ML20197J824

Notice of Violation from Insp on 860308-0411

ML20197J824
Person / Time
Site:	Crystal River
Issue date:	05/15/1986
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20197J820	List: ML20197J817 ML20197J824 ML20197J840 ML20197J860
References
50-302-86-12, NUDOCS 8605200181
Download: ML20197J824 (2)

Text

j ENCLOSURE 1 NOTICE OF VIOLATION Florida Power Corporation Docket No. 50-302 Crystal River Unit 3 License No. DPR-72 The following violations were identified during an inspection conducted on March 8 - April 11,1986. The Severity Levels were assigned in accordance with the NRC Enforcement Policy (10 CFR Part 2, Appendix C).

1. Technical Specification (TS) 6.8.1 requires that written procedures be implemented to cover those activities recommended in Aapendix A of Regulatory Guide 1.33, November 1972, and to implement the Offsi te Dose Calculation Manual (0DCM).

Regulatory Guide 1.33, Appendix A, recommends maintenance procedures and/or work instructions for the performance of maintenance.

Step 7.2.9 of Maintenance Procedure MP-149, Check Valve Ca? Removal and Reinsta11ation, equires that check valve cap studs be lubr<icated prior to initial torquing Ste 5.2 of Work Request No. 075920 requires that Emergency Feedwater Pulp testing be stopped if vibration readings exceed the specified alert limits.

The ODCM Representative Sampling Method No. 3.1-5 requires the reactor building (RB) purge make-up (supply) fans to be shut down whenever both the RB personnel and equipment hatches are open.

Contrary to the above:

a. On March 14, 1986, procedure MP-149, Check Valve Cap Removai and Reinsta11ation, was not implemented in that check valve cap studs for check valve RWV-117 were not lubricated prior to initial installation of the check valve cap and torquing of the stud nuts,

b. During the period of March 10-11, 1986, Work Request No. 075920, which directed post-maintenance testing of the turbine driven emergency feedwater pump (EFP), was not implemented in that the testing was not stopped when EFP vibration levels reached and exceeded the alert ranges specified in the instructions.

c. On March 17, 1986, during the period from approximately 11:00 a.m.

to 11:45 a.m. , the RB purge make-up fans were not shut down while both the RB personnel and equipment hatches were open.

This is a Severity Level IV violation (Supplement I).

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Florida Power Corporation Docket No. 50-302 Crystal River Unit 3 2 License No. DPR-72

2. Technical Specification 6.8.2.b requires that certain procedural changes receive intradepartmental and interdisciplinary reviews by qualified reviewers prior to approval by the responsible superintendent or manager.

The Plant Review Committee (PRC) shall then review the 10 CFR 50.59 evalua-tion within 14 days of approval.

Technical Specification 6.8.1.a requires that written procedures be estab-lished to cover those activities recommended in Regulatory Guide 1.33, November 1972.

Regulatory Guide 1.33, Section A, recommends that administrative procedures be established to provide the method for changing procedures.

Contrary to the above, procedure AI-401, Origination of and Revisions to P0QAM Procedures, which implements TS 6.8.2.b., was found to be inadequate in that it allows Housekeeping Changes (HKCs) to be made to procedures and implemented following approval by the responsible superintendent or manager.

These HKCs do not receive the required review by appropriate intradepart-mental and interdisciplinary qualified reviewers nor are the associated safety evaluations reviewed within 14 days by the PRC.

As a result, several curves in the OP-103 series, Plant Curve Book, have been changed using HKCs. These include curves for radiation monitors for the Reactor reactor plantBuilding heatup /cooldown curves. air and Auxiliary Building liquid release paths an Additionally, on March 20, 1986, a HKC was used to add a quality control (QC) hold point to a maintenance procedure (MP-174) without receiving the reviews required by TS 6.8.2.b.

This is a Severity Level IV violation (Supplement I).

3. 10 CFR 50.73 (a)(2)(V)(B) requires the submittal of a Licensee Event Report (LER) within 30 days of the event for any condition that could result in a loss of the plant's ability to remove residual reactor heat.

Contrary to the above, on December 19, 1985, it was determined that a design error could cause a loss of residual reactor heat removal ability and no LER was issued.

This is a Severity Level V violation (Supplement I).

Pursuant to 10 CFR 2.201, you are required to submit to this office a written statement or explanation in reply, including: (1) admission or denial of the alleged violations; (2) the reasons for the violations if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved.

Security or safeguards information should be submitted as an enclosure to facilitate withholding it from public disclosure as required by 10 CFR 2.790(d) or 10 C R 73.21.

MY 15 1986 Date: