR-3) was in Mode 5, the licensee determined that the cable and circuits did not meet Crystal River 3's separation criteria. There was no isolation between safety-related and non-safety related portions of the electrical cables to the toxic gas monitors.
The apparent cause of this event was personnel error by both installation and design personnel.
Plant personnel improperly routed the cable, creating a separation problem.
The design engineer was not familiar with Crystal River Unit 3 electrical separation and isolation requirements.
Corrective actions included discussions with the design engineering review board to heighten awareness for future design
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reviews, a dissemination of lessons learned to all design personnel, and modifications necessary to bring the circuits / cables to full qualification.
Although this item was a noncompliance with regulatory requirements, for the reasons discussed in IR 50-302/97-21, the licensee met the criteria for enforcement discretion per Section VII.B.2 of the NRC Enforcement Policy as described in NUREG-1600.
Consequently, this item was closed and was identified as another example of NCV 50-302-97-21-01, Examples of Noncompliance in Design Control. 50.59 Evaluations, Procedure Adequacy Re)ortability, and Corrective Actions That Are Subject to
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Enforcement )iscretion.
08.4 (Closed) VIO 50-302/96-11-01: Inadeouate Work Instructions to Prevent the Inadvertent Start of Emeraency Diesel Generator EGDG-1A (92901)
A clearance was written to support load testing on Emergency Diesel Generator EGDG-1A. Normally, the clearance would include tripping the fuel racks: however, the racks were not tripped because this would prevent the measurements being made as part of the test.
During restoration, the diesel inadvertently started when the operator opened the air isolation valve, thus allowing enough air to be admitted to roll the diesel.
Subsequent tests conducted by the licensee determined that when the diesel was configured with the fuel racks engaged and the starting air isolated, rapid opening of the isolation valve can cause the diesel to start as the air reaches the diesel prior to the air supply valves isolating.
The licensee changed the standard clearance process for the diesels to add a note to open the air isolation valves slowly.
Information labels have been installed on the air. isolation valves for both diesels,
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reinforcing to the operators that the diesels can potentially start if the air isolation valves are not opened slowly.
An Operations Study Book entry was made to notify Jersonnel of the event.
Training for primary plant operators was enlanced to include lessons learned from the event. Additionally, the Maintenance Activity Control System (MACS) was changed to add a caution to open the air isolation valves slowly.
The inspectors concluded that the licensee's corrective actions were a)propriate, verified the corrective actions were implemented, and t1erefore consider the issue closed.
II. Maintenance M1 Conduct of Maintenance M1.1 Conduct of Maintenance (62707 and 61726)
Maintenance and surveillance activities-were observed or reviewed by the resident inspectors during the reporting period to verify that work was conducted in accordance with approved procedures, Technical Specifications, and a)plicable codes and standards. The inspectors verified that the worc was performed by properly qualified personnel and that the work instructions provided sufficient detail and guidance for i
the intended work activity. Work documents were examined to verify 3 roper authorization to begin work, provisions for control of fire lazards and housekeeping, as low as reasonably achievable exposure control, proper return of equipment to service, and any applicable
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limiting conditions for operation were met. The inspectors observed all or portions of the following work requests (WR) and surveillance procedures (SP) and reviewed associated documentation:
SP-130 Engineered Safeguards Monthly Functional Test
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SP-334B SFP-1B Quarterly Surveillance SP-340F MUP-1C and Valve Surveillance
WR 352230 AHF-17B Fan Inspection
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WR 345943 Run AJiF-17B Motor for Vibration Checks
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l The inspectors did not identify any significant deficiencies with these l
work activities.
Notable work inspection observations and reviews by regional inspectors are discussed in the following paragraphs.
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I M1.2 Review of Intearated Maintenance Activities i
l a.
Insoection Scooe (62707 and 61726)
The inspectors observed maintenance in process, examined records of l
. completed maintenance, and reviewed Preventive Maintenance I
(PM) activities for selected components to evaluate the effectiveness of i
L-the licensee's maintenance program.
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b.~ Observations and Findinas b.1 Observation of In-orocess Maintenance The inspectors observed maintenance / surveillance activities for selected portions of the following WRs and SPs, and reviewed associated documentation to verify that maintenance was planned, i
controlled and performed in a manner to enhance safe operation of i
the plant:
1 Procedure SP-113. Power Range Nuclear Instrumentation
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Calibration WR NU 0344386. Calibration of Decay Heat Service
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Cooler DCHE-1B Sea Water Instruments RW-32-THE, RW-32-I TI, and RW-32-TT
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WR NU 0352999, Repair Seat Leak on Turbine Gland Seal I
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Valve GGV-215 WR NU 0351670, Repair Packing Leak on Turbine Gland
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Seal Valve GSV-3 WR NU.0353326, Shoot and Clean Nuclear Service Water
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Heat Exchanger SWHE-1A WR NU 0352234 Inspect Turbine Generator TBTG-1 Ground
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Strap Procedure SP-521, Quarterly Battery Check for B
250/125V Battery Bank WR NU 351243. Troubleshoot Alarm Circuit for Inverter
VBIT-1D During observation of the above in-process maintenance work, the inspectors evaluated procedure use, assignment and )erformance of Quality Control (QC)-lold points. Foreign Material Exclusion (FME)-
controls, Maintenance and Test Equipment (M&TE) controls, Post Maintenance Testing (PMT), and qualification of maintenance personnel. The applicable revisions of 3rocedures were in place and were being conscientiously followed )y qualified maintenance personnel.
Personnel had a questioning attitude and had procedure or WR requirements clarified before proceeding with an activity.
l Maintenance supervision was closely involved with monitoring in-
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process maintenance work.
Good interface between maintenance and j
operations personnel was observed. Applicable FME controls M&TE
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controls, PMT requirements, and OC hold points were being l
accomplished in accordance with requirements The inspectors also observed that work activities were properly documented and a_________
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were appropriately resolved,
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b.2 Review of Comoleted WR Packaael The inspectors reviewed the following recently completed WR packages to assess the adequacy of documentation of completed work:
NU 0353242 NU 0353005 NU 0351260 NU 0353273 NU 0353245 NU 0350482 NU 0352884 NU 0352ce.J NU 0351567 NU 0353328 NU 0352618 NU 0352087 NU 0350951 NU 0353120 NU 0351083 NU 0351532 NU 0325315 NU 0346593 NU 0353365 The WR packages were reviewed in the areas of: general content and reference to appropriate procedures, evidence of observing FME requirements, evidence of OC hold point assignments and sign offs, evidence of pre-job briefings, and specification and completion of post maintenance testing.
For these WRS, the inspectors found l
that the work was being appropriately documented in accordance
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with program requirements.
b.3 Review of PM Activities l
The inspectors reviewed PM requirements and records as follows to verify that appropriate PM was being performed on selected i
equipment:
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Fire 3rotection equipment for the safety-related 4160V switc1 gear rooms consists of two alarmed smoke detectors and j
one fire extinguisher in each room, fire barriers, l
penetration seals, and fire doors.
In addition to walkdown
inspection of each room to observe the general condition of
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the fire protection equipment, the inspectors reviewed the following completed surveillance to verify that the equipment was being inspected and maintained:
Procedure SP-190D, Functional Check of Fire
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Detection System, completed on 8/14/97 and
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3/11/98 Procedure SP-800, Monthly Fire Extinguisher
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Inspection, completed 4/3/98 Procedure SP-805, Surveillance of Plant Fire
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Doors, completed on 4/15/98 PM/ surveillance requirements for the fire protection equipment for the 4160V switchgear were being met, and the
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inspection / review indicated that the equipment was being adequately maintained.
During the last outage a dedicated non-safety-related diesel
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generator (MTDG-1) was added for backup power for non-safety-related auxiliary feedwater pump 7 (FWP-7).
Technical S) edification Change Request Notice 210 considered MTDG-1 and NP-7 as defense-in-depth for certain accident conditions.
The inspectors reviewed the surveillance requirements and PM requirements for MTDG-1.
The surveillance requirements were detailed in procedure SP-348A. Revision 4 Auxiliary Feedwater Pump (FWP-7) Testing and MTDG-1 Surveillance Test, which specified running FWP-7 at full rated re-circulation flow one hour monthly while powered by MTDG-1. When questioned about the PM requirements for MTDG-1, the licensee provided WR NU 0351207, which implemented PM Control Sheet CS5452 and specified a PM at a 6-month interval.
Review of this WR revealed that it contained little detail when compared to the details identified in the vendor manual. After questions by the inspectors, licensee personnel identified a procedure, PM-275, Revision 3. General Preventative Maintenance Work, that included PM requirements for MTDG-1 and addressed most of the PM details in the vendor manual.
Procedure PM-275 had been revised as part of the modification 3rocess that installed MTDG-1.
After discovery of procedure )M-275, the licensee immediately issued a revision to WR NU 0351207 to reference procedure PM-275 for PM of MTDG-1. The discre)ancy between the requirements of procedure PM-275 and the )H Control sheet CS5452 (WR NU 0351207) was considered a weakness in the PM process. The licensee issued Precursor Card (PC) 3-C98-2125 to determine why PM Control Sheet CS5452 (WR NU 0351207) was not consistent with the requirements of procedure PM-275 for PM of MTDG-1.
c.
Conclusions Maintenance activities were adequately performed and documentation was good.
Procedures were.in place and were being conscientiously followed i
by qualified maintenance personnel.
Interface between maintenance and operations personnel was good. Applicable FME controls, M&TE controls, i
PMT requirements, and QC hold points were being accomplished in i
accordance with requirements.
PM/ surveillance requirements for the fire protection equipment for the 4160V switchgear were being met.
However, a weakness was identified because' of a discrepancy between.PM Procedure
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PM-275 requirements and the implementing PM Control sheet and WR for the
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Auxiliary Feedwater Pump FWP-7 Backup Power Supply MTDG-1.
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M2 Maintenance and Material Condition of Facilities and Equipment M2.1 Material Condition and Housekeeoino Observations (62707 and 61726)
In addition to observations during inspection of in-process maintenance activities, the inspectors performed a general walkdown inspection of the turbine and auxiliary buildings to observe plant material condition and housekeeping. The inspectors also discussed with the licensee ongoing improvements in material condition. The licensee stated that the coatings project, which will clean and re-paint the entire plant, was about 25-30 percent complete.
In addition to the material condition improvements made during the last outage, i.e., overhaul of all the major pumps, and upgrades of the emergency diesel generators and the turbine generator, as of late April 1998, the main control board deficiencies had been decreased to 12 and the total control room deficiencies decreased to 46. Also, at the time of the inspection, the circulation water system was being upgraded.
During the walkdown inspections, the inspectors noted improved material condition in the areas where the coatings project had been completed, such as the intermediate building and the upper levels of the turbine building. However, in areas that had not yet been cleaned and re-coated, such as the sea water room and the lower level of the turbine building, there was some evidence of corrosion and deterioration of equipment and supports, M6 Maintenance Organization and Administration M6.1 Maintenance Improvement Plan Assessment a.
