ML20206K036
| ML20206K036 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 06/19/1986 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20206K034 | List: |
| References | |
| 50-302-86-13, NUDOCS 8606270398 | |
| Download: ML20206K036 (41) | |
See also: IR 05000302/1986013
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June 19, 1986 !
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ENCLOSURE
SALP BOARD REPORT
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U. S. NUCLEAR REGULATORY COMMISSION
REGION II
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SYSTEMATIC ASSESSMENT OF LICENSEE PERFORMANCE
INSPECTION REPORT NUMBER
50-302/86-13
FLORIDA POWER CORPORATION
CRYSTAL RIVER UNIT 3
NOVEMBER 1, 1984 THROUGH MARCH 31, 1986 ;
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8606270398 860619
PDR ADOCK 0S000302
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I. Introduction
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The Systematic Assessment of Licensee Performance (SALP) program is an
integrated NRC staff effort to collect available observations and data on a
i periodic basis and to evaluate licensee performance based upon this informa-
tion. The SALP program is supplemental to normal regulatory processes used
to determine compliance with NRC rules and regulations. The SALP program is
intended to be sufficiently diagnostic to provide a rational basis for
allocating NRC resources and to provide meaningful guidance to licensee
management to promote quality and safety of plant corstruction and operation.
An hRC SALP Board, composed of the staf f members listed below, met on
May 27, 1986, to review the collection of performar.ce observations and data
to assess licensee performance in accordance with guidance in NRC Manual
Chapter 0516, " Systematic Assessment of Licensee Performance." A summary of
the guidance and evaluation criteria is provided in Section II of this
report.
This report is the SALP Board's assessment of the licensee's safety
performance at Crystal River Unit 3 for the period November 1, 1984, through
March 31, 1986.
SALP Board for Crystal River Unit 3:
L. A. Reyes, Acting Director, Division of Reactor Projects (DRP) RII
(Chairman)
A. F. Gibson, Director, Division of Reactor Safety, RII
D. M. Collins, Acting Director, Division of Radiation Safety and
Safeguards, RII
D. M. Verrelli, Chief, Reactor Projects Branch 2, DRP, RII
H. Silver, Project Manager - Crystal River, PWR Project Directorate #6, NRR
G. E. Edison, Deputy Project Director, PWR Project Directorate #6, NRR
T. Stetka, Senior Resident Inspector, Crystal River, DRP, RII
Attendees at SALP Board Meeting:
J. A. Hind, Director, Division of Radiation Safety and Safeguards, RIII
S. A. Elrod, Chief, Reactor Projects Section 2C, DRP, RII
K. D. Landis, Chief, Technical Support Staff (TSS) DRP, RII
S. Guenther, Project Engineer, Reactor Projects Section 2C, DRP, RII
J. K. Rausch, Reactor Engineer, TSS, DRP, RII
T. C. MacArthur, Radiation Specialist, TSS, DRP, RII
B. Mozafari, Project Manager, PWR Project Directorate #6, NRR
J. E. Tedrow, Resident Inspector, Crystal River, DRP, RII
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II. Criteria
! Licensee performance is assessed in selected functional areas depending on
whether the facility has been in the construction, preoperational, or
operating phase during the SALP review period. Each functional area l
represents an area which is normally significant to nuclear safety and the
environment and which is a normal programmatic area. Some functional areas
may not be assessed because of little or no li zensee activity or lack of
meaningful NRC observations. Special areas may be added to highlight
significant observations.
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One or more of the following evaluation criteria was used to assess each
functional area; however, the SALP Board is not limited to these criteria
and others may have been used where appropriate.
A. Management involvement in assuring quality
B. Approach to the resolution of technical issues from a safety standpoint
- C. Responsiveness to NRC initiatives
D. Enforcement history
E. Operational and construction events (including response to,
analysis of, and corrective actions for)
i F. Staffing (including management)
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G. Training and qualification effectiveness
Based upon the SALP Board assessment, each functional area evaluated is
classified into oneiof three performance categories. The definitions of
these performance categories are:
Category 1: i
Reluced NRC attention may be appropriate. Licensee
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management attent. ion and involvement are aggressive and oriented toward
i nuclear safety; iicensee resources are ample and effectively used such
that a high level of performance with respect to operational safety or
j construction quality is being achieved.
Category 2: NRC ittention should be maintained at normal levels.
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Licensee management attention and involvement are evident and are
J concerned with nuclear safety; licensee resources are adequate and are
reasonably effective such that satisfactory performance with respect to
l operational safety or construction quality is being achieved.
Category 3: Both NRCx and licensee attention should be increased.
Licensee management agtention or involvement is acceptable and
considers nuclear safety, but weaknesses are evident; licensee
resources appear to be .3 trained or not effectively used such that
minimally satisfactory performance with respect to operational safety
or construction quality is being achieved.
The functional area being evaluated may have some attributes that would
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place the evaluation in Category 1, and others that would place it in either
Category 2 or 3. The final rating for each functional area is a composite
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of the attributes tempered with the judgement of NRC management as to the
significance of individual itens.
The SALP Board may also include an appraisal of the performance trend of a
functional area. This performance trend will only be used when both a
definite trend of performance within the evaluation period is discernible
, and the Board believes that continuation of the trend may result in a change
of performance level. The trend, if used, is defined as:
Improving: Licensee performance was determined to be improving near the I
close of the assessment period.
Declining: Licensee performance was determined to be declining near the
close of the assessment period.
III. Summary of Results
A. Overall Facility Evaluation
- The Crystal River Facility was effectively managed and has achieved a
l satisfactory level of operational safety. The licensee continued to
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exhibit a strong maintenance program and has improved deficiencies
J identified during the last SALP assessment period in the surveillance
) area. However, general weaknesses were noted in the areas of procedural
- adherence and adequacy, the review and approval process for making
1 changes to plant procedures, the control of contract personnel,
i training and qualification effectiveness, and security. In addition,
while still satisfactory, a weakening and declining trend was noted in
j the area of radiological controls.
The licensee has initiated a program to address the procedural
adherence issue. Reports of recurrent procedural noncompliance receive
] high level management review to determine the root cause of the problem
, and to assess the adequacy of corrective actions. The long-term
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results of this program are not readily apparent and its overall
effectiveness cannot be judged at this time. Based on the findings
during this assessment period, management involvement in these areas
should continue and is recommended.
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j The licensee continues to have problems with procedural adequacy both i
. in content and in the review and approval process. To improve in this '
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area, the licensee has attempted to clarify these requirements by ;
I revising the administrative instruction governing the review and l
l approval of changes to plant procedures and by constructing writer's 1
i guides for departmental procedures. The licensee has also implemented
a training summary sheet to accompany revisions to administrative and
- compliance procedures in an attempt to minimize misunderstanding of
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these revisions. The licensee should continue its efforts to improve
I performance in this area.
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l Actions taken to improve control of contractor personnel include a t
training program in modification procedure usage. To strengthen this
area, the licensee needs to pursue this program and increase the
monitoring of contractor activities.
Regarding the licensee's security program, the recurring finding of
breached vital area barriers remained a weakness during this SALP
period. We understand that frequent surveys of the barriers have been
directed by plant management in an attempt to correct this recurring
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violation. The licensee has audited its security program and found
numerous other items which need to be corrected or upgraded to meet
! regulatory commitments.
Diminished radiological control of work practices was evidence of a ,
weakening of the overall radiation protection program. Problem areas
observed were typified by failure to implement existing radiation
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protection procedures or use of procedures that inadequately
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implemented regulatory requirements. The nature and frequency of
inspection findings were indicative of insufficient plant management
review, involvement and support for this functional area.
B. The performance categories for the current and previous SALP period in
j each functional area are as follows:
l July 1, 1983 - November 1, 1984 -
i Functional Area October 31, 1984 March 31, 1986
Plant Operations 2 2
Radiological Controls 2 2
Maintenance 1 1
! Surveillance 3 2
Fire Protection Not Rated 2
- Security and Safeguards 3 3
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Outages Not Rated 2
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l Quality Programs and Administrative 2 3
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Controls Affecting Quality l
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Licensing Activities 2 2 ;
Training and Qualification Not Rated 3 l
Effectiveness
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IV. Performance Analysis
l A. Plant Operations
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1. Analysis
During this evaluation period, inspections of plant operations
were performed by the resident and regional inspection staffs.
Major operational decisions were made at a management level
adequate to assure appropriate supervisory involvement. Plant
operations were generally conducted in a conservative manner to
ensure plant safety. An example of this conservative approach to
operations included the decision to shut down the plant af ter an
increase in unidentified reactor coolant system leakage was
observed even though license conditions allowed continued plant
operation.
- Overall control of plant operations was satisfactory. In September
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1985, plant operators responded effectively to a failed reactor
coolant system pressure transmitter, thereby preventing a reactor
trip and minimizing the resultant pressure transient to which the
plant was subjected.
