IR 05000302/1997020: Difference between revisions

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{{Adams
{{Adams
| number = ML20199G686
| number = ML20216B844
| issue date = 01/16/1998
| issue date = 03/03/1998
| title = Insp Rept 50-302/97-20 on 971201-16.Violations Noted.Major Areas Inspected:Operations,Radiological Protection,Maint & Surveillance Programs
| title = Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-302/97-20.Response Meets Requirements of 10CFR2.201
| author name = Julian C
| author name = Jaudon J
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
| addressee name =  
| addressee name = Anderson R
| addressee affiliation =  
| addressee affiliation = FLORIDA POWER CORP.
| docket = 05000302
| docket = 05000302
| license number =  
| license number =  
| contact person =  
| contact person =  
| document report number = 50-302-97-20, NUDOCS 9802040326
| document report number = 50-302-97-20, NUDOCS 9803130201
| package number = ML20199G643
| title reference date = 02-13-1998
| document type = INSPECTION REPORT, NRC-GENERATED, TEXT-INSPECTION & AUDIT & I&E CIRCULARS
| document type = CORRESPONDENCE-LETTERS, OUTGOING CORRESPONDENCE
| page count = 70
| page count = 3
}}
}}


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=Text=
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! NUCLEAR REGULATORY COMMISSION


l               f
March 3, 1998 l Florida Power Corporation l Crystal River Energy Complex
                '
! Mr. Roy A. Anderson-(SA2A)
        . REGION 11
l- Sr. VP. Nuclear Operations    4 l
              ,
f Docket Nos :  50 302 License Nos.:  DPR 72
:  Report Nos.-:  50 302/97 20        .
Licensee:  Florida Power Corporation
:  Facility:  Crystal River 3 Nuclear Station i  Location:. 15760 West Power Line Street Crystal River, FL  34428 6708 i
,
Dates:  December 1 - 16, 1997 t
Team Leader:  C. Julian Technical Assistant Division of Reactor Safety-        ;
Inspectors:  _ B. Crowley, Senior Reactor Inspector, Maintenance -
'
Branch, RI!
      - Ron Gibbs, Senior Reactor Inspector, Maintenance Branch, Ril Russell Gibbs, Resident inspector,. North Anna-Site E Girard; Senior Reactor Inspector, Special Projects-Branch, RII        >
K. 0'Donohue, Resident inspector, Vogtle Site L, Wert. Senior Resident inspector Browns Ferry Site      . Wright. Senior Radiation Specialist, Plant Support Branch Ril Approved By:
C. Julian Technical Assi(tyt
        -
1'
D/te Sig'ned
            /8  h
    - Division-of Reactor Safety
              :
-
Enclosure 2
,
G  PDR
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          '
e . + - - - - --i--a ..-w,.m-,,4.-...- .w-v -..,,-,.w--v.--.-.-- r v,- + - . . . . _ _ re mi , . - - , . ,_w.mw.m., --,.-,#--,..,..n...m.,e,.w..ww.,,..--,y,-%%
 
EXECUTIVE SUMMARY l
C.wstal River 3 Nuclear Station NRC Inspection Report No. 50 302/97 20 This inspection included an assessment of the current status of the licensee .
programs for Operations. Radiological Protection, Maintenance, and Surveillance.
 
+
Overall, the inspection team concluded that the licensee Operation Radiological Protection. Maintenance, and Surveillance programs were adequate to support plant operation.
 
Operations
= Overall, the team concluded that the conduct of operations was adequate to support plant restart. The team noted there have been numerous recent changes and that some aspects of the programs were not yet fully implemented.
 
+ Control room operators were consistently professional and demonstrated a positive attitude. Communications, procedural compliance, turnovers, and response to off-normal conditions were strong. The widespread utilization of radios for communications was effective. The operators demonstrated a sense of ownership of the plant. Attention to detail during some control board walkdowns was weak, Control room access control during backshift hours and level of detail in the logs were areas needing improvement. (Section 01.1)
+ Several areas were identified in which procedural controls over annunciators and alarms should i>e improved. There was no formal mechanism to address compensatory measures for disabled annunciator Annunciator windows expected to be lit due to plant conditions were not designated as such. Procedural guidance did not address actions to be taken for invalid annunciators / alarms. Computer alarm points removed from scan were not periodically verified. (Section 01.2)
* Deficiencies were noted in the questioning attitude and attention to detail on the part of some plant equipment operators. The licensee effectively used temporary enclosures, referred to as "Hiltons" in the operating space The use of personnel safety equipment was excellen (Section 01.3)
Enclosure 2
 