Insoection Scooe (62707)-
The inspector reviewed the licensee's Maintenance Improvement Plan and the existing performance indicators and trends in the maintenance area.
b.
Observations and Findinas A number of target objectives have been established to address areas of improvement identified in licensee self-assessments and NRC inspections.
The objectives include improved communications, work efficiency, maintenance coordination and schedules, management field time, defined responsibilities and expectations, work force stability, and improved engineering interface. These objectives were designed to be addressed j
by focusing effort in the areas of organization and organizational
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rocess controls, development, management / worker relations, training,' p/ temporary employee effectiveness monitoring, facilities, and contractor training. The inspector has been monitoring the progress the licensee has been making in identified action steps. The improvement plan has
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been approximately 40 percent implemente.J. This implementation has
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remained on schedule, with extensions requested in just a few areas.
The inspector noted that approximately 80 percent of the improvement
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effort has been assigned to either training improvements or process improvements.
The inspectcr has been monitoring maintenance performance indicators to assess any changes in the maintenance im) lamentation of tasks.
As part of the improvement plan, an improved worc controls process and schedule has been implemented by the hiring of new personnel with operational experience, bench marking with other facilities, and the implementation of a 12 week integrated rolling work schedule. This improvement was also included as a 1998 Site Performance Goal as noted in Section 01.3 to support safe and reliable plant operation and coordinated, efficient use of resources. Th'rteen weeks of the new schedule process had been completed at the time of the review.
During that period, an average of 88 Jercent of the work activities have been completed, as scheduled, per weet. This parameter was closely monitored by licensee management and has shown a consistently improving trend with most recent weeks
averaging above 90 Jercent. Management oversight and expectations for j
schedule adherence lave been stringent and have resulted in very good j
work coordination and scheduler performance. The inspectors have l
observed that work week managers are held to a high degree of accountability. The weekly schedule performance is reviewed in detail the following week and the impact of rescheduled activities and emergent work are individually discussed by senior management. The inspectors observed that the development of an accurate schedule was a significant
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licensee priority and that schedule adherence and planning had improved I
coordination of work between licensee departments.
The corrective maintenance backlog has been maintained below the goal of 200 WRs since the restart of the unit in February 1998.
The schedule since then was designed to maintain an equilibrium backlog, while resources were assigned the completion of special projects since the restart.
During that same period, the late preventative maintenance activities backlog has reduced from approximately 200 PMs to under the goal of no more than 50, with a continuing declining trend. Maintenance planning backlogs have established a constantly reducing trend during this period.
The inspector noted that there were still some areas where the goals had not been met: such as main control board deficiencies, even though improvements have been noted in these areas.
c.
Conclusions The licensee.has established an improvement plan for the maintenance function at the plant. While still in the early stages of implementation, the plan appears to be thorough, defining the weak areas and systematically addressing the targets to be implemented to address the weaknesses.
Many of the licensee goals for the maintenance performance indicators have been met, or sustained positive trends have been established demonstrating improvement in the implementation of the maintenance l
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program.
Final assessment will depend on the licensee's completion of the plan and sustained improvement in the various areas.
Th'e development of an accurate schedule was a significant licensee priority.
Schedule adherence and planning had improved coordination of work between licensee departments.
M8 Miscellaneous Maintenance Issues M8.1 (Closed) VIO 50-302/96-09-01: Failure to Follow a Procedure Resulted in an Inadvertent Initiation of t1e Control Room Emeraency Ventilation System (92902)
During the )erformance of Periodic Test t?T)-366 Toxic Gas Detection System Cali) ration, the lead Instrument and Control (I&C) Technician made a decision to leave and allow an unqualified contract technician to perform a step in the test procedure. The lead I&C technician then attempted to talk the unqualified technician through the procedure over the telephone. While performing a step in the procedure, the contract technician was instructed to place the SAMPLE /ZERO switch to the ZERO position.
In error, the technician ) laced the main power switch to the OFF position instead.
This caused t1e monitor to deenergize and tripped the control complex ventilation system to the emergency mode.
Licensee management counseled the lead I&C technician on the appropriateness of his decision to allow an unqualified technician to perform work independently.
A two hour plant wide stand down meeting was held the following day to review the incident and emphasize the use of the licensee's Event Free Operations Program.
The review included emphasis on the requirement for trained personnel to perform work at CR-3.
Training was conducted for all temporary personnel assigned to the maintenance shop that had not received Stop. Think, Act. Review (STAR)
or procedure use training. A maintenance study book entry was.made to review the event and included emphasis on the use of STAR, the use of qualified personnel to perform independent tasks, and the need to 3rovide training to temporary personnel.
Lastly, the Maintenance Mpartment required all new personnel to complete the Maintenance l
Department Employee Orientation Checklist of the Nuclear Maintenance Manual before they are assigned to work on plant equipment. The inspectors concluded that the licensee's corrective actions were a)propriate, verified the corrective actions were implemented, and t1erefore consider the issue closed.
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M8.2 (Closed) VIO 50-302/97-13-02: Failure to Pet.fgrm an Enaineerina
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Evaluation for the Installation of Scaffolding in the vicinity of Safety
Related Eauioment a.
Insoection Scoce (92903)
The inspector reviewed VIO 50-302/97-13-02 and the licensee's corrective i
i actions, as discussed in a letter dated November 11, 1997.
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b.
Observations and Findinas The inspector reviewed the licensee's response to the violation and the associated corrective action plan developed to resolve the identified
. problems.
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The licensee design engineering department has developed specific requirements for the erection of scaffolding near safety related or vital components. The licensee has created criteria for erecting scaffolding in a seismically rugged configuration. These requirements were added to administrative instructions (AI) 1803.' Safety Standards for Ladders, Scaffolds, and Ancillary Equipment, on November 28, 1997.
Procedure AI-1803 was revised on January 28, 1998 to incorporate a methodology by which scaffolding activities will be evaluated to determine a risk level associated with the work activity. This risk assessment determines whether special considerations are necessary to protect safety-related equipment.
The inspector reviewed the revised procedure and training records for the new programs. Walkdowns of currently installed scaffolding were performed, by the inspector, and improvements were noted in the use of scaffolding.
c.
Conclusions All corrective' actions committed to in the licensee res)onse to the i
violation were verified to be completed.
Improvements lave been noted in the erection of scaffolding near safety-related equipment. This violation is closed.
l III. Enaineerina i
El Conduct of Engineering E1 1 Enoineerina Sucoort for Maintenance a.
Insoection Scooe (37550)
The inspector reviewed several engineering activities that supported maintenance. _ These activities included a temporary modification for the ICS: the calculation nethod for sizing thermal overloads for motor operated valves (MOVs): and the use of thermography to identify and trend a hot spot connection on the "C" phase step-up transformer. The inspector reviewed these items to determine if adequate support was provided and if the support was in accordance with licensee's procedures, FSAR, and NRC requirements.
. b.. Observations and Findinos
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The inspector's observations and finding were:
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1)
Tomocrary Modification for Intearated Control System (ICS)
On February 11, 1998, the unit tripped from full power due to a failure of an ICS power monitoring circuit.
Since then the ICS has had a series of problems that are discussed in detail in IR 50-302/98-03.
One problem identified was that one half of a redundant 24V DC power sup)1y had failed (the -24V side).
The DC
)ower supply contained bot1 a +24V side and a -24V side.
Engineering developed a temporary modification MAR T98-03-07-01.
Addition of Temporary Power Sup)1y to ICS, to replace the -24V side.
The inspector reviewed t1e installation procedure and observed a simulated run through of the procedure that was performed at the training building, using an identical Janel to the ICS panel installed in the plant. An inspector wal(down of the control room ICS panel was performed for the temporary power supply.
This non-safety-related temporary modification was performed by the licensee in accordance with their requirements.
2)
Sizina Thermal Overloads for Motor Doerated Valves (MOV)
The inspector reviewed the licensee's method for sizing overload (OL) heaters in the motor starters for MOVs. The FSAR, Section 6.1.2.4, states that " overload protection, sized one size larger than reconinended by the motor control center manufacturer, is provided for safety-related, motor operator valves for motor protection." The inspector reviewed electrical procedure EDC 4.
Revision 3, Electrical Design Criteria Motor Overload Protection, to examine the methodology used for the sizing calculations. The procedure was detailed and met the FSAR requirement.
Regulatory Guide (RG) 1.106. Thermal Overload Protection For Electric Motors On Motor-Operated Valves, states that " thermal overload devices should be established with all uncertainties resolved in favor of completing the safety related action." The licensee's method met the position in RG 1.106.
One concern identified was that OL heaters may not be available as listed in the original manufacturer's specification tables in their sales literature. The reason was that this sales literature may be outdated. The licensee procurement engineering section addressed this problem by having detailed specifications listed on the purchase orders. These specifications contained the physical characteristics, including heater element resistance.
Receipt inspection was required to verify that the overload heaters met the detailed s)ecifications and the heater element resistance.
This assured tlat the correct overloads were ordered and received.
The inspector concluded the licensee's method for sizing and purchasing overload heaters for MOVs was satisfactory and would prevent the wrong sized OL from being installed.
No safety concern was identified.
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3)
Steo-uo Transformer Hot Soot Maintenance (transmission group) identified a hot spot on the phase "C" step-up transformer during a required thermal scan. The Nuclear Maintenance Department submitted to engineering a Request for Engineering Assistance (REA) No. 980272 concerning the hot spot.
The REA requested that engineering evaluate and provide
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temperature limits for the hot spot.
PC 98-1663 was initiated to
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d3 scribe the problem and recommend corrective action.
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engineering initiated thermography inspections of the three single
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phase step-up transformers to monitor and trend potential elevated temperatures.
Corrective action was recommended and implemented.
The hot spot was caused by a high connection resistance.
The four connector bolts had worked loose and a portion of the contact
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paste had dried.
New contact paste was added, new bolts were j
torqued, and the contact resistance was measured. The contact
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resistance was lowered from the high "as found" value of 319 milli-ohms to the acceptable value of seven milli-ohms. The inspector concluded engineering provided good support to maintenance.
4)
Enaineerina Evaluation of GE SMB Switches General Electric (GE) issued a 10 CFR Part 21 Notification that identified spring return binding in GE Type SMB control switches.
Crystal River Unit 3 had four SMB control switches installed in the main control panel in the control room. The failure mode identified by GE was that the SMB control switches with the spring return function had failed to reset (return to normal position)
properly.
The failure mode had been identified as binding due to an interference between the rear brass bearing and the phenolic rear bearing support. The root cause had been determined to be
" post mold cure" (inadequate curing) shrinkage of the phenolic material.
This condition required an increase in the force to l
operate the switch and caused a sluggish return. The return l
spring did not generate enough torque to overcome the friction.
However, the switch could be manually returned or reset. GE stated the switches should be fully cured over a two year period and the " post mold cure" shrinkage would be corrected.
The engineering evaluation considered two options:
1) replace the switches, or 2) attach a white instruction tag to each switch for a two year period. The instruction tag would require the operator to manually return or reset the switch after each o)eration. The
licensee opted for option two since there was a hig1 risk involved with replacing the switches and associated wiring under the main control panel. The inspector examined the control switches SWP-1A, SWP-1B, RWP-2A, and RWP-2B to verify that a white instruction tag was installed on each switch and that the operators understood l
the instructions. The ins)ector concluded that the engineering resolution for the 10 CFR 3 art 21 GE SMB control switch notification was sound. There was no safety concern.
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Conclusions The inspector concluded that engineering had provided good support to maintenance for resolving issues and concerns with sizing of overload heaters for MOVs. the thermography for monitoring the step-up transformer hot spot, the re)lacement of the ICS power supply, and the resolution of the GE 10 CFR 3 art 21 for the SMB control switches.
El.2 Reactor Coolant Pumo Lube Oil Collection Tanks Canacity Reduced a.
Insoection Scooe (92903)
The inspector reviewed the licensee's root cause report on reactor coolant pump (RCP) lube oil collection tank (LOT) capacity being reduced.
b.
Observations and Findinas The lube oil collection (LOC) system consists of two 400 gallon tanks plus associated piping, with a resultant usable volume of 802 gallons.
The total oil volume for all four RCP motors is approximately 760 gallons: thus the available reserve is approximately 42 gallons.
On February 16, 1998, the LOTS were pumped down after reaching the 10 percent administrative limit as denribad in surveillance procedure SP-300, Operating Daily Surveillance Log. Ap7oximately 62 gallons of fluid were removed from the LOTS. exceeding ti,e reserve volume of the
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LOC system by a) proximately 20 gallons.
Histor1 Rlly, when the LOTS were drained, t1e 10 percent level, as indicated on level indicator LO-48-LI, corresponded to approximately 20 gallons of fluid.
Level transmitter LO-48-LT is used to measure the liquid level in the LOTS and provides a signal to LO-48-LI.
Prior to May 1996. LO-48-LT was calibrated based on the centerline elevation of the transmitter, which is 5.3 inches below the tanks * bottom in a common drain header.
In May 1996, the licensee changed the calibration of the transmitter to more j
accurately reflect the fluid volume inside the tanks (i.e.
indicated
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fluid volume was calibrated from the bottom of the tanks). This recalibration would affect the level limitations in surveillance i
procedure SP-300. At the time the calculation data sheet was revised.
l adequate reviews were not performed to determine the effect of the change to the level indicator or to the associated surveillance procedure.
l The Code of Federal Regulations, Title 10. Part 50 (10CFR50), Ap)endix R. Paragraph III.0, states that the oil collection system for RC)s shall be capable of collecting lube oil from all potential pressurized and unpressurized leakage sites and drain it to a vented closed container that can hold the entire lube oil system inventory. The licensee's Fire Protection Plan (FPP). Section 6.7, states that the RCPs are equipped with an oil collection system in accordance with 10CFR50, Appendix R,
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Section III.O.
In addition. the FPP states that the combined storage
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capability of the LOTS is 800 gallons and would hold the entire volume
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of the lube oil system of all four RCPs. The amount of fluid removed from the LOTS on February 16, 1998, exceeded the reserve limit of the LOC system by approximately 20 gallons and therefore, insufficient volume was available for the collection of RCP lube oil.
j The immediate corrective action implemented by the licensee was the generation of a Short Term Instruction (STI) that established a new administrative limit to ensure LOT capacities would not be exceeded.
Additional corrective actions to be implemented are to revise the calculation for LO-48-LT and incorporate the new administrative limit for LO-48-LI into SP-300.
In addition, Administrative Instruction AI-409. Processing of Data Sheets, will be revised to ensure that the entire instrument string for a component will be reviewed to determine if any surveillance procedures will be affected.
The licensee has several other corrective actions in progress due to previous problems incorporating system changes in to procedures. These actions will address the root cause of this problem.
This licensee identified and corrected violation is being treated as a l
Ncn-Cited Violation, consistent with Section VII.B.1 of the NRC Enforcement Policy.
It is identified as NCV 50-302/98-04-02, Insufficient Volume Available For Collection of RCP Lube 011.
c.
Conclusions The inspectors considered this issue an example of a poor implementation of a revised calculation that resulted in the LOC system being incapable of collecting all four RCPs' lube oil.
E2 Engineering Support of Facilities and Equipment E2.1 [ontainment Penetration Exoansion Chamber Ruoture Disk Failures (Closed) LER 50-302/98-05-00: Premature Failure of Ruoture Disks
Resulted in a lack of Over pressurization Protection in Containment
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a.
Insoection Scooe (37551 and 92903)
As discussed in IR 50-302/98-03, several of the licensee's installed expansion chamber rupture disks had failed routine surveillance checks
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of the chambers. The licensee had already initiated )lans to replace i
the failed disks with higher pressure rated disks.
iowever, during i
this report period, they identified the root cause of the failures. The inspector reviewed the licensee's root cause investigations and their
planned actions. The licensee had issued LER 50-302/98-05-00 on this problem which was reviewed by the inspector.
b.
Observations and Findinos l
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The licensee's previous determination, that their rupture disk sizing l
design was overly conservative relative to normal operational parameters l
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in the affected piping, remained valid.
The disks were sized using system design pressures which were often just above normal operating pressures instead of much higher code allowable stresses for the piping
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material.
However, the licensee root cause investigation determined that the ru)ture disks were also being damaged from application of 55 psig of backpressure on the disk for performance of a containment local leak rate test (LLRT) to verify containment integrity after reassembling an expansion chamber. The 55 psig backpressure was part of the licensee's purchase specification with the disk vendor but they subsequently determined that the vendor interpreted this as 55 psig behinc the disk with normal system pressure on the front side of the disk. The LLRT is done with only atmospheric pressure on the front side of the disk.
The vendor reported that this could potentially deform the disks lowering their rupture setpoint. The inspector observed disks the licensee removed that had been damaged in this manner. Therefore, the combination of the low initial setpoint determination and the damage from the LLRT backpressure caused several of the disks to be ruptured by minor transients in the systems.
The licensee was appropriately
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processing design changes to raise some of the disk set points and procuring different design disks from the vendor that were capable of withstanding a 55 psig LLRT backpressure without deformation.
Although some of the chambers were still awaiting new upgraded disks at the end of this report period, the design changes and the licensee's investigation were complete.
The inspector also reviewed a Request for Engineering Assistance (REA) 980273 analysis that determined the
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operability impact resolution for penetrations 333 and 377 if the rupture disk in the associated expansion chamber were to fail. These two penetrations are for normal reactor coolant letdown and reactor coolant pump seal leak off. A failure would have required isolating these penetrations which in turn would require the reactor to be shutdown due to loss of these functions.
The REA concluded that the penetrations would still be operable even if the expansion chamber were filled with water due to a broken disk and could remain in service.
Although the licensee has not experienced any problems with these two expansion chambers, they proactively were planning for problems and wanted to have the analysis completed in advance. The inspector did not identify any problems with the assumptions of their analysis.
The inspector verified the licensee completed the training and promulgation of lessons learned committed to in the LER. The inspector did not
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identify any further concern with the licensee's actions so this issue
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and LER 50-302/98-05-00 are considered closed.
c.
Conclusions The licensee had effectively determined the cause for premature failures of rupture disks in their containment penetration expansion chambers.
Their investigation was thorough and methodical and resolved the design concerns.
As a contingency action, they proactively performed an operability assessment on chambers that had not experienced problems.
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E8 Miscellaneous Engineering Issues FR.1 (Ocen) VIO 50-302/97-11-07: Deletion of Water Quality Requirements from the FSAR a.
Insoection Scooe (92903)
This violation involved the deletion of water quality requirements from the CR-3 FSAR. The inspectors reviewed the licensee's response to this violation dated October 8,1997, in order to determine if the corrective actions specified in the response had been completed.
b.
Observations and Findinas The inspectors reviewed the following corrective actions that were specified for this violation:
(1)
Previously removed FSAR Tables-4-10, 4-11, and 9-3 were corrected, as necessary, and incorporated into FSAR Revision 24.
The inspectors verified that previous FSAR Tables 4-10 and 4-11 had been incorporated back into the FSAR per FSAR Revision 24 dated January 26, 1998. Previous FSAR Table 9-3 was not incorporated into the FSAR because~ the information was included in FSAR Table 4-10. The inspectors reviewed Table 9-3 and verified that the information was included in FSAR Table 4-10. The inspectors also reviewed compliance procedure (CP)-213. Preparation of a Safety Assessment and Unreviewed Safety Question (USQ) Determination (10 CFR 50.59 Safety Evaluation), Revision 5, and verified that the procedure had been revised to require a review of the Improved Technical Specifications (ITS) Safety Evaluation Report prior to removal of information from the FSAR, in order to increase awareness of the ITS process.
(2)
Configuration Document Integration Project (CDIP) personnel have been made aware of enectations related to the removal of l
information from the SAR.
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The inspectors reviewed a memorandum dated September 26, 1997, from the l
CDIP project manager to CDIP personnel. The memorandum re-emphasized the licensee's expectations regarding the removal of information from i
the FSAR.. The inspectors also held discussions with CDIP personnel and
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verified that they were familiar with the September 26, 1997 memorandum and management's expectations regarding the removal of information from l
the FSAR.
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-(3)
Benchmark the regulatory arocess for updating the FSAR against Systematic Assessment of _icensee Performance (SALP) 1 plants and
revise the process as necessary.
The inspectors noted that the licensee had visited other plants to
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review the regulatory process for updating the FSAR. The licensee
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documented the results of those visits in the Licensing and Regulatory
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Performance Benchmarking Report, dated March 28, 1998.
The inspectors further noted that the licensee was developing compliance )rocedure CP-216, Maintenance of the Final Safety Analysis Report, at t1e time of this inspection. This procedure, when issuea, would provide additional guidance for controlling the removal or relocation of informat;on from the FSAR.
(4)
Several discrepancies identified during the review of License Amendments 149 (upgrade from Standard Technical Specifications TS to the ITS), 150, 151, 152, 153, 154, and 155 for compliance with FSAR information inclusion requirements, will be resolved prior to the scheduled submittal of FSAR Revision 25 on July 31, 1998.
During review of this corrective action item, the inspectors noted that the extent of condition review involved reviewing information contained in the previous TS which was to have been relocated to the FSAR and appropriate procedures as a result of the conversion to the ITS (License Amendment 149). The extent of condition review also included reviewing License Amendments 150 through 155 for compliance with FSAR information inclusion requirements. The licensee had not resolved all of the discrepancies that were identified during the extent of condition review for this violation.
Specifically, no actions had been taken to resolve at least two potential FSAR discrepancies. Therefore Violation 50-302/97-11-07 will remain open pending licensee evaluation and resolution of the FSAR discrepancies identified during the extent of condition review of License Amendments 149 through 155.