Three notable instances of inadequate control of plant operations
! were observed. The first instance occurred whtle the reactor was
shut down in August 1985, when operators reset an initiating
! signal for the emergency feedwater system without verifying
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whether the actuation was necessary. Since the actuation signal
! was valid, this action resulted in another automatic actuation of
j this system. The second instance occurred in November 1985, when
, a reactor trip occurred when transferring control of the main
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feedwater system while conducting a plant shutdown. Inadequate
corrective action for a feedwater control valve problem identified
during a previous post-trip review, combined with operator error, j
resulted in insufficient feedwater flow to the steam generator and -
{ a high pressure reactor trip. The third instance occurred while
the reactor was shut down in December 1985, when an operator error
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in not bypassing the reactor coolant pump (RCP) power monitor trip
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resulted in a reactor protection system actuation causing a group
of control rods to drop into the core. !
The plant underwent a refueling and extensive modification outage
in which major new equipment was installed. Extensive operator
- training on these plant modifications was conducted to familiarize
i the operators with the new equipment. The plant had several
! minor, short-term maintenance shutdowns following this outage.
These shutdowns were well planned and coordinated. l
Eight reactor trips from power operation occurred during the
assessment period; seven were caused by equipment failures and one
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by an operator error. All of the trips occurred during the
operating period following the 1985 refueling / modification outage
and many are attributable to startup problems associated with
j equipment modifications. Prior to the refueling shutdown on
March 9,1985, the unit had operated since April 26, 1984 without
a reactor trip and had a 1984 availability factor of 94.5%. In
l January 1986, the plant suffered a reactor trip due to a failed
reactor coolant pump shaft and has remained shutdown pending
completion of extensive repairs. (See Section V.J for a reactor
trip summary).
Operations staffing was adequate. Because there has been little
- licensed operator turnover, there has been generally good continuity
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in the level of understanding and implementation of plant procedures
! and practices,
j Findings by an NRC training assessment team and performance on NRC
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requalification exams resulted in the necessity to requalify all
j licensed operators during the major outage discussed above (see
the Training analysis for additional discussion). This necessitated ,
i a sharp increase in overtime for on-shif t operators, which,
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coupled with the retrainirg efforts, had a detrimental effect on
- operator morale; however, no detrimental effect was noted on plant
operations.
The plant staff appeared observant of Limiting Conditions for
i Operation (LCOs) and was generally conservative in its application I
of action statement requirements. However, violations (a), (b) .
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and (d) listed below involve failures to comply with Technical
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Specification (VS) requirements.
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Viciations (c), (e) and (0) identified below involve procedural
! inadequacies and operator failures to comply with procedures. The t
l licensee is addressing this weakness by implementing an operations ,
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procedure writing guide to oe used in improving and clarifying
i procedures. Another part of the procedure improvement program
i includes validation of procedure requirements and an actual
walkthrough of the procedures. When this program is fully
- implemented, it should have a positive effect on plant operations.
Additionally, the licensee has used senior reactor operators on a
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routine basis to observe performance of operating procedures to
i verify procedural adherence and adequacy. This process appears to
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be effective.
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I Violations (f), (h) and (i), listed below pertain to inadequate
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review and approval of changes to procedures. Similar violations i
related to the procedure change process are identified in the i
Surveillance, Outage and Quality Programs analyses. This indicates !
a lack of familiarity by plant personnel with the administrative l
procedure which controls this process. l
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The conduct of shift turnover meetings continues to be a strong
point in plant operations. Attendance by other departments is
required during these meetings; this has a positive effect on
overall plant control and coordination of plant activities. These
meetings are held in the control room, and access to this area is
restricted during these meetings. Control room operations have
been and continue to be conducted in an orderly and professional
manner.
Nine violations and two deviations were identified:
a. Severity Level IV violation for failure to take reactor
coolant system grab samples after a change in power level as
required by Technical Specifications. (84-30)
b. Severity Level IV violation for failure to secure waste gas
additions to a radioactive waste gas decay tank when required
by Technical Specifications. (84-33)
c. Severity Level IV violation for failure to have an adequate
procedure for valve lineup verification. (85-33)
d. Severity Level IV violation for failure to have an operable
emergency diesel generator during core alterations and mode
changes as required by Technical Specifications. (85-33)
e. Severity Level IV violation for failure to adhere to the
requirements of a reactor startup procedure. (85-41)
f. Severity Level IV violation for an improper temporary change
to a decay heat removal system operating procedure. (86-09)
g. Severity Level IV violation for failure to adhere to the
requirements of a procedure. (86-0a)
h. Severity Level IV violation for an improper change to the
procedure for decay heat seawater system operation. (85-08)
1. Severity Level V violation for making an improper procedure
change to the Operations Section Implementation Manual and
failure to conduct a periodic review. (85-08)
j. Deviation for failure to maintain the emergency diesel
generator air start system pressure. (85-21)
k. Deviation for failure to .Taintain the corrective actions
taken for a previous violation of a waste gas decay tank
Technical Specification. (85-44)
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2. Cor.clusion
Category: 2
3. Board Recommendations
Failures to comply with Technical Specification requirements in
this area warrant further licensee effort to improve performance.
No changes in NRC inspection resources are recommended.
B. Radiological Controls
1. Analysis
During the assessment period, inspections were performed by the
resident and regional inspection staffs. This included confirma-
tc > j measurements using the Region II mobile laboratory.
In comparison with the previous assessment period, the licensee
showed weakening of the radiation protection program. Problems
were identified in the positive access control program for high
radiation areas (violatiofis d and f), and also in the area of
personnel monitoring in which procedures were not adequate to
implement good frisking practices (violation a). This area was
cited a second time when the licensee's corrective action was
found inadequate (violation c). Implementation of the Radiation
Work Permit (RWP) program also exhibited deficiencies in that, on
two separate occasions, individuals were observed in noncompliance
with the protective clothing requirements of the RWP (violations e
and i). The RWP program was also found to be procedurally deficient
in that adequate controls were not specified for RWP revisions
(violation h). Other procedural deficiencies were noted during
the assessment period and included such areas as Maximum Permissible
Concentration (MPC) hour calculations from ingestion (violation k),
calibration of the whole body counter (violation 1), Offsite Dose
i Calculation Manual requirements (violation j) and Technical
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Specification requiren1ents (violation b).
Licerisee management support and involvement in the radiation
protection program appeared weak. This was exemplified by the
onsite health physics staff's lack of stop work authority when
failures to comply with RWP requirements were detected. The
health physics technicians and their first line supervisors must
go through their management chain to plant management to stop work
on a job when the radiological conditions warrant such action. In
February 1986, the potential for an unmonitored release from the
reactor building was identified. A reactive inspection was
conducted at which time it was determined that containment
integrity was not established after it was known that an airborne
radioactivity problem existed. The failure was attributed to the
lack of authority by health physics to require closure of the
containment hatches.
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The licensee's health physics staffing level was adequate. In
conjunction with the contract health physics technicians normally
maintained onsite, adequate coverage was available for routine
operation. The health physics staff was further augmented by
additional contract technicians during outage operations. The
health physics staff turnover was low during the evaluation
period. The licensee relied strongly on offsite contractor
expertise for such services as dosimetry processing, waste
classification and quality assurance auditors.
During 1985, the licensee developed a formal training and
qualification program for radiation protection and chemistry
technicians. A task analysis methodology was utilized in
development of these programs and it was anticipated that both
programs would be submitted to the Institute of Nuclear Power
Operations for certification during 1986.
The licensee's approach to resolving health physics technical
issues was, in general, adequate. In the area of radiological
measurements, the licensee's understanding of technical issues and
its approach to problem solving was generally adequate; however,
problems with measurement controls were noted. Specific conceras
included biases in gaseous effluent measurements and disagreement
for one nuclide in the NRC's spiked sample analysis program.
Corrective action for the latter has not been reviewed at this
time. Previous corrective actions for similar matters were
adequate and timely.
The licensee submitted the required effluent and environmental
reports during the rating period. Both liquid and gaseous
effluents were within limits for total quantities and concentra-
tions of radioactive material released and for radiation dose to
the maximally exposed individual. There were eight unplanned
gaseous effluent releases during the second half of 1985, all of
which were related to reactor trips. All of these releases were
adequately monitored. There were no unplanned liquid releases
during the assessment period. As discussed earlier, the potential
for an unmonitored release from the reactor building due to
maintenance activities occurred late in the evaluation period and
has been corrected.
Plant chemistry and corrosion control compliance has improved
since the previous assessment interval even though a serious
problem with corrosion product buildup in the steam generators
attributed to plant design continued during this period.
Significant improvement in the efficiency of the condensate
polishing system was achieved, permitting effective implementation
of the licensee's water chemistry program. The licensee's ability
to implement the program was improved by the acquisition of
additional personnel and upgraded instrumentation. The licensee
has improved its chemistry program by incorporating the Electric
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Power Research Institute (EPRI) guidelines int; its chemistry
procedures. The licensee is also actively involve:i in the develop-
ment of the once through steam generator (OTSG) water slap technology
and is conducting research on chemical cleaning of OTSGs.
A weakness discussed in the last SALP report, that of chemistry
personnel failing to adhere to radiochemistry procedures, appears
to have been corrected as evidenced by the absence of violations
in this area.
Personnel exposures during 1985 were approximately 646 man-rem,
which was a large increase over the 46 man-rem reported in 1984.
This is explained by the fact that a major refueling, maintenance,
and modification outage was conducted in 1985 while no significant
outages took place in 1984 (94.5 percent unit availability). The
collective dose was higher than the average (425 man-rem) for
similar PWR facilities, but is not significant considering the
scope of outage work perforced in l'J85.
