ML20211A733

Notice of Violation from Insp on 861107-870107

ML20211A733
Person / Time
Site:	Crystal River
Issue date:	02/04/1987
From:	Reyes L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20211A707	List: ML20211A703 ML20211A733 ML20211A812
References
50-302-86-38, NUDOCS 8702190226
Download: ML20211A733 (3)

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ENCLOSURE 1 NOTICE OF VIOLATION Florida Power Corporation Docket No. 50-302 Crystal River Unit 3 License No. DPR-72 During the Nuclear Regulatory Commission (NRC) inspection conducted on November 7,1986 - January 7,1987, violations of NRC requirements were identi-fied. The violations involved an inadequate procedure, inadequate corrective action, failure to issue Licensee Event Reports, failure to adhere to radiation protection posting requirements, failure to meet surveillance testing interval frequencies, and failure to meet containment leak rate testing requirements. In accordance with the " General Statement of Policy and Procedure for NRC Enforce-ment Actions," 10 CFR Part 2, Appendix C (1986), the violations are listed below:

A. Technical Specification (TS) 6.8.1.c requires that procedures be established for surveillance and test activities of safety-related equipment.

Technical Specification 3.1.1.1.1 requires the reactor shutdown margin to be greater than 1.0*; delta-k/k.

Surveillance procedure SP-421, Reactivity Balance Calculations, provides the procedure for determining the shutdown margin for the reactor. Step 6.3.1 of this procedure directs the method of calculation to determine the available shutdown margin and in Step 6.3.3 directs the calculation of the required shutdown margin.

Contrary to the above, on November 12, 1986, procedure SP-421 was found to be inadequate in that the procedure calculations could have allowed the reactor shutdown margin to exceed the limits set forth in TS 3.1.1.1.1. As a result of this inadequacy, a shutdown margin was incorrectly calculated on November 11, 1986 (though the requirements of TS 3.1.1.1.1 were not exceeded).

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

B. 10 CFR 50 Appendix B, Criterion XVI requires corrective action measures that assure that nonconformances are promptly identified and corrected and that such measures will prevent repetition of these nonconformances.

Section 1.7.1.16 of Florida Power Corporation's (FPC) Quality Program requires nonconformances to be promptly identified and corrected and that corrective action taken be sufficient to prevent recurrence of the: noncon-formance.

8702190226 DR 870204 ADOCK 05000*?O2 PDR

FER 0 41987

. Florida Power Corporation 2 Docket No. 50-302 Crystal River Unit 3 License No. DPR-72 In Licensee Event Report (LER) 85-32, submitted on . January 6,1986, the licensee identified that an auxiliary transformer installed in the 230 KV switchyard did not have the diverse DC control power, which supplied Units 1 and 2 Batteries, for the primary and backup protective relaying as described in the Final Safety Analysis Report (FSAR). .The corrective action for this event included a review of other interfaces as described in the FSAR and verification that no additional deficiencies existed. The corrective action review did not identify any additional deficiencies.

Contrary to the above, the licensee's corrective actions were inadequate in that:

On December 10, 1986, it was identified that during the period of December 1976 through December 10, 1986, modifications were performed on the Unit I and Unit 2 batteries to install additional loads. As a result, these batteries were not tested to the correct load profile until this condition was identified.

On December 15, 1986, it was identified that during the period of 1981 through 1982 three breakers were installed in the 230 KV switchyard and these breakers did not have independent sets of tripping coils supplied from separate DC supplies as described in the FSAR.

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

C. 10 CFR 50.73 (a)(2)(1)(B) requires the submittal of an LER within 30 days of the event for any operation or condition prohibited by the plant's Technical Specificatior.s.

Contrary to the above, on November 13, 1986, the licensee identified that the containment leakage rate could not be verified within the limits specified by the TS. Further, on November 14, 1986, the licensee identified that two TS surveillance requirements were not being fully accomplished. As of January 6, 1987, no LERs had been issued for these events.

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

l D. Technical Specification 6.11 requires adherence to procedures for all l operations involving personnel radiation exposure. Radiation protection l procedure RSP-101, Basic Radiological Safety Information and Instructions for " Radiation Workers," defines posting of radiation areas as a radio-logical control in step 2.3.26 and requires adherence to these radiological controls in step 3.1.3.4.

Contrary to the above, on November 18, 1986, three individuals were observed in the reactor building, a posted beta protec tion required area, without beta protection glasses.

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

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FEB 0 41987 Florida Power Corporation 3 Docket No. 50-302 Crystal River Unit 3 License No. DPR-72 E. Technical Specification 4.0.2.b requires each surveillance test to be performed within the specified time interval with a total maximum combined interval time for any three consecutive tests to not exceed 3.25 times the specified interval.

Contrary to the above, during the period of September 29, through November 14, 1986, eight surveillance tests exceeded their total maximum combined interval times.

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

F. 10 CFR Part 50, Appendix J, paragraph III.D.2(b)(ii), requires air locks, that are opened during periods when containment integrity is not required, be tested at accident pressure (Pa) prior to entering a period that requires containment integrity.

Contrary to the above, during the period of November 14-22, 1986, air locks were opened while containment integrity was not required and were not tested at Pa prior to entering operational modes that required containment integrity. ,

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

Pursuant to the provisions of 10 CFR 2.201, Florida Power Corporation is hereby required to submit to this Office within 30 days of the date of the letter transmitting this Notice a written statement or explanation in reply including ior each violation: (1) admission or denial of the alleged violations; (2) the reasons for the violations if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved.

Where good cause is shoun, consideration will be given to extending the sponse time.

FOR THE NUCLEAR REGULATORY COMMISSION Original Signed by Luis A. Reyes Luis A. Reyes, Acting Director Division of Reactor Projects i Dated at Atlanta, Georgia this day of 19

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