During further review of this corrective action item, the inspectors noted that the licensee documented the results of the License Amendment
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extent of condition reviews in Interoffice Correspondence (IOC) NL97-0262, dated August 25, 1997.
All of the discrepancies, except for one i
example in License Amendment 152, were identified in License Amendment 149. The IOC documented potential FSAR discrepancies and procedure discrepancies. The IOC indicated that either a PC had been written or a PC needed to be written for at least 15 of the discrepancies (including the potential FSAR discrepancies). The PC numbers for the discrepancies were not documented in IOC NL97-0262. The inspectors requested copies of the PCs referenced in the IOC in order to determine the status of the
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resolutions. The licensee provided the inspectors with co)ies of PC 97-5686 and PC 97-6292, which were written for two of the FSAR discrepancies. The inspectors noted that PC 97-5686 was referenced in IOC NL97-0262 and was written for the discre)ancies that were the subject of this violation.
PC 97-6292, whic1 was not referenced in IOC NL97-0262, was written for the FSAR discrepancy identified in License Amendment 152. The inspectors questioned licensee personnel about the i
status of the other discrepancies identified in IOC NL97-0262.
The licensee stated that, although the IOC indicated that PCs were written.
PC 97-5686 and PC 97-6292 were the only PCs found in the corrective
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l action program database for the discrepancies discussed in the IOC.
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number of the discrepancies did not aplear to be getting addressed because PCs did not get entered into t1e licensee's corrective action
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program.
There were no actions in progress to resolve at least two of r
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the jotential FSAR discrepancies As a result of the questions raised by tie inspectors, the licensee initiated PCs 98-2129, 98-2130, and 98-2131 to evaluate the two )otential FSAR discrepancies and the other
procedure discrepancies t1at wre identified in IOC NL97-0262. The inspectors rev1ewed the discre)ancies to determine if they were processed in accordance with tie licensee's corrective action program requirements.
Compliance procedure CP-111, Processing of Precursor Cards for Corrective Action Program, Revision 58, dated August 12, 1997, required, in part, that the precursor card process be used to identify,
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document, evaluate, and correct adverse conditions. Adverse conditions
. include non-hardware conditions such as failure to comply with the operating license, technical specifications. licensing commitments, procedures, instructions,. or regulations.
The inspectors determined that the licensee did not comply with the requirements of their corrective action program, in that, the discre)ancies identified in IOC
.NL97-0262 were not processed in accordance wit 1 procedure CP-111. The discrepancies were identified and documented on August 25, 1997. As of April 24,1998, the discrepancies had not been entered in the corrective action program via a 3recursor card to be evaluated and corrected. The inspectors informed tie licensee that this issue would be identified as Violation 50-302/98-04-03, Failure to Follow Procedure CP-111 for Documenting, Evaluating, and Correcting Adverse Conditions.
c.
Conclusions The inspectors concluded that Violation 50-302/97-11-07 will remain open pending licensee evaluation and resolution of the FSAR discrepancies identified during the extent of condition review of License Amendments 149 through 155.
The inspectors identified a violation when it was
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determined that the licensee did not comply with the requirements of
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their corrective action program, in that, the discrepancies identified
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in IOC NL97-0262 were not processed in accordance with procedure CP-111.
E8.2 (Closed) VIO 50-302/97-14-02: Failure to Assure That Conditions Adverse to Quality Are PromDtly Identified and Corrected (92903)
This violation resulted from a weakness in the work control process.
Initially, the licensee identified that several MOVs did not have valve-stem covers installed. Work orders were written to install the missing
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L stem covers. However, the work orders were canceled without the work i
being performed.
Later, the licensee identified that a substantial number of other MOVs also did not have valve stem covers installed. All
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the MOVs were purchased with the stem covers. The licensee identified j
these deficiencies with the missing MOV valve stem covers as a condition l
- adverse to quality without promptly correcting the condition. This l
resulted in a violation of NRC requirements of 10 CFR 50 Appendix B
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Criterion XVI, Corrective Action.
j The licensee. corrected the deficiencies by installing valve stem covers on all the safety-related and Generic Letter (GL) 89-10 MOVs. The inspector conducted a walkdown inspection of the MOVs and verified that f
the valve stem covers were installed.
In addition, the inspector i
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reviewed and verified that Compliance Procedure CP-113A, Work Request Initiation And Work Package Control, Revision 22, was revised to prevent further similar occurrences of that type.
The inspector concluded that the licensee had implemented appropriate corrective action for this violation and to prevent future occurrence.
VIO 50-302/97-14-02 was closed.
E8.3 (Closed) VIO 50-302/97-14-06: Failure to Evaluate Out-of-Tolerance M&TE (92903)
An NRC inspection team identified that the licensee's program to control installed M&TE was deficient in that there was no way to accom)lish
" previous use evaluations" of out-of-tolerance instruments. T1e licensee's calibration laboratory did have a good program to control portable M&TE instruments.
It was controlled by a program within compliance procedure CP-146, M&TE Calibration and Control.
However, the installed M&TE instruments were not controlled under that program and procedure.
The installed M&TE instruments included pressure gauges and other process instrumentation used in Inservice Test (IST) Program. The procedure used in the IST B, and Valve Surveillance. program was procedure SP-340C, MUP 1-A MVP 1-Several installed instruments used as M&TE in the IST program with procedure SP-340C were not evaluated for out-of-tolerance calibrations.
The licensee stated that the reason for the violation was a program weakness.
The licensee corrective action included a review of all IST surveillance where installed instruments were used as M&TE. Nineteen installed instruments were found to be out-of-tolerance.
Appropriate action was implemented to correct these deficiencies.
In addition, the licensee developed new requirements and guidance for installed M&TE in Technical Support Standarc (TSS)-10. Review of Out of Tolerance Instruments.
TSS-10 provides the detailed guidance to the Nuclear Plant Technic 61 Su3 port (NPTS) Engineer (s) on what reviews and notifications are needed w1en out-of-tolerance instruments are identified.
The inspector concluded the licensee had implemented adequate corrective action to address this violation and prevent future occurrence.
VIO 50-302/97-14-06 was closed.
E8.4 (Closed) VIO 50-302/97-14-07: Failure to Follow Foreion Materiai Exclusion Procedure Requirements (92903)
The NRC inspection team identified that the removed motor for the reactor building spray pump had not been protected and sealed following maintenance activities.
The stator and field windings were clearly visible and an exclusion area around the motor was not established.
Procedure CP-116A, Foreign Material Exclusion Control, provided the requirements and instructions for establishment and control of an FME area. These requirements and controls were not in place or followed for the motor.
The licensee stated the reason for the viol ~ tion was a programmatic weakness that resulted in human error. The inspector verified that
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adequate corrective action was implemented to prevent further occurrences.
Compliance procedure CP-116A, Revision 5 Foreign Material Exclusion Control, was extensively revised to provide better instructions and requirements.
Special training of the plant staff was implemented for the review of revised procedure CP-116A, Revision 5.
The FME program was updated to include "10 Key's To A Successful FME Program." The inspector concluded that the licensee had implemented adequate corrective action to address this violation and prevent future occurrence.
VIO 50-302/97-14-07 was closed.
E8,5 (Ocen) VIO 50-302/97-16-03: Failure to Desian and Install Radioactive Waste Disoosal System Pinina as Described in the FSAR (Closed) LER 50-302/97-38-00: An Enaineerina Oversicht Resulted in Ooeration Outside of the Desian Basis for the Waste Disoosal System a.
Insoection Scooe (92903)
This violation and LER involved the licensee's failure to design and install portions of the radioactive waste disposal system (WDS) piSing as described in the FSAR. The inspectors reviewed the status of t1e licensee's corrective actions to address this violation.
b.
Observations and Findinas The licensee responded to this violation in a letter dated December 17, 1997, and issued LER 50-302/97-38-00, on November 22, 1997. The inspectors reviewed the corrective actions for this violation and LER and previously documented the results of that review in IR 50-302/98-01.
Corrective actions specified in the violation response and LER 97-38-00 included the following:
Upgrading the liquid and gas outlet piping for the waste gas
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decay tanks (WGDT) to Seismic Class I prior to entering Mode 2.
Upgrading the liquid outlet piping to Seismic Class I prior
to restart from the next scheduled refueling outage (11R)
for the miscellaneous waste storage tank (MWST), spent resin storage tank (SRST), and neutralizer tank.
Development of a justification for continued operation (JCO)
for the WDS by Florida Power Corporation (FPC), consistent with NRC GL 91-18, Revision 1, prior to entering Mode 4 from the current outage.
l Reactor coolant drain tank (RCDT) process piping and liquid e
outlet p1 Jing were being evaluated by FPC, in accordance
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with 10 C R 50.59, as a change from seismic to non-seismic.
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The NRC concluded in IR 50-302/98-01 that the corrective actions completed for this violation and LER were acceptable for Crystal River
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Unit 3 restart in January 1998.
The corrective action which had not been completed in January 1998 nor at the conclusion of this current inspection for both the violation and LER was upgrading the liquid outlet piping to Seismic Class I prior to restart from the next scheduled refueling outage (11R) for the miscellaneous waste storage tank, spent resin storage tank, and neutralizer tank.
Refueling outage 11R is currently scheduled for the fall of 1999.
The inspectors noted that the remaining modification field work will be performed in accordance with MAR 97-10-01-01, Waste Disposal System Piping Support Upgrade. This MAR was also used to upgrade the liquid and gas outlet piping for the waste gas decay tanks to Seismic Class I prior to CR-3 restart in January 1998.
The inspectors determined that LER 50-302/97-38-00 was closed and the remaining corrective actions for this LER will be tracked in conjunction with VIO 50-302/97-16-03.
Although this item is a noncompliance with regulatory requirements, for the reasons discussed in IR 50-302/97-21, the licensee met the criteria for enforcement discretion per Section VII.B.2 of the NRC Enforcement Policy as described in NUREG-1600.
Consequently this item was closed and was identified as another example of NCV 50-302/97-21-01. Examples of Noncom)liances in Design Control. 50.59 Evaluations, Procedure Adequacy, le)ortability, and Corrective Actions That Are Subject to I
Enforcement )iscretion.
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c.
Conclusions
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The inspectors concluded that the corrective actions which had been i
implemented for VIO 50-302/97-16-03 and LER 97-38-00 were acceptable for restart of CR-3 in January 1998. The inspectors determined that LER 50-
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302/97-38-00 was closed and the remaining corrective actions for this LER will be tracked in conjunction with VIO 50-302/97-16-03. The specific corrective action which remains open is upgrading the liquid outlet piping to Seismic Class I prior to restart from the next scheduled refueling outage (11R) for the miscellaneous waste storage tank, spent resin storage tank, and neutralizer tank.
E8.6 (00en) VIO 50-302/97-16-04: Failure to Follow Procedure CP-111 by not Performino a 10 CFR 50.59 Safety Evaluation Within 90 Days After Identification of a Non-Conformina Condition Which Conflicted with the FSAR Description a.