The licensee began tracking contaminated areas of the facility in
October 1985, when approximately 21,000 square feet of the plant
were maintained as contaminated. By January 1, 1986, the contami-
nated area had been decreased to 12,500 square feet which corresponded
to approximately 18 percent of the auxiliary building. The
licensee had initiated action to increase its contamination
control effort by dedicating a full time, six man crew to
decontamination work. This decontamination program has increased
plant accessibility and has improved plant housekeeping.
During 1985, the licensee made 43 shipments of radioactive waste
consisting of 17,643 cubic feet of waste containing 4,595 curies
of activity. This is more than the national average of 11,653
cubic feet shipped by other utilities with similar facilities, but
is not significant considering the scope of outage work perforced
in 1985. Approximately 2,646 cubic feet of solid waste remained
onsite at the end of the assessment period.
Fourteen violations were identified:
a. Severity Level IV violation for inadequate procedure to
assure implementation of the whole body frisking program. l
(85-12)
b. Severity Level IV violation for failure to take grab samples
when a radiation monitoring instrument was inoperable as
required by Technical Specifications. (85-33) l
c. Severity Level IV violation for failure to perform personnel
frisks and instrument checks. (85-34)
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d. Severity Level IV violation for failure to post and barricade
a High Radiation Area. (85-41)
e. Severity Level IV violation for failure to follow the
protective clothing requirements of a Radiation Work Permit.
(85-41)
f. Severity Level IV violation for failure of a worker to
possess a monitoring device to continuously indicate dose
rates in a High Radiation Area. (86-06)
g. Severity Level IV violation for failure to perform surveys
necessary to evaluate an airborne radioactivity release to
unrestricted areas and evaluate the radiological hazards that
could be present during hydrolasing activities. (86-11)
h. Severity Level IV violation for inadequate procedure for
Radiation Work Permit revisions. (86-11)
1. Severity Level -IV violation for failure to wear appropriate
protective clothing in a contaminated area. (85-44)
j. Severity Level IV violation for failure to adhere to the
requirements of the Offsite Dose Calculation Manual. (85-29)
k. Severity Level V violation for failure to maintain an adequate
procedure to calculate MPC hours for cases of radioactive
material ingestion. (85-34)
1. Severity Level V violation for failure to have approved,
written procedures for calibration of the whole body counting
system. (85-05)
m. Severity Level V violation for failure to properly label
containers of radioactive material. (85-12)
n. Severity Level V violation for failure to post documents as
-required by 10 CFR 19.11. (85-12)
One additional, apparent Severity Level IV violation was proposed
for failure to provide reasonable assurance that radioactive waste
was properly classified. (86-06). The licensee has contested
this citation, and the matter is under review by the NRC.
2. Conclusion
Category: 2
Trend: Declining
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3. Board' Recommendations
Based on the observed declining trend, increased licensee manage-
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ment attention is needed to address and correct the weakening
program. The NRC should increase its inspection resources to
monitor progress in this area.
C. Maintenance
1. Analysis
During this evaluation period, inspections were conducted by the
resident and regional inspection staffs.
The maintenance program continued to be strong. High management
involvement in maintenance planning and practices was evident.
First line supervisors and maintenance personnel generally
indicated a high awareness for procedural adherence. There was
one violation in the area of procedural adherence and one violation
, involving procedural adequacy. To minimize these occurrences, the
licensee has instituted a procedure rewrite program for this
department designed to remove human factors errors in reading
these procedures, thereby improving procedural adequacy and
adherence. This program was nearly complete at the end of this
evaluation period.
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In most areas the licensee's approach to the resolution of
technical issues continued to be sound. Subsequent to the RCP
shaft failure in January 1986, all the RCP shafts were tested and
evaluated for possible degradation. The licensee decided to
replace all the RCP rotating assemblies despite the absence of
hard evidence that all the shafts were indeed flawed. Other plant
equipment was promptly. repaired or replaced when degradation was
. indicated by the predictive maintenance program.
The use of predictive maintenance analysis is a continuing strength
of the licensee's program. This program utilizes oil and vibration
analyses on mechanical equipment and infrared analysis on electrical
equipment, and is beginning to use the Motor Operated Valve
Analysis and Testing System (M0 VATS) to determine operability of I
motor operated valves. These techniques have enabled the licensee
to predict degrading trends in equipment performance and effect
repairs before equipment failure occurs. The licensea is evaluating
the use of a raliability centered maintenance program to further
increase the reliability of plant equipment. This program utilizes
machinery history data and the frequency at which components fail
in an effort to anticipate component failures. If added, this
program would further strengthen the maintenance program.
An inspection conducted to evaluate the licensee's actions in
response to Generic Letter 83-28 revealed that maintenance
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activity and pon-maintenance testing were adequate to ensure
reactor trip system reliability.
Two violations were identified:
a. Severity Level IV violation for failure to adhere to a
maintenance procedure while installing control rod drive
motor tubes. (85-29)
b. Severity Level IV violation for failure to have an adequate
preventive maintenance procedure for conducting diesel
generator insulation resistance checks. (86-09)
2. Conclusion
Category: 1
3. Board Recommendations
No changes in the NRC's inspection resources are recommended.
D. Surveillance
1. Analysis
During this assessment period, inspections of surteillance testing
activities were performed by the regional and resident inspection
staffs. The surveillance testing program and calibration control
program were also reviewed by the regional inspection staff.
Considerable inspection effort has been devoted to this area as a
result of the previous SALP rating.
The licensee's surveillance testing and calibration control
program was generally well established and implemented.
Scheduling and completion of surveillances have been -within
Technical Specification time limits and have received adequate
management attention. Selected survefilance test procedures
appeared well written.
Several aspects of surveillance testing have been improved by the
licensee during this assessment period. The plant's engineering
and technical services groups have made definite progress in
revising and clarifying surveillance procedures using writer's
guides. This has greatly increased operator and technician
understanding and compliance with surveillance test procedures.
The licensee's procedure adherence review plan has also helped to
increase the awareness of plant personnel to procedural compliance.
Surveillance and maintenance procedures have been revised to
require the recording of actual calibration dates for measuring
and test equipment (M&TE) thus providing acknowledgment by the
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person performing the test that calibrated equipment is being
used.
The licensee has improved and updated the installed instrumenta-
tion calibration program, which is now a useful tool in tracking
and scheduling instrument calibrations. While there are some
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problems with the computer data base, the improvement of this
program has strengthened this area considerably.
Violation (a) indicated an improper change to a surveillance
procedure. This issue is similar to that discussed in the
Operations analysis and is indicative of an inadequacy in the
administrative procedures governing the control of these changes.
Violation (c) involved a failure to perform surveillance testing
when required and violation (b) identified a failure to adhere to
the requirements of a procedure. The number of violations of this
type has decreased substantially since the previous SALP.
Surveillance procedures used during the refueling process to
confirm proper operation of systems disturbed during refueling or
to confirm core design parameters were generally lacking in
guidance on data collection and analysis. Consequently, the
quality of some data was poor. Procedural inadequacies included
insufficient data and log sheets necessary to record test
observations, inconsistency between procedures, inadequate
statistical bases for data rejection criteria, and inadequate
definition of terms and data sources to be used in equations. The
licensee had recognized this problem prior to the inspection and
had begun to develop the procedure writer's guide to address the
problems.
Four violations were identified:
a. Severity Level IV violation for an improper change to an
emergency diesel generator surveillance procedure. (85-21)
b. Severity Level IV violation for failure to adhere to a
surveillance procedure while conducting nuclear services
seawater system hydrostatic testing. (85-26)
c. Severity Level IV violation for failure to perform a
surveillance test of the source range neutron flux monitor.
(85-29)
d. Severity Level V violation for an inadequate meteorological
system surveillance procedure. (84-34)
2. Conclusion
Category: 2
l
,
.
16
3. Board Recommendations
.
Management attention in improving surveillance procedures has
resulted in definite progress in this area. No changes in the
NRC's inspection resources are recommended.
E. Fire Protection
1. Analysis
During the assessment period, inspections were conducted by the
regional inspection staff in the areas of fire prevention and
protection and the status of the licensee's implementation of
their commitments regarding the safe shutdown requirements of
The licensee has issued procedures for the administrative control
of fire hazards within the plant, for the surveillance and
maintenance of the fire protection systems and equipment, and for
the organization and training of a plant fire brigade. These
i procedures were reviewed and found to meet the NRC's requirements
and guidelines.
The inspectors reviewed the licensee's implementation of the fire
protection program and administrative controls. General house-
keeping and control of flammable materials were satisfactory. The
fire protection extinguishing and detection systems were found to
be serviceable. Organization and staffing of the plant fire
brigade met the NRC's guidelines. The training and drills for the
- brigade members met the frequency specified by the procedures and
the NRC's guidelines.
The Appendix R review performed by the licensee identified
numerous cable interaction discrepancies, fire barrier
discrepancies and open or unprotected fire barrier penetrations
throughout the plant. However, fire vatch patrols were posted in
- accordance with the Technical Specifications.