_ ._ . __ _
 
.
The new work control process had not yet fully implemented. Operations personnel were well informed regarding all significant maintenance and testing activities in progress. Operations actively participated in briefings for maintenance activities. (Section 01.4)  .
.
A weakness was identified regarding a lack of strict compliance with clearance tags. The team noted that information tags were inconsistently utilized. (Section 01.5)
.
The Equipment Out of Serv Ma log was accurate but was not being rigorously maintained. i ct.m 01.6)
. The lack of a separate program w control temporary modifications could lead to temporary modifications being performed without proper assessment. No safety significant examples of this were identifie There was no designated log for jumpers and lifted leads, but they were adequately controlled by various mechanisms. (Section 02.2)
. The procedural controls and emphasis on the work around program needed to be improved. Monitoring of control board deficiencies was not being performed accurately. (Section 02.3)
. Numerous examples of poor housekeeping were note Lighting was not effectively maintained and some areas of the plant were not well li Numerous inconsistencies and deficiencies were identified in equipment labeling. The licensee's labeling upgrade program should be continue (Section 02.4)
. The availability of computerized programs such as NUPOST and View / Print was considered a strength. Procedure adherence and usage was goo Several uncontrolled operator aids were identified. There was no procedural guidance for time to core uncovery/ boil curves for extended shutdowns. Two deficiencies were noted associated with outdated revisions of controlled procedures. (Section 03.1)
. Operator knowledge of significant Probabilistic Safety Assessment information needed to be improved. Overall knowledge of Technical Specification requirements and system operations was good. (Section 04)
- Personnel in Operations worked significant amounts of overtime during the last several months of the extended shutdown. The team did not
'    Enclosure 2
 
observe any indications of significant fatigue on the part of the operator The licensee had decided to piace personnel experienced in operations into other working groups and will need to continue efforts to obtain more licensed operators to decrease the required working ,
hours. (Section 06)
.
Chemistry sampling required by Technical Specifications and the Offsite Dose Calculation Manual was properly implemented. (Section 08)
.
The licensee had plans for strengthening of the current Operations self assessment program. (Section 07)
Maintenance
.
Overall, the Maintenance Program was adequate to support restart of the unit. Maintenance was being performed in accordance with procedures in a quality manner by trained and qualified craftsmen. In general, maintenance procedures provided adequate detail for the control of maintenance. (Sect 4on M1.1)
.
The strong maintenance supervision presence and involvement on the job site was considered a strength. (Section M1.1)
.
Maintenance personnel had a positive attitude about performing and documenting maintenance correctly, and procedure use was goo (Section M1.1)
.
The maintenance training and certification program, which was comprehensive with detailed multiple task performance training requirements specified for each discipline, was considered a strengt (Section M1.1)
.
Corrective and preventive maintenance backlogs were low, and the strong emphasis on control of maintenance backlogs was considered a strengt (Section M1.1)
. Activities relative to foreign material exclusion (FME) controls, quality contro' (OC) hold points, pre-job briefings. interface with operations and engineering post maintenance testing, and control of measuring and test equipment M&TE were performed in accordance with program requirements and were found to be satisfactory. (Section M1.1)
Enclosure 2 ,
 
________________ - _ _ _
l
 
4
+
The following programmatic weaknesses were identified: (Section M1.1)
There was a possibility that, for " troubleshooting" work requests (WRs), .
the added post maintenance test (PMT) requirements would not receive Operations review and approval as required by procedur The process for evaluation of the effectiveness of the preventive maintenance (PM) program, including evaluation of the effect of repeated maintenance on the program, was not formalize Repetitive maintenante was being documented and tracked, but was not being used to monitor and improve maintenance of equipment.
 
l The responsibilities for the ' Gator Team" (quick response maintenance team) were not proceduralize .
Licensee implementation of the Maintenance Rule program was evaluated as satisfactory, with the following observations. (Sect <on M1.2)
Strengths:
The licensee had developed and implemented an on-line risk monitor as e tool for assessing risk when removing equipment from service during power operations, inspection of structures under the Rule were comprehensive, and documentation of inspection deficiencies including the location and extent of condition was excellen Weakness:
Deficiencies identified by the structural inspections had not yet been evaluated to determine if any structures should have been classified as (a)(1) under the Rule with goals and monitoring established. This weakness was corrected during the inspectio No structures were classified as (a)(1).
 
.
The licensee's surveillance program was acceptable for plant operatio Surveillances were satisfactorily scheduled, proceduralized, performed-and documented, (Section M1.3)
Enclosure 2
 
_ _  __ _ _ ___ _ _ _ _ _ _ _ _ _ _ __
S
+
Pre job briefings for the surveillances were thorough and well-presented. (Section M1.2)
+
Licensee nondestructive inspection examiners were thoroughly aware of .
recent industry experience involving high pressure injection piping and thermal sleeve cracking at other sites and had performed appropriate examinations to assure the condition did not exist at Crystal River. A weakness that could impact future examinations was noted in the licensee's written examination criteria. The licensee prepared a precursor card to address this weakness. (Section M1.3)
Plant Sucoo .
Overall, the radiation protection program was adequate to support restart of the uni .
A violation (50-302/97-20 01), was identified for failure to provide adequate written instructions for documenting personnel contamination (Section R1.1)
.
A violation (VIO 50 302/97 20-02) was identified for failure to follow radiation protection program procedures for documenting personnel contamination events. (Section R1.1)
.
A violation (50-302/97 20 04) was identified for failure of radiation workers to follow contamination control procedure (Section R1.1)
. An Inspector followup Item (50 302/97-20 03) was identified to review  '
the licensee's technical basis for dose conversion factors during a future NRC inspection. (Section RI.1)
.
The Radiation Monitoring System Readiness Review was thorough. The corrections made to the system and others proposed should improve the equipment operability, ensure equipment is capable of performing intended functions, and impi ve quality of supporting and administrative documentation for the equipment. (Section R2.1)
. The inspectors verified thi:. the Mhole Body Counter was properly calibrated, monitored, and maintained. (Section R2.2)
Enclosure 2
 
