ML022970626
| ML022970626 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  (DPR-072) |
| Issue date: | 10/23/2002 |
| From: | Wert L NRC/RGN-II |
| To: | Young D Florida Power Corp |
| References | |
| IR-02-003 | |
| Download: ML022970626 (40) | |
See also: IR 05000302/2002003
Text
October 23, 2002
Mr. Dale E. Young, Vice President
Crystal River Nuclear Plant (NA1B)
ATTN: Supervisor, Licensing &
Regulatory Programs
15760 West Power Line Street
Crystal River, FL 34428-6708
SUBJECT:
CRYSTAL RIVER UNIT 3 - NRC INTEGRATED INSPECTION REPORT
50-302/02-03
Dear Mr. Young:
On September 28, 2002, the NRC completed an inspection at your Crystal River Unit 3. The
enclosed report documents the inspection findings which were discussed on October 7, 2002,
with you and members of your staff.
The inspection examined activities conducted under your license as they relate to safety and
compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed
personnel.
This report documents one NRC identified finding of very low safety significance (Green). The
finding was not a violation of regulatory requirements. Additionally, one licensee identified
violation is listed in Section 4OA7 of this report. If you contest this non-cited violation, you
should provide a response within 30 days of the date of this inspection report, with the basis for
your denial, to the Nuclear Regulatory Commission, ATTN.: Document Control Desk,
Washington DC 20555-0001; with copies to the Regional Administrator Region II; the Director,
Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC
20555-0001; and the NRC Resident Inspector at the Crystal River Nuclear Plant.
In accordance with 10 CFR 2.790 of the NRC's "Rules of Practice," a copy of this letter and its
enclosure will be available electronically for public inspection in the NRC Public Document
2
Room or from the Publicly Available Records (PARS) component of NRCs document system
(ADAMS). ADAMS is accessible from the NRC Web site at
http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
//RA//
Leonard D. Wert, Chief
Reactor Projects Branch 3
Division of Reactor Projects
Docket No.: 50-302
License No.: DPR-72
Enclosure: Inspection Report 50-302/02-03
cc w/encl:
Daniel L. Roderick
Director Site Operations
Crystal River Nuclear Plant (NA2C)
Electronic Mail Distribution
Jon A. Franke
Plant General Manager
Crystal River Nuclear Plant (NA2C)
Electronic Mail Distribution
Richard L. Warden
Manager Nuclear Assessment
Crystal River Nuclear Plant (NA2C)
Electronic Mail Distribution
R. Alexander Glenn
Associate General Counsel (MAC - BT15A)
Florida Power Corporation
Electronic Mail Distribution
Attorney General
Department of Legal Affairs
The Capitol
Tallahassee, FL 32304
(cc w/encl contd - See page 3)
3
(cc w/encl contd)
William A. Passetti
Bureau of Radiation Control
Department of Health
Electronic Mail Distribution
Craig Fugate, Director
Division of Emergency Preparedness
Department of Community Affairs
Electronic Mail Distribution
Chairman
Board of County Commissioners
Citrus County
110 N. Apopka Avenue
Inverness, FL 36250
Jim Mallay
Framatome Technologies
Electronic Mail Distribution
4
Distribution w/encl:
B. Mozafari, NRR
RIDSNRRDIPMLIPB
PUBLIC
OFFICE
RII:DRP
RII:DRS
RII:DRS
RII:DRP
RII:DRP
SIGNATURE
SBR
GBK1
KXD
JSS
JSS/FOR
NAME
SRudisail
GKuzo
KDavis
SStewart
SSanchez
DATE
10/22/02
10/21/02
10/21/02
10/21/02
10/21/02
10/ /2002
10/ /2002
E-MAIL COPY?
YES
NO YES
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PUBLIC DOCUMENT
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OFFICIAL RECORD COPY DOCUMENT NAME: C:\\ORPCheckout\\FileNET\\ML022970626.wpd
Enclosure
U.S. NUCLEAR REGULATORY COMMISSION
REGION II
Docket No.:
50-302
License No.:
Report No.:
50-302/02-03
Licensee:
Florida Power Corporation (FPC)
Facility:
Crystal River Unit 3
Location:
15760 West Power Line Street
Crystal River, FL 34428-6708
Dates:
June 30 to September 28, 2002
Inspectors:
S. Stewart, Senior Resident Inspector
S. Sanchez, Resident Inspector
G. Kuzo, Team Leader Plant Support Branch (PSB)
(Sections 2OS1, 2OS3, 4OA1)
Don Forbes, Radiation Specialist (Section 2PS1)
James Kreh, Radiation Specialist, (Section 2PS3)
K. Davis, Physical Security Inspector (Section 3PP1)
Approved by:
Leonard Wert, Chief
Reactor Projects Branch 3
Division of Reactor Projects
SUMMARY OF FINDINGS
Inspection Report 05000302-02-03, Florida Power Corporation, 06/30/2002 - 09/28/2002,
Crystal River Unit 3, One finding in Problem Identification and Resolution.
The inspection was conducted by the resident inspectors, a physical security inspector, and
three radiation protection specialists. One finding of very low safety significance (Green) was
identified in the Problem Identification and Resolution area. The significance of issues is
indicated by their color (Green, White, Yellow, Red) and was determined by the Significance
Determination Process in the NRC Inspection Manual Chapter 0609. Findings to which the
SDP does not apply are indicated by No Color or by the severity level of the applicable
violation. The NRC's program for overseeing the safe operation of commercial nuclear power
reactors is described in NUREG-1649, Reactor Oversight Process, Revision 3, dated July
2000.
A.
Inspector Identified Findings
Cornerstone: Initiating Events
Green. The licensees corrective actions for a failed power cable were insufficient to
prevent recurrence of a partial loss of offsite power event. The finding was more than
minor because it increased the likelihood of a loss of offsite power.
The finding was determined to be of very low safety significance by the safety
determination process because it did not involve a total loss of offsite power and power
remained available for safety equipment. (Section 4OA2)
B.
Licensee Identified Violations
A violation of very low safety significance, which was identified by the licensee, was
reviewed by the inspectors. Corrective actions taken or planned by the licensee have
been entered into the licensees corrective action program. The violation and corrective
action tracking number are listed in Section 4OA7 of this report.
Report Details
Summary of Plant Status
Crystal River 3 operated at or near 100% rated thermal power throughout the inspection period.
1.
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity [Reactor-R]
1R04
Equipment Alignment
a.
Inspection Scope
The inspectors reviewed the alignment of risk-significant systems to evaluate the
readiness of the redundant trains or backup systems while one train was out of service
for maintenance. The inspectors checked switch and valve positions using the
alignment specified in operating procedures, and checked electrical power to critical
components. Nuclear condition reports were reviewed to verify that the licensee was
identifying and correcting component alignment issues. The specific systems walked
down were:
Emergency feedwater pump, EFP-3, when feedwater pump, FWP-7, and its
backup power supply, MTDG-1, were tagged out of service for preventive
maintenance per work orders 370849 and 246497. The walkdown was done
using the component position checklists in Operating Procedure OP-450,
Train B control complex chiller when the A train was out of service for preventive
maintenance per work order 288986. The walkdown was done using the
component positions specified by Operating Procedure OP-409, Plant Ventilation
System.
The inspectors also performed a detailed inspection of the high pressure injection
system to verify accident mitigation readiness. The verification included checks of
supply tank levels and boron concentrations, and verification that critical valves and
power supplies were aligned in accordance with technical specification and licensee
procedure requirements. Reviews were performed of outstanding design issues and
maintenance work requests to determine system operability and reliability. The
following documents were reviewed and used in the verifications: Operating Procedure
OP-402, Makeup and Purification System, 1st Quarter System Health Report, and
drawings for the Makeup and Purification System; P-304-662, FD-302-661, P-304-665.
b.
Findings
No findings of significance were identified.
2
1R05
Fire Protection
a.
