ML20155A918

Insp Rept 50-302/88-24 on 880716-0812.Violations Noted.Major Areas Inspected:Plant Operation,Security,Radiological Controls,Lers & Nonconforming Operation Repts

ML20155A918
Person / Time
Site:	Crystal River
Issue date:	09/13/1988
From:	Holmesray P, Petrosino J, Tedrow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20155A895	List: ML20155A894 ML20155A898 ML20155A918
References
50-302-88-24, NUDOCS 8810060116
Download: ML20155A918 (15)

See also: IR 05000302/1988024

Text

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NUCLEAR REGULATORY COMMISSION

o REGION ll

k ,* ,,,, [ 101 MARIETTA ST., N.W.

ATLANTA GEORGIA 30323

Report No: 50-302/88-24

Licensee: Florida Power Corporation

3201 34th Street, South

St. Petersburg, FL 33733

Docket No: 50-302 License No.: DPR-72 ,

' I Facility Name: Crystal River 3

Inspection Conducted: July 16 - August !?, 1988

Inspectors: W} b 3.[ em b 4h/82

Seni r Resi nt Inspector Dats Signed

f' Holmes-Ray, WS ~

b aw 9hht

Date S1'gned

J. Tedrow, Resident in pect{

G). S ., w La sl m e

J. Petrosi NRR, Division (gfReactorInspection batd S(gned

and Sa g rds

Approved by: e [ N [

R. rg g ak, Sectifn Chief " ~0(te S~igned

Division of Reactor Projects

SUMMARY

Scope: This routine inspection was conducted by two resident inspectors and

an accompanying NRR inspector in the areas of plant operations,

security, radiological controls. Licensee Event Reports and

Nonconforming Operations Reports, facility modifications, control of

incoming vendor related technical information, and licensee action on

previous inspection items. Numerous facility tours were conducted ,

and facility operations observed. Some of these tours and obser- t

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vations were conducted on backshifts,

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Results: One violation was identified: Inadequate evaluation and procedures to

control incoming vendor technical issues, paragraph 8.d.

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Two unresolved items * were identified: To determin? the significance

of the findings from the licensee's review of the disposition of

vendor identified technical issues, paragraph 8; and to determine the

significance of the findings from the licensee's review of the  ;

procedural control of sendor identified technical issues, paragraph  !

9.

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"Unresolved items are matters about which more information is required to

determine whether they are acceptable or may involve violations or deviations.

8810060116 880919

PDR ADOCK 05000302

0 PDC 7

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REPORT DETAILS

1. Persons Contacted

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Licensee Employees

T. Austin, Principal Nucleer Mechanical Engineer

K. Baker, Manager, Nuclear Engineering Assurance

• W. Bandhauer, Assistant Nuclear Plant Operations Manager

• G. Becker, Manager, Site Nuclear Engineering Services

• J. Brandely, Manager, Nuclear Integrated Planning

• G. Castleberry, Nuclear Engineering Supervisor

• M. Collins, Nuclear Safety and Reliability Superintendent

J. Fiijouf, Nuclear Regulatory Specialist

H. Gelston, Supervisor, Site Nuclear Engineering Services

D. Green, Nuclear Licensing Specialist

• V. Hernandez, Supervisor, Nuclear Quality Assurance Surveillance

• B. Hickle, Manager, Nuclear Plant Opera +' .ns

• R. Jones, Nuclear Modifications Specialist

K. Lancaster, Manager, Site Nuclear Quality Assurance

S. Loflin, Senior Nuclear Quality Assurance Specialist

• G. Longhauser, Nuclear Security Superintendent

*M. Martin, Supervisor, Nuclear Electrical / Instrument and Control

• P. McKee, Director, Nuclear Plant Operations

j *R. Murgatroyd, Nuclear Maintenance Superintendent

G. Oberndorfer, Manager, Procurement and Miterial Quality Assurance

• S. Robinson, Nuclear Chemistry and Radiation Protection Superintendent

"V. Roppel, Manager, Nuclear Operations Maintenance and Outages

• W. Rossfeld, Manager, Nuclear Compliance

S. Stearns, Nuclear Site Engineering

P. Tanquay, Manager, Nuclear Operations Engineering

J. Vattamattam, Senior Nuclear Structural Engineer

H. Walker, Supervisor, Nuclear Electrical / Instrument and Control

"R. Widell, Director, Nuclear Operations Site Support

• M. Williams, Nuclear Regulatory Specialist

Other licensee employees contacted included office, operations,

engineering, maintenance, chemistry / radiation and corporate personnel.