.
The inspectors verified that the licensee's whole body contamination monitors were being properly calibrated, monitored, and maintaine (Section R2.3)
    .
Enclosure 2
 
__ _ _ . _ . _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ -  _ . _ . _ . _ - _ _
i-i Reoort Details    i St rv of Plant Status      :
        !
Crystal River 3 was in an extended shutdown during the inspection perio I
        '
L  Introduction      i
  - The primary focus of Phase One of this Operatiomi Safety Team inspection was to verify that the licensee had achieved readiness to' resume plant operations, inspection areas focused on operations, maintenance, and surveillance. The inspection was performed by a team of inspectors that included a Team Leader, four region based inspectors _and three resident. inspector I. OPERATIONS 01 Conduct of Operations-01.1- Control Room Observations (93802) Insoection Scone      '
The team _ observed the conduct of Operations in the control room for significant periods, including approximately 72 hours of continuous shift coverage. The team observed operator. professionalism, attentiveness, awareness of plant status, communications, conduct of evolutions, response to alarms, and control of plant activities.
 
. Observations _1rcluded response to a malfunctioning transformer which resulted in-a_ loss-of the control . room annunciator system. - The team  >
also performed inspection of routine Operations shift activities including shift turnovers, control-board walkdowns, and control room environment. -Shift operating logs, night orders, and short term instructions were reviewe Observations and Findinos
 
Throughout the inspection, the team noted that numerous changes had recently been made affecting the Operations department. In recent
     ~
  -weeks._ revisions to operating practices including reissuance of the Operating Instructions.and changes to major'watchstation titles had been
    ~
      -
completed. During the inspection, other_ significant Operations
' = -
procedures were changed. The team'noted that some aspects of the Enclosure 2
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l
 
programs had not yet been fully incorporated into the plant operating routine. Major revisions were planned in the near future for the
!
Operations self assessment program and work around control progra The team observed a consistently positive attitude on tne part of Operations ,
personne Several members of the team observed tne operators' response to a loss of control room annunciators on December 10, 1997. In response to indications of degraded oscillating voltage with the annunciator system, the operators verified that the control room computer was unaffected and deenergized the annunciators to prevent equipment damage. The appropriate abnormal procedure was immediately entered. The problem was traced to a malfunction of an alternate transformer supplying power to several vital loads. The operators utilized procedures and returned the loads to their normal source. The team observed that the actions for the loss of annunciators were completed. The control room operators contacted watchstanders in the plant and increased monitoring of indications and equipment. The team noted that emphasis was placed on monitoring of the decay heat removal sy; tem. The Nuclear Shift Supervisor effectively directed the overall activities. Operations management and the annunciator system engineer promptly responded to the control room. The emergency plan was reviewed for entry requirements, and it was determined that entry into the emergency plan was not required because the plant computer remained operable during the even Access control and traffic in the control room wat evaluate Generally, the team found that the control room environment was conducive safe plant operation. During backshift hours there was more trr  the control room than expected. The team observed on numerous .casions that maintenance personnel entered the control room (
to obtain permission to perform work. The team asked selected workers if they had tried to get permission from the Work Control Center (WCC),
and they had not. The workers explained that the WCC was sometimes not manned with a Senior Resident Operator (SRO). especially during backshifts. The team observed that controlled key issuance was performed from the control room. This oractice caused more control room traffic than necessary. On several occasions, the team observed that individuals entered the control room without permission from the SR ._
Enclosure 2
 