A subsequent regional Appendix R fire protection team inspection
was conducted on July 29 - August 2, 1985. Findings generally
coincided with the licensee's findings and included such issues as
incomplete installation of cable raceway fire barriers, incomplete
fire door modifications, inadequate interior fire hose stations,
incomplete review of emergency lighting and communications for
remote safe plant shutdown, and incomplete operator procedures and
training for safe plant shutdown in the event of a fire. These
items were typical of findings at other facilities and were not
identified as enforcement issues since, at the time of the
inspection, the plant's Appendix R fire protection program was not
yet required to be in place or implemented. The licensee's
corrective actions for these findings were scheduled to be
!
'__________
. ..
%
..
17
- completed near the end of this assessment period and have not been
reinspected.
The annual fire protection / prevention audit, the 24 month QA fire
protection program audit by offsite organizations and the triennial
audit by an outside fire protection organization required by the
Technical Specifications were reviewed. These audits were conducted
within the specified frequency and appeared to cover all of the
essential elements of the fire protection program. The licensee
>
had implemented corrective action on discrepancies identified by
the audits.
In general, the management involvement and control in assuring
quality in the fire protection program was adequate as evidenced
by the issuance and effective implementation of fire protection
procedures that meet the NRC requirements and guidelines.
'
During the Appendix R fire protection team audit, the licensee's
engineering staff and their consultants displayed a clear
understanding of the fire protection issues. The licensee '
responded to NRC initiatives by implementing the Appendix R
requirements or requesting exemptions where necessary.
The fire protection staff positions are adequately identified and
authorities and responsibilities are defined. Personnel appear
qualified for their assigned duties. The licensee has a limited
fire protection technical staff and made extensive use of consultants
for inost of the Appendix R analysis effort. Frequent overtime was
required to accomplish work activities. However, some improvement
4 has been seen during the assessment period with the hiring of an
additional technical staff member.
No violations or deviations were identified.
l 2. Conclusion
Category: 2
3. Board Recommendations
The size of the onsite fire protection staff appears marginal and
there is some concern whether adequate technical expertise will
remain onsite in the long term. Licensee management should take
measures to ensure that the staff's size and technical expertise
remains adequate. No changes in the NRC's inspection resources
are recommended.
j
_ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ - - _ - _ _ - _ _ - _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ - _ - - _ _ - _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ - _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ .
%
.
.
18
t
1. Analysis
- During the assessment period, inspections were performed by the
. regional and resident inspection staffs. These included observa-
I tion of an annual emergency preparedness exercise and one routine
inspection.
The routine inspection and exercise evaluation indicated that the
onsite emergency organization was effective in dealing with
,
simulated emergencies. Adequate staffing of the etergency
response facilities was demonstrated. Corporate management
appeared to be ccamitted to maintaining an effective emergency
'
response program, and was directly involved in the annual exercise
and several subsequent critiques. Personnel assigned to the
emergency organizations were cognizant of their emergency response
roles, and, with the exception of dose assessment personnel during
i the exercise, were adequately trained in the required areas of
!
emergency response (See additional discussion below).
Evaluation of the annual emergency preparedness exercise disclosed
that the following essential elements for emergency response were
acceptable: emergency classification; notification and communica-
! tions; public information; shift staffing and augmentation;
emergency preparedness training; emergency worker protection;
post-accident measurements and instrumentation; changes to the
emergency preparedness program; and annual quality assurance
audits of the plant and corporate emergency planning programs.
The exercise demonstrated that the plan and procedures could be
effectively implemented in the areas of communications, accident
i assessment, and exposure control . The licensee also demonstrated
'
an adequate working relationship with offsite emergency support
organizations. The licensee has been responsive to NRC initiatives
- regarding correction of identified weakness and suggested program
improvements.
- The exercise evaluation disclosed an adverse finding in the area
! of dose assessment. The dose assessment / projection values
calculated and recorded by the Emergency Operations Facility (EOF)
differed significantly from those calculated by the Technical
- Support Center (TSC), and neither facility's rasults agreed with
the simulated radiological releases and accident parameters
defined in the exercise scenario. The differences between the
projected offsite doses calculated by the TSC and EOF caused
unnecessary delays in event classification and protective action
i recommendations. The licensee committed to conduct a detailed
l review of the TSC and E0F dose assessment computer programs and
manual calculations in an effort to resolve the apparent ;
!
'
l
! __
.
4
..
19
discrepancies. No violations were issued for actions during the
exercise.
During routine inspection interviews, walkthroughs and observa-
tions, the licensee's emergency response personnel demonstrated
the following capabilities: prompt and effective classification
of hypothetical emergency events; implementation of appropriate
action to control the plant casualty; prompt notification of
State, local and offsite organizations; appropriate protective
action recommendations; and controlled management of field
monitering teams. The inspection disclosed a violation related to
the emergency operating procedure for seismic events.
With the exception of dose assessment performance, the routine
inspection and annual exercise evaluation indicated that the
onsite emergency organization was effective in dealing with
simulated emergencies.
One violation was identified:
Severity Level V violation for failure to provide an adequate
procedure regarding timely reactor shutdown in the event of
an earthquake. (85-18)
2. Conclusion
Category: 2
3. Board Recommendations
No changes in the NRC's inspection resources are recommended.
G. Security and Safeguards
1. Analysis
During the evaluation period, inspections were conducted by the
resident and regione) inspection staffs. The NRC Regulatory
Effectiveness Review was also conducted during this evaluation
period.
The licensee has adequately staffed its contract site security
organization, and has trained and equipped its security shif ts in
an appropriate manner to meet the requirements of its Physical
Security Plan. This was evident during an unannounced security
contingency drill conducted during the early morning hours which
required the security force to respond to a scenario involving an
intruder. Liaison with offsite response forces was also apparent,
and included onsite familiarization with the facility.
.
,
.
.
20
The licensee's program for maintaining a current Physical Security
Plan has been adequate. However, the last revision to the Plan,
Revision 4, dated November 1, 1985, contained several changes
which were determined by NRC Region II to be inconsistent with the
provisions of 10 CFR 50.54(p). These changes decreased the
overall effectiveness of the Security program as reflected in
current commitments to the NRC.
Reports of Safeguards Events submitted as required by 10 CFR 73.71
were accurate and timely. The reports received during this SALP
l evaluation period suggest that the age and design of the security
!
equipment and systems require excessive repair and maintenance,
necessitating compensatory security measures. As noted in the
previous SALP, the licensee has been auditing its security program
to identify hardware and equipment deficiencies which will require
improvements to meet the commitments contained in its Plan. This
effort has resulted in the finalization of a schedule for installing
an improved protected area intrusion detection system, a new
security perimeter fence, and a standby computer. The licensee
- has met with the NRC Region II security staff to update milestones
in this equipment upgrade and to make improvements to its Plan.
'
The Regulatory Effectiveness Review identified several deficiencies.
.
The licensee's audit program had previously identified many of
!
those daficiencies and was addressing corrective actions.
While this audit effort is to the licensee's credit, it has
resulted in the finding of failures to meet regulatory require-
ments and long-standing licensee commitments.
The licensee has continued to experience serious and repetitious
'
, failures to maintain vital area barriers. This trend was
identified in the previous SALP report and resulted in the
'
licensee taking minimal corrective measures. In that SALP period
a Civil Penalty of $50,000 was issued for failure to maintain
vital area barriers. The current Severity Level III violation,
and proposed $100,000 Civil Penalty, involves a degraded vital
area barrier which was identified and reported by the licensee.
7
However, the Region II inspection of this recurrence revealed that
an inadequate compensatory measure was taken by the licensee and
that the barrier violation had existed for an unacceptably long
i time. It should be noted that the violation is cited as one
Severity Level III with five examples of regulatory noncompliance,
including an inadequate investigation of the incident, and the
failure of non-security personnel to perform their security-
.
related duties. The proposed escalated enforcement action was
i issued on April 16, 1986, after the close of this SALP evaluation
period. As of the date of this report, the licensee has responded
to this violation requesting partial mitigation of the Civil
Penalty. This request is being reviewed by the NRC. Vital area
__ - _ _ _ _ - - _ - _ _ _ - - _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ - - - _ - _ - _ _ _ - - _ _ _ _ _ _ _ _ - _ - - _
. -
'
,
,
T
..
21
barrier integrity is the single most pressing security issue
4 requiring management attention.
Four violations were identified:
a. Severity Level III violation for a breached vital area
barrier. (86-02). The licensee's request for partial
mitigation of the proposed $100,000 Civil Penalty is being
evaluated.
l b. Severity Level IV violation for inadequate communications
I with local law enforcement agencies. (85-35) i
i c. Severity Level IV violation for failure to control access to
the protected area. (85-35)
d. Severity Level IV violation for an inadequate assessment
capability. (86-10)
I 2. Conclusion
Category: 3
,
3. Board Recommendations
Increased licensee and NRC management attention is necessary in
this functional area.
H. Outages
1 1. Analysis
During this evaluation period, inspections of refueling
.
activities, outage management, major plant modifications and
'
post-outage startup testing were performed by the regional and
'
resident inspection staffs. The regional staff also reviewed the
design change program; inservice inspections (ISI) of safety-
,
related components and associated piping, supports, and snubbers;
j inservice testing (IST) of pumps and valves; welding; nondestruc-
tive testing; and work associated with the failure of the reactor
coolant pump (RCP) shafts.