• Attended exit interview

Acronyms and initialisms used throughout this report are listed in the

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last paragraph.

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2. Review of Plant Operations (71707)

a. Shift Logs and Facility Records (71707)

The inspector reviewed records and discussed various entries with

operations personnel to verify compliance with the Technical

Specifications (TS) and the licensee's administrative procedures.

The following records were reviewed:

Shift Supervisor's Log; Reactor Operator's Log; Equipment Out-Of-

Service Log; Shif t Relief Checklist; Auxiliary Build'ng Operator's

Log; Active Clearance Log; Daily Operating Surveillance Log; Work

Request log; Short Term Instructions (STI); and Selected Chemistry /

Radiation Protection Logs.

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In addition to these record reviews, the inspector independently

verified clearance order tagouts.

No violations or deviations were identified.

b. Facility Tours and Observations (71707)

Throughout the inspection period, facility tours were conducted to

observe operations and maintenance activities in progress. Some

operations and maintenance activity observations were conducted

during backshif ts. Also, during this inspection period, licensee

meetings were attended by the inspector to observe planning and

management activities.

The facility tours and observations encompassed the following areas:

security perimeter fence; control room; emergency diesel generator

room; auxiliary building; intermediate building; battery rooms; and

electrical switchgear rooms.

During these tours, the following observations were made:

(1) Monitoring Instrumentation -

The following irstrumentation

and/or indications were observed to verify that indicated

parameters were in accordance with the TS for the current

operational mode:

Equipment operating status; area atmospheric and liquid

radiation .nonitors; electrical system lineup; reactor operating

parameters; and auxiliary equipment operating paraaeters.

No violations or deviations were identified.

(2) Safety Systems Walkdown (71710) - The inspector conducted a

walkdown of the Nuclear Services Closed Cycle Cooling (SW)

system to verify that the lineup was in accordance with license

requirements for system operability and that the system drawing

and procedure correctly reflect "as-built" plant ;onditions.

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No violations or deviations were identified.

(3) Shif t Staffing (71707) - The inspector verified that operating

shift staffing was in accordance with TS requirements and that

control room operations were being conducted in an orderly and

professional manner. In addition, the inspector observed shif t

turnovers on various occasions to verify the continuity of plant

status, operational problems, and other pertinent plant

information during these turnovers.

No violations or deviations were identified.

(4) Plant Housekeeping Conditions (71707) - Storage of material and

components, and cleanliness conditions of various areas

throughout the facility were observed to determine whether

safety and/or fire hazards existed.

During a plant tour, it was noticed that the housekeeping in the

SW room of the Auxiliary Building was less than desired. The

condition was conveyed to FPC management who took immediate

action to have the SW room cleaned up. Clean up of the SW room

was prompt and thorough.

No violations or deviations were identified.

(5) Radiological Protection Program (71709) - Radiation protection

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control activities were observed to verify that these activities

were in conformance with the facility policies and procedures,

and in compliance with regulatory requirements. These

observations included:

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Selected licensee conducted surveys;

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Entry to and exit from contaminated areas, including

step-off pad conditions and disposal of contaminated

clothing;

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Area postings and controls;

- Work activity within radiation, high radiation, and

contaminated areas;

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Radiation Control Area (RCA) exiting practices; and

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Proper wearing of personnel monitoring equipment,

protective clothing, and respiratory equipment.

Area postings were independently verified for accuracy by the

inspector. The inspector also reviewed selected Radiation Work

Permits (RWPs) to verify that the RWP was current and that the

controls were adequate.