. _ _ _ _ . . _ _ _ _ _ . _  . . . _ _ _ . _ _ _ . _ _ . _ _ _ _
 
Throughout the inspection period, the inspectors observed good communications practices by Operations personnel. Three part communications were consistently utilized. The phonetic alphabet was used in almost all communicat Mns, The team observed one incident  .
involving a loss of annunciators and several days later, a loss of the plant compute Communications did not degrade during response to the incidents. Although use of the phoretic alphabet was not as consistent throughout the plant staff, management emphasis was placed on correcting errors in this area. During offnormal conditions, shift management provided briefings to the Operating crew which were concise, accurate, and timely, The extensive use of radios by plant personnel reduced the noise level in the control room by decreasing incoming phone calls. The use of radios also significantly decreased reliance on the plant paging syste The team noted that although operations personnel used three way communications on the radios, some of the other depart.vnts were not consiscent in this are The team observed good procedural compliance by Operations personne In response to off-normal conditions, procedures were actively referenced and followed in step sequence. The team observed tnat operating and testing procedures were followed correctly. Alarm response procedures were utilized as required in response to alarm During the performance of pr vedural steps, the team noted that Stop-Think-Act-Review (STAR) principles were usually e*aploye The team observed that the operators were very professional and demonstrated a positive attitude. The background noise levels in the control room were low. The general control room atr ;phere was maintained as business oriented with non plant conversation and outside distractions limited. When one board operator left the control board area, there was appropriate comaunications to ensure the remMning board operator was fully aware of the absence. During discussions and pre-job  -
briefs, the operators were attentive and actively participate The team conducted multiple operator interviews and found that the operators vare open about issues. The operators were willing to discuss areas of needed improvemen Shift turnovers were thorough and informative. The team obst.rved numerous watch stations conduct turnovers. Overall. the team concluded Enclosure 2
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that sufficient time was allocated to ensure plant and equipment status were know The team noted that shift relief checklists were used by the various operator watch stations. In addition to equipment status and log reviews..the checklists included reviews of degraded equipmen .
'
.
evolutions in progress, temporary plant configuration changes, and equipment / controls in manual. The team observed active participation by plant equipment operators-in the shift turnover briefings. The team verified the effectiveness of shift turnovers through discussions with a operators. The team concluded that the turnovers were effect.1ve and that 3 operators were well informed of plant conditions.
 
.
One of the inspectors noted that several control board indicating lights were not lit after turnover board walkdowns were completed. Control room personnel explained that the indicating lights were not lit because equipment was isolated in the field. The equipment was not tagged on the control board. Investigation identified that about half of the approximately a dozen dark indications checked were caused by burned out light bulbs, not isolated equipment. One broken light socket was aleo identified during light bulb replacement. The team noted that the practice of not indicating active clearances on the affected control board equipment placed a burden on control room personnel and could mask control room equipment failure The team noted that the shift operating logs, while usually meeting the requirements specified for contents in Operating Instruction 01-5 were not detailed. In some cases information was not icgged which could be useful to management and other reviewer The team noted that a Daily Plant Status Report, which was used to provide an overview of plant conditions and system alignments, contained some inaccurate information regarding the status of safety equipmen The licensee reviewed the report and identified that the information, along with some other data, had been incorrectly carried over from a previous days reports. The error was apparently caused by inattention to detai After reviewing shift personnel assignments, control room staffing, and fire brigade assignments, the team determined that shift manning practices were adequate nd met Technical Specification 5.5.2. " Unit Staff" requirements. Cc :icting staff assignments were not identified, although the low-number t licensed operators resulted in heavy work Enclosure 2
_
 
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _  __-
. S loads for shift personnel. Back shift work activities were often
;  controlled by the on shift SRO rather than work control personne The team reviewed the use of Short Term Instructions (STis). operating .
instructions, night orders, and the shift study book. In general, they were adequate and used correctly. The ST!s and night orders were few in I
number and addressed appropriate topics. Most shift members reviewed each book during shift turnover or soon after. Several operators stated that they do not review all of the books every night, although they did acknowledge that it was part of the turnover process. The study book contained several updates on abnormal procedure revisions as well as other plant information. A few of the active updates were initiated in October, 1997 and had not yet been read by all personnel, in response to questioning by the team, the licensee stated that there were no formal interpretations of Technical Specifications. One long term night order contained operability guidance regarding the use of Once Through Steam Generators for decay heat removal. The team concluded that the guidance in the night order would be more appropriately controlled if incorporated into a procedure, Conclusions Control room operators were consistently professional and demonstrated a positive attitude. Communications, procedural compliance, turnovers, and response to off normal conditions were strong. The widespread utilization of radios for communications was effective. The operators demonstrated a sense of ownership of the plant. Attention to detail during some control board walkdowns was weak. Control room access control during backshift hours and level of detail in the logs were areas ne2 ding improvemen .2 Alarms and Annunciators Insoection Scone (93802)
The team reviewed the controls associated with the annunciator system
  'and computer alarm .
Administrative controls for disabling alarms and tracking the status of alarms were reviewed. Portions of the corrective actions for a malfunctioning annunciator were observed. The status of the sliding links associated with the annunciator system were verified by one of the inspector Enclosure 2
 
_ _ _
!
 