1
A refueling and extensive plant modification outage commenced in
- March 1985, and was completed in August 1985. Major licensee
activities during the outage included an inservice inspection of
the reactor vessel, inspection and replacement of reactor core
i barrel bolts, completion of NUREG 0737 required items including
the installation of an emergency feedwater initiation and control
(EFIC) system, and completion of Appendix R fire protection
requirements including the installation of a new remote shutdown
panel. Another major,- but unplanned, plant outage commenced in
_ _ _ _ - _ . - _
_
.- -
-
1
'.
22
l
l
January 1986, to replace the rotating assemblies on all four
reactor coolant pumps. This outage was still in progress at the
end of this assessment period.
- Preparations for refueling and refueling procedures were found to
l be adequate. Fuel handling activities were observed to be
i generally acceptable. Compliance with Technical Specifications
l and adherence to refueling procedures were observed to be
! acceptable. Violation (c) relates to a failure to adhere to the
i
requirements of a refueling procedure and violation (f) involves a
failure to adhere to the requirements of a Technical Specification
during refueling operations.
Overall control and planning for major outages is a strength.
Pre-outage planning and preparations were commenced months before
the scheduled shutdown and included the start of modification
preparations in the field. This resulted in a significant amount
of work around operating equipment in the plant; the fact that no
i plant trips occurred demonstrated good control over personnel,
i The Nuclear Outage and Modificatien Department was restructured
such that the Outage Manager reports directly to the
Vice-President for Nuclear Operations; the effectiveness of this
restructuring cannot be judged at this time.
The use of outage planning meetings is also noted as a strength of
this program. These meetings were held twice daily to schedule
activities and resolve conflicts during the outage.
Another strength in this area is the verification of job comple-
tion. This process verifies the satisfactory completion of
individual jobs which together comprise an entire modification
before the functional testing for the modification is performed.
Walkdowns of the installed modification are performed with '
interdepartmental personnel to further identify problems before
functional testing.
1
The net effect of these activities was the timely completion of
all planned modifications near the scheduled outage completion
date.
,
The overall control and planning of outages of short duration was
!
also a decided strength. Even for outages of short duration, the
j work is properly planned with regard to scope, repair parts and
work procedures.
'
Some problems were identified in the engineering verification
i process for changes in design. This problem concerns the extent
l of management's involvement in ensuring the adequacy of completed
designs. Numerous errors in Engineering Instructions associated
l
with completed designs were identified in the field. One apparent
l
problem was identified in connection with a design change to the
,
'
. - - _ . _ _ _ . _ _
- __ _. -. - _ . .__ _ _ . . . _ _ _ _ . _ _ ~ _ , _ _ _ _ . _ _ - , _ _ __ _ _ . _ _ . _ - -
_ __
,-
l
1 ..
i
23
,i
i
i
l safety-related makeup and purification system. A second example
! involved the inadequate design of the EFIC system level detectors,
which contributed to numerous spurious system actuations after the
1985 refueling outage. These activities involved the use of
engineering design contractors and the apparent lack of management
control over their activities and are symptomatic of a concern
,
expressed in the previous SALP.
i To prevent recurrence of such problems, the licensee has initiated
'
program enhancements providing for systam walkdowns prior to and
during the detailed design process. The main purpose is to
'
establish and maintain continuous commbnication between the
! design office and site personnel. The development and implementa-
j tion of the enhanced design change progra'n should improve the (
- licensee's management involvement in assuring quality,
i
'
! Additional weaknesses exhibited in the modification area involved
,
procedural adherence. Several violations listed below involve
noncompliance with and adequacy of plant modification procedures.
1 Of these, violations (a), (b), (d) and (e) involved contractor
-
personnel. This continuing contractor problem does not appear to
have improved. The licensee is attempting to address these issues
i with the procedural adherence review program. Additionally, the
licensee has started 1 training program for contr<ct workers in
'
which modification procedures are addressed.
1 i
i The licensee's administrative controls of the welding program were
'
relatively weak as evidenced by inadequate procedures' for control
- of filler metal, unauthorized use of welding procedJres, and
'
improper transfer of welder performance qualificatios records.
'
.
These deficiencies resulted, in part, from the licensee!s decision
to cancel the contract with a service organization ar.d assume
responsibility for administratior of the welding program. This
,
task was undertaken prior to making adequate preparations for
implementing the program, e.g., hiring qualified personnel and
'
writing an adequate welding program manual for implementing the
program. Following NRC identification of these deficiencies, the
licensee took appropriate measures to rectify the situation.
In January 1986, following the failure of the "A" reactor coolant
i
pump shaf t assembly the regional staff performed two inspections.
The inspection effort included observation of the pump disassembly
and nondestructive examination of the broken and replacement
shafts. The staff found that licensee personnel involved in the
-l failure investigation and pump repair were fully qualified. Also,
as discussed in the Maintenance analysis, management appeared to
be supportive of the site's engineering decisions,
t One violation listed below involved an improper change to a
, refueling procedure. This issue is similar to that discussed in
j the Plant Operations analysis. ;
1
,-
,
24
Eight violations were identified:
a .. Severity Level IV violation for failure to adhere to the
requirements of a modification procedure and for inadequate
control of scaffolding. (85-16)
b. Severity Level IV violation for failure to follow a welding
procedure. (85-17)
c. Severity Level IV violation for failure to adhere to the
requirements of a refueling procedure. (85-19)
d. Severity Level IV violation for failure to follow a welding
procedure. (85-23)
e. Severity Level IV violation for failure to adhere to the
requirements of a modification procedure for anchor bolt
torquing. (85-26)
f. Severity Level IV violation for failure to adhere to
Technical Specification requirements for source range reactor
flux monitor operability during fuel handling. (85-27)
g. Severity Level IV violation for an inadequate emergency
feedwater pump modification procedure. (85-42)
h. Severity Level V violation for an improper change to a
refueling procedure. (85-08)
One additional, apparent Severity Level IV violation involved a
failure to verify the adequacy of a design change to the makeup
and purification system. (86-01). This violation is being
contested by the licensee.
2. Conclusion
Category: 2
3. Board Recommendations
There are continuing problems involving the control of contractor
personnel and procedural adequacy and compliance in the design
change area. Licensee attention is needed to address and correct
these weaknesses. No changes in the NRC's inspection resources
are recommended.
L ;
_- - . . - _ _.
,.
,
25
I, Quality Programs and Administrative Controls Affecting Quality
1. Analysis
During this assessment period, routine inspections were performed
-
'
by the resident and regional staffs. The following specific areas
were reviewed by the regional staff during this period: QA
program; audits; offsite support staff; QA/QC administration;
!
procurement; receipt, storage, and handling; and tests and
experiments. In addition, the resident and regional staffs
reviewed the implementation of the measuring and test equipment
(M&TE) calibration program.
The annual QA program review was conducted concurrent with a
l review of the QA audit program and the offsite support staff.
i
Several problems were identified in the audit areas. In general,
audit findings were significant and in-depth but they were not
always resolved in a timely manner. Violations were identified
for failure to document a disagreement between the audited and
auditing organization and the failure to provide appropriate
'
criteria for elevating unresolved QA audit findings to upper
management. The licensee has initiated programmatic enhancements
to assure that conditions adverse to quality are promptly
corrected.
Further discussion > of the QA audit program, as it relates to
specific functional areas, are found in the Fire Protection, ,
- Security and Safeguards, and Training analyses. While the
-
licensee's ' Appendix R reviews and fire protection audits were
successful in finding program deficiencies, the same is not true
in the training area. Numerous significant training program
deficiencies remained undetected by the licensee. until they were
found by an NRC training assessment team. The licensee is
credited with finding hardware and commitment deficiencies in the
security area, but corrective actJons have not always been timely
and some long-standing commitments remain unfulfilled.
The offsite support staff generally fulfilled its mission,
however, several weak areas were identified. The interface and
communication between corporate and site groups was poor,
particularly between licensing and site compliance.
A review of the plant's snubber surveillance program by a regional
inspector revealed that QA audits had not been performed in this
a ret, within the two years preceding the inspection. Some
j surveillance records were found to be incomplete and some were
- illegible; they were, in general, not well maintained and were
~
difficult to retrieve. A violation was issued for failure to
adequately document numerous snubber visual inspections.
I
,
_ _ _ _ - _ _ _ _ _ _ _ _ _ .
.
-
.
26
In the area of QA/QC administration, the licensee's QA program
documents clearly identified the structure of the QA program and
the procedures and responsibilities necessary to execute it.
Methods existed to modify the program to provide increased
emphasis on identified problem areas.
The procurement of safety-related equipment and services and the
receipt, storage, and handling of materials met regulatory
requirements. Procurement documents were complete and accurate,
and equipment storage areas were well organized and clean.
An inspection conducted to confirm the adequacy of the licensee's
actions in response to Generic Letter 83-28 (Required Actions
Based on Generic Implications of Salem Anticipated Transient
Without Scram) revealed adequate management involvement and
control to ensure the quality of procedures and work related to
reactor trip breaker modifications, testing, and maintenance. The
same inspection also verified the adequacy of post-trip data
collection and review, however, a violation was identified
involving a failure to maintain computer generated post-trip data
in a quality manner.
