ML20042B696
| ML20042B696 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 12/10/1981 |
| From: | Baynard P FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20042B668 | List: |
| References | |
| 3F-1281-24, CS-81-326, NUDOCS 8203250544 | |
| Download: ML20042B696 (6) | |
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- 3F-1281 -24 Mr. J. P. O'Reilly, Director Office of Inspection & Enforcement U.S. Nuclear Regulatory Commission 101 Marietta St., Suite 3100 Atlanta, CA 30303
Subject:
Docket No. 50-302 Licensee DPR-72
Reference:
RII:TFS 50-302/81-21
Dear Mr. O'Reilly:
We offer.the following response to the violations listed in the referenced inspection report.
NOTICE OF' VIOLATION (sic)
A.
Technical Specifications 6.8.1.b requires adherence to procedures directing refueling operations.
Refueling procedure FP-409, Reactor Vessel Closure Head Removal, revision 3, requires in step 8.02 that the man in charge of perform-ing the activity initial the check-cff list after each step identi-fled with an "X" is performed. The procedure also requires in step 8.10 that the disconnection of all position indication and power cables be recorded to denote cable numbers and locations to assure proper reconnection.
Contrary to the above, personnel did not adhere to the requirements of the procedure FP-409 as follows:
-On October 15, 1981, procedural steps 8.2 through 8.36, identified with an "X" were initialed as being completed on this date even though a number of these steps were completed prior to that date;
-As of October 21, 1981, procedural step 7.8 which was to be performed prior to the reactor vessel head lift which occurred on October 15, has not been initialed; and, l
8203250544 820318 PDR ADOCK 05000302 O
PDR General Uttice 3201 Thirty fourth Street South e P O Box 14042 St Petersburg. Flonda 33733 e 813-866-5151
Notice of Violation Ref: RII:TFS 50-302/81-21 Page 2
-As of October 21, 1981, the procedural data sheet that documents position indication and power cable numbers and locations as required by procedural step 8.10 had not been completed.
A. Response: Florida Power Corporation agrees that the procedural requirement of having the individual in charge of performing the activity, initial the check-off list, was not adhered-to. The actual steps required by step 8.10 of FP-409 were performed but were not properly signed off.
Procedural step 7.8 was not signed off at all.
The steps listed as exampics of the violation required considerable activity and were conducted over a period of several days. With the exception of Sections 8.6 and 8.1.0, they were performed by other pro-cedures that are referenced by FP-409. These other procedures are cur-rently in their review cycles and can offer documentary evidence of the performance of these steps.
The most significant item cited in this violation appears to be the failure to complete the cable " connect / disconnect" data sheets in step 8.10 of FP-409.
This step should have been marked "NA" and annota-ted that the step had been satisfied by the performance of MP-108, Control Rod Drive Handling, which had been completed several days earlier.
The data sheets contained in MP-108 are available for review.
The individual in charge of this activity has been counseled as to his responsibilities in completing procedure data sheets.
Concerned Main-tenance personnel will have this violation and its possible consequences reviewed prior to January 15, 1982, and compliance will be achieved.
B.
10 CFR 73.55(d)(6) requires that individuals not authorized by the licensee to enter protected areas without escort shall be escorted by a watchman, or other individual designated by the licensee, while in l
a protected area and shall be badged to indicate that an escort is re-l quired. The Security Plan requires that all personnel not issued one of the Nucicar Plant badges shall be handled as visitors and escorted at all times while within the Protected Area.
Contrary to the above, on October 14, 1981, at 0840, two individuals l
not authorized to enter the protected areas without an escort were ob-served to be inside the protected area without an escort.
B. Response:
Florida Power Corporation concurs with the stated violation and the below listed actions were taken:
-Upon notification of the occurrence by the NRC Resident Inspector, the Nuclear Security and Special Projects Superintendent immediately went to the scene and counseled the escort and two visitor-badged indivi-i duals with respect to their responsibilities.
In addition, a new form,
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(attached) was instituted in November, 1981, which clearly defines responsibilities of escorts for red-badged visitors. This form documents the names of visitors and escort.
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Notice of Violation Ref: RII:TFS 50-302/81-21 Page 3
-Escort responsibility may be transferred by telephone; however, Security Force personnel have been instructed to read the escort re-sponsibilities to the the new escort if he/she is not familiar with them.
-As an additional measure, the Nuclear Plant Manager reviewed and deleted all nonessential names from the list, of personnel who can authorize visitors into the protected area.
The aforementioned violation and remedial action was discussed with all department heads on October 16, 1981, and full compliance was achieved.
C.
In accordance with the provisions of IE Inspection 81-21, no response is required for this violation, as the corrective action taken at the time of its occurrence was sufficient.
D.