Inspection Scope
The inspectors walked down risk-significant plant areas to check that controls of
transient combustibles and ignition sources were consistent with the licensees Fire
Protection Plan and 10 CFR Part 50, Appendix R. The inspectors also evaluated the
material condition, operational lineup, and operational effectiveness of fire protection
systems and assessed operational status and material condition of fire barriers used to
contain fire damage. The inspections were completed using the standards of the Fire
Protection Plan, 10 CFR Part 50, Appendix R, the Florida Power Corporation Analysis of
Safe Shutdown Equipment, and the Final Safety Analysis Report. The inspectors
reviewed sections of OP-880, Fire Service System, and checked performance of SP-
800, Monthly Fire Extinguisher Inspection, to verify the operational condition of fire
protection equipment. The inspectors checked that compensatory measures for fire
system problems were properly implemented and observed performance of selected fire
alarm checks. The components and areas receiving specific fire protection walkdowns
were:
A and B 480 Volt Engineered Safeguards Switchgear Rooms
Auxiliary Building, Seawater Pump Room
160 ft. Control Complex HVAC Equipment Room
95 ft. Intermediate Building and Emergency Feedwater Pump, EFP-2, area
Emergency Diesel Generator Rooms
A and B Decay Heat and Building Spray Pump Areas
Main Control Room
General Auxiliary Building including Spent Fuel Pool Area
1E Battery Rooms
b.
Findings
No findings of significance were identified.
1R06
Flood Protection Measures
a
Inspection Scope
The inspectors reviewed the Crystal River Unit 3, Final Safety Analysis Report, Chapter
2, that depicted the design flood levels and protection for areas containing safety-related
equipment to identify areas that may be affected by internal or external flooding. A
general site walkdown was conducted, with a specific walkdown of the auxiliary building
seawater room, to ensure that flood protection measures were in accordance with
design specifications. Specific attributes that were checked included sealing of
penetrations below the design flood line and between flood areas, adequacy of
watertight doors between flood areas, operability of sump pumps, level alarm and
control circuits, and availability of procedures to cope with flooding. The inspectors
verified that a deficiency involving the watertight seal between a turbine building
ventilation wall and a flood wall, documented in non-conformance report 71763, was
corrected by the licensee.
3
b.
Findings
No findings of significance were identified.
1R11
Licensed Operator Requalification
a.
Inspection Scope
The inspectors observed a licensed operator simulator session to check that operator
performance was consistent with 10 CFR 55 requirements and industry guidelines. The
inspectors checked that licensee evaluators properly implemented 10 CFR 55.59
requirements. During the observed session, the inspectors checked the crews abilities
in making an alert emergency classification and the required notifications as part of the
simulated emergency operations during performance of licensee Evaluated Simulator
Exercise SES-05. Proper use of abnormal and emergency operating procedures was
also checked.
b.
Findings
No findings of significance were identified.
1R12
Maintenance Rule Implementation
a.
Inspection Scope
The inspectors routinely checked that the licensee promptly entered problems with plant
equipment into either the corrective action program or the corrective maintenance
program. The inspectors checked that the licensee monitored work practices and when
appropriate, documented work problems in the corrective action program. The
inspectors checked that licensee personnel monitored unavailability of equipment
important to safety and trended key performance parameters. For the equipment issues
described in the nuclear condition reports (NCR) or work orders (WO) listed below, the
inspectors reviewed the licensees implementation of the Maintenance Rule
(10CFR50.65) with respect to the characterization of failures, the appropriateness of the
associated a(1) or a(2) classifications, and the appropriateness of either the associated
a(2) performance criteria or the associated a(1) goals and corrective actions. The
inspectors checked if the licensee maintained safety functions when equipment
important to safety was out of service for maintenance. The inspectors also periodically
reviewed the licensees implementation of 10 CFR 50, Appendix B and technical
specification requirements regarding safety system problems.
NCR 63922, Water found in lubrication oil for the 1B makeup pump
NCR 62928 and NCR 66692, Failure of the Offsite Power Transformer due to
cabling fault
b.
Findings
No findings of significance were identified. A related Green finding is discussed in
Section 4OA2.
4
R13
Maintenance Risk Assessments and Emergent Work Evaluation
a.
Inspection Scope
The inspectors reviewed daily maintenance schedules and observed work controls to
check risk management while maintenance was conducted. The inspectors employed
standards for operability of equipment such as those found in technical specifications,
the Final Safety Analysis Report, licensee procedures, and regulatory information such
as NRC Generic Letter 91-18, Revision 1, Information to Licensees Regarding NRC
Inspection Manual Section on Resolution of Degraded And Nonconforming Conditions.
The inspectors also reviewed maintenance schedules to check that overall risk was
minimized through preservation of safety functions such as decay heat removal
capability, reactor coolant system inventory control, electric power availability, reactivity
control, and primary containment control. The inspectors checked if licensee personnel
were managing risk by assuring that key safety functions were preserved and that upon
identification of an unplanned situation, the resulting emergent work was evaluated by
the licensee for risk and controlled as described in technical specifications, licensee
Compliance Procedure CP-253, Power Operations Risk Assessment and Management,
and Operations Instruction OI-7, Control of Equipment and System Status. The
inspectors checked that risk significant emergent work was documented in the
corrective action program and that risk management actions were promptly initiated.
The following work week risk assessments and/or the unplanned maintenance
conditions were checked:
Work Week 02W26, updated risk assessment for cleaning of the service water
heat exchangers following raw water pump shifts
Work Week 02W28, updated risk assessment for grass intrusion at the intake
Work Week 02W29, updated risk assessment for partial loss of off-site power
due to de-energization of the offsite power transformer (NCR 66523)
Work Week 02W31, updated risk assessment for the station battery inspection
per surveillance procedure SP-522, Station Batteries, when high resistance
readings were identified on one terminal of the B train safety battery
Work Week 02W37, planned maintenance assessment
b.
Findings
No findings of significance were identified.
1R15
Operability Evaluations
a.
Inspection Scope
The inspectors reviewed degraded or nonconforming conditions such as those listed in
nuclear condition reports (NCRs), work schedules, or engineering documents to
determine if operability was consistent with technical specifications, the Final Safety
Analysis Report, 10CFR Part 50 requirements, and when applicable, NRC Generic Letter 91-18, Revision 1, Information to Licensees Regarding NRC Inspection Manual
Section on Resolution of Degraded and Nonconforming Conditions. The inspectors
monitored licensee activities to check if operability issues were being identified at an
5
appropriate threshold and documented in the corrective action program, consistent with
10 CFR 50, Appendix B requirements, and licensee procedure NGGC-200, Corrective
Action Program. The inspectors checked that when plant problems were identified, the
resulting change in plant risk was identified and managed. The following issues,
including nuclear condition reports (NCRs), were specifically checked:
July 3, 2002, Service Water heat exchanger operability evaluation using
Operating Procedure OP-103B, Operating Curves; Curve 15, Service Water
Heat Exchangers
NCR 67591, Grade 68 oil added to emergency feedwater pump EFP-2 in lieu of
Synthetic 626
NCR 67948, Service Water heat exchanger found to be 83 percent blocked with
shells and grass, Safety Evaluation SE02-0098
NCR 71304, Chilled water system pipe supports for EFIC room cooling does not
match drawings
b.
Findings
No findings of significance were identified.
1R16
Operator Workarounds
a.
Inspection Scope
The inspectors reviewed the operator workaround database on August 13, 2002, to
determine the cumulative effects of operator workarounds. The inspectors reviewed the
affect of the workarounds on reliability, availability, emergency operations, and potential
misoperations of the systems involved. The inspectors checked for operator
workarounds that had not been identified by the licensee by reviewing the compensatory
actions list for plant operators, the operations communications log, the degraded
equipment log, the operator at the controls and superintendent of shift operations logs.
Additionally, the inspectors looked for workarounds while accompanying operators on
routine rounds, on plant tours, and in related discussions. The inspectors checked
whether deficient conditions could increase an initiating event frequency or could affect
multiple mitigating systems. The inspectors also checked the cumulative effects of
operator workarounds on operator correct and timely response to plant transients and
accidents.
b.
Findings
No findings of significance were identified.
1R17
Permanent Plant Modifications
a.
Inspection Scope
The inspectors reviewed Engineering Change (EC) 50081 for replacement of the
10 CFR 50 Appendix R chiller (CHHE-2). The inspectors verified the electrical
requirements of the new chiller and checked the resulting emergency diesel generator
6
loading against engine operating limits and design requirements. Performance
requirements of the chiller such as capacity, rating, and system output were checked for
adequacy of design. Post-installation testing was checked to assure that the chiller met
design specifications.
b.
Findings
No findings of significance were identified.
1R19
Post-Maintenance Testing
a.