Administrative controls for tests and experiments were adequately
delineated in writing. Special tests were performed under the
existing test program which meets regulatory requirements.
There have been substantial improvements in the licensee's M&TE
calibration program. No occasions of using non-calibrated
equipment were found in this evaluation period. Surveillance and
maintenance procedures have been revised to require the recording
of actual calibration dates for measuring and test equipment thus
providing acknowledgment by the person performing the test that
calibrated equipment is being used.
The storage of M&TE and the follow-up on M&TE found to be out of
calibration (either due to equipment drift or damage) was poor;
two violations were identified in this area. The M&TE storage
facilities appeared to be marginal compared to other facilities in
Region II. Recordkeeping in this area was also marginal, but
adequate.
The licensee still has problems with procedural adequacy and
methods to change procedures. The procedural adequacy problem
should improve with the implementation of the various procedure
writer's guides. The procedure change method problems seem to be
caused by the following two factors:
-
failure of the licensee to direct personnel to use the
Immediate Temporary Change (ITC) for making procedure changes
(which complies with the Technical Specifications), and l
l
_ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
-
.-
.
27
i
an attempt by the licensee to reduce the amount of paper work
'
-
reviewed by the Onsite Review Committee.
The use of ITCs has increased considerably since personnel have
- been instructed to make changes using this method. The procedure
- change area is improving and should continue to imorove as manage-
- ment continues to stress the use of ITCs and as personnel become
more familiar with the process.
l The licensee has made a number of changes to administrative
4 procedures in an effort to reduce the paperwork burden on the
Onsite Review Committee. Some of these procedure changes,
however, have been too general and have resulted in violations.
Three violations listed in the Plant Operations analysis and
I violation (h) listed below were caused by these administrative
l policy changes. The licensee has further revised these
administrative procedures and now appears to have a better
understanding of the license requirements. Insufficient time has
elapsed to allow judgement of these changes st this time.
One additional violation identified in the area of quality
< programs involved a nonconformance, which was written against
l discrepant procedures and was documented as complete in the
j absence of adequate corrective actions. Two other violations (one
!
of which is listed in the Outage analysis) involved inadequate
i quality inspection of maintenance activities. These two
violations, in addition to other recent events (as documented in
- plant nonconformance reports) involving the failure of QC
'
personnel to perform adequate quality inspections, indicate a
J
weakness that apparently is being caused by the use of contractor
j personnel who receive only minimal training and by the use of
unqualified Quality Control supervision.
These violations highlight a continuing problem with the adequacy
of and adherence to plant procedures and the inadequate control of
contractor personnel. Other examples of procedural weaknessos and
inadequate contractor control are identified in other functional
areas within this report.
Ten violations were identified:
a. Severity Level IV violation for failure to document a
ncnconformance regarding a disagreement between QA audit
personnel and audited organizational personnel. (85-15)
.
b. Severity Level IV violation for failure to establish criteria
, for escalating QA audit findings. (d5-15)
,
c. Severity Level IV violation for failure to ensure that
nonconformances are corrected. (85-19)
!
1
k
__ __ _ -. - - -
'
.
.
28
d. Severity Level IV violation for failure to properly inspect a
maintenance activity for quality and to ensure replacement
parts were of the proper quality level. (86-07)
e. Severity Level IV violation for failure to establish suitable
environmental conditions for calibration of M&TE. (85-13) :
f. Severity Level V violation for failure to ensure M&TE
out-of-tolerance evaluctions were performed by contractors.
(85-13)
g. Severity Level V violation for failure to maintain adequate
records of activities affecting quality. (85-20)
h. Severity Level V violation for an inadequate procedure to
control the review and approval of changes to plant
procedures. (85-11)
1. Severity Level V violation for failure to report a condition i
outside the design basis of the plar.t. (85-44) l
j. Severity Level V violation for failure to properly maintain
quality assurance records. (85-07) l
2. Conclusion
Category: 3
3. Board Recommendations
The licensee has displayed a general weakness in its ability to
detect and correct its own prcblems and deficiencies. The
licensee's QA organization failed to identify significant
deficiencies in the training area and failed to expedite the
correction of deficiencies identified in the security area. The
rating in this area reflects an overall concern regarding the
licensee's commitment to quality and not merely the adequacy of
the onsite QA/QC staf f. The licensee's inability to exercise
adequate control over contractor activities is also a significant
Board concern.
J. Licensing Activities
1. Analysis
The licensee's performance was evaluated in the areas of manage-
ment involvement, approach to the resolution of technical issues
from a safety standpoint, responsiveness to NRC initiatives, and !
reporting and analysis of reportable events.
.
,
I
L
.- _ - . _ _ -. .- . _
. -
. .
,
- t
'
29
i
!
l
This performance assessment is based on the NRC's evaluation of
4
the licensee's performance in support of licensing actions that
had a significant level of activity during the evaluation period.
i These actions included licensee requests for license amendments
and for exemptions or relief from regulatory requirements,
j responses to generic letters, and various submittals of informa-
tion for multi plant and TMI items.
The licensee has maintained or slightly improved the extent and
j consistency of management involvement and control since the last
j SALP report.
!
i
Improvements may be illustrated by the improvement in the quality
1
of significant hazards determinations in license amendment
requests. Management attsntion was most evident, as may be
j expected, in more significant or complex issues such as fire
i protection and the requested exemption from the existing General
i
Design Criterion IV (GDC-IV) requirements related to the
'
leak-before-break issue. Periodic updating of FPC's position,
status and priority for outstanding issues was also beneficial in
- our planning process. On the other hand, the review of the Cycle
VI reload report was made more difficult because of late submittal
by the licensee and by use of an unreviewed code in the analysis.
During the Cycle VI reload review, the licensee's attempt to
identify issues needed for restart was only partially successful
because of changes in these issues which caused some NRC effort on
items which subsequently proved unnecessary for restart.
In general, the approach of the licensee and its contractors to
,
'
resolution of technical issues demonstrated an adequate under-
standing of those issues and resulted in sound, timely, viable.
l
'
and conservative resolutions. However, this was not always the
case. For example, in the amendment involving natural circulation
cooldown, several iterations over a four year period occurred
before the issue was resolved. Overall, however, the licensee
performed well in this area and improvement is continuing. ,
The licensee has taken an active role in owners group activities
and in incorporation of plant improvements (e.g., participation in
the TS improvement program, redesign of reactor coolant pump
l
restraints, and incorporation of EFIC). ;
'
FPC has generally been well prepared and responsive, and has made !
i concerted efforts to resolve issues during the reviews and
I discussions in this assessment period. Although, as discussed
! above, the Cycle VI reload report was submitted somewhat late, the
, licensee responded quickly to NRC requests and necessary matters
!
were resolved without a delay in restart. Response to NRC
- requests and initiatives was prompt and effective in the areas of
!
1
!
I
!
4
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30
improvement of significant hazards determinations and in the
exemption request for GDC-IV.
FPC has tried to meet deadlines and notified NRR when deadlines
could not be met. Fewer requests for extension to respond to our
requests for additional information on some long-standing issues
brought about resolutions during this assessment period as well.
! During the report period, Crystal River 3 reported 43 events to
the NRC Operations Center as required by 10 CFR 50.72. Four of
these events were security-related. Ten of these events involved
reactor trips, five of which were from reactor power levels
greater than 90 percent. During these events, systems generally
functioned as expected.
Fifteen of the events reported involved engineered safety features
(ESF) actuations, of which six included an auto-start of an
emergency diesel generator (EDG). Five of the six EDG auto-starts
occurred during the performance of maintenance and surveillance
activities related to the EDG systems. Four of these can be
attributed to personnel error. These occurrences suggest that the
licensee needs to provide better training and procedures for work
associated with the EDGs. Five of the reportable events placed
the licensee into LCO action statements.
The licensee has generally been timely and accurate in reporting
events, the number of which ha s been about average for the report
period.
The licensee utilizes contractor personnel to a significant extent
in connection with licensing efforts. FPC personnel appeared to
exert adequate control over these support organizations. In
total, staf fing appears adequate to meet the licensing demands.
.
'
FPC has not had delays in the licensing area attributable to
inadequate quality or quantity of staff. Staff members are well
informed and ef fective in their interactions with the NRR staff.
2. Conclusion
Category: 2
,
3. Board Recommendations
No changes in the NRC's inspection resources are recommended.
K. Training
1. Analysis
A special training inspection was conducted by Region Il personnel
at Crystal River during this SALP period. Training areas
____ __ _ _ . _ _ _ ___ - ____
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31
4
inspected included licensed and nonlicensed operator, licensed
operator requalification, shift technical advisor, maintenance
technician, plant engineer and management, quality control
inspector, operational experience feedback, and general employee
training. This inspection indicated a significant- lack of
management control over, and attention to, the areas of licensed
operator requalification training, the implementation of training
commitments, and the accuracy of license applications to the
Commission. An investigation was conducted by the Office of
Investigation (01) to determine if intent was involved in the
misinformation provided to the Commissio, as detailed in 01
Investigation Report No. 2-85-004. The OI investigation confirmed
NRC Region II's findings but failed to identify any willful
violation of commitments and requirements. Escalated enforcement
action is currently under consideration by the NRC. The
inspection report contains multiple examples of potential
violations in several areas including failure to implement the
NRC-approved requalification training program, potential material
false state-ments on license applications and other communications
with the Commission, failure to establish or imploment adequate
training procedures, and failure to maintain adequate training
records.