The implementation of the licensee's As Low As Reasonably

Achievable (ALARA) program was reviewed to determine personnel

involvement in the objectives and goals of the program.

No violations or deviations were identified.

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(6) Security Control (71881) -

In the course of the monthly

activities, the inspector included a review of the licensee's

physical security program. The composition of the security

organization was checked to insure that the minimum number of

guards were available and that security activities were

conducted with proper supervision. The performance of various

shifts of the security force was observed in the conduct of

daily activities to include: protected and vital area access

controls; searching of personnel, packages, and vehicles; badge

issuance and retrieval; escorting of visitors; patrols; and

compensatory posts. In addition, the inspector observed the

operational status of Cicsed Circuit Television monitors, the  ;

Intrusion Detection system in the central and secondary alarm '

stations, protected area lighting, protected and vital area

barrier integrity, and the security organization interface with

operations and maintenance.

No violations or deviations were identified.

(7) Fire Protection (71707) - Fire protection activities, staffing

and equipment were observed to verify that fire brigade staffing

was appropriate and that fire alarms, extinguishing equipment,

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actuating controls, fire fighting equipment, emergency ,

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equipment, and fire barriers were operable.  ;

On August 8 a fire drill was observed and the post drill

critique was attended. Several problems were noted:

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The fire team was slow to respond. All members (5) were

not on the scene until about 20 minutes after the drill

started.

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One team member had a SCBA, but no face mask and had to

leave his position on the fire hose to get his mask.

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When backup fire fighters arrived, not enough SCBAs were  :

readily available.

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The PA system was weak in some areas.

These and other minor problems prompted FPC to declare the drill

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unsatisf actory and to schedule another drill. The rescheduled

drill was conducted on August 9 satisfactorily.

No violations or deviations were identified.

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(8) Surveillance (61726) -

Surveillance tests were observed to l

verify that approved procedures were being used; qualified -

personnel were conducting the tests; tests were adequate to  !

! verify equipment operability; calibrated equipment was utilized;

and TS requirements were followed, i

The following tests were observed anJ/or data reviewed: ,

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- SP-317, Reactor Coolant System Water Inventory Balanc6;

- SP-715, Containment Building Spray Semiannual Surveillance

Program; and

- PT-213, Seating Test for FWV-43.

No violations or deviations were identified.

(9) Maintenance Activities (62703) -

The inspector observed

maintenance activities to verify that correct equipment

clearances were in effect; work requests and fire prevention

work permits, as required, were issued and being followed;

quality control personnel were a/ailable for inspection

activities as required; and TS requirements were being followed.

Maintenance was observed and work packages were reviewed for the

following maintenance activities:

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Shoot and clean 5WHE-1A in accordance with PM-112, Heat

Exchanger Maintenance Inspection / Cleaning / Shooting and

Plugging.

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PT-213, Seating Test for feedwater valve FWV-43. This

test was performed to attempt to seat check valve FWV-43 as

a follow-up to the leak from the bonnet of EFV-18. Four

attempts to seat FWV-43 were made without success. The

temperature of penetration 109 was monitored and held below

110 degrees F. A similar test was performed earlier on

emergency f eedwater check valve EFV-44; and EFV-44 was

successfully seated.

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June 19 - Open and inspect decay heat exchanger (DCHE)-B .

in accordarce with PM-112, Heat Exchanger Maintenance

Inspection / Cleaning / Shooting and Plugging. During the

beginning of the job, tools were selected by trial and

error. To determine which wrench was needed to remove the

closure nuts, several were tried for size prior to finding

the correct size. The procedure was not on the job site at

this time. The inspector obtained a copy of the procedure

(PM-112). Review of PM-112 revealed that the procedure was

not adequate to be performed on a DCHE as written. The

procedure wts written for a service water heat exchanger

(SWHE) and could not be followed for a DCHE, since the

applicable enclosure for DCHE is not referred to in the

procedure. When maintenance management was questioned about

PM-112, they agreed that the procedure was inadequate. The

procedure was last revised on June 18, 1983. A temporary

revision was processed to allow completion of DCHE-B work.