Inspection Scope
The inspectors evaluated the following post-maintenance testing activities for risk
significant systems to check the following (as applicable): (1) the effect of testing on the
plant had been adequately addressed; (2) testing was adequate for the maintenance
performed; (3) acceptance criteria were clear and demonstrated operational readiness;
(4) test instrumentation was appropriate; (5) tests were performed as written; and
(6) equipment was returned to its operational status following testing. The inspectors
evaluated the licensee activities against the technical specifications, the Final Safety
Analysis Report, 10 CFR Part 50 requirements, licensee procedures, and various NRC
generic communications. The inspectors routinely checked that post maintenance
testing issues were documented in the licensees corrective action program and
corrected.
The specific post-maintenance activities evaluated included:
Post Maintenance Test 287910-02, and 282185-02: weld inspections and leak
checks following replacement of raw water valve, RWV-131, in the raw water
pump flush system per work order 287910-01
Surveillance Test SP-340E, Decay Heat Pump DHP-1B, Building Spray Pump
BSP-1B, and Valve Surveillance following replacing the torque switch for decay
heat valve DHV-12 per work order 221840-3
Surveillance Test SP-340B, Decay Heat Pump DHP-1A, Building Spray Pump
BSP-1A and Valve Surveillance for post-maintenance test of valve DHV-8,
following inspection and lubrication of linkage per work order 294268
Surveillance Test SP-349B, Emergency Feedwater Pump EFP-2 and Valve
Surveillance, following inboard and outboard pump bearing and turbine bearing
oil change per work orders 292230-01/02
Surveillance Test SP-395, CHHE-2 Appendix R Chiller Surveillance, following
chiller replacement per work order 300779-07
Surveillance Test SP-340E, Decay Heat Pump DHP-1B, Building Spray Pump
BSP-1B, and Valve Surveillance following preventive maintenance on the motor
actuator for decay heat pump DHP-1B recirculation isolation valve DHV-7 per
7
b.
Findings
No findings of significance were identified.
1R22
Surveillance Testing
a.
Inspection Scope
The inspectors observed surveillance testing or reviewed test data for risk-significant
systems or components, to check compliance with technical specifications, 10 CFR Part 50, Appendix B, and licensee procedure requirements. The testing was also checked
for consistency with the Final Safety Analysis Report. The inspectors checked if the
testing demonstrated that the systems were ready to perform their intended safety
functions. During the inspections, consistent with 10 CFR Part 50, Appendix B, Criterion
XVI, and licensee procedure CAP-NGGC-200, Corrective Action Program, the
inspectors verified that licensee personnel were documenting surveillance problems in
the corrective action program.
Inservice test (IST) activities were reviewed to ensure testing methods, acceptance
criteria, and corrective actions were in accordance with the ASME Code,Section XI, and
Florida Power Corporation ASME Section XI, Ten Year Inservice Testing Program,
dated May 4, 1998.
The specific surveillance activities checked included:
SP-354A, Monthly Functional Test of Emergency Diesel Generator EGDG-1A
SP-340E, Decay Heat Pump DHP-1B, Building Spray Pump, BSP-1B, and Valve
Surveillance (IST)
SP-711A, Core Flood Tank Boron Surveillance
SP-120A, Anticipated Transient Without Scram - Diverse Scram System
Functional Test
SP-317, Reactor Coolant System Water Inventory Balance
b.
Findings
No findings of significance were identified.
1R23
Temporary Plant Modifications
a.
Inspection Scope
The inspectors reviewed temporary plant modifications for systems that were ranked
high in risk for departures from design basis and for inadvertent changes that could
challenge the systems to fulfill their safety function. Also, the specific temporary
modification listed below was checked for operability implications and for inadvertent
changes to the system design basis. The inspectors conducted plant tours and
8
discussed system status with engineering and operations personnel to check for the
existence of temporary modifications that had not been appropriately identified and
evaluated.
Temporary Modification T-02-00-00-03; Reduce Flow Induced Vibration for Main
Steam Safety Valves
b.
Findings
No findings of significance were identified.
2.
RADIATION SAFETY
Cornerstones: Occupational Radiation Safety (OS) and Public Radiation Safety
(PS)
2OS1 Access Controls To Radiologically Significant Areas (71121.01)
.1 Access Controls
a.
Inspection Scope
Licensee program activities for monitoring workers and controlling their access to
radiologically significant areas and tasks were evaluated. The inspectors assessed
adequacy of procedural guidance; directly observed implementation of administrative
and established physical controls; and assessed resultant worker exposures to radiation
and radioactive material. Radiation worker and Health Physics Technician (HPT)
proficiency in implementing Radiation Protection (RP) program activities were
appraised.
During the onsite inspection, radiological controls for maintenance and calibration
activities associated with the Make-up Tank Room General Area Radiation Monitor
(RM-G6) detector were observed and discussed. In addition, access controls and
monitoring for five radiologically significant tasks conducted since October 1, 2001, were
evaluated. The evaluations included, as applicable, Radiation Work Permit (RWP)
details; use and placement of dosimetry to monitor occupational exposures involving
significant dose rate gradients; and electronic alarming dosimetry (EAD) set-points and
use in loud noise areas. Effectiveness of established controls were assessed against
area radiation and contamination survey results, potential for transient elevated dose
rates, and occupational doses received. Physical and administrative controls and their
implementation for locked-high radiation area (LHRA) and Very High Radiation Area
(VHRA) entries and for storage of highly activated material within the spent fuel pool
were evaluated through interviews of Health Physics technician and supervisory staff;
reviews of current survey records; and direct observations of the Spent Fuel Pool area,
selected auxiliary building HRA/LHRA locations, and waste processing and storage
facilities.
9
Occupational workers adherence to selected RWPs and HPT proficiency in providing
job coverage were evaluated through direct observations, review of selected exposure
records and investigations, and interviews with licensee staff. Occupational exposure
data associated with direct radiation, potential radioactive material intakes, and from
discrete radioactive particle (DRP) or dispersed skin contamination events identified
from October 1, 2001 through June 17, 2002, were reviewed and assessed
independently.
Radiological postings and physical controls for access to designated HRA or LHRA
locations within the auxiliary building locations, and waste processing and storage areas
were examined during facility tours. In addition, the inspectors independently measured
radiation dose rates and evaluated established posting and access controls for the
following areas and/or equipment:
Auxiliary Building (AB) 95 foot () elevation, Make-Up Pump Equipment and Valve
Alley Areas
AB 95' elevation, Triangle Room
AB 95' elevation, High Pressure Penetration Area
AB 119' elevation, Block Orifice Room
Radiation protection program activities and their implementation were evaluated against
Title 10 Code of Federal Regulations (10 CFR) 19.12; 10 CFR 20, Subparts B, C, F, G,
H, and J; Final Safety Analysis Report (FSAR) Section 11, Radioactive Waste and
Radiation Protection; Improved Technical Specification (ITS) Sections 5.6.1,
Procedures, Programs and Manuals, and 5.8.1, High Radiation Area; and approved
licensee procedures. Licensee guidance documents, records, and data reviewed within
this inspection area are listed in Section 2OS1 of the report Attachment.
b.
Findings
No findings of significance were identified.
.2
Problem Identification and Resolution
Issues identified through department self-assessments, Nuclear Assessment Section
(NAS) audits, and Corrective Action Program (CAP) documents associated with
radiological controls, personnel monitoring, and exposure assessments were reviewed
and discussed with responsible licensee representatives. The inspectors assessed the
licensees ability to characterize, prioritize, and resolve the identified issues in
accordance with licensee procedure NGGC-200, Corrective Action Program,
Revision (Rev.) 5.
Specific assessments, audits, and Action Request (AR)/Nuclear Condition Report (NCR)
documents reviewed and evaluated in detail for this inspection area are identified in
Section 2OS1 of the report Attachment.
b.
Findings
No findings of significance were identified.
10
2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)
.1
Area Radiation Monitoring and Post-Accident Sampling Systems
a.
Inspection Scope
The operability, availability, and reliability of selected direct area radiation monitor (ARM)
and continuous air monitor (CAM) equipment used for routine and accident monitoring
activities were reviewed and evaluated. The inspectors directly observed ARM
equipment material condition, installed configurations (where accessible), and conduct
of performance checks for selected monitors. Established ARM alarm set-points and
recently completed performance checks were evaluated and discussed in detail.