Insoection Scoce (92903)
This violation involved the licensee's failure to follow compliance procedure CP-111 by not performing a 10 CFR 50.59 safety evaluation within 90 days after identification of a non-conforming condition which conflicted with the FSAR descriptio _ _ _ _ - _ -
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Observations and Findinos
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l The corrective actions for this violation were 3rovided in the j
licensee's response dated December 17, 1997.
T1ese corrective actions included:
Counseling of the engineering personnel responsible for
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resolving PC 97-1515 on meeting the requirements of procedure CP-111, Processing of Precursor Cards for Corrective Action Program.
Completing three Unreviewed Safety Question Determinations e
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(USQDs) for PC 97-1515, which included a JC0 for the WGDT liquid and gas outlet piping, a JC0 for other WDS tank liquid outlet piping (excluding the RCDT), and a FSAR change to reflect the RCDT liquid outlet piping as Seismic Class III.
Performing an extent of condition review (by January 31,
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1998) of open PCs initiated prior to October 1, 1997, to determine whether the failure to identify nonconforming conditions recuiring performance of a safety assessment /US00 was widespreac or an isolated case The NRC had previously reviewed the corrective actions for this violation and documented the results in IR 50-302/98-01 and IR 50-302/98-03. The corrective action which had not been completed at the conclusion of IR 50-302/98-03 was the extent of condition review, which included engineering's re-evaluation of the PCs that were identified as involving potential nonconforming conditions. The licensee documented
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the results of this effort in PC 97-7425.
During this current inspection, licensee personnel indicated that the extent of condition review and re-evaluation of the PCs involving potential nonconforming conriitions had been completed. The inspectors reviewed PC 97-7425 and noted that the documentation of the status of the engineering re-evaluations for the PCs was not adequate at the conclusion of this inspection to support closure of this item.
Specifically. the inspectors were not able to independently verify the results of this corrective action item because the documentation did not identify (by PC number) which PCs required re-evaluation, it did not indicate whether the re-evaluations had been completed, and it did not provide the results of the re-evaluations. The inspectors informed the licensee that this violation would remain open pending further NRC
review of the extent of condition review results.
c.
Conclusions The inspectors concluded that, although all of the corrective actions for this violation appeared to be complete, the documentation of the status of the engineering re-evaluations for the PCs was not adequate at the conclusion of this inspection to support closure of this item.
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Specifically, the inspectors were not able to independently verify the results of this corrective action item because the documentation did not: (1) identify (by PC number) which PCs required re-evaluation, (2)
indicate whether the re-evaluations had been completed, and (3) provide the results of the re-evaluations. This violation remained open.
E8.7 (Closed) VIO 50-302/97-16-05: Comoliance with the ODCM Surveillance Requirements for the WGDTs a.
Insoection Scooe (92903)
This violation involved the licensee's failure to comply with TS and Offsite Dose Calculation Manual (0DCM) surveillance requirements for the WGDTs. The ins)ector followed up on the corrective actions for this violation, whic1 were provided in the licensee's response dated December 17, 1997.
b.
Observations and Findinas The inspector noted that the corrective actions for this violation included the following:
Making the Chemistry Department personnel aware of this
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violation.
Revising the ODCM to allow use of an indirect method for
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determining the quantity of radioactive material in each WGDT.
l Performing an US00 to support sampling the makeup tank (MUT)
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instead of each WGDT.
Submitting a letter to the NRC by January 31, 1998, l
clarifying FPC's implementation of the NRC Safety Evaluation l
Report (SER) Technical Evaluation Report statement related to sampling each WGDT.
The inspectors previously reviewed the corrective actions for this violation and documented the results of that review in IR 50-302/98-01.
The corrective action item which remained open from the previous review was the licensee's submittal of a letter to the NRC by January 31, 1998, clarifying FPC's implementation of the NRC SER Technical Evaluation Report statement related to sampling each WGDT.
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During this current inspection, the ins)ectors verified that the j
licensee had submitted a letter to the 4RC (3F0198-28 dated January 30, 1998) to clarify the licensee's implementation of the SER requirement.
The inspectors discussed the status of this letter on April 23, 1998, with the NRC Office of Nuclear Reactor Regulation (NRR) ]roject manager for CR-3. The NRC 3roject manager indicated that the su) ject letter was being reviewed by tie NRR.
If there are any questions regarding the licensee's letter, NRR will follow up with the licensee. The inspector
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determined that actions taken by the licensee were satisfactory.
This violation was closed.
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Conclusions The inspector concluded that all of the corrective actions for this violation had been completed satisfactorily. This violation was closed.
E8.8 (Ocen) IFI 50-302/97-17-03: Review of Cable Amoacity Issue (92903)
IFI 50-302/97-17-03 was opened in IR 50-302/97-17 to track the licensee's final and long term resolution of the cable ampacity issue.
Initially LER 50-302/97-31-00, Inadequate Cable Sizing Due to Nonconservative De-Rating Factor Could Reduce the Cable Re.1aining Qualified Life, reported cable ampacity deficiencies.
Violation 50-302/97-01-09, Inadequate Corrective Actions for Cable Ampacity, was issued by the NRC as a result of the deficiencies identified in LER 97-31-00.
The licensee implemented adequate corrective action for the specific cables identified in the LER: however, long term corrective action was not implemented at that time.
Both VIO 50-302/97-01-09 and LER 50-302/97-31-00 were closed in IR 50-302/97-17. since IFI 50-302/97-17-03 was opened to track this issue.
The licensee stated that Revision 1 of LER 50-302/97-31-00 would be issued as a supplement, with the results of the initial evalu; tion and the planned corrective action.
Revision 1 had been issued a:; long term corrective action was scheduled prior to the next refueling outage (RO)
11 in 1999. At the time of this inspection, the licensee had not fully approved the cable ampacity project.
The insoector could not follow-up with this concern since limited progress had been made by the licensee.
Therefore IFI 50-302/97-17-03 remained open.
E8.9 (Closed) LER 50-302/96-16-00: CREVS Filter Testina did not Meet Technical Specifications (92903)
(Closed) LER 50-302/97-20-00: Misinterpretation Leads to Noncompliance With Imoroved Technical Specification Criteria Involvina Past In-Place Filter Testina (92903)
LER 50-302/96-16-00 stated that a review of Control Room Emergency Ventilation Systam (CREVS) test results revealed that they were not consistent with the ITS. The ITS 5.6.2.12 surveillance requirement for the High-Efficiency Particulate Air (HEPA) filters or charcoal filter bank filters was <0.05 percent for penetration and system bypass.
The licensee's " pre-ITS" Ventilation Filter Testing Program acceptance criteria was not in accordance to the criterid listed in RG 1.52. When this inconsistency was identified, as corrective action. the licensee re-performed the ventilation surveillance using the ITS criteria of
<0.05 percent.
The test results were within the ITS <0.05 criteria.
Additional corrective action was a full-scope review of ITS requirements for the ventilation filter testing against requirements contained in the
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Ventilation Testing Program (procedures CP-148 and SP-186) where the
<0.05 percent criteria was to be incorporated.
l LER 50-302/97-20-00 reiterated the findings in LER 60-302/96-20-00.
It
also reported that the testing requirements for the Reactor Building l
Purge System and the Auxiliary Building Ventilation Exhaust System were removed from the ITS in 1994.
However, prior to that time, the surveillance acceptance criteria did not meet the criteria <0.05 percent i
addressed 'n RG 1.52. Revision 1.
The additional corrective action specified was to revise procedure CP-148. Ventilation Filter Test Program, to reflect acceptance criteria of >99.95 percent removal of the test medium for the Reactor Building Purge system and the Auxiliary Building Ventilation Exhaust System filters.
The inspector verified that the licensee implemented corrective action by:
1) re-testing the CREVS that met the <0.05 percent criteria: 2)
revised procedure CP-148, Ventilation Test Program: 3) revised surveillance test procedure SP-186. AHFL-4A/B (Control Room) In-Place Filter Testing; and 4) verified procedure SP-186 was successfully completed for both A and B filters.
Although LER 50-302/97-20-00 was a noncompliance with regulatory
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requirements, for reasons discussed in IR 50-302/97-21. the licensee met the criteria for enforcement discretion per Section VII.B.2 of the NRC
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l Enforcement Policy as described in NUREG-1600.
Consequently this item was closed and was identified as another example of NCV 50-302/97-21-01.
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Examples of Noncompliance in Design Control. 50.59 Evaluations,
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E8.10 (Closed) LER 50-302/97-31-01: Inadeauate Cable Sizina Due to
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Nonconservative De-Ratina Factors Could Reduce the Cable Remainina Life (92903)
LER 50-302/97-31-00 was closed in IR 50-302/97-17. Revision 01 of LER 50-302/97-31-00 was issued as a supplement (follow-up) by the licensee to. state their commitment that "FPC has a long term project to evaluate cable sizing and the remaining cable qualified life."
IFI 50-302/97-17-03. Review of Cable Ampacity Issue, was opened to track the long term resolution of cable ampacity evaluation (cable sizing and remaining
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qualified life): therefore, LER 50-302/97-31-01 was closed.
E8.11 (Closed) LER 50-302/96-10-00: Low Flow in SW System Results in Ooeration Outside the Desian Basis a.
Insoection Scooe (92903)
This item involved 12 examples of safety-related components receiving less than required cooling flowrates from the nuclear services closed-cycle cooling system (SW). The licensee discovered these during an SW system flow balance and corrected 11 of the 12 problems by readjusting the throttle valves. The twelfth problem involved a valve with a
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separated stem and disk which was repaired. The inspector reviewed the l
licensee's actions for adequacy and to verify they were completed.
b.
Observations and Findinos The licensee initially determined the causes of the low flow to be both
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corrosion products blocking a few of the valves and the effect on the flow balance for already balanced small lines from some adjustments in 1992 of some large flow valves. The impact of the adjustments on the other lines was not recognized at the time. As documented in Section 08.1 of IR 50-302/97-11, during a review of a violation associated with the cause of this event, an inspector verified that all the closed
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cooling system flows measured during the last flow balances were within the required range. The licensee also considered another contributing cause to be the lack of operator guidance for positioning throttle valves.
The inspector verified guidance has been developed and permanently issued in an Operations Instruction. The twelfth example,
.due to the separated stem and disk in the throttle valve, was repaired and the licensee did not identify any generic valve concerns.
l The licensee later revised their conclusion for the corrosion product blocking of the throttle valves due to the discovery of resin in the system and the lack of any problems with corrosion products blockage in the similar Decay Heat Closed Cycle Cooling System (DC). The SW system has a. demineralized containing resin while the DC system does not. A previous problem had released resin in the SW system and the remaining-resin fines were suspected to be the source of the clogging. The licensee performed a flush of the system by opening all of the
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potentially clogged valves and allowing any resin to be removed by the i
SW system filter.