Maintenance management informed the inspector that the shop '

also realized that the procedure was inadequate and had

initiated ac. ion to get it changed. .

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, There are two weaknesses illustrated by this event:

1) The review cycle which allowed the procedure to be

issued in its inadequate form was 'ess than effective.

2) Review of the procedure prior to job commencement was

inadequate in that the plant entered a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, LC0

for removal of the DCHE from service when the

procedure was inadequate to perform the work,

No citation is issued for this event since the

licensee (concurrently with the inspector) identified

the inadequate procedure and corrected the~ procedure

prior to its use.

No violations or deviations were identified. ,

(10) Pipe Hangers and Seismic Restraints (71707) - Several pipe

hangers and seismic restraints (snubbers) on safety-related

systems were observed to assure fluid levels were adequate and

r.o leakage was evident, restraint settings were appropriate, and

anchoring points were not binding.

No violations or deviations were identified.

3. Review of Licensee Event Reports (9N00) and Nonconforming Operations

Reports (71707)

a. Licensee Event Reports (LERs) were reviewed for potential generic

impact, to detect trends, and to determine whether corrective actions

appeared appropriate. Events that were reported immediately were

reviewed as they occurred to determine if the TS were satisfied.

LERs 86-18 and 88-14 were reviewed in accordance with the current NRC

Enforcement Policy. LER 86-18 is closed.

(1) (Closed) LER 86-18: This LER reported that contaminated

material was found outside of the radiation control area, This

matter is already being tracked by an unresolved item

(Unresolved Item 302/86-35-05).

(2) (0 pen) ' ER 88-14: This LER reported excessive temperatures

in Eme, uncy Feedwater (EN) system piping. This event is

discussed in more detail in NRC Inspection Report 50-302/88-18.

The licensee's short term corrective actions as stated in the

LER have been completed, however the following corrective

actions remain to be done:

- Disassembly and repair of leaking valves in the EFV system

(EFV-18, EFV-33, and FW-43);

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Analysis to upgrade the EPW system piping to operate at

higher temperatures;

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Development of leakage criteria and test procedures for EFW

system check valves; and,

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Evaluation of the possibility of "water hammer" effects by

formation of steam voids in these lines.

This LER will remain open pending completion of these corrective

actions.

b. The inspector reviewed Nonconforming Operations Reports (NCORs) to

verify the following: TS are complied with, corrective actions as

identified in the reports or during subseouent reviews have been

accomplished or are being pursued for completion, generic items are

identified and reported as required by 10 CFR Part 21, and items are

reported as required by TS.

All NCORs were reviewed in acco/ dance with the current NRC

Enforcement Policy.

No violations or deviations were identified.

4. Bulletin (BU) Followup (92703)

. BU 88-05: Nonconforming Materials Supplied by Piping Supplies Inc. at

Folsom, New Jersey and West Jersey Manufacturing Comp &ny at Williamstown,

New Jersey.

On July 14, 1988, in accordance with Supplement I to NRC Bulletin 88-05,

the licensee made a report to NRC Operations Center of nonconforming

material (17 flanges in the Nuclear Services and Decay Heat Seawater

system (RW)). Licenses analysis of the strength of the flanges shows that

the strength of tae material exceeds the required safety factor, even

though tensile strength and hardness are less than specification. The

licensee concludes that the above mentioned material is suitable for use

in the RW system.

The licensee continues to take action as required by BU 88-05.

5. Review of Multi-Plant Action Item B-03, PWR Moderator Dilution (71707)

The inspector reviewed the licensee's efforts to prevent the inadvertent

injection of sodium hydroxide (NaOH) into the Reactor Coolant System

! (RCS). In LER's 77-17 and 77-52, the licensee reported that an

unterminated injection of the NaOH tank (BST-2) into the RCS could result

i in inadvertent reactor criticality. In Februsry 1977, with the plant in

the cold shutdown condition, NaOH was introduced into the Decay Heat

Remaval (OH) system during the performance of a surveillance test to

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exercise the isolation valves associated with tank BST-2. The cycling of

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the isolation valves allowed NaOH to drain into the DH system and the NaOH

was then subsequently transmitted into the RCS during routine OH system

operation. Although this event did not result in a sufficient reduction  :

in RCS boron concentration to create an inadvertent criticality,

subsequent aralyses determined that the possibility existed to do so. In

June 1977, the licensee imposed administrative safeguards to preclude such

an event. This action was reviewed and approved by the NRC in an l

dmendment to the facility operating license (license amendment #20).