Current calibration data for the following radiation monitoring equipment was reviewed
and discussed with responsible staff:
Control Room Gas Channel Radiation Monitor (RM)-A5 Calibration, and associated
Control Room Rate Meter Calibration, conducted 08/01/01
Control Room Iodine Channel RM- A5 Calibration, conducted 06/06/01
Reactor Building Incore Instrument Removal Area, 135 elevation, RM-G18
Calibration, conducted 09/30/01
Decant Slurry Pump/Control Room RM-G12 Calibration, conducted 06/20/01
Containment High Range Radiation Monitor RM-G29 and RM-G30 Calibrations,
conducted 10/19-20/01
Post-Accident Sampling System (PASS) equipment operability, and procedural
guidance and its implementation were evaluated. The evaluation included review of
current program guidance, assessment of recent surveillance tests, and status of PASS
equipment/instrumentation availability and operability and review of completed and
planned training.
Program guidance, performance activities, and equipment material condition for the
direct radiation detection instrumentation and continuous air sampling equipment were
reviewed against details documented in ITS Section 5.6, 10 CFR Parts 20 and 50,
FSAR Section 11, and associated licensee procedures. Radiation detection and
sampling equipment required for use in accident monitoring was reviewed against ITS
5.6.2.6, Post-Accident Sampling; applicable sections of NUREG-0737, Clarification of
Three Mile Island (TMI) Action Plan Requirements, November 1980; Radiological
Emergency Response Plan, Rev. 22; and Regulatory Guide (RG) 1.97, Instrumentation
for Light-Water-Cooled Nuclear Power Plants to Assess Plant and Environs Conditions
During and Following an Accident, Rev. 3. Licensee guidance documents, records, and
data reviewed within this inspection area are listed in Section 2OS3 of the report
Attachment.
b.
Findings
No findings of significance were identified.
11
.2
Personnel Survey Instrumentation
a.
Inspection Scope
Current program guidance, including calibration and operation procedures, and its
implementation to maintain operability and accuracy of selected portable survey
instruments was reviewed and evaluated. During the week of August 5, 2002, the
inspectors reviewed current calibration data for selected personnel survey instruments
and assessed operability of various portable survey instruments staged or in use by the
Health Physics (HP) staff. Instrument selection and operability determinations
conducted by HPT staff prior to performing selected radiological surveys and monitoring
were reviewed and discussed. The accuracy and operability determinations for
instrumentation used to perform surveys in high radiation or greater areas were
assessed. Responsible staffs knowledge and proficiency regarding on site
instrumentation calibration activities were evaluated through interviews, record reviews,
and direct observation of source calibration of the RM-G6 detector.
Operability and analysis capabilities of the whole body counting (WBC) equipment for
monitoring internally deposited radionuclides and Personnel Contamination Monitor
(PCM) equipment utilized for surveys of individuals exiting the radiologically controlled
area (RCA) were evaluated. For both WBC and PCM equipment, current calibration
and recent operational/performance test surveillance data, as applicable were
evaluated. The inspectors directly observed conduct of monthly PMC-9 surveillance
tests. Selected WBC data analysis sheets results were reviewed and discussed with
responsible staff to assess knowledge and proficiency in resolving unknown energy
peaks and evaluating WBC results. The licensees data base of radionuclides for the
ingestion and inhalation radionuclide libraries used for routine WBC analyses and for the
backup master library were reviewed and evaluated.
Licensee activities associated with personnel radiation monitoring instrumentation were
reviewed against ITS 5.6; 10 CFR 20.1204 and 20.1501; and applicable licensee
procedures listed in Section 2OS3 in the report Attachment.
b.
Findings
No findings of significance were identified.
.3
Respiratory Protection - Self-Contained Breathing Apparatus (SCBA)
a.
Inspection Scope
The licensees respiratory protection program guidance and its implementation for Self-
Contained Breathing Apparatus (SCBA) equipment use were evaluated. The number of
available SCBA units and their general material and operating condition were observed
during tours of the Control Room and Technical Support Center. Current records
associated with supplied air quality, and maintenance activities for staged SCBA
equipment were reviewed and discussed. Proficiency and knowledge of staff
responsible for maintaining SCBA equipment were evaluated through discussions and
demonstration of a SCBA quarterly functional test. The inspectors reviewed records
12
and evaluated status of medical qualifications, fit test results, and training status for
Emergency Response Organization personnel on-call during the week of August 5,
2002. In addition, staff members were interviewed to determine their level of knowledge
of available SCBA equipment storage locations, proper use and bottle change-out, and
availability of prescription lens inserts, if required.
Licensee activities associated with maintenance and use of SCBA equipment were
reviewed against ITS; 10 CFR Part 20.1703; FSAR Section 11; Radiological Emergency
Response Plan Details, Rev. 22; RG 8.15, Acceptable Programs for Respiratory
Protection, Rev. 1, October 1999; American National Standards Institute (ANSI)-Z88.2-
1992, American National Standard Practices for Respiratory Protection; and applicable
licensee procedures listed in Section 2OS3 of the report Attachment.
b.
Findings
No findings of significance were identified.
.4
Problem Identification and Resolution
a.
Inspection Scope
The inspectors reviewed selected NCR documented issues associated with area
radiation monitoring equipment, portable radiation detection instrumentation, and
respiratory protective program activities were reviewed and assessed. The inspectors
assessed the licensees ability to characterize, prioritize, and resolve the identified
issues in accordance with licensee procedure NGGC-200, Corrective Action Program,
Rev. 5.
Specific documents reviewed and evaluated are listed in Section 2OS3 of the report
Attachment.
b.
Findings
No findings of significance were identified.
2PS1
Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems (71122.01)
.1
Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems
a.
Inspection Scope
The operability, availability, and reliability of selected effluent process sampling and
detection equipment used for routine and accident monitoring activities were reviewed
and evaluated. Inspection activities included record reviews and direct observation of
equipment configuration and operation. The following effluent monitoring equipment
was included in the inspection:
- Radiation Monitor (RM)-A1, Reactor Building Exhaust Monitor
- RM-A2, Auxiallary Building Exhaust Monitor
13
- RM-A5, Control Area Exhaust Monitor
- RM-L2, Main Liquid Release Monitor
- RM-L7, Liquid Radiation Monitor
During the week of August 5, 2002, the inspectors directly observed process effluent
sampling and monitoring equipment material condition, installed configurations (where
accessible), and operability; evaluated local and control room data regarding flow rates
and channel response checks; and reviewed and evaluated established effluent release
set-points. In addition, six effluent release permits completed and documented since
October 1, 2001, were reviewed, discussed, and evaluated. The inspectors assessed
sample representativeness, radionuclide concentration sensitivities, achieved analyses
accuracies, pre-release dose calculation completeness, and adequacy of effluent
radiation monitor set-point determinations.
Both the licensee and vendor laboratories quality control (QC) program activities for
liquid and airborne sample radionuclide analyses were evaluated. The inspectors
discussed and reviewed, as applicable, laboratory QC activities including current
gamma spectroscopy and liquid scintillation detection equipment calibrations and daily
system performance results; preparation, processing and storage of composite
samples; radionuclide lower limit of detection (LLD) capabilities and achieved
accuracies; and results of the quarterly cross-check spiked radionuclide samples
analyzed during calendar year (CY) 2001.
The inspectors directly observed and evaluated chemistry staff proficiency in conducting
weekly plant vent surveillance activities, including particulate filter and charcoal cartridge
change-out. Also, technician proficiency in conducting pre-release processing,
sampling, and gamma spectroscopy analyses was observed and evaluated. Interviews
were conducted with two chemistry technicians to evaluate staff proficiency and
knowledge of effluent release requirements, equipment capabilities, and procedural
details.
Program guidance, equipment configuration and material condition for the effluent
sampling and monitoring equipment were reviewed against details documented in ITS
5.6.1; 10 CFR Part 20, FSAR Section 11; Offsite Dose Calculation Manual (ODCM),
Rev. 25; ANSI-N13.1-1969, Guide to Sampling Airborne Radioactive Materials in
Nuclear Facilities; ANSI-N13.10-1974, ANS Specification and Performance of On-Site
Instrumentation for Continuously Monitoring Radioactivity in Effluents, and approved
procedures listed in Section 2PS1 of the report Attachment.
In-place liquid effluent release equipment, observed task evolutions, and offsite dose
results were evaluated against 10 CFR Part 20 requirements, Appendix I to 10 CFR
Part 50 design criteria, ITS 5.6.1; FSAR Section 11 details, ODCM Rev. 25
specifications; and applicable procedures listed in Section 2PS1 of the report
Attachment. Laboratory and sample processing QC activities were evaluated against
RG 1.21, Measuring, Evaluating and Reporting Radioactivity in Solid Wastes and
Releases of Radioactive Materials In Liquid and Gaseous Effluents from Light-Water
Cooled Nuclear Power Plant, June 1974; and RG 4.15, Quality Assurance for
Radiological Monitoring Programs (Normal Operation) - Effluent Streams and the
Environment, December 1977.