The licensee-verified the filter removed a small portion of resin and considered their actions successful. The inspector identified that they had not verified the success of this flush by taking confirmatory flow measurements to verify no further blockage was
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occurring. However, the inspector considered it extremely unlikely that-any appreciable resin remained in the system following the flush and the
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potential for further blockage was minimal.. Additionally, several of the cooled components contained temperature alarms which would alert the
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operators to any flow blockage. The inspector also identified that the.
licensee corrective action system paperwork and commitment tracking system did not reflect the change in the licensee's blockage i
determination from corrosion products to resin. They had comitted in the LER to evaluate actions or modifications to take to minimize the valve blockage and originally determined that periodic cycling of the
throttle valves was required to flush the corrosion products. The l
commitment to perform this was tracked as number 24393I and was closed L
.in ihe licensee *s system based on a vague engineering memo detailing
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plans to cycle the valves one time, before any action had been taken.
This did not adecuately address the original periodic valve cycling determination anc was insufficient justification to close the commitment.
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Conclusig_qi The inspector verified the licensee completed the needed corrective action, so Dis item is closed.
However, the final corrective actions to address potential throttle valve blockage were not verified to ensure they were successful and they were not delineated or tracked in the licensee's corrective action and commitment tracking systems. This was considered an example of poor corrective action and commitment closure.
E8.12 LCJm ed) IFI 50-302/96-03-16: Review of HPI Flow Indicator Modification.
Installation Packace. and Functional Testino Results (92903)
This Inspector Follow-up Item (IFI) addressed a similar issue to IFI 50-302/96-03-15 which was for review of the high pressure injection (HPI)
flow indicator 10 CFR 50.59 change analysis and TS bases changes.
IFI 50-302/96-03-15 was inspected and closed in Inspection Report 50-302/97-11. The inspector verified that the reviews documented in that report also encompassed the review of the modification installation and testing package listed under IFI 50-302/96-03-16. Modification Approval Record (MAR) 96-02-09-01 which installed the new flow meters, was reviewed under that effort and only minor discrepancies were noted as documented in IR 50-302/97-11.
Those discrepancies have been corrected.
Consequently this item is closed.
E8.13 (Closed) IFI 50-302/96-05-06: Laroe Break Loss-of-Coolant-Accident (LBLOCA) Analysis Generic Concerns (92903 and 92700)
This item involved a generic issue identified by the licensee's reactor vendor regarding the validity of an assumption that no fuel spacer grid
. plastic deformation would occur on a LBLOCA.
Since this problem affected all similar vendor-designed plants, it.was addressed generically through the NRC Office of Nuclear Reactor Regulation (NRR)
and tracked under TAC number M95480. This issue was closed as documented in an NRR letter to the reactor vendor dated August 20, 1997, following staff review of the revised analysis for the fuel spacer grid deformation using leak-before-break methodology on the main reactor coolant loop pi)1ng. The inspector verified this methodology was applicable to t1e licensee. The staff letter did not identify any further required actions or concerns, so this item is closed.
E8.14 (Closed) VIO 50-302/96-15-01: Failure to Perform Reauired Technical Specification Surveillance Test for Remote Shutdown System (92903 and 92700)
This item involved the transfer of an instrument channel check to another procedure and the subsequent reduction in the frequency of the procedure performance which resulted in exceeding the required surveillance interval. The inspector verified the licensee's corrective actions were complete with the exception of a related action to revise the Fire Protection Plan. The inspector verified the completed actions adequately addressed the surveillance requirements and the cause of the oversight. Consequently this item is closed.
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E8.15 (Closed) LER 50-302/97-27-00: Failure to Add Antifreeze to the Diesel Generator Coolant Radiators May Render EDG Inocerable Durina Subfreezing Temperatures (92903 and 92700)
As discussed in Inspection Report 50-302/98-03, the licensee had yet to finalize administrative guidance for the addition and removal of EDG radiator antifreeze and guidance for compensatory actions if ambient temperature changes created an operability concern.
During this inspection period the licensee addressed these remaining open items.
The inspector reviewed the final corrective actions taken to resolve these remaining issues.
The inspector verified that appropriate administrative guidance was instituted in the preventative maintenance process to schedule the coolant change out and operability contingencies were issued by Engineering to Operations. 0)erations initially inap3ropriately issued the guidance as a Nig1t Order which is discussed furtler in Section 03.2.
Final implementation of the guidance was accomplished by revisions to EDG operating procedures and logging surveillance procedures.
Although this item is a noncompliance with regulatory requirements, for the reasons discussed in Inspection Report 50-302/97-21, the licensee met the criteria for enforcement discretion per Section VII.B.2 of the NRC Enforcement Policy as described in NUREG-1600.
Consequently this item is closed and is identified as a further example of Non-cited Violation NCV 50-302/97-21-01. Examples of Noncompliance in Design Control. 50.59 Evaluations, Procedure Adequacy, Deportability, and Corrective Actions That Are Subject to Enforcement Discretion.
IV. Plant Sucoort l
R1 Radiological Protection and Chemistry (RP&C) Controls
R1.1 Observation of Samolina and Laboratory Activities a.
Insoection Scoce (84750)
The inspectors observed chemistry activities to verify applicable I
sampling and analysis requirements were being implemented.
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b.
Observations and Findinas
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The inspection included reviews of records and procedures, interviews with licensee personnel, and observations of work activities in progress. The inspectors made observations in the auxiliary building l
and chemistry laboratory.
Inspectors observed chemistry personnel performing daily routines including: the performance of analytical equipment quality controls; sampling; analysis: and documentation of sample results. The inspectors found the technicians knowledgeable in the performance of those activities. During the observations two minor procedure deficiencies L
were identified. One of the deficiencies was identified by a technician
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The findings, while not significant in
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themselves, indicated a lack of attention to detail which was discussed with Chemistry Department and Plant Management.
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Conclusions The inspectors concluded that the chemistry activities were performed in accordance with ]rocedures and in each case the desired results were obtained. A lacc of attention to detail in the chemistry procedures was observed.
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R1.2 Review of Plant Chemistry Parameters a.
Insoection Scooe (84750)
The review was made to verify primary and secondary water chemistry control parameters were within applicable limits.
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b.
Observations and Findinas The licensee's Reactor Coolant System (RCS) water chemistry program was selected to provide the necessary boron content for reactivity control and to minimize corrosion of the RCS surfaces.
The chemistry specifications were described in plant procedures. Technical Specification (TS) 3.4.15 required the specific activity of the reactor coolant to be within acceptable operation ranges provided in Figure 3.4.15-1, and required specific actions when the Dose Equivalent Iodine was greater than 1.0 microcuries/ gram.
The inspectors reviewed licensee documentation which correlated reactor power output and various RCS chemistry parameters and discussed the performance of the primary monitoring program with Chemistry Department personnel.
Overall, the primary chemistry parameters were maintained well below licensee limits.
Technical Specification 5.6.2.11 required a Secondary Water Chemistry Program to define, monitor, and control critical variables for the secondary water system. The purpose of the controls was to inhibit steam generator tube degradation and low pressure turbine disc stress corrosion cracking. The inspectors reviewed licensee procedures, discussed the secondary monitoring program with Chemistry Department personnel, and reviewed performance documentation of secondary system chemistry parameters.
In general, the secondary chemistry parameters were maintained well below procedure limits.
c.
Conclusions Overall, the plant water chemistry for primary and secondary water systems was being maintained well within the applicable TS and procedure limits.
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R1.3 Annual Radiological Effluent Release Reoort a.
Insoection Scoce (84750)
The report was reviewed to verify reporting requirements were met and to review the licensee's efforts to minimize radiological effluents, b.
Observations and Findinas Licensee TS 5.7.1.1 specified the requirements for the Radioactive Effluent Release Report. The review included an examination of the liquid and gaseous effluents for the period as compared to previous reports. The 1997 release quantities were generally lower than those of 1996.
c.
Conclusions No adverse trends were identified and all effluents were well within limits.
R1.4 (Closed) VIO 50-302/96-03-11: Failure to Wear Face Shields as Reauired by the Radiation Work Permit l
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Insoection Scooe (92904)
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The inspector reviewed violation 50-302/96-03-11 and the licensee's response, in a letter dated June 20, 1996, to determine the status of the proposed corrective actions.
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b.
Observations and Findinas This violation concerned an observation by an inspector of workers conducting activities in a contaminated area, where the potential to spread contamination to their heads existed.
The Radiation Work Permit (RWP) required the workers to attend a pre-job briefing and adhere to any additional restrictions outlined during the meeting. These included measures to reduce the likelihood of sareading the contamination by requiring that the workers wear face slields, during this activity. The inspector observed the workers performing the activity without the face shields in place.
i The inspector reviewed a letter addressed to all radiation workers reviewing this event and stressing that adhering to the requirements in a Health Physics (HP) pre-job briefing are as important as the requirements in the RWP. The inspector also reviewed the Health Physics training lesson plan, NUCHPT-025CT, Operations and Maintenance (Continuous Job Coverage), and determined that this event had been included in the training along with stressing the requirements for HP pre-job briefings.
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c, Conclusions The inspector verified that all corrective actions committed to had been completed. This violation is closed.
R3 RP&C Procedures and Documentation R3.1 Radioactive Waste Processina and Transportation of Radioactive Material a.
Insoection Scoce (86750)
The inspector reviewed licensee procedures and documentation for transporting radioactive waste and radioactive materials.
b.
Observations and Findinas
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The inspector randomly selected shipments of radioactive waste and i
radioactive materials and reviewed the licensee's documentation for those shipments.
c.
Conclusions Radioactive waste and radioactive material shipping papers were properly completed.
l R7 Quality Assurance in RP&C Activities R7.1 Documentation and Corrective Actions a.
Insoection Scoce (83750. 84750)
A review of radiation protection and chemistry items documented in the licensee's corrective action tracking program was made to identify trends and to evaluate the adequacy of corrective actions.
b.
Observations and Findinas
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The inspectors obtained lists of recent HP and chemistry issues identified in the licensee's corrective action system.
The inspectors selected items from those lists to follow up on and to evaluate the
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extent of the licensee's corrective actions.
i The inspectors noted that the threshold for placing HP and chemistry issues into the licensee's corrective action program appeared to be lower than observed during previous inspections. The analysis of the problems was better than previously seen and corrective actions to prevent recurrence were more comprehensive.
c.
Conclusions The analysis and corrective actions for HP and Chemistry related program deficiencies or problems were adequate and improving.
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R8 Miscellaneous RP&C Issues l
98.1 (Closed) VIO 50-302/97-20-01: Failure To Provide Adeauate Written Instructions For 6cumentina Personnel Contaminations (83750 and 92904)
The inspectors followed up on the licensee's corrective actions for a violation concerning the licensee's failure to provide HP technicians adequate guidance for investigating and documenting Personnel Conta;nination Events (PCE).