b. Observations and Findinas
  -
Section 5 of Operating Instruction 017, Control of Equipment and System
; Status, contains the procedura! requirements for disabling annunciator .
f The inspectors noted that eleven annunciators were listed in the Annunciator / Event Point Ala_rm Defeat Log, With the assistance of an operator trainee; an inspector verified that only the sliding links associated with the annunciators listed as defeated were opened. None of the defeated annunciators were of a nature that would be expected to be described in the Updated Final Safety Analysis Report (UFSAR). The licensee was not sure which annunciators, if any, were described in the UFSAR. The_ annunciator system is not a safety related system. The inspector noted that the administrative procedures did not require a specific safety review or assessment prior to disabling an annunciato Green dots were used to mark annunciator windows which were disabled or have a open work request. One of the inspectors verified that the dots and logbook, which contained documentation for the open work request were in agreement. None of the work requests associated with the annunciators had been open for an excessive time period. The number o windows with open work requests or that were disabled were not excessiv he team. discussed with-reactor operators the procedural guidance for removing annunciators from service when annunciators were invalid. The team noted two invalid annunciators that had not been disabled or marked with a' green dot. The team noted that Operating Instruction 01 07
  -
Control of Equipment'and System Status, did not provide sufficient guidance to address the issue. Questioning by one of the inspectors identified that a reactor operator was not aware that one of the two annunciators was invali ,
The team also noted that the licensee had not established a practice to label or mark the lit annunciator windows which were " expected u,be lit" due to plant conditions. Since numerous annunciators were lit due
  -
to the long term outage conditions. this might facilitate the operators'
awareness of offnormal conditions. During observation of a recovery from loss of annunciators. the team noted that such a practice would have been particularly usefu Enclosure 2 sf
 
__-. - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
 
l i
The team noted that the procedural controls for disabling of annunciators or alarms do not require or recommend consideration of compensatory measures. No formal method for tracking or monitoring completion of such compensatory measures was identified. Trough .
discussions with the operators on watch. the team was informed that on-shift personnel did give consideration to what compensatory actions were appropriate and how to monitor them. The licensee indicated that consideration would be given to establishment of procedural guidance in this are The team noted that changes to computer alarms such as removal from scan by the operators were listed in the computer alarm change log in the control room. One of the inspectors determined that there was no requirement or expectation that a computer printout of points removed from scan be generated periodically. This printout could be reviewed against the log to ensure the correct status of alarm points is know The computer alarm change log is reviewed daily. In response to the observation, the licensee obtained a printout and determined that numerous points not listed on the log maintained in the control room were in fact removed from scan. At the close of the inspection period, the licensee was evaluating methods for periodic review of computer points removed from servic The team observed some of the corrective actions taken due to a malfunctioning annunciator. The electrical worker who performed the job appeared very familiar with the task. Configuration control of the sliding links was maintained through use of the temporary sliding link log as required, The work was completed under a generic work reques A specific request was not generated 'or the job. The inspectors questioned how the performance of the work would be tracked for equipnent reliability considerations. Subsequently, the licensee issued work request 350630 to document the work and a precursor card was initiated on the issue, c, Conclusions
 
Several' areas were identified in which procedural controls over annunciators and alarms could be improved. There was no formal mechanism to address compensatory measures for disabled annunciator Annunciator windows expected to be lit due to plant conditions were not designated as such. Procedural guidance did not address actions to be
  ~
Enclosure 2
 
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l
      '
 
.
taken for invalid annunciators or alarm Computer alarm points removed l
from scan were not periodically verifie .3 Doerations Watchstandina Activities Outside of the Control Room , Insoection Scone (93802)
The team members accompanied several plant operators during routine building rounds and other plant activities. These included rounds in the Auxiliary Building, Control Center Complex, intermediate building, and the Turbine Building. Attentiveness to overall conditions and communications were assessed as well as the quality of the tours, Observations and Findinas During the observation of some tours, the team found that attention to detail and questioning attitude was not strong. The team noted several items which indicated that some operators were not paying close attention to building conditions and certain practices. There were several examples of poor radiological protection practices such as water on step off pads, personnel conducting conversations on step off pads, an individual not properly wearing radiation monitoring equipment, and a container of used anti Cs located outside of a contaminated are Numerous building light bulbs were burned out and were not reported to the maintenance department, A controlled key was missing from a locked enclosure. One confined space appeared to have an expired permit or certificate. A pipe cap was missing from a boric acid storage tank sample line. An individual was not wearing appropriate security identification. Precursor cards were initiated to address the conditions. The team noted that the operators consistently demonstrated ownership of the equipment and conditions by prompt followup of any questioned condition The building operators have field offices which are known as "H11 tons."
 
Administrative activities such as phone communications, procedure review, and shift turnover are generally conducted in the Hilton There is also a computer in the Hiltons that allows the operators to print controlled procedures. The team discussed the value of the Hiltons with operators who stated that these field offices allowed them Enclosure 2
 
_ __
 
to conduct their business more efficiently because less trips to the control room area were necessary. This also allowed the operators to spend more time in their assigned area .
'
The team observed a very high emphasis was placed on the use of personnel safety protection equipment. Hardhats, safety glasses, and earplugs were consistently worn as require Conclusions
 
Deficiencies were noted in the questioning attitude and attention of detail by some plant equipment operators. The licensee effectively used temporary enclosures referred to as "Hiltons" in the operating space The use of personnel safety equipment was excellent.
 