14
b.
Findings
No findings of significance were identified.
.2
Problem Identification and Resolution
a.
Inspection Scope
NCR issues documented for effluent processing and monitoring activities were
reviewed. The inspectors assessed the licensees ability to characterize, prioritize, and
resolve the identified issues in accordance with licensee procedure NGGC-200,
Corrective Action Program, Rev. 5. Five NCRs documented in Section 2PS1 of the
report Attachment were reviewed and evaluated in detail.
b. Findings
No findings of significance were identified.
2PS3 Radiological Environmental Monitoring Program (REMP) and Radioactive Material
Control Program (71122.03)
.1
REMP Implementation
a. Inspection Scope
The licensees 2001 Annual Radiological Environmental Operating Report was reviewed
and discussed with licensee representatives. The inspectors assessed data analyses,
surveillance results, and land-use census information. Report details were evaluated for
required sample types, sampling locations, and monitoring frequencies.
During the week of August 5, 2002, the inspectors toured and evaluated selected
sampling stations for location and material condition of REMP equipment. Collection of
air particulate filters and charcoal cartridges and determinations of flow rates were
observed at air sampling stations C07, C40, and C46. The proficiency and knowledge
of technicians collecting the samples and the adequacy of collection techniques were
assessed. The placement and material condition of thermoluminescent dosimetry (TLD)
were evaluated at monitoring locations C07, C14G, C40, C64, C72, C75, and C76.
Using Global Positioning System equipment, the inspectors independently determined
selected TLD locations and compared the results to the locations documented by the
licensee in the Annual Radiological Environmental Operating Report.
Program guidance, procedural implementation, and environmental monitoring results
were reviewed against ITS 5.6; 10 CFR Parts 20 and Appendix I to 10 CFR Part 50
design criteria requirements; FSAR Section 12 details; ODCM, Rev. 25 guidance; and
applicable procedures listed in Section 2PS3 of the Attachment to this report. Specific
QC activities associated with sample collection and analyses, and data reporting were
evaluated against RG 1.21, Measuring, Evaluating and Reporting Radioactivity in Solid
Wastes and Releases of Radioactive Materials In Liquid and Gaseous Effluents from
15
Light-Water Cooled Nuclear Power Plant, June 1974; and RG 4.15, Quality Assurance
for Radiological Monitoring Programs (Normal Operation) - Effluent Streams and the
Environment, December 1977.
b. Findings
No findings of significance were identified.
.2 Meteorological Monitoring Program
a. Inspection Scope
Licensee program activities to assure accuracy and availability of meteorological data
were evaluated. The inspectors reviewed and evaluated data obtained from the primary
and backup meteorological towers. During the week of August 5, 2002, the inspectors
toured meteorological facilities and assessed equipment material condition, observed
conduct of the weekly performance test of the propane generator associated with the
primary meteorological tower, and reviewed instrument operability and current
meteorological data accuracy within the Control Room. In addition, the inspectors
compared the most recent meteorological monitoring data against licensee assumptions
used for effluent releases and assessments.
The meteorological program implementation and activities were reviewed against
10 CFR Part 20; ITS 5.6.1; FSAR Section 2.3.3; ODCM, Rev. 25; and applicable
procedures documented in Section 2PS3 of the report Attachment.
b.
Findings
No findings of significance were identified.
.3
Unrestricted Release of Materials from the Radiologically Controlled Area (RCA)
a. Inspection Scope
Radiation protection program activities associated with the unconditional release of
materials from the RCA were reviewed and evaluated. During the week of August 5,
2002, the inspectors directly observed surveys of potentially contaminated materials
released from the RCA using Small Article Monitor (SAM)-9, ITM-4T, and Tool
Contamination Monitor (TCM) -2 equipment. In addition, SAM-9 equipment sensitivity
was assessed using a low-level radioactive source, i.e., activity approximately 5000
disintegrations per minute. Current calibration and performance check data were
reviewed and discussed. To evaluate the appropriateness and accuracy of release
survey instrumentation, radionuclides identified within the most current waste stream
analyses were compared against current calibration and performance check source
radionuclide types.
The licensee practices and implementation of monitoring for unconditional release of
materials from the RCA were evaluated against 10 CFR Part 20; ITS 5.6.1; FSAR
Section12; and applicable licensee procedures. The applicable licensee guidance,
16
calibration records, and performance data are documented in Section 2PS3 of the report
Attachment.
b.
Findings
No findings of significance were identified.
.4
Problem Identification and Resolution
a. Inspection Scope
Licensee NCRs associated with REMP operations and with program activities
associated with unrestricted release of materials from the RCA were reviewed and
evaluated. Specific NCRs reviewed and evaluated in detail are identified in Section
2PS3 of the Attachment to this report. The inspectors assessed the licensees ability to
characterize, prioritize, and resolve the identified issues in accordance with licensee
procedure NGGC-200, Corrective Action Program, Rev. 5.
b. Findings
No findings of significance were identified.
3.
SAFEGUARDS
Cornerstone: Physical Protection (PP)
3PP1
Access Authorization (AA) Program (Behavior Observation Program)
a.
Inspection Scope
During the period of August 19 through August 23, 2002, the inspector reviewed the
licensees behavioral observation program to evaluate the effectiveness and proper
implementation of the behavioral observation portion of the personnel screening and
fitness for duty (FFD) program. Five representatives of licensee management and six
representatives assigned escort duties were interviewed to determine their
understanding of the behavior observation program. The inspector evaluated the
effectiveness of each individuals training, including their ability to recognize aberrant
behavioral traits, indications of narcotic and alcohol use, and knowledge of work call-out
reporting procedures.
The inspector reviewed the licensees Semi-Annual FFD report for the period July
through December 2001, and a sample of the licensees Nuclear Condition Reports
(NCRs) and Safeguards Event Logs for the period January through September 2001,
and January through April 2002, to evaluate the licensees threshold for recommending
for-cause testing for events related to human performance. In addition, the inspector
interviewed the Access Authorization Manager and reviewed licensees procedures and
controls used by supervisors to determine whether employees were continuously
observed in accordance with the established continual behavior observation program.
17
The licensees activities were evaluated against requirements in the Crystal River 3
Nuclear Plant Physical Security Plan, associated plant procedures, and 10 CFR Part 26,
Fitness For Duty Program. Specific licensee documents evaluated are described in the
attachment to this report.
b.
Findings
No findings of significance were identified.
3PP2
Access Control
a.
Inspection Scope
During the period of August 19 through August 23, 2002, the effectiveness of the
licensees access control procedures and associated equipment designed to detect and
prevent the introduction of contraband into the protected area were evaluated. On
August 20, 2002, the inspector evaluated via direct observation the adequacy of the
licensees equipment testing procedures performed by a licensee representative on in-
use access control equipment and on in-service standby equipment at the sites primary
personnel access portal. The inspector evaluated the equipment testing procedure to
determine if testing was performance based and challenged the presently installed and
configured site equipment. Through observation of licensee performance testing, the
inspector assessed the adequacy of the card readers and biometric hand readers
located at the primary personnel access portal to prevent unauthorized entry into the
protected area and to preclude multiple entries without logging out of the protected area.
In addition, the inspector reviewed the licensees process for restoring search
equipment to service following repair and post maintenance testing. The inspector also
observed and assessed in-processing searches of personnel and packages at the
primary personnel access portal and search of vehicles at the Sally Port.
The licensees Key and Lock Program and associated procedures for limiting and
controlling vital area keys were examined, including key inventories for the first and
second quarters of 2002. A random audit of security daily shift reports for the current
year was conducted to verify each shifts accountability for vital area keys. On
August 22, 2002, the inspector verified operations accountability for Emergency
Operations Keys maintained in the Control Room to gain access to vital equipment
during an emergency. The inspector also discussed with the Access Authorization staff
safeguards in place to protect against unauthorized access to the site security
computers from outside the protected area.
The licensees procedures and processes for granting unescorted access to vital area
equipment were evaluated to determine if access was granted to only those personnel
identified as having a need for such access. Specifically, site access authorization
personnel were interviewed to determined their knowledge associated with supervisors
actions when maintaining the employee monthly protected and vital area access list.
