ML20214V322
| ML20214V322 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/18/1986 |
| From: | Walker R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20214V320 | List: |
| References | |
| 50-302-86-23, NUDOCS 8610020245 | |
| Download: ML20214V322 (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 July 4 -
August 1, 1986, violations of NRC requirements were identified. The violations ir.vc,1ved failure to perform a surveillance required by the technical specifi-cations, procedure adherence, adequacy of a plant modification procedure, and compliance with a technical specification limiting condition for operation. In accordance with the " General Statement of Policy and Procedure for NRC Enforcement Actions," 10 CFR Part 2, Appendix C (1986), the violations are listed below:
A.
Technical Specification 4.7.8.1.b.2 requi res in part that the Auxiliary Building (AB) ventilation exhaust system be tested in accordance. with the test. procedures of' Regulatory Guide 1.52, revision 1, July 1976.
Regulatory Guide 1.52, July 1976, Position C.S.a, requires that a visual inspection of the system be made before each test in accordance with the recommendations of section 5 of American National Standard (ANSI) N510-1975.
ANSI N510-1975 section 5 specifies a list of items to visually check. and lists these items in Appendix A.
Included in this list is an inspection of the system's prefilters and High Efficiency Particulate Air (HEPA) filters.
Surveillance procedure SP-187, Auxiliary Building Ventilation Exhaust System Testing,. that was written to implement the requirements of TS 4.7.8.1, requires in Step 9.2.5 that prior to commencement of in place testing, a visual inspection of the items identified in enclosure 3, Checklist for Visual Check, will be performed. Enclosure 3 includes a visual' inspection of the system's HEPA filters and prefilters.
Contrary to the above, visual inspections of the AB ventilation exhaust
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system's HEPA filters were not accomplished as part of the testing conducted on July 12, 1983, July 20, 1985, and May 29, 1986.
Visual inspection of the prefilters were not accomplished as part of the testing conducted on July 20, 1985 and May 29, 1986.
This is a Severity Level IV violat hn, (Supplement I).
8.
Technical Specification 6.8.1.a requires adherence to written procedures 1.
that cover those activities recommended in Appendix A of Regulatory l
Guide 1.33, November 1972.
Regulatory Guide 1.33, Appendix A, paragraph I.5 recommends procedures for the control of maintenance, repair, replacement and modification work.
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Florida Power Corporation 2
Docket No. 50-302 Crystal River Unit 3 License No. DPR-72 Procedure CP-114, Procedure for Handling Permanent Modifications, Temporary Modifications, Modification Revisions, Field Change Notices, and Advance Field Change Notices, was written to meet the requirements of Regulatory Guide 1.33 and requires, in step 3.11, the use of a Modification Approval Record (MAR) to document the safety evaluation, review, and approval for nuclear plant modificatfor,s.
Contrary to the above, on July 21,_1936, a physical alteration was made on the lube oil system for the "B" Emergency Diesel Generator (ECG-la) without the appropriate safety evaluation. review, and apprcval required for a nuclear plant modification.
This is a Severity Level IV violaticn, (Supplement I).
C.
Technical Specification 3.9.11 requires all the missile shields to be installed over the Spent Fuel Pool (SFP) whenever fuel handling operations are not in progress.
Drawing S-521-116, Spent Fuel Pit Missile Shielding, requires each missile shield panel to be installed with four bolts.
Contrary to the above, during the period of January 17, 1936 through July 21, 1986, twenty of the thirty-two SFP missile shields were not installed with the required tour bolts.
This is a Severity Level IV violation, (Supplement I).
D.
10 CFR Part 50, Appendix B, Criterion V as implemented by the approved Florida Power Corporation Operational Quality Program, paragraph 1.7.1. 5, requires that procedures or drawings include adequate instructions for work affecting quality.
Contrary to the above, as of July 30, 1986, plant modification procedures (MARS 79-11-70-01 and 79-11-70-02) were inadequate in that they caused the Containment Hydrogen Monitoring system to be installed incorrectly and failed to identify the incorrect installation during subsequent post-installation testing.
This is a Severity Level IV violation (Supplement I).
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Florida Power Corporation 3
Docket No. 50-302 Crystal River Unit 3 License No. DPR-72 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:
(1) admission or denial of the alleged violation; (2) the reasons for the violation 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 shown, consideration will be given to extending the response time.
FOR THE NUCLEAR REG TORY COMMISSION
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. j l Roger D. Walk
, Director J
Division of Reactor Projects Dated at Atlanta, Georgia this 18 day ofseptember 1986 I
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