While reviewing Health Physics Procedure (HPP)-104, Personnel Monitoring and Decontamination, Revision 13 dated June 2, 1997, the inspectors found the procedure had conflicting guidance concerning the criteria for documenting personnel contaminations. Additionally, the procedures did not require the HP staff to determine a cause or probable cause of the personnel contamination for tracking, trending, or corrective action purposes.
The inspectors found that the licensee had revised HPP-104 to clarify the requirements for documenting personnel contaminations. The licensee also developed guidance for determining the causes of personnel contamination to prevent recurrence.
To ensure personnel were utilizing the correct forms for documenting PCEs, the licensee removed all of the old forms from HP facilities. The corrective action was expanded to remove all forms from HP facilities.
The licensee required HP personnel to print out forms, as needed, from a controlled database.
Licensee eyroctive actions for the violation were appropriate and completed. 3drefor :. VIO 50-302/97-20-01 was closed.
R8.2 (Closed) IFI 50-302/97-20-03: Review Technical Basis Documentation For Radioactive Contamination Dose Conversion Factors (83750 and 92904)
This IFI was opened to review the licensee's technical basis for a skin dose factor used in licensee contamination control procedures.
The licensee's Personnel Clothing / Skin Contamination Form included a factor for converting gross contamination activity to shallow skin dose rates. The technical basis for the factor was not in a controlled document or available for the inspector's review during a previous inspection. The licensee reported that the basis for the factors had been documented in a letter that could not be located during the-inspection.
The inspectors found that the licensee had developed a HP Technical I
Basis document to describe and control the skin dose methodology. The corrective action was appropriate. The licensee had addressed the
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documentation problem in the site corrective action program. As a l
result of the licensee's corrective action processes, the licensee found the need to document other technical basis in the same format.
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The licensee adequately documented the technical basis for contamination l
skin dose factors in a controlled document.
The licensee also began generating technical basis for other radiation protection procedures.
As a result, the quality of HP documentation was improved through the application of good corrective action and quality assurance processes.
R8.3 LClosed) VIO 50-302/96-03-12: Failure to Reoort The Transoort of a BIjloactively Contaminated Individual Offsite (92904)
This item involved the licensee's determination that an individual transported to a local hospital for fall injuries was not a reportable occurrence because she was not contaminated after her contaminated protective clothing was removed.
The licensee attributed the incorrect decision to a misinterpretation of the reporting requirements in 10 CFR 50.72 and a failure to reference the guidance contained in NUREG 1022.
Event Reporting Guidelines. The licensee promulgated the lessons learned from the event and the inspector verified that the individuals making deportability determinations were familiar with the error. As discussed in IR 50-302/97-17 the inspector previously performed a complete review of the licensee's deportability program. The licensee had significantly upgraded their deportability program procedural guidance and the use of the NUREG 1022 guidance is now routine. These actions have superseded the corrective actions the licensee took for this violation. Based on the improvements to the licensee program and the familiarity of licensee personnel with the lessons learned from this problem, this item is closed.
S1 Conduct of Security and Safeguards Activities S1.1 Access Authorization l
a.
Insoection SCoDe (81700)
l The inspectors evaluated the licensee's Access Authorization (AA)
Program with respect to denial of unescorted access and the appeal process that was provided to individuals b.
Observations and Findinas 10 CFR 73.56(e) requires licensees to provide a procedure for the review of a denial or revocation of unescorted access authorization of an employee of the licensee, contractor or vendor that adversely affects employment.
The inspectors reviewed 10 randomly selected records of those individuals denied unescorted access at Crystal River 3 within the last 6 months. Of those 10. two individuals requested an appeal.
The inspector's records review revealed that the licensee appropriately offered the appeal process to those individuals denied unescorted access in a timely manner.
Individuals were informed of the grounds that the denial was based upon and were given the opportunity to provide L
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additional relevant information. Appeals that were granted were conducted by individuals that had no responsibility for decision making within the AA Program, therefore providing an objective review.
Additionally, records of individual appeals were available for review by the inspector.
c.
Conclusions Records reviewed by the inspector reflected that the licensee was in compliance with 10 CFR 73.56(e) and implementing procedures.
S2 Status of Security Facilities and Equipment S2.1 alarm Stations a.
InsDection Scooe (81700)
The inspector's determined if Secondary Alarm Station (SAS) operations were effective and complied with Chapter 7 of the Physical Security F}sn (PSP) and implementing procedures.
b.
Observations and Findinas The inspectors observed operations at the SAS and interviewed SAS operators to determine if recently added administrative work assignments affected the SAS operators' ability to monitor the response activities of the Central Alarm Station (CAS). Additional administrative duties
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that were recently added included reports, logs, and badge access level l
actions. The licensee incorporated these assignments into the SAS
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operators' duties in an effort to better utilize supervisory personnel in the field.
SS-201, " Security Force Personnel General Orders, Duties and Responsibilities," Revision 32 required that SAS operators monitor the response activities of the CAS. This activity takes precedence over any other assigned responsibility. Additionally, SS-201 also states as an additional duty that SAS operators shall maintain various logs and records as required.
Upon interview of the SAS operators, the inspector determined that they were knowledgeable of the requirements stated in SS-201 and worked in conjunction with the CAS to complete other assigned duties. Of those interviewed, all operators maintained that com)letion of other assignments did not impede upon their responsi)ility to monitor the CAS as a primary duty.
c.
Conclusions The inspectors determined that additional administrative duties assigned to SAS operators did not impede their responsibility to monitor the alarm response activities of the CAS.
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i S2.2 Vehicle Barrier System i
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Insoection Scooe (81700)
The inspectors verified that the Vehicle Barrier System (VBS) remained l
in place and operational as required by the PSP.
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Observations and Findinas
On May 5,1998, the inspector performed a walkdown of the VBS.
Exterior I
concrete filled bollards were in place and appropriately spaced less I
than three feet apart. Other passive barriers in place: airline cable,
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cement structures and hurricane protection wave steps, and jersey l
bouncers were in place and appropriately anchored. Active barriers were l
operational and in good working condition, as evidenced by minimal l
problems since the last inspection
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c.
Conclusions Both passive and active barriers of the VBS were in place and operational as required by the PSP.
S3 Security and Safeguards Procedures and Documentation S3.1 Security Proaram Plans a.
Insoection Scooe (81700. 92904)
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Available information was reviewed to determine if the provisions of 10 l
CFR 50.54(p)(1) were met by the licensee.
b.
Observations and Findinas During an inspection conducted December 2-6 and December 16-19, 1996,
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and documented in IR 50-302/96-18, the inspectors identified that
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Revision 6-13 of the Physical Security Plan decreased the effectiveness of the security plan, without prior. approval from the Commission. The
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licensee submitted Revision 6-13 under the provisions,of 10 CFR 50.54(p)
rather than 10 CFR 50.90.
10 CFR 50.54(p) requires that a licensee
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shall make no change which would decrease the effectiveness of the security plan or guard training and qualification )lan without ]rior NRC i
approval. Unresolved Item (URI) 50-302/96-18-06, Failure to Adlere to 10 CFR 50.54(p)(1) - Physical Security Plan Submitted Decreased Plan Effectiveness, was identified for this discrepancy.
' pon further in-office review, the NRC determined that the licensee was U
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in violation of 10 CFR 50.54(p) for the submitted Revision 6-13 to the Physical Security Plan, which allowed the use of a roving vital area patrol to compensate for five degraded vital area doors.
This revision was executed on August 12, 1996.
This change decreased the effectiveness of the Physical Security Plan, in that Revision 6-12 l
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utilized posted security personnel to compensate for reductions of the effectiveness of barriers.
As a result of this failure to meet the requirements of 10 CFR 50.54(p),
a violation of regulatory requirements was identified, VIO 50-302/98-04-04. Failure to Adhere to 10 CFR 50.54(p)(1).
c.
. Conclusions The inspector concluded that Revision 13 of the Physical Security Plan decreased the effectiveness of the security plan and was in violation of 10 CFR 50.54(p)(1).
S8 Miscellaneous Security and Safeguards Issues S8.1 Actions on Previous Insoection Findinas (92904)-
(C'osed) VIO 50-302/97-10_02: Failure to provide adequate assessment of protected area zones.
NRC Inspection Report No. 50-302/97-10 documented that the licensee failed to have adequate assessment capability in place to facilitate response to detection of penetration of the protected area perimeter.
In response, the licensee installed a video capture system to assist the CAS/SAS operators in assessing perimeter zones. The video capture system records 5 frames before the alarm, two frames to capture the alarm, and three frames after the alarm.
During the course of this.
inspection, the inspectors observed the testing of all zones of the protected area with the use of a security officer walking through each zone.
In all but one zone, the officer who performed the test was easily viewed in the alarm stations. The one zone that appeared inadequate to the inspector contained an extremely long camera run, which became degraded towards the top of the monitor in the SAS.
However, The licensee immediately added additional lighting in the zone to assist in assessment. The licensee will evaluate this issue to determine if additional measures should be taken. This violation is closed.
V. Manaoement Meetinas X1 Exit Meeting Summary-The inspection scope and findings were summarized on May 12, 1998.
Proprietary information is not contained in this report.
Dissenting comments were not received from the licensee.
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X3 Management Meeting Summary X3.1 On April 8,1998, a meeting was held in the Region II office to discuss the licensee's Security Improvement Plan. A separate meeting sumary was issued on April 16, 1998.
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X3.2. On April 20, 1998, licensee management met with the NRC in the Region II office to present their self-assessment of FPC performance. A separate meeting summary was issued on April 22, 1998.