The inspector assessed a sample of the licensees evaluations and corrective actions
identified in the annual Plant Security Assessment Reports for 2001 and 2002, to
determine if observations related to access controls were being appropriately
dispositioned.
18
The licensees activities were evaluated against requirements contained in the Crystal
River 3 Physical Security Plan, associated procedures, 10 CFR 73.55, Requirements for
Physical Protection of Licensed Activities in Nuclear Power Reactors Against
Radiological Sabotage, and 10 CFR 73.56, Personnel Access Authorization
Requirements for Nuclear Power Plants. Specific licensee documents evaluated are
described in the attachment to this report.
b.
Findings
No findings of significance were identified.
3PP3
Response to Contingency Events (71130.03)
The Office of Homeland Security (OHS) developed a Homeland Security Advisory
System (HSAS) to disseminate information regarding the risk of terrorist attacks. The
HSAS implements five color-coded threat conditions with a description of corresponding
actions at each level. NRC Regulatory Information Summary (RIS) 2002-12a, dated
August 19, 2002, NRC Threat Advisory and Protective Measures System, discusses
the HSAS and provides additional information on protective measures to licensees.
a.
Inspection Scope
On September 10, 2002, the NRC issued a Safeguards Advisory to reactor licensees to
implement the protective measures described in RIS 2002-12a in response to the
Federal government declaration of threat level orange. Subsequently, on
September 24, 2002, the OHS downgraded the national security threat condition to
yellow and a corresponding reduction in the risk of a terrorist threat.
The inspector interviewed licensee personnel and security staff, observed the conduct of
security operations, and assessed licensee implementation of the threat level orange
protective measures. Inspection results were communicated to the region and
headquarters security staff for further evaluation.
b.
Findings
No findings of significance were identified.
4.
OTHER ACTIVITIES
4OA1 Performance Indicator (PI) Review
.1
Protected Area Equipment Performance Index, Personnel Screening Program
Performance and Fitness for Duty/Personnel Reliability Program Performance PIs
a.
Inspection Scope
The inspector evaluated the licensees Performance Indicator (PI) data associated with
the Intrusion Detection System (IDS) and Closed Circuit Television (CCTV) to determine
19
if the licensee provided accurate reporting for compensatory time relative to equipment
degradation for the protected area Equipment Performance Index PI. The evaluation
included a sample review of tracking and trending reports, security logs, and security
event reports for the year of 2001 and the first quarter of 2002. A review of a sample list
of licensees event reports and security logs for the same period were also conducted to
determine the accuracy of PI data associated with the Personnel Screening Program
Performance and Fitness for Duty/Personnel Reliability Program Performance PIs.
b. Findings
No findings of significance were identified.
.2
Initiating Event and Mitigating Systems Cornerstone
a.
Inspection Scope
The inspectors checked the accuracy of the performance indicators for reactor coolant
system activity and leakage. Performance indicator data submitted in June 2002, was
compared for consistency to data obtained through the review of chemistry department
records, monthly operating reports, and control room records from September 2001
through June 2002. During routine plant tours, the inspectors checked proper controls
for plant personnel exposure and radioactive releases.
a.
Findings
No findings of significance were identified.
.3
Occupational Radiation Safety Performance Indicator Verification
a.
Inspection Scope
The licensees Occupational Exposure Control Effectiveness performance indicator (PI)
results for the Occupational Radiation Safety Cornerstone were reviewed for the period
October 1, 2001 through July 2, 2002. For the review period, the inspectors reviewed
data reported to the NRC, and subsequently sampled and evaluated applicable
corrective action program events and selected Health Physics Program records. The
reviewed records included selected health physics shift logs, contamination occurrence
logs and assessments, internal exposure evaluations, and personnel exposure
investigation reports and licensee NCRs listed in Sections 2OS1 and 4OA1 of the report
Attachment. The licensees dispositioning of the reviewed issues and events was
evaluated against NEI 99-02, Regulatory Assessment Performance Indicator Guideline,
Rev. 2.
b.
Findings
No findings of significance were identified.
20
.4
Public Radiation Safety Performance Indicator Verification
a.
Inspection Scope
The inspectors reviewed and discussed the Radiological Control Effluent Release
Occurrence PI results for the Public Radiation Safety Cornerstone from October 1, 2001
through July 31, 2002. For the review period, the inspectors reviewed data reported to
the NRC and evaluated selected radiological liquid and gaseous liquid and gaseous
effluent release data, selected out-of-service process radiation monitor and
compensatory sampling data, abnormal release results, and NCRs documented in
Sections 2PS1 and 4OA1 of the report Attachment.
The licensees classification of reviewed data was evaluated against NEI 99-02,
Regulatory Assessment Performance Indicator Guideline, Rev. 2.
b.
Findings
No findings of significance were identified.
4OA2 Problem Identification and Resolution
a.
Inspection Scope
The inspectors routinely checked that equipment, human performance, and program
issues were being entered into the licensee corrective action program and that
corrective actions were implemented in accordance with licensee procedure CAP-
NGGC-0200, Corrective Action Program and 10 CFR Part 50, Appendix B. Specifically,
the inspectors checked that NCR 60607 was written when a valve test was not done as
scheduled. The inspectors checked if the licensee adequately evaluated the problem
and specified appropriate corrective actions to prevent recurrence. The inspectors also
checked that the corrective actions had been completed and independently checked the
extent of condition. The inspectors completed similar checks for nuclear condition
report NCR 66523, written after a loss of preferred power to one plant safety bus. The
inspector checked that the licensee appropriately considered reportability consistent with
10 CFR 50.73. In both cases, the inspectors checked if corrective actions had been
implemented and if the occurrence had been reviewed by plant management as
specified by licensee procedures.
b.
Findings
(Green) The inspectors determined that the licensees corrective actions for a failed
power cable were insufficient to prevent recurrence of a partial loss of offsite power
event.
On June 17, during an electrical storm, power from the unit Offsite Power Transformer
was lost when a ground fault developed in cabling between the transformer and a 4160
volt Engineered Safeguards bus. After jacketing of the cable, the as-left cable meggar
readings showed resistance to ground values below an industry minimum standard.
The licensee concluded in Engineering Change 49604R0 that the cable insulation
21
resistance was adequate and that it was acceptable to return the transformer to service.
On July 20, a second non-weather-related cable failure occurred. When the faulted
cable was inspected, approximately 0.5 gallons of water was drained from the cable
jacketing in the vicinity of the fault. Subsequently, when the cables were dried to the
maximum extent practical, and taped with electrical tape, resistance to ground readings
above the industry standard minimum were obtained.
Following the cable failures, the inspectors determined that the licensees corrective
actions for the June 17 event were insufficient to prevent recurrence on July 20, 2002.
The ineffective corrective action is considered a licensee performance deficiency and
the transformer cable failures were evaluated by the inspectors using the NRC
Significance Determination Process (SDP). A regional senior reactor analyst performed
a validation of the Phase II SDP using the NRCs Crystal River 3, Probabilistic Risk
Assessment model and the licensees full scope probabilistic risk assessment model. In
both cases, the loss of offsite power frequency was increased by an order of magnitude
and the delta core damage frequency remained less than 1x10-6. This analysis
confirmed a result of Green.
The offsite power transformer power cables were outside of the plant protected area
and were not safety related equipment. The cables were maintained with normal utility
maintenance procedures and practices. As such, the finding did not involve any
violation of NRC requirements.
4OA3 Event Followup
.1
(Closed) Licensee Event Report 50-302/02-001-00: Automatic Start of An Emergency
Diesel Generator Due to Loss of the Offsite power Transformer. This licensee event
report (LER) reported two actuations of an emergency power source, the first on June
17, 2002, and the second on July 20, 2002. The events were reviewed by the
inspectors and resulted in one finding of very low safety significance (Green) discussed
in Section 4OA2 of this report. Because the equipment which caused the event, the
offsite power transformer cabling, was outside of the plant protected area and was not
safety related equipment, the finding did not result in any violation of NRC requirements.
The LER is closed.
4OA6 Meetings, Including Exit
Exit Meeting Summary
The resident inspectors presented the inspection results to Mr. D. Young and other
members of licensee management at the conclusion of the inspection on October 7,
2002. The inspectors asked the licensee whether any of the material examined during
the inspection should be considered proprietary. The licensee did not identify any
proprietary information.