In March 1985, the NRC administered a requalification examination
to approximately 25 percent of the licensed reactor operators and
senior reactor operators at Crystal River. The results of this
examination confirmed the inspection findings in the area of
requalification training. Only 5 of 17, or 29.4 percent, of the
licensed operators passed this requalification examination; the
requalification program was consequently judged to be unsatis-
factory per NUREG 1021. The licensee divided the remaining
licensed personnel who had not passed the NRC examination into two
groups for accelerated regt.alification training. One group
received an NRC examination in May 1985 and achieved an 85.7
percent pass rate, and the second group in July 1985 had a pass
rate of 58.8 percent. The average of the examinations
administered following upgrade requalification training was 71
percent. Based upon these results, the licensee's requalification r
program was determined to be deficient pending additional i
corrective actions,
i
Based upon the inspection findings and NRC examination results,
the licensee has taken corrective actions including a QA audit of l
Training Department revisions to training procedures, implementa- l
tion of training commitments, revision of record keeping l
procedures, and replacement of key training staff. These
corrective actions have not been inspected in detail to date.
To further strengthen operator training, the licensee has
implemented the use of a " check operator", who is a full time
experienced senior reactor operator, to conduct on-shif t training
L
. ._ _ _ - _ - _ _ _
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32
for licensed and nonlicensed operators. This program should
produce positive effects in the future.
Interviews with licensed personnel and the success rate on NRC !
license examinations indicated that replacement license training ,
was effective. Four reactor operator and seven senior reactor
operator replacement examinations were administered during the
SALP period. All of the reactor operators passed, and six of the
seven senior reactor operators passed for an overall pass rate of
90.9 percent. i
A review of the training records and license applications for the
group of applicants who took NRC license examinations in
December 1984, indicated, however, that the licensee had not
established adequate measures to ensure that all required training
was successfully completed and documented prior to taking the
examinations. These deficiencies were the subject of a Confirma-
tion of Action Letter (CAL-50-302/85-02) issued on January 29, '
1985, from the NRC to Florida Power Corporation. The CAL
confirmed FPC's commitment to resolve all identified training i
deficiencies for the December 1984 license applicants and to .
'
recertify their eligibility to take an NRC license examination
pursuant to 10 CFR 55.10(a)(6). In a letter to the NRC dated
April 4,1985, the licensee stated that the recertification was
complete and that the resulting documentation was available for ,
review. A follow-up inspection by Region 11 revealed that the .
I
recertification process was inadequate in that the training
records still did not support the licensee's contention that the
candidates had successfully completed all of the required
training.
In summary, the failures to (1) fully implement the requalifica-
tion program, (2) conduct valid and regular evaluations of
operations personnel, (3) adequately control the preparation and
grading of examinations, (4) maintain adequate and readily
retrievable training records, (5) provide in-depth QA audits for
training records and training program requirements, and (6) to i
'
take adequate corrective actions on identified deficiencies, are
evidence of a breakdown in the management controls necessary to
ensure the performance and qualifications of licensed personnel, i
No violations were issued during this appraisal period, however, l
proposed escalated enforcement action is pending regarding
apparent deficiencies detected in the licensed operator
requalification training program.
2. Conclusion
Category: 3
Trend: Improving ,
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3. Board Recommendations
No changes in the NRC's inspection resources are recommended.
V. Supporting Data and Summaries !
A. Licensee Activities
The scope of major outage work at Crystal River Unit 3 was as follows:
- 1. Reactor Coolant Pump Rotating Assembly Replacement - The "A"
i reactor coolant pump (RCP) shaft failed during power operation on ;
) January 1, 1986. Disassembly of the "A" RCP revealed that the
j shaft had sheared; ultrasonic testing of the other three RCP
j shafts revealed possible crack indications. All four shafts /
J rotating assemblies are being replaced. The outage was still in
'
progress at the end of this SALP period.
2. NUREG 0737 and Appendix R Fire Protection Items - A new emergency
a feedwater initiation and control (EFIC) system and a new remote ;
] shutdown panel were installed.
i
j 3. Once Through Steam Generator (OTSG) Water Slap - A water slap '
- process was developed and utilized in an attempt to remove sludge
l buildup from the OTSG tube support plates. This process proved
j only partially successful,
i
1 4. Reactor Vessel Inservice Inspection (!$1) - ISI examinations were
j performed in accordance with ASME Boiler and Pressure Vessel Code,
i Section XI, 1974 edition, Summer 1975 addenda. Babcock & Wilcox
! completed the examinations under contract to FPC.
5. Reactor Core Barrel Bolt Inspection - During the last refueling
(Refuel 5) the licensee detected cracking on some lower core
barrel bolts; these bolts were subsequently replaced with bolts
- composed of a corrosion resistant material. During the refueling
conducted during this appraisal period (Refuel 6) the remaining
accessible core barrel bolts were replaced.
I ,
B. Inspection Activities
i The routine inspection program was performed during this period, with
j special inspections conducted to augment the program as follows:
f
] 1. January 14-18, 1985, in the areas of licensed operator replacement
i trainino, requalification training, general employee training,
l support engineer training, maintenance training, quality control
[ inspector training, shift technical advisor training, and ;
j management training.
! l
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1
l
2. March 4-8, 1985, to review the licensee's implementation of a
program per the requirements of 10 CFR 50.49 for establishing and
maintaining the qualification of equipment. The inspection also
included evaluations of the implementation of equipment qualifi-
l cation (EQ) corrective action commitments made as a result of '
l deficiencies identified in the January 11, 1983, Safety Evaluation
l Report (SER) and the October 1,1982, Franklin Research Center :
l (FRC) and Technical Evaluation Report (TER). l
3. April 29 - May 1,1985, to verify the licensee's actions and !
documentation regarding recertification of the December 1984,
operator license applicants per Confirmation of Action Letter
(302/85-02) and Florida Power Company response letter dated
April 4, 1985.
,
4. July 29 - August 2, 1985, in the areas of fire protection and the
licensee's actions regarding the implementation of the require-
ments of 10 CFR 50, Appendix R, Sections III.G, III.J, III.L. and
III.O.
5. August 22-23, 1985, to review and determine the circumstances of a
licensee identified and reported incident relating to alleged
unauthorized introduction of firearms into the protected area.
6. January 2-3, and 28,1986, to review the circumstances associated
with a physical security event reported by the licensee on
December 19, 1985.
7. January 3-7, 1986, to follow-up on the event involving the failure
of reactor coolant pump (RCP) 1A and the subsequent reactor trip
on January 1,1986. Areas under review included: an inspector *
review of recorded values of selected plant parameters associated
with the event; an inspector review of the licensee's post-trip
review; an inspector review of selected plant chemistry data for
indication of fuel element failure; and an inspector review of RCP
1A's surveillance, preventive maintenance, corrective maintenance
and predictive maintenance programs.
8. March 3-13, 1986, to investigate airborne radioactivity concerns
and potential airborne radioactivity . released to unrestricted
areas as a result of hydrolasing activities.
C. Licensing Activities >
Ouring the evaluation period, licensing activities included requests !
for license amendments, requests for exemption or relief from
regulatory requirements, responses to generic letters, and various
submittals of information for multi plant and TMI items. Active issues
during this period are classified below. A total of 31 licensing
actions were completed.
,
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j 1. 58 Plant-Specific Actions (17 completed): Included in this l
.
category and used to provide input to this evaluation:
- ;
l
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Emergency and Security Plans
i
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Change to Section 3.0.4 Applicability C
{
- Fire Protection Exemption Requests
j -
Operating Modes for RV Head Seismic Instrumentation
! - ISI Relief Request
! -
Hydrogen Recombiner Valve Replacement
j -
Heatup and Cooldown Curves
{
-
Increase Controlled Leakage Rate r
1
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Emergency Feedwater Initiation ard Control (EFIC) TS i
j -
Cycle VI Reload Report ;
l
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ES Actuation Testing
'
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Dedicated HVAC
! -
Licensed Operator Requalification Program l
]
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j 2. 32 Multi-Plant Actions (12 completed): Included in this category ,
-
and used to provide input to this evaluation: !
j
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Environmental Qualification of Safety-Related Equipment
a
-
Natural Circulation Cooldown
! -
Post-Maintenance Testing
l
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Post-Trip Review - Data and Information Capability '
1
4
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Automatic Actuation of Shunt Trip
f 3. 14 TMI (NUREG-0737) Actions (two completed): Included in this ,
category and used to provide input to this evaluation: ;
j
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Post-Accident Sampling Modifications
4. NRR/ Licensee Meetings (8) {
) Division Director Status '
Reload Codes
l Backfit Issues
j Detailed Control Room Design Review
'
! EFW System Reliability
l EFW Event of November 22, 1985
I .