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PARTIAL LIST OF PERSONS CONTACTED l
Licensees
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R. Anderson, Senior Vice President. Energy Supply J. Baumstark, Acting Director, Nuclear Engineering and Projects S. Bernhoft, Manager, Nuclear Licensing J. Cowan, Vice President, Nuclear Operations R. Das:s,' Assistant Plant Director, Operations and Chemis ry R. Gruio, Director, Nuclear Regulatory Affairs
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l G. Halnon, Acting Director, Nuclear Quality Programs-B. Hickle, Acting Director Nuclear Operations Training J. Holden Director, Site Nuclear Operations
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M. Marano, Director, Nuclear Site & Business Support
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'C. Pardee, Director, Nuclear Plant Operations l
W.' Pike. Manager, Nuclear Regulatory Com)liance f
M. Schiavoni Assistant Plant Director, maintenance fBC l
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.C. Casto, Deputy Director, Division of Reactor Projects, Region II (May-7, 1998)
B. Crowley, Reactor Inspector, Region II (April 20-24, 1998)
J. Jaudon, Director, Division of Reactor Safety. Region II (May 5. 1998)
M. Miller, Reactor Inspector, Region II (March 30 - April 3, April 20-24
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S. Ninh, Project Engineer, Region II (April 22-24, 1998)
L. Stratton, Physical Security Specialist, Region II (May 7-8, 1998)
M. Thomas, Reactor Inspector, Region II (April 20-24, 1998)
L. Wiens' Senior Project Manager, NRR (April 6-8, 1998)
F. Wright. Senior Radiation Specialist, Region II (April 27 - May 1.1998)
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INSPECTION PROCEDURES USED
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IP 37550:
Engineering IP 37551:
Onsite Engineering i
IP 40001:
Resolution of Employee Concerns
IP 40500:
Effectiveness of Licensee Controls in Identifying, Resolving and Preventing Problems IP 61726:
Surveillance Observations
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IP 62707:
Conduct of Maintenance IP 64704:
Fire Protection Program IP 71707:
Plant Operations IP-81700:
Physical Security Program for Power Reactors
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IP 83750:
Occupational Radiation Exposure
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IP 84750:
Radioactive Waste Treatment and Effluent and Environmental Monitoring IP 86750:
Solid Radioactive Waste Management and Transportation of Radioactive Material
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IP 92700:
Onsite Followup of Written Reports of Nonroutine Events at Power
Reactor Facilities IP 92901:
Followup - Operations IP 92902:
Followup - Maintenance IP 92903:
Followup - Engineering IP 92904:
Followup - Plant Support ITEMS OPENED. CLOSED. AND DISCUSSED Ooened ly.pg Item Number Status Description and Reference NCV 50-302/98-04-01 Closed Failure to Implement Design Change Assumptions Results in Noncompliance with Equipment Station Blackout Design
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Requirements. (Section 03.1)
NCV 50-302/98-04-02 Closed Insufficient Volume Available For Collection of RCP Lube 011. (Section E1.2)
i VIO 50-302/98-04-03 Open Failure to Follow Procedure CP-111 for Documenting, Evaluating, and Correcting Adverse Conditions. (Section E8.1)
VIO 50-302/98-04-04 Open Failure to Adhere to 10 CFR 50.54(p)(1).
(Section S3.1)
Closed Tygg Item Number Status Description and Reference-
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IFI 50-302/95-21-02 Closed Modification to the Standby Feedwater Pump Recirculation Line. (Section 08.1)
LER :50-302/96-09-00 Closed Failure to Reattach Instrument Tubing to
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Seismic Supports After Modification Leads to Operation Outside Design Basis.
(Section 08.2)
l LER. 50-302/96-15-00 Closed Personnel Errors Cause Cable Separation / Isolation Concerns Resulting in Operating Outside the Design Basis.
(Section 08.3)
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VIO 50-302/96-11-01 Closed Inadvertent Work Instructions to Prevent the Inadvertent Start of the A Emergency Diesel Generator.-(Section 08.4)
VIO 50-302/96-09-01 Closed Failure to Follow a Procedure Resulting in the Inadvertent Initiation of the Control Room Emergency Ventilation System.
(Section M8.1)
VIO 50-302/97-13-02 Closed Failure to Perform a Safety Evaluation
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Prior to Erecting Scaffolding in the i
Vicinity of Safety-Related Equipment.
(Section M8.2)
NCV 50-302/98-04-02 Closed Insufficient Volume Available For Collection of RCP Lube Oil. (Section E1.2)
l LER 50-302/98-05-00 Closed Premature Failure of Rupture Discs l
Resulted in a Lack of Over pressurization Protection in Containment. (Section E2.1)
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l VIO 50-302/97-14-02 Closed failure to Assure that Conditions Adverse to Quality are Promptly Identified and Corrected. (Section E8.2)
VIO 50-302/97-14-06 Closed Failure to Evaluate Out-of-Tolerance M&TE.
(Section E8.3)
VIO 50-302/97-14-07 Closed Failure to Follow Foreign Material l
Exclusion Procedure Requirements. (Section E8.4)
LER 50-302/97-38-00 Closed Engineering Oversight Results in Operation Outside Design Basis for Waste Disposal System. (Section E8.5)
VIO 50-302/97-16-05 Closed Compliance with the ODCM Surveillance Requirements for the WGDTs. (Section E8.7)
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LER 50-302/96-16-00 Closed CREVS Filter Testing Did Not Meet TS l
Specs. (Section E8.9)
LER 50-302/97-20-00 Closed Misinterpretation Leads to Noncompliance With ITS Criteria Involving Past CREVS In-Place Filter Testing. (Section E8.9)
LER 50-302/97-31-01 Closed Inadequate Cable Sizing Due to Nonconservative De-Rating Factors Could Reduce the Cable Remaining Qualified Life.
(Section E8.10)
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LER -50-302/96-10-00 Closed Low Flow in SW System Cooled Com)onents Causes Operation Outside Design 3 asis.
(Section E8.11)
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'50-302/96-03-16 Closed Review of MAR 96-02-09-01. HPI Flow
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Indicators, Installation Package and Functional Testing Results. (Section E8.12)
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50-302/96-05-06 Closed Large Break Loss of Coolant Accident Analysis. (Section E8.13)
t VIO -50-302/96-15-01 Closed Failure to Perform a Required TS
Surveillance Test for Remote Shutdown
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System. (Section E8.14)
LER 50-302/97-27-00 Closed Failure to Add Antifreeze to the Diesel
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Generator Coolant Radiators May Render EDG Inoperable During Sub-freezing
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Temperatures. (Section E8.15)
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'VIO 50-302/96-03-11 Closed failure to Follow Radiation Work Permit Requirements. (Section R1.4)
VIO 50-302/97-20-01 Closed Failure to Provide Adequate Written Instructions for Documenting Personnel Contaminations. (Section R8.1)
IFI 50-302/97-20-03 Closed Review Licensee Technical Basis Documentation for Radioactive
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Contamination Shallow Dose Conversion Factors. (Section R8.2)
VIO 50-302/96-03-12 Closed Failure to Report the Transport of a Radioactively Contaminated Individual Offsite. (Section R8.3)
L URI 50-302/96-18-06 Closed Possible Failure to Adhere to 10 CFR 50.54(p)(1). (Section S3.1)
VIO 50-302/97-10-02 Closed Failure to Provide Adequate Assessment of Protected Area Zones. (Section 58.1)
i Discussed Iy.pg item Number Status Description and Reference p
URI 50-302/96-03-06 Closed Instrument Tubing Supports Removed Without Work Instructions and Not Reinstalled.
(Section 08.2)
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NCV 50-302/96-05-03 Closed Removal of Instrument Tubing Supports.
(Section 08.2)
NCV 50-302/97-21-01 Closed Noncompliance in Design Control. 50.59 Evaluations. Procedural Adequacy / Adherence, Deportability and Corrective Actions. (Sections 08.3, E8.5, E8.9 E8.15)
VIO 50-302/97-11-07-Open Deletion of Water Quality Requirements from the FSAR.
(Section E8.1)
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VIO.'50-302/97-16-03 Open-Failure to Design and. Install Radioactive l-Waste Disposal System Piping as Described j
L in the FSAR. (Section E8.5)
l l
VIO 50-302/97-16-04 Open Failure to Follow Procedure CP-111 by not Performing a 10 CFR 50.59 Safety Evaluation Within 90 Days After Identification of a Non-Conforming Condition Which Conflicted with the FSAR Description. (Section E8.6)
IFI 50-302/97-17-03 Open Review of Cable Ampacity Issue.
(Section E8.8)
VIO 50-302/97-01-09 Closed Inadequate Corrective Actions for Cable Ampacity. (Section E8.8)
LER 50-302/97-31-00 Closed Inadequate Cable Sizing Due to Nonconservative De-Rating Factor Could Reduce the Cable Remaining Qualified Life.
(Section E8.8)
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LIST OF ACRONYMS USED ADV
- Atmospheric Dump Valve
AHF
- Air Handling Fan AI
.- Administrative Instruction CAB:
- Contaminated Area Boundary CARB'
- Corrective Action Review Board CARC
- Corrective Action Review Comittee
'CDIP
- Configuration Document' Integration Project CFR'
- Code of Federal Regulations CP-
- Compliance Procedure CREVS! - Control Room Emergency Ventilation System
'CR3
- Crystal River Unit 3 DC
. Direct Current EDG
- Emergency Diesel Generator EFW-
- Engineered Safeguards FCN
- Field Change Notice h
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- Foreign Material Exclusion FPC
- Florida Power Corporation FSAR
- Final Safety Analysis Report FST
- Fire Water Storage Tank FWP
- General Electric GL
- Generic Letter gpm
- gallons per minute HEPA High Efficiency Particulate HP Health Physics HPI
- High Pressure Injection HPP
- Health Physics Procedure I&C
- Instrumentation and Control IFI
- Inspection Followup Item
'
IOC
- Interoffice Correspondence INP0
- Institute of Nuclear Power Operations
.
IR
- NRC Inspection Report IST
- In Service Test ITS
- Improved Technical Specifications LBLOCA - Large Break Loss of Coolant Accident
.
LC0
- Limiting Condition for Operation LER
- Licensee Event Report LLRT
- Local Leak Rate Test LOC
- Lube 011 Collection LOCA
- Loss of Coolant Accident LOT-
- Lube Oil Collection Tank MAR
- Modification Approval Record MOV
- Motor Operated Valve M&TE
- Maintenance and Test Equipment MVP
- Makeup Pum)
MUT
- Makeup Tanc MUV
- Make-up Valve NCV
- Non-cited Violation NOV
- Notice of Violation NQA
- Nuclear Quality Assessments NRC
- Nuclear Regulatory Commission NRR
- Office of Nuclear Reactor Regulation
.NSM
- Nuclear Shift Manager NSS
- Nuclear Shift Supervisor l
- Operating Instruction OL
- Overload COS
- Out Of Service l
.0P
- Operating Procedure
'
OSB
- Operator Study Book OTSG
- Once Through Steam Generator PC.
- Precursor Card i
l PCE
- Personnel Contamination Event
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- Preventive Maintenance PMT
- Post-Maintenance Test l
PPO
- Primary Plant Operator L
PT-
- Periodic Test
'
- QC
- Quality Control l
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- Reactor Building RCP
- Reactor Coolant Pump RCS
- Reactor Coolant System REA
- Request for Engineering Assistance RG
- Regulatory Guide
-
RP&C
- Radiation Protection and Chemistry RSP
. Radiation Safety Procedure RW
- Raw Water RWP
- Raw Water Pump RWV
- Raw Water Valve SALP
- Systematic Assessment of Licensee Performance SBLOCA - Small Break Loss of Coolant Accident SER
- NRC Safety Evaluation Report SM
- Shift Manager SP
- Surveillance Procedure SR
- Surveillance Requirement SR0
- Senior Reactor Operator SW
- Nuclear Services Closed Cycle Cooling System STAR
- Stop, Think, Act, Review STI
- Short Term Instruction TDEFP - Turbine Driven Emergency Feed Pump TMAR
- Tem)orary Modification Approval Record TS
- Tec1nical Specifications TSS
- Technical Support Standard UHS
- Unresolved Item USQ
- Unreviewed Safety Question US00
- Unreviewed Safety Question Determination l
- Violation
.WDS
- Waste Disposal System WGDT
- Waste Gas Decay Tank WR
- Work Request
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