22
4OA7 Licensee Identified Violations
The following violation of very low safety significance (green) was identified by the
licensee and is a violation of NRC requirements which met the criteria of Section VI of
the NRC Enforcement Policy, NUREG-1600, for disposition as an non-cited violation
(NCV).
ITS 5.6.1 requires written radiation protection procedures covering access control to
radiation areas, including a Radiation Work Permit (RWP) system, to be established,
implemented, and maintained as recommended in Appendix A, of RG 1.33, Quality
Assurance Program Requirements, Rev. 2, February 1978. On February 12, 2002, the
failure to adequately develop and implement RWP 02-0025 radiological controls for
Decay Heat Valve -32 maintenance activities resulted in unplanned intakes of
radioactive material and internal exposures to three workers as described in NCR
55691. Because the licensees personnel contamination monitors identified the potential
for internal contamination and subsequent detailed licensee evaluations determined no
regulatory occupational dose limits were exceeded, this violation is of low safety
significance and is being treated as a non-cited violation.
Attachment
Supplementary Information
A. PARTIAL LIST OF PERSONS CONTACTED
Florida Power Company
M. Annacone, Manager, Operations
S. Bernhoft, Supervisor, System Engineering
W. Brewer, Manager, Outages and Scheduling
R. Davis, Manager, Training
J. Franke, Plant General Manager
S. Gangi, Senior Security Specialist
P. Gerardin, Lead Assessor, Nuclear Assessment Section
C. Gurganus, Manager, Maintenance
D. Herrin, Lead Engineer, Licensing & Regulatory Affairs
D. Roderick, Director, Site Operations
S. Johnson, Supervisor, Self-Evaluation
M. Folding, Superintendent, Security
S. Powell, Supervisor, Licensing
R. Prince, Radiation Protection Manager
J. Stephenson, Supervisor, Emergency Preparedness
J. Terry, Manager, Engineering
R. Warden, Manager, Nuclear Assessment
D. Young, Vice President, Crystal River Nuclear Plant
M. Folding, Security Manager
NRC
L. Wert, Chief, Reactor Projects Branch 3, NRC Region II
B. ITEMS OPENED AND CLOSED
Closed
50-302/02-001-00
LER
Automatic Start of An Emergency Diesel Generator Due to Loss
of the Offsite Power Transformer
2
C. LIST OF DOCUMENTS REVIEWED
2OS1 Access Control To Radiologically Significant Areas (71121.01)
Procedures, Instructions, Lesson Plans, and Manuals
Health Physics Procedure (HPP) - 106A, Radiation Work Permit Procedure,
Revision (Rev.) 10
HPP-202A, Radiological Surveys and Inspections, Rev. 20
HPP-213A, Area and Equipment Postings, Rev. 11
HPP-214, Very High Radiation Area Controls, Rev. 3
HPP-216, Diving Operations in Radiological Environments, Rev. 4
CRI-414, Radiation Protection Shift Activities, Rev. 3
Radiation Work Permits (RWPs)
RWP-0483, Change Out Post Filter, conducted 03/12/02
RWP-0483, Sluice Primary Resin, conducted 03/15/02
RWP-0483, Change Out Post Filter, conducted 05/20/02
RWP-0588, Adjust Packing on Make-Up Valve 41, conducted 05/18/02
RWP-0483, Move Resin HIC to On Site Storage Cask, conducted 05/21/02
Records and Data
Health Physics Shift Logs, Selected Entries July 1, 2002, through August 6, 2002
Contamination Occurrence Logs, October 1, 2001, through August 5, 2002
Personnel contamination event records and supporting dose assessment data, for selected
evaluations conducted from October 1, 2001, through August 5, 2002
Personnel Exposure Investigation Data Sheets documented from October 1, 2001, through
June 12, 2002
Initial Intake Assessment Data Sheets documented from October 1, 2001, through June 12,
2002
Audits, Self-Assessments, and Nuclear Condition Report (NCR) Documents
Nuclear Assessment Section (NAS), Environmental and Radiation Control (ERC)
Assessment Report Number (No.) C-ERC-01-01, dated August 29. 2001.
- NAS, Offsite Dose Calculation Manual (ODCM) Assessment Report No. C-ODCM-01-01,
dated December 18, 2001
- Self-Assessment Report No. SSAERC 51190, conducted March 4 -30, 2002
NCR-00049102, Contaminated Worker with DRP, 10/03/01
NCR-00050103, Incore Reel at Receiving Warehouse, 10/18/01
NCR-00052536, Hot Particles Found in the Auxiliary Building, 12/11/01
NCR-00064400, Make-Up Pump - 1B, High Radiation Area Posting, 6/29/02
NCR-00065752, High Radiation Area Swing Gate Open, 7/12/02
3
2OS3 Radiation Monitoring Instrumentation and Protective Equipment (71121.03)
Procedures, Standing Orders, Guidance Documents
Chemistry Procedure (CH) -401 E, RM-A5 Calibration, Rev. 1
- Surveillance Procedure (SP)-166, Calibration of the General Area Radiation Monitor
(RM-G) 29 & RM-G30, Rev. 14
Surveillance Procedure (SP)-7011 , RM-A5 Iodine Channel Calibration, Rev. 2
Chemistry Sampling Procedure (CH)-630A. Post-Accident Sampling and Analysis of the
Reactor Building Vent, Rev. 2
CH-630B. Post-Accident Sampling and Analysis of the Auxiliary Building Vent, Rev. 2
CH-632A. Post-Accident Sampling and Analysis of the Reactor Coolant System, Rev. 4
CH-601, Breathing Air Sampling, Rev. 4
Health Physics Procedure (HPP)-320, Whole Body Counting System Operation, Rev. 13
HPP-320, Whole Body Counting System Calibration, Rev. 6
HPP-414, Calibration and Operation of Eberline Personnel Contamination Monitors
Rev. 10
HPP-423, Ion Chamber Calibration, Rev. 8
HPP-424, Calibration of Neutron Instruments, Rev. 6
HPP-433, Operation and Calibration of the National Nuclear Portal Monitor, Rev. 4
HPP-502, Respirator Inspection and Maintenance, Rev. 10
HPP-507, Respiratory Equipment Leak Testing, Rev.1
HPP-515, IAP Operation and Maintenance, Rev. 2
Nuclear Operations Training, Special Technical Training, MSA SCBA Users Practical
Training, Rev. 1
Records, Worksheets, and Drawings
Surveillance Procedure (SP) 335A, RM-G6 Functional Test, conducted 08/07/02
SP 335A, Quarterly Radiation Monitoring Instrumentation Functional Test , conducted
5/09/2002 and 7/13/2002
SP 335C, Radiation Monitoring Instrumentation Functional Test of RM-A1, A2, A6, A11,
and A12, conducted 07/19/2002, 8/02/2002
SP 335D, RM-A1 (M), (H) and RM-A2 (M) (H) Source Checks, conducted 7/27/2002,
HPP-414, Monthly Operational Checks (6/2002) and Weekly Alarm Checks (6/13/2002) for
Personnel Contamination Monitor (PCM)-1B/1C Equipment Serial Numbers (S/N) 7640-01,
7640-02, 7640-05, 119, 120, 121, 122, 123, and 124,
HPP-420, Radiation Calibration Certificate Portable Air Sampling Equipment Calibration
Records associated with the Eberline Model RAS-1, SN 39914-05, conducted 9/24/001;
RADeCO Model H-809V-1, S/N 3830, 3835, 6364, 4377, 3836, 6240, 3119, 6902, 3199,
3117, 3933, 2827, and 3116 conducted 9/17-18/2001
Radiation Protection Instrument Calibration Certificate records for Eberline
RO-20 survey meter, SN 2444 and RO-2 survey meter SN 5108, conducted 3/11/02
HPP -433, Radiation Protection Instrument Calibration Certificate records for Gamma 60
Portal Monitor, SN 980017, 12/19/01; SN 930380, 2/15/02; SN 910390, 8/14/01; and
Response Checks from October 2001, through June 2002,
Certificates of Calibration for Ludlum Measurements Neutron Measurement Survey
equipment Model 12-4 (SN 141277) and 42-31 (SN PR144368); and Model 12-4
4
(SN 141275) and 42-31 (SN PR144365) conducted 04/08/02 Neutron Survey
Whole Body Counter (WBC) Calibration Records, completed 05/01/02,