J 01.4 Doerations Control of Maintenance. Troubleshootina. and Surveillance Testina Activities
      , Insoection Scone (93802)
The team reviewed the interface between Operations and other groups during maintenance and testing activities, Obcarvations and Findinas The control room staff was well informed of ongoing activities in the plant, in particular they understood the field work which affected control room equipment and indications. The inspectors noted that appropriate questions were asked by the control room staff about the
:'
work during job pre briefs. Additionally, work was postponed if there were unanswered concerns or if it was determined to be too disruptive for the control room. The team observed that on a few occasions. the combination of control room activities resulted in a level of noise l
,
which was potentially distracting to the operator Shift personnel were often responsible for controlling all aspects of work control in addition to the daily control room activities. The shift mandger and nuclear shift supervisor addressed the development, review and approval of clearances: scheduled manpower; coordinated support groups and directed shift operators. The team was informed that in the future, most of tha work control activities would be addressed by Enclosure 2
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additional Senior Reactor Operators (SR0s) who were in license class at the time of the inspectio Additionally, the new work control program was not fully implemented due to insufficient numbers of SR0 personnel, A review of the new work control program indicated that once fully .
implemented, the work control activities should be adequately removed from the control room are The team observed a pre brief for the tag out of one train of the decay heat system to repair a leaking pump seal. A SR0 conducted the brief using a check off list which addressed multiple considerations for tag out personnel, in addition to the technical aspect!. f the clearance, which were discussed at length, the brief included discussions of past experiences from INP0 and lessons learned directly by the licensee, and the use of STAR for self-checking. Communications HP support including expected dose rates and how to accommodate system drainage, expected job duration, equipment needs, and what could go wrong were also discusse Operators actively participated in the brief. The team concluded that the brief was thorough and appropriately prepared operators for the tag out, c, Conclusions The new work control process was not yet fully implemented. Operations personnel were well informed regarding all significant maintenance and testing activities in progress. Operations actively participated in briefings for maintenance activities.
 
01.5 Clearance and Information Tagaina Insoection Scoce (93802)
The team reviewed the use of clearance and information tags. The inspectors observed clearance development activities, control of clearances, and tag placement and removal. The inspectors also reviewed numerous active clearances for accurac Observations and Findinas Compliance Procedure Cp-115. Nuclear Plant Tags and Tagging Orders, was recently revised to supply detailed directions on the development, placement. verification and removal of clearances. Discussions with Enclosure 2
 
. _- ___ _ _ _ _ _ _ _ _ . _ _ .
 
operations personnel indicated that they were familiar with the changes and procedure requirements. The team found that the clearances were adequate, tags were placed accurately, and the work performed under the clearance was appropriate. However, in a few cases, the inspectors .
observed that inadequate labeling of plant equipment made tag placement difficult. Although no deficiencies were identified, the potential for error due to inadequate labeling existe Attention to detail, self checking and caution were observed during tag placement. The plant operators involved with the clearances thoroughly understood the activities and were prepared for potential problem During plant walkdowns, several hundred tags were inspected for accuracy by the inspectors. No incorrectly installed tags were identifie During a discussion with maintenance management, the team was informed that under the new work control program, each clearance would be walked down prior to placement. The team noted that although personnel involved in the tagging process reviewed the piping and instrumentation diagrams for clearance development, they did not walk each clearance down prior to placement, This deficiency was forwarded to licensee
; management for resolutio One of the inspectors noted that a 480 volt motor control center breaker control switch handle was in the "on" position but had a clearance tag attached indicating that the switch should be in the "off. not locked position." A primary plant operator was notified. He indicated that he considered the situation to be a problem and immediately contacted the control room. Subsequently. it was determined that the breaker had been removed from the interior of the cabinet. Consequently, the control switch handle was not connected to the breaker and therefore was not being physically supported in the tagged position. The breaker cannot be removed if locked in a certain position. Some Operations personnel indicated that they did not regard the situation as a problem since the breaker was not installed. Several days later, the inspectors observed an electrical worker manipulate a similar breaker switch handle (with the door open so the switch was not connected to the component) which had a clearance tag on it. The team noted that some personnel did not regard this as a significant problem since the breaker itself was not being operated. The team discussed the concern with Operations management regarding the importance of strict compliance with clearance tags in that such tagged components are not to be manipulated. A precursor card was initiated to address the issu The licensee's Enclosure 2
 
review identified several other breakers in which the tagged switches were not in the specified position due to the breakers being remove The team observed that white or "information* tags were extensively ,,
use Section 4.15 of Compliance Procedure CP 115, Nuclear Plant. Tags -'
and Tagging Orders. contains procedural guidance for these tags. The information tags do not receive the same reviews as clearance tags arid can be placed by any employee as directed by the department superviso The team noted numerous examples in which the tags communicated valuable information and were appropriate. These tags were in heavy use on the control boards and throughout the plant. The information tags are audited and are permitted to be installed for a maximum of three months before reissue if required. The inspectors notd that there was not a pcsitive mechanism in place to prevent information on a white tag from being reissued indefinitel Information tags were noted on temporary jumpers and on opened sliding links. The team noted some instances in which information tags were used to indicate that a component was not functioning properly due to a maintenance issue but no work request sticker was present, A few tags provided guidance for the operation of balance of plant equipment. Some conditions were noted in which it appeared an information tag would be appropriate but was not used. For example, unidentified cabling and other material was present in the back of the control room panels, in response to the inspector's question. it was determined that the items were for future modification work. The team concluded that close monitoring of the use of information tags was necessary to prevent the tags from being used as informal procedures, work around description or in place of clearance or blue tags, c. Conclusions A weakness was identified regarding a lack of strict compliance w1".h clearance tags, The team noted that information tags were inconsistently utilize Enclosure 2
 