Subsequsnt amendments to the operating license restricted the shutdown i

reactivity margin to 3.0*4 delta k/k. This shutdown reactivity would

prevent a moderator dilution accident of this type from resulting in an

inadvertent reactor criticality.

In 1983, the licensee emptied and isolated tank BST-2 from the DH system

and provided for NaOH addition from the present NaOH Spray Additive Tank

BST-1. This tank provides Na0H to the reactor building spray system

instead of the DH system and is isolated from the DH system by check

valves. This modification prevented the introduction of NaOH into the OH

s system and RCS. The NRC reviewed and approved of this thodification in

license amendment #64 (dated August 2, 1983), which also restored the

j shutdown reactivity margin to the previous value.

In reviewing the above information, the intpector noticed that the

moderator dilution accident described in the Final Safety Analysis Report

(FSAR) Section 14.1.2.4.2, Unterminated Oilution Through the Decay Heat

Removal System, still described the old BST-2 tank configuratio i with

associated administrative controls to prevent this type of accident. This

finding was discussed with licensee personnel who stated that Chapter 14

of the FSAR was in the process of being reviewed and revised for the next

annual update in July 1989. The licensee w'il include revisions to the

moderator dilution accident analysis to-reflect the current method of NaOH

addition as part of this annual FSAR update.

IFI (302/88-24-01): Reviaw the licensee's revision to the moderator

dilution accident analysis in the FSAR. (TI 2515/94 is closed.)

6. Inspection of Quality Assurance for Diesel Generator Fuel Oil (71707)

The inspector reviewed the licensee's purchasing requirements plat.ed on

f uel oil ordered for the emergency riiesel generators. The licensee buys

this product as a "Safety-Related" commercial grade purchase and utilizes

the>:ommodity rethod of procurement specified in the licensee's Nuclear

Procurement and Storage Manual. This method requires a receipt inspection

and test of the new fuel received.

Tne inspector discussed this process with licensee material quality

assurarce personnel and reviewed recent procurement, purchase order, and

receipt inspection documentation for the purchase of this fuel oil (TI

2515/93 is closed.)

No violations or deviations were identified.

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7. Licensee Action on Freviously Identified Inspec.; ton Findings (92702 and

92701) ,

(Closed) Unresolved Item 302/84-21-05: Change the Plant Review Committee

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(PRC) Charter to Correct the Use of Alternate Members and Change PRC

Meeting Activities

As stated in NRC Inspection Report 50-302/85-21, this item remained open

pending a clarification of job position philosophy and subsequent revision

to the PRC charter. Subsequent verbal ccmmunication between the NRC and

the licensee on May 24, 1988, has clarified this issue. The temoorary

absence of a full time PRC member can only be filled by a designated

alternate me3.ber. This reouirement ensures that continuity of con.mittee

activities is maintained. The licensee has subsequently revised the PRC

charter (revision 26 dated July 15, 1938) to reflect tnis position.

8. Licensee Disposition Actions in Regard to Vender Related Issues (36100)

The inspect.or reviewed the licensee's hardware problem disposition actions

associated with the followiag issues:

a. 10 CFR Part 21 report from Brown Boveri Company (BBC) dated May 13

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1985, in regard to an incorrectly configured short time delay band

lever for BBC (also identified as ITE) K-Line circuit breakers.