Technical Specification 6.8.1 requires adherence to procedures covering applicable activities recommended in Appendix "A" of Regulatory Guide 1.33, November, 1972.
Regulatory Guide 1.33, Section 1.5 requires procedures for thc control of maintenance which includes a method of obtaining permission for work to be accomplished and a method for logging of such work.
Compliance Procedure CP-113. Procedure for Handling and Controlling Work Requests, Revision 26, step 5.3.1.1 requires the Nuclear Shift Supervisor to sign all Maintenance Work Requests before work is started to inu_re that the Nuclear Shift Supervisor is cognizant of the work being performed.
Contrary to the above, on October 16, 1981, an audit of twenty-one work requests covering the period of February 11, 1981, through October 5, 1981, indicates that eleven of the work requests had work completed prior to obtaining the Nuclear Shift Supervisor's signature, thereby preventing the Shift Supervisor from being cognizant of work being performed.
D. Response: Florida Power Corporation agrees with the stated violation.
It occurred due to the failure of Contract Maintenance Personnel to follow the applicable plant operating procedures. A comprehensive, documented review of the following procedures was conducted:
-1.
CP-103 Control and Issue of Welding Material
-2.
CP-ll3 Procedure for Handling and Controlling Work Requests
-3. CP-114 Procedure for Preparation of Permanent and Temporary Modifications
-4. CP-115 Inplant Equipment Clearance and Switching Orders
-5. AI-400 Plant Operating Quality Assurance Program Control Document.
Notice of Violation Ref: RII:TFS 50-302/81-21 Page 4 This documented review and the stressing of procedural compliance during initial employee indoctrination and Security badge training is considered adequate corrective action and full compliance has been achieved.
E.
Technical Specification 3.7.12 requires all penetration fire barriers protecting safety-related areas to be functional.
In addition, a continuous fire watch is to be established for any non-functional fire penetration barriers.
Contrary to the above, on October 20, 1981, at approximately 0645, fire barrier door D-203, separating "A" and "B" emergency diesel generator motor control center rooms and D-204, separating "A" emergency diesel generator were found propped open without a continuous fire watch established.
E. Response: When Crystal River Unit #3 committed to establishing Technical Specification 3.7.12 Fire Barrier Penetrations, Crystal River #3's under-standing was that this included only electrical penetration type fire stops. Also, the Technical Specification for Crystal River #3, under the basis definition of a fire penetration discusses only those types of penetrations that are a passive means in preventing fire spreading from one zone to another. This again points out that Crystal River
- 3 Technical Specification 3.7.12 does not cover fire doors between fire zones.
At no time in the past has the NRC, in writing, officially presented Crystal River #3 with a revised interpretation, nor has the NRC/NRR officially advised Crystal River #3 to upgrade our Technical Specifications to address fire doors as a penetration type fire barrier.
Therefore, we feel that this alleged fire protection violation may be I
a unilateral interpretation and lacks consistency from plant to plant.
For these reasons, we do not agree with the violation.
Should there be any questions, please contact us.
Very truly yours, FLORIDA POWER CORPORATION O
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Nuclear Plant Manager Nu lear Support Services JC/rc Attachment
ESCORT RESPONSIBILITY FOR RED BADGED VISITORS Personnel escorting Red Badged Visitors within the Crystal River #3 protected area are responsible for the following escort requirements:
a.
Responsible for maintaining visual contact with the visitor at al) times (the only exception would be for a visitor to enter a restroom with only one exit).
b.
Responsibic for the industrial and radiological safety of escorted visitors.
If an Alert, Site or General Emergcacy classification is declared, the visitor must immediately be escorted to the Guardhouse. A Red Badged visitor must not be escorted into a Radiation Controlled Area (RCA) without approval from a Health Physics Supervisor. When access to the RCA is required, ensure that the exposure limits specified by Chem / Rad are not exceeded and that safe radiological control practices are maintained.
c.
Escort responsibility may be transferred to another qualified individual; however, the person who signs for the visitor main-tains responsibility until a proper transfer is effected.
I understand the above stated duties for the visitors listed below.
Signature:
Date:
Transfer of escort duties for the above listed visitor (s) may be accomplished by calling extension 194.
Name of New Escort Time Effected Name of Security Force Individual Authorizing Transfer
STATE OF FLORIDA COUNTY OF PINELLAS PATSY Y. BAYNARD states that she is the Manager, Nuclear Support Services, of Florida Power Corporation; that she is authorized on the part of said company to sign and file with the Nuclear Regulatory Commission the information attached hereto; and that all such statements made and matters set forth therein are true and correct to the best of her knowledge, information, and belief.
2tw f.wm P TSY F.BAYNARD Subscribed and sworn to before me, a Notary Public in and for the State and County above named, this 10th day of December,1981.
W Nota 6f Public Notary Public, State of Florida at Large, My Commission Expires: May 29,1984