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- 5. NRR Site Visits (1)
s I
j Site Visit With Commissioner Asselstine l
1
j 6. Commission Briefings - None
i
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l 7. Schedule Extensions Granted (2)
I Surveillance Interval Extensions
Surveillance Capsule Removal
8. Reliefs Granted (6) .
j ISI Relief Requests (6)
i
i 9. Exemptions Granted (7)
}'
Fire Protection (6)
- Reactor Vessel Head Vent
) 10. License Amendments Issued (20)
i
l 11. Emergency Technical Specifications Changes Issued - None
'
l 12. Orders Issued - None
! 13. NRR/ Licensee Management Conferences (2) i
) D. Investigation and Allegation Review
)
{ One major investigation involving concerns about lic.ensed operator
-
recertification activities was conducted during this SALP period.
E. Escalated Enforcement Actions
1. Civil Penalties
Severity Level III (Supplement III) violation for failure to
l afford vital equipment the level of protection specified in the
! Physical Security Plan. A Proposed Imposition of Civil Penalty of
- $50,000 was issued on January 10, 1985. FPC denied the violation
)
on March 1,1985, and an Order Imposing Civil Penalty was issued l
'
on July 29, 1985. This violation was included in the basis for
the previous SALP analysis and is listed here for continuity.
2. Orders
l As noted in paragraph E.1 above.
i F. Licensee Conferences Held During Appraisal Period
1. Members of the NRC's Committee to Review Generic Requirements
(CRGR) visited the Crystal River facility on December 5-6, 1984.
I 2. An enforcement conference was held on January 15, 1985, to discuss
{ an individual's entry into a locked high radiation area with dose
rates of 200 - 1200 R/hr.
f
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,- !
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37
,
! 3. A management meeting was held on February 1,1985, to discuss the
findings identified during the Region II training assessment
(reference Inspection Report No. 50-302/85-01) and FPC's corrective
actions. -
'
4. A management meeting was held on March 12, 1985, to review the
results of the SALP program for the Crystal River facility.
I 5. A management meeting was held on March 15, 1985, to discuss the
i NRC and FPC positions regarding ci,ted Violation 84-09-04.
1
i 6. A management meeting was held on April 3, 1985, to discuss the NRC
- administered operator requalification examination and FPC's plans
for operator retraining and recertification.
7. A management meeting was held on May 15, 1985, to discuss the NRC
"
inspection findings documented in Inspection Report No. 50-302/85-22
l concerning the recertification of licensed operator candidates at
! Crystal River 3.
8. A management meeting was held on July 16, 1985, to discuss a
proposed 10 CFR 50.54(p) change to the Crystal River Physical
Security Plan.
9. A management meeting was held on July 16, 1985, to discuss the-
application of 10 CFR 50, Appendix R at Crystal River and the
'
forthcoming Appendix R inspection.
'
'
10. A management meeting was held on July 18, 1985, to discuss the
staffing of Crystal River 3, p'otential procedural problems, and
the training required on the recent plant modifications.
,
11. A management meeting was held on July 31, 1985, to discuss FPC's
,
quality assurance program, its management and implementation.
1
! 12. A management meeting was held on September 6,1985, to discuss
FPC's QA review of operator training procedures, as requested in
CAL-50-302-85-02, and plans to improve the operator requalifica-
tion training program.
13. An enforcement conference was held on September 13, 1985, to
discuss the apparent failure to control personnel and material
j access to the protected area of the Crystal River 3 facility.
14. An enforcement conference was held on January 28, 1986, to discuss
failures to comply with NRC regulatory requirements in the area of
licensed operator training and an event involving the breach of a
vital area barrier.
.
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G. Confirmation of Action Letters
1. A Confirmation of Action Letter (CAL-50-302-85-01) was issued on
January 22, 1985, concerning the removal of a senior reactor
operator from licensed duties when an NRC inspector determined
during a training audit that the operator had failed the facility-
administered annual requalification make-up examination.
2. CAL-50-302-85-02 was issued on January 29, 1985, concerning the
recertification of licensed operator applicants examined by the
NRC in December 1984. FPC also confirmed that it would conduct a
QA audit of training procedures and activities and meet with the
NRC to discuss the audit results.
H. Licensee Event Report (LER) Analysis
During the evaluation period, 26 LERs were evaluated by the NRC staff
to determine event cause.
The distribution of these events was as follows:
CAUSE NUMBER
Component Failure 12
Design , 1
Construction / Fabrication 1
Personnel
-
Operating Activity 3
- Maintenance Activity 2
-
Test / Calibration Activity 5
-
Other Activity 2
TOTAL 26
I. Enforcement Activity
FUNCTIONAL NO. OF DEVIATIONS AND VIOLATIONS IN EACH
AREA SEVERITY LEVEL
D V IV III II I
Plant Operations 2 1 8
Radiological Controls * 4 10
Maintenance 2
Surveillance 1 3
I
Fire Protection
Security 3 1 l
Outages * 1 7
'
Quality Programs and 5 5
Administrative Controls
Licensing Activities
Training *
TOTAL 2 13 38 1
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- Additional apparent violations have been proposed as noted in the
functional area analyses.
Ten unplanned trips and six manual shutdowns occurred during this
evaluation period. The unplanned trips are l'isted below:
1. August 20, 1985 - This anticipatory reactor trip from 21 percent
power was caused by a manually initiated main turbine trip in
response to a ruptured 2-inch drain line on the main turbine high
pressure crossover line. The drain line was repaired and the
reactor was restarted later the same day. The same steam line
failed again on August 21 because of excessive steam pipe
vibrations induced by newly installed, modified turbine governor
valves. The plant was placed in cold shutdown on August 22 to
repair the steam line and turbine governor valves.
2. August 20, 1985 - This reactor trip from approximately 20 percent
power occurred during the restart from the reactor trip described
in paragraph J.1 above. The automatic trip was caused by a
reactor coolant system high pressure signal which was actuated
because of plant temperature and pressure oscillations induced by
sluggish feedwater control valve operation. The integrated
control system (ICS) was adjusted and the feedwater system was
repaired prior to the reactor restart on August 21,
3. September 27, 1985 - The reactor was manually tripped after
control rod group number 7 dropped into the reactor core while
attempting to transfer a control rod from the auxiliary power
supply back to its normal group power supply. A faulty jogging
motor in the auxiliary power supply's programmer control assembly
caused the entire rod group to drop into the core adding
sufficient negative reactivity to shut down the reactor from
13 percent power. The auxiliary power supply was repaired and
critical operation was resumed on October 1.
4. October 9,1985 - The reactor was manually tripped from approxi-
mately 96 percent power in response to the inadvertent closure of
two main steam isolation valves (MSIVs) for the "B" once through
steam generator (OTSG). The MSIVs closed when a personnel error
was committed during troubleshocting activity on the emergency
feedwater initiation and control (EFIC) system resulting in
satisfaction of the two-out-of-four main steam isolation channel
trip logic for the "B" OTSG. Troubleshooting and repair of the
EFIC system was completed and critical operation was resumed later
the same day.
,'
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40
5. October 26, 1985 - An anticipatory reactor trip from 97 percent
power was caused when the main turbine was manually tripped by the
operators. An inverter failure had interrupted the primary power
supply to the control rod position indication (RPI) system and an
improperly adjusted backup power supply resulted in a momentary
indication that all control rods were fully inserted. The operators
responded to this false scram indication by tripping the main
turbine in accordance with plant procedures when they observed
that it had not automatically tripped. The inverter was repaired
and the reactor was restarted on October 27.
6. November 8, 1985 - The reactor tripped from 95 percent power on a
high reactor coolant system pressure signal. A feedwater booster
pump tripped causing a plant runback to 55 percent power. This
power reduction resulted in less heat transfer from the reactor
coolant system thereby increasing its temperature and pressure to
the trip setpoint. The licensee could detect no reason for the
booster pump trip; the plant was restarted after the pump was
satisfactorily tested.
7. November 22, 1985 - The reactor tripped from 18 percent power on a
high reactor coolant system pressure signal. A plant shutdown was
in progress and the operators encountered difficulties controlling
the "A" OTSG level with the startup flow and low load control
valves. A low level in the "A" OTSG tripped the EFIC cystem and
started the emergency feedwater (EFW) pumps. The cool emergency
feedwater caused a slight power excursion and contributed to RCS
temperature and pressure oscillations. The operators secured the
EFW pumps, but sluggish low load control valve response caused the
"A" OTSG level to decrease again resulting in the reactor high
pressure trip.
8. December 3, 1985 - An anticipatory reactor trip occurred from
93 percent power when loss of the "B" 6900 volt unit auxiliary bus
deenergized two reactor coolant pumps (RCP-18 and 10). An
inspection revealed that a loose wire termination on the RCP-ID
breaker created a phase-to phase fault which caused the bus feeder
breakers to trip. That and other switchgear connections which
were found to be loose were retorqued and the protective relays
were functionally tested and found to be satisfactory.
9. December 7, 1985 - An anticipatory reactor trip occurred while the
reactor was in the shutdown condition with a group of control rods
fully withdrawn. The reactor trip was caused by an operator error
while starting and stopping reactor coolant pumps.
L.
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10. January 1, 1986 - The reactor tripped from about 92 percent power
due to a reactor power to reactor coolant flow mismatch. The
RCP-1A shaft sheared causing reactor coolant system flow to
decrease below the established minimum setpoint for the existing
power level. The other reactor coolant pump shafts were
subsequently tested and found to contain possible defects. All
four RCP shafts are being replaced during the ongoing maintenance
outage,
-
j
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A
= - -