This issue was previously identified as an inspector tollowup item

(IFI 302/87-19-04) and was also discussed in Information Notice (IN)

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85-64. NRC Inspection Report 302/87-19 stated, in part, that work

request (WR) 69571, dated 7/11/85 was initiated to verify whether or

I not any of the safety-related or balance of plant (80P) circuit

breakers in the DBC K Line breaker series contained the incorrectly

configured lever. The vendor identified two circuit breakers as

suspect at Crystal River in its May 13, 1985 letter; however,

subsequent licensee communications with BBC discovered that the

incorrect link may have been installed on K-Line circuit breakers

manufactured earlier than was previously stated, but was limited to

the 480 VAC auxiliary power BOP and safety-related breakers.

Therefore, WR 69571 was written to inspect all of the 480 VAC BBC

devices that may contain the incorrect lever.

The inspector followup on this issue revealed that the WR is not

completed for the B0P circuit breakers; however, the safety-related

circuit breakers have all been inspected and no incorrect band levers

were found. The licensee has taken satisf actory corrective actions

to determine the applicability of this issue to Crystal River.

Action on this matter is complete and this issue is considered closed

(P21SS-03).

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b. Two 10 CFR Part 21 reports from Brown Boveri Company in regard to

other BBC K-Line circuit breaker problems were received by Crystal

River as follows: (1) a March 19, 1985, BBC letter discussing the

potential of cut auxiliary switch control wires on its K-Line circuit

breakers, that can occur during racking operations due to '

interference with a sharp edge on a stationary breaker dust t:over,

and (2) a June 30, 1986 BBC letter discussing the potential of cut

and shorted control wire harness wiring due to oversi7e clearance

holes in the K-Line panel enclosure that allows the harness to come  ;

into contact with the racking gear teetn.

Adequate investigative and corrective actions are being performed by

the licensee, as follows: (1) Work request 69571 discussed above was

also scoped to include work activities to install protective gasket

material over the sharp edge of the dust cover and secure the wires  !

to the auxiliary switch, and (2) Work requests 94001-94011, dated ,

September 14, 1987, were written to inspect and repair as necessary

the applicable 480 VAC K-Line breakers, To date, WRs 94006, 94007,

94008, 94009, 94010 and 94011 have been completed with no problems

found. WR's 94001, 94002, 94003, 94004, and 94005 are still

uncompleted.

The licensee has taken action to determine the applicability of this

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issue to Crystal River. The above WRs are noted as optn but should

be adequately controlled by the licensee maintenance and quality

control organizations. Therefore, action on this matter is complete

and this issue is considered closed (P2185-06 and P2186-02). *

c. A 10 CFR Part 21 report from Limitorque Corporation dated

December 19, 1980, in regard to potential Limitorque DC motor lead

wire groun;ing/ shorting problems due to the type of lead wire -

insulating material (Nomex-Kapton) used by the motor vendor. IN

87-08 was subsequently issued and discusses the problem in greater ,

detail. l

The licensee performed inspections of all applicable Limitorque

operators and discovered that none had the questionable insulation; r

instead, the DC notor leads have an epoxy impregnated glass braid on  :

top of Nomex type insulation which is consicered environmentally -

qualified by Limitorque. These actions are discussed in a Florida  :

Power Letter, dated February 15, 1988, letter 3F0288-13, to the  :

Region II Administrator. [

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The licensee has taken satisfactory corrective actions to determine

the applicability of this issue to Crystal River. Action en this

matter is complete and this issue is considered closed (P2186-03).

d. Two 10 CFR Part 21 reports concerning Limitorque Corporation  !

actuators were received in 1935 by Crystal River, and do not appear

to have been evaluated for the design basis hardware functionality

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aspect, as follows: (1) A ':ay 8,1985, Babcock and Wilcox letter

discusses Limitorque actuators supplied to the Bellefonte Plant that

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have an actual weight that exceeds the valve vendor documents and

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stress analysts bases, which is therefore non-conservative, and (2)

An August 13,19S5 Limitorque letter that discusses potential worm

shaf t gear failures when certain critical speeds are combined with

repetitive actuator clutch nechanism transfer of size-2, type SM3, SB

and $80 actuators.

The inspector and licensee reviews indicate that the two issues have

not been evaluated for their effect on the operation of the plant

systems, nor has all of the eo,uipment or systems been identified.