WBC Daily Quality Control and Background Performance Records, June 2002
WBC Radionuclide Library Data, Inhalation, Ingestion, and Master Libraries; as of 7/09/02,
SCBA Monthly Inspection Data Sheets, March - June 2002
Annual Grade D Air Sample Results for Fill Station Equipment, 6/19/2002
Emergency Response Weekly On-Call List, dated 08/05/2002,
Quarterly PT-160A PASS Standby Operation Testing Results October 2001 through April
2002
AR/NCR Documents
NCR-00051971, PCM Efficiency Out of Specification, 11/27/01
NCR-00056015, Air Leak on SCBA Unit, 2/19/02
NCR-00057048, RM-G26 and RM-G27 Calibration Not Performed in Accordance With
HPP 436, 3/07/02
NCR-00060515, Source Checks for Friskers, 5/09/2002,
NCR-00060896, Respirator Fit Test Data Is Not Being Entered into PADS, 5/16/02,
NCR-00061539, SCBA Cylinder in Emergency Kit with Low Pressure, 5/30/02
2PS1 Radioactive Gaseous and Liquid Effluent Treatment and Monitoring Systems
(71122.01)
Procedures, Guidance Documents, and Operating Manuals
CH-220V, RM-L7 Calibration, Rev., 6
Nuclear Chemistry Quality Control Manual, Rev. 1
CH-230A, Gamma Specroscopy System Operating Instructions, Rev.0
SP-736G, SDT-1, Release To The Discharge Canal, Rev. 8
CRI-357, Changing Process Atmospheric Radiation Monitoring System Filters, Rev. 4
SP-736F, SDT-1, Turbine Building Release To The Settling Ponds, Rev. 3
CHA-206B, Tritium Air Sample, Rev. 8
CH-616, RM-A2 Sampling, Rev. 4
SP-731A, Auxiliary Building Ventilation Continuous Release, Rev. 6
Operating Instruction (OI)-29, Liquid Release Sampling Request, Rev. 14
Crystal River Off-site Dose Calculation Manual, Rev. 25
Crystal River Off-site Dose Calculation Manual Records Transmittal Form 09/06/01
Effluent Monitoring Program Records and Effluent Release Permits Reviewed
Radiation Monitor RM- A1 and RM- A2, Calibration Data 07/31/01
Radiation Monitor RM- L7, Calibration Data 08/21/01
Radiation Monitoring Maintenance Report Data, Previous 12 Months, June 29, 2002
Gamma Spectroscopy Analysis Data for SDT-1 Liquid Tank release 08/07/02
Gaseous Effluent Permit Auxillary Building Exhaust, conducted 08/08/02
Gaseous Effluent Permit Auxillary Building Exhaust conducted 07/31/02
Gaseous Effluent Permit Reactor Building Purge, conducted 05/17/02
Liquid Effluent Permit SDT-1, conducted 08/07/02
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Liquid Effluent Permit WDT-10A, conducted 03/07/02
Liquid Effluent Permit WDT-1A, conducted 04/24/02
Audits, Self Assessments, and NCR Documents
NAS, Offsite Dose Calculation Manual (ODCM) Assessment Report No. C-ODCM-01-01,
dated December 18, 2001
NCR-52926, Overall SW System Leakage Trending Upward, 12/18/01
NCR-60352, RM-A6 Gas Channel Set Point Change, 05/06/02
NCR-60966, RM-L7 Set Point Determination During Condensate Release, 05/17/02
NCR-56413, Intralaboratory Cross Check Program, 02/25/02
NCR-59807, Turbine Building Sump, 04/24/02
Annual Reports
Crystal River-3, 2001 Annual Radioactive Effluent Release Report, dated 04/18/02
2PS3 Radiological Environmental Monitoring Program (REMP) and Radioactive Material
Control Program (71122.03)
Crystal River 3, Off-Site Dose Calculation Manual, Rev. 25
HPP-418, TCM Calibration and Operation, Rev. 8
HPP-438, Calibration and Operation of NE Technology Model SAM-9, Rev. 0
HPP-441, Calibration and Operation of NNC Model ITM-4T, Rev. 1
SP-153, Primary System Meteorological Monitoring Instrumentation Calibration, Rev. 10
SP-157A, Meteorological System Surveillance, Revision 18
SP-158, Backup System Meteorological Monitoring Instrumentation Calibration, Rev. 22
Records
Annual Calibration of the following contamination monitors: SAM [Small Article Monitor]-9,
S/N 265, conducted 07/02/2002; ITM-4T, S/N 370263, conducted 03/19/2002; and TCM
[Tool Contamination Monitor], S/N 463, conducted 04/17/2002
Semiannual calibration of primary meteorological monitoring instrumentation (per SP-153);
conducted 08/20/2001 and 02/05/2002
Semiannual calibration of backup meteorological monitoring instrumentation (per SP-158):
conducted 01/08/2002
Most recent calibration of State of Florida air-sampling equipment: location C07
S/N CA918984, conducted 06/10/2002; location C40, S/N 8191862, conducted
06/07/2002; and location C46, S/N 1695321, conducted 06/07/2002
NCR Documents
NCR 00045488, Poor Condition of Primary Met. Tower Building, dated 07/25/2001
NCR 00051051, Contaminated Tool, dated 11/05/2001
NCR 00052110, Backup Contamination Monitor Out of Service, dated 11/28/2001
NCR 00052534, Deficiencies in Control of Environmental Sampling Vendor, dated
12/04/2001
6
NCR 00057441, ITM-4T Gamma Release Monitor Out of Calibration, dated 03/09/2002
NCR 00060176, Backup Met. Tower Wind Direction Appears Incorrect, dated 05/02/2002
NCR 00068397, Rad. Prot. Rad. Monitor ITM-4T Failure to Detect Rad. Source, dated
08/07/2002
Audits and Self-Assessments
Annual Reports
Crystal River 3, 2001 Annual Radiological Environmental Operating Report, submitted
05/13/2002
3PP1
Access Authorization (Behavior Observation Program) and 3PP2 Access Control
Crystal River 3 Physical Security Plan (Sections applicable to the inspection being performed)
Licensee Procedures:
Fitness for Duty For-Cause Chemical Testing, SEC-NGGC-2142, Revision 9
Fitness for Duty Program, SEC-NGGC-2140, Revision 17
Reporting of Safeguards & Fitness For Duty Events, SEC-NGGC-2147, Revision 0
Continual Behavioral Observation Program, SEC-NGGC-2130, Revision 11
Nuclear Workers Screening Program for Unescorted Access, SEC-NGGC-2101, Revision 20
Compliance Procedure, CP-141, Safeguards Events & FFD Reporting Requirements,
Revision 12
Restrained Components & Key Control Procedure, CP-123, Revision 47
Security Key & Lock Controls, SS-301, Revision 12
Security Equipment Testing, Calibration, Inspection & Maintenance, SS-300, Revision 36
Security Access Controls, AI-803, Revision 2
Security Force Personnel General Orders, Duties & Responsibilities, Revision 43
Security Assessment Reports:
C-SC-01-01, dated 5/17/01
C-SC-02-01. dated 5/9/02
Access Authorization/Fitness for Duty Assessment Report, 02-07-AA/FFD-C, dated 6/14/02
NCRs:
00064283, 6/28/01, Unsafe Plant Conditions On AHF-27A/B/C Intake Screens
00044789, 7/11/01, Individual Injured In NAB Document Area by Rolling Shelf
00047829, 9/12/01, Incorrect Date Entered On Permanent Record
00048645, 9/26/01, Packaged Radioactive Material Fell Off Trailer
00054284, 1/18/02, Assessment Capability Deficiency
00057534, 3/15/02, Computer Records Retention
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4OA1 Performance Indicator Verification (71151)
Records
Florida Power Corporation TLD Number General Exposure Listing 01/01/2001 through
12/31/2001, and 01/01/2002 through 8/5/2002,
Calendar Year (CY) 2001, Electronic Alarming Dosimeter Alarm Summary,
Electronic Alarming Dosimeter Evaluations, dated 05/18/02 and 05/20/02
Crystal River-3, 2001 Annual Radioactive Effluent Release Report, dated 04/18/02
Audits, Self Assessments, and Nuclear Condition Report (NCR) Documents
NAS, ERC Assessment Report Number (No.) C-ERC-01-01, dated August 29. 2001.
NAS, ODCM Assessment Report No. C-ODCM-01-01, dated December 18, 2001
Self-Assessment Report No. SSAERC 51190, conducted March 4 -30, 2002