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Failure to provide an adequate evaluation and procedures to control

incoming vendor technical issues is contrary to 10 CFR Part 21 and

10 CFR Part 50, Appendix B, Criterion XVI, and is considered to be a

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violation (Violation 302/88-24-02). This issue is also discussed in

i section 9, below. Action on these issues as 10 CFR Part 21 items ir,

complete, and will be followed as part of the corrective action for

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violation 302/83-24-02. This issue is therefore considered closed

(P2185-02).

l Violation (302/38-24-02): Inadequate evaluation and procedures to

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control incoming vendor technical issues.

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e. A 10 CFR Part 21 report frem GA Technologies (Sorrento Electronics

Division), dated February 23, 1937 in regard to a Sorrento

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Electronics model RD-23 ion chamber detector Rockbestos coaxial cable

insulation resistance probloa at high temperatures (LOCA conditions).

The letter identifies Crystal River as having procured the analog

I' version of ,its post-LOCA high range radiation monitor (HRRM) syrtem

for use in containment.

. The inspector reviewed the site nuclear engineering evaluation ef the

problem, and the package (Doc. Catl. No. T87-73) indicated that

Crystal River does not use the RD-23 in the identified application.

The package stated, in part, that the Crystal River HRRM devices

"...are supplied by Gammametrics and not Sorrento Electronics.

! kockbestos cable is not utili:ed in a safety related function for

! equipment located in a harsh environment. . .The attached technical

i information from Sorrer.to Electronics is not applicable..." However,

> contrary to the licensee statements the inspector's r eview of the

Crystal River master instrument list and discussions with licensee

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staff indicated that Crystal River does have Sorrento Electrontes

RD-23 devices installed in the HRRM application (RM-G29/G30) and has

the Sorrento Electronics RP-23 analog readout module. Additional

j verification efforts by the inspector appear to indicate that the

d

Rockbestos cables are installed according to the electrical circuit

I schedules. The licensee's evaluation of this Part 21 report is

,

considered incorrect, and is used as an example in violation

i

302/88-24-02 because procedures were inadequate to assure that a

l proper evaluation is conducted.

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Subsequent discussions with the licensee staff revealed a second

licensee evaluation of a Sorrento followup letter. This evaluation

was handled correctly and resulted in a Gilbert / Commonwealth

engineering heat transfer calculation being performed to determine if

the problem was applicable. The calculation indicates that the cable

is qualified for its application. This issue is therefore considered

closed (P2187-01).

f. An April 30, 1987 letter from Colt Industries, as required by

Section 21.21 of 10 CFR Part 21, identifies an indicator valve plug

failure (P/N-92-002-SS3) in its Fairbanks-Morse model 38TD8-1/8 EDG

adapter relief and indicator valve. The lett1r recommends that

Crystal River remove and inspect the brass plug threads for

deterioration and to implement a periodic inspection program at least

once in five years. Work Request 896S8, dated May 5, 1987 was issued

to inspect the plugs on EDG 1A and 18. All plugs were replaced with

new parts, even though no degradation was indicated on the WR.

Crystal River interoffice letter No. SNES83-0486 was issued to

incorporate an inspection attribute in the EDG preventative

maintenance program.

The licensee has taken satisfactory corrective actions to determine

the applicability of this issue to Crystal River. Action on this

matter is complete, and this issue is considered closed (P2187-02).

(

i

j g. The inspector reviewed a Crystal River engineering evaluation of a

i February 10, 1988 letter from Power Conversion, to determined whether

i or not the licensee evaluated the impact of an electrical circuitry

'

design change (i.e., to increase an existing 100 ampere fuse to a 225

ampere fuse) contained in the Power Conversion letter.

The inspector concluded that the design change was not addressed in

the evaluation conducted by the licensee's engineering reviewer, and

therefore represents an inadequate evaluation. This is used as an

example in violation 302/88-24-02.

In conclusion four out of nine licensee evaluation packages of incoming

vendor technical issues that were reviewed were found to be incomplete

and/or inadequate. Two limitorque items, which were in the Nuclear

Operations Engineering Department REI format, were initiated in in85 and

1986 but were found to be incomplete and still open. The other two issues

(Sorrento Electronics and Power Conversion) were found in the Nuclear Site

Engineering evaluation packages. All four evaluations, as discussed

above, do not adequately determine the individual impact on the design

function of the component or system.

Thus, the results of this inspection bring into question how many other

inappropriate or incomplete technical issues were performed by the

licensee staff. The licensee has committed to implement immediate

corrective action to determine whether or not this is a problem to the

plant components or systems.

,

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UNR (302/88-24-03): To determine the significance of the findings from

the licensee's review of the disposition of vendor identified technical

issues.

9. Nuclear Operation Selected Procedure Establishment and Implementation

Review (42700)

Based on the problems identified as Violation 302/88-24-02, the inspector

performed a cursory review of the following procedures:

-

N00-06, Technical Information Program, dated 11/14/85;

-

OC/RM-375, Routing and Processing Incoming Technical Information,

dated 6/1/85;

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AI-404, Review of Technical Information, dated 7/22/88;

-

CP-111, Documenting, Reporting, and Reviewing Nonconforming

Operations Reports, dated 6/4/88;

-

N L-06, Resolution of Safety Concerns, dated 11/8/85;

-

NEP-144, 10 CFR Part 21, dated 6/1/88;

-

NEP-141, Corrective Action, dated 6/1/88; and,

-

NEP-201, Preparation and Processing of REIs, SPs, and

Engineering Studies, dated 6/1/88.

The review indicated that the procedures were inadequate to assure

compliance with the requirements of 10 CFR Part 21; therefore, violation

202/88-24-02 was identified.

Furthermore, a review of the procedures appears to indicate that the

licensee may not be adequately controlling all of the incoming vendor

technical information to assure that the information is addressed per the

intent of NRC Generic letter 83-28. Each department appears to be

attempting to establish its own instructions and procedures without

verifying that its controls will not negatively af fect another procedure

or department. The licensee f.taff is currently reviewing this concern.

UNR (302/88-24-04): To deternine the significance of the findings from

the licensee's review of the procedural control of vendor identified

technical issues.

10. Exit Interview (30703)

The inspector met with licensee representatives (denoted in paragraph 1)

at the conclusion of the inspection on August 12, 1988. During this

meeting, the inspector summarized the scope and findings of the inspection

as they are detailed in this report with particular emphasis on the

violation, unresolved items, and inspector followup item.

The licensee representatives acknowledged the inspector's comments and did

not identify as proprietary any of the materials provided to or reviewed

by the inspectors during this inspection.

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11. Acronyms and Abbreviations

ALARA - As Low As Reasonably Achievable

BBC - Brown Bovtri Company

BOP - Balance of Plant

BU - Dulletin

CFR - Code of Federal Regulations

DC - Decay Heat Closed Cycle Cooling

DCHE - Decay Heat Heat Exchanger

DH - Decay Heat Remeval

EDG - Emergency Diesel Generators

EFW - Emergency Feedwater

FPC - Florida Power Corporation

FSAR - Final Safety Analysis Report

HRRM - High Range Radiation Monitor

IFI - Inspector Followup Item

IN - NRC Information Notice

LCO - Limiting Condition for Operation

LER - Licensee Event Report

LOCA - Loss of Coolant Accident

MAR - Modification Approval Record

NaOH - Sodium Hydroxide

NCOR - Nonconforming Operation Report

NRC - Nuclear Regulatory Commission

NRR - Nuclear Reactor Regulation

PM - Freventive Maintenance

PRC - Plant Review Committee

RCA - Radiation Control Area

RCS - Reactor Coolant System

REI - Request for Engineering Information

RW - Nuclear Services and Decay Heat Seawater

RWP - Radiation Work Permit

SP - Surveillance Procedure

STI - Short Term Instruction

SW - Nuclear Services Closed Cycle Cooling

SWHE - SW Heat Exchanger

TS - Technical Specification

UNR - Unresolved Item

VIO - Violation

WR - Work Request

.