      :
i
      !
i
      't '
 
01.6 Eouinment Out of Service Reoort Insnection Scone (93802)
      .-
The team reviewed the Equipment Out of Service Report and interviewed operators to determine its usefulness for ensuring action statements are satisfied. Plant conditions were also reviewed to determine the accuracy of the repor Observations and Findinos The Equipment Out of Service Report was computer generated, kept in the control room area, and was updated daily. Guidance for the report was in Section 2.0 of 01 07. Control of Equipment and System, Revision 7, The report primarily includes equipment which was associated with T the Plant Fire Plan, and the Offsite Oose Calculation Manual where an action statement _was entered or tracked when equipment was removed from service. The Nuclear Shift Manager had the authority to add to the report if desired for other equipment. In the same section of the notebook, non action statement equipment was also tracked. The team reviewed the report and compared it to actual plant equipment or systems removed from service and no discrepancies ware foun Several operators were interviewed to assess the usefulness of the report. All those interviewed stated that the report was reviewed prior to assuming the shift and was one of several sources for_ tracking equipment status and associated Sction statements. Several operators stated that the report was recently placed on computer, and there was-some frustration associated with its use. Some operators stated that-the computerized report was slow and frustrating to us The. team performed a line by line review of portions of the report with a senior reactor operator. There were several entries-that were incomplete or were marked as *N/A' inappropriatel ' Conclusim s The_ team concluded that the Equipment Out of Service Report was accurate but was not being rigorously maintaine Enclosure 2
 
02 Operational Status of Facilities and Equipment 02.1 Safety System Walkdowns
      ' Insoection Scoce-(93802)
The team performed walkdowns of portions of several safety system The inspections focused on valve alignment and overall conditions of the ;
system Observations and Findinos A walkdown of the Decay Heat (DH) Removal system was performe The team limited the walkdown to the B Train which was in operation as the protected tnin during an A Train outage. Accessible valves in the main system flow p0th were in their correct positions and were generally found to be in good condition. The DHV-111 valve mechanical drive position indicator (MDPI) was found not indicating properly. Work request 341871 hatt been previously generated to replace the MDPI chain which would correct. the indication problem. The team noted that a tag had not been placed on the DHV-lll valve to alert operators that the problem had already been identified. No valves exhibited excessive packing or boron leakage, missing handwheels or bent stems. All components were labeled; however, the laceling was not complete. The team found that component descriptions were not included on the label As discussed in Section 02.4. the team was informed that a plant labeling project was planned to correct overall plant labeling deficiencies. Power supplies for system valves and the pump were verified to be in their correct positions with edequate labelin Piping supports were found to be in good condition. Lighting in the DH pit was adequate. Control ocard switches and instrumentation were properly labeled and were operating properly. The team reviewed the operating procedure in effect and compared it to the existing plant parameters and no problems were found. The team found that appropriate measures were taken to protect against a loss of deca / heat remova Protected train signs were placed at the access area to the DH pit and throughout the plant to ensure plant personnel received proper approval prior to entering protected arets. The team concluded that the B Train of the DH system was properly aligned and in good conditio Enclosure 2
    . . - - -
 
_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
____--
 
The team also performed a partial walkdown of the Nuclear Services and Decay Heat Sea Water Systems. There was a leak at the "A" decay heat exchanger vent which was not contained or directed to a drai Additionally, a few missing labels and housekeeping deficiencies were ,
foun c, Conclusior ;
No safety significant deficiencies were identified during walkdowns of portions of several safety systems, Minor housekeeping and labeling problems were note .2 Control of Temocrarv Modifications. Jumners. and Lifted Leads a, Insoection Stone (93802)
The team reviewed the effectiveness of the licensee's controls over temporary modifications, jumper.c. and lifted leads, Observations and Findinas In accordance with Operating Instruction 01-7. Control of Equipment and J  System Status, the licensee maintains a Temporary Modification or Temporary Modifi:ation Approval Record (T MAR) log. The log indi:ated that only five T-MARS were presently installed, The team questioned why several specific conditions noted during tours of the facility were not classified as T MARS. One involved a temporary power supply to an electrical distribution panel, Another was a temporary chiller connected to the control complex ventilation system. The licensee had installed the temporary power supply under the Temporary Power Supply control prograin which appears to have the required aspects of a temporary modification program. The temporary chiller was installed under a work request as a maintenance support issue. The chiller did not appear to have any potential to affect control complex ventilation under accident conditions. The team reviewed Nuclear Engineering Procedure NEP-210, Modification Approval Records (MARS). Section V.C cf NEP-210 addressed T-MARS and primarily descric.d T-MARS as being prepared in the same manner as permanent MARS, Procedure NEP-210 did
_
_ _ _ _  _
Enclosure 2
 
__ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -  ___-_
 
not define what activities should be considered as MARS. The team concluded that requiring the same elaborate processes for T MARS as for permanent MARS would discourage classification of activities as temporary modification .
Thelicenseecontrolledtemporaryjumpersthroughseveraladministrative processe Processes such as operating procedures, clearances, and modification procedures were used to install jumpers. A separate jumper log is not maintained. During the inspection, the team examined numerous circuits and the interior of many cabinets. The team did not identify any uncontrolled jumpers. Three jumpers were noted in a back control room panel. The inspector verified that the jumpers were installed in accordance with the operating procedure referenced on the attached information tags. The inspectors noted that the licensee did nat utilize wiring with any distinguishable characteristics such that
'
'
installed jumpers would be easily observed. While the jumpers did contain an information tag, they were not easily discerned from other wirin During inspection of the cong ol room panels, one of the inspectors noted a lifted lead which was not tagged or marked as intentionally lifted. Subsequently, the licensee identified that the lead had been intentionally lifted for modification work, and it was re landed. The licensee informed the inspector that the lead was controlled within the MAR process. The inspector noted that a modification or information tag would have been beneficial to an operator questioning the lifted lea Conclusions The lack of a separate program from the normal MAR process to control temporary MARS could lead to temporary modifications being performed without proper assessment. No safety significant examples of this were identified. Jumpers and lifted leads were adequately controlled by various mechanism .3 Control of Goerator Work Arounds and Control Board Deficiencies
ATTN: Mgr.. Nuclear Licensing    I 15760 West Power.Line Street
  - Insoection Scone (93802)
. Crystal River. FL 34428-6708 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-302/97-20)
The_ team _ examined the programs for the identification and monitoring of Operations Work Arounds and Control Board deficiencie Enclosure 2
 
._ _ _._ _.__ _. __ _ __._._ __ _ _ _        . _ - - -
              ;
 
r
              ,
              '


, Observations and Findinas
==Dear Mr. Anderson:==
  .The licensee maintained a list of operator work arounds on a computer bulletin board which could be accessed by Operations. personnel. There'      .
Thank you for your response of February 13, 1998, to our Notice of Violation issued on January 16. 1998. concerning activities conducted at your Crystal  j River facility. We have evaluated your response and found that it meets the i requirements of 10 CFR 2.201. We will examine the implementation of your  l l corrective actions during future inspections.   {
were six work arounds listed as active. The team verified through      ,
discussions with Operations management that most of the listed _ work-arounds will be corrected prior to startup. Although a formal procedure was being developed to set forth requirements for classifying conditions
              '
as work arounds, no procedure currently provided such guidanc .
Operations personnel indicated that the procedure was expected to be issued in January 1998. The inspectors noted several equipment issues which would most likely be classified as low priority work arounds under a formal program. One example consisted of a series of equipment problems-associated with the raw water system traveling screens. While no single problem was significant in itself, discussions with operators indicated that the combination of issues resulted in delays in correcting increasing screen differential pressures. The taam concluded that development of a formal work around process wwld i . beneficia The licensee monitors control board deficiencies as well as operations equipment deficiencies as performance indicators, Operations equipment deficiencies. include all identified problems in the field that have associated controls on the main control board. Control board deficiencies are associated with. control--board indication problems, The licensee has established a goal of less than ten open control board deficiencies. The team was informed that there currently were no control      ;
  '
board deficiencies. One of the inspectors walked down the control panel and_noted several-problems-which appeared to be control board-      ,
deficiencies. After additional review the licensee revised the list of-      *
control board deficiencies to include at least six deficiencie : Conclusion '
The procedural. controls and emphasis on the work around program needed to be improved. Monitoring of control board deficiencies was not being performed accuratel '
L          Enclosure 2 i
i x ,. ,: r ,1 ,,,c~.,, .,o_ r,'~ , _, y._ -...y..,._, ,,...,,,m._-__.,,.r,. , - . , . . . _ , ~ , . . , . , . - - , . , , , _ , , . , , _ _ _ _ , . , _ _


_ _ - _ _ _ _ _ _ _ _ - _ - _ _ _ _ - - _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ - _    ____  _- _ _ - _ _ _
We appreciate your cooperation in this matter.
 
02.4 Overall Plant and Ecuioment Material Conditions Insoection Scone (938.02.).
            .
The team assessed overall plant housekeeping and material condition Obsevations and Findinas During the first few days of the inspection, the team noted that excessive condensation from the Nuclear Services cooling syste.ns piping in the auxiliary building had the potential to cause problem The condensation caused puddles to develop on the floor, some of which ran across barriers posted as contamination areas and the stepoff pads for those areas. The wet floors could also result in personnel injury due to slipping. Some condensation was observed to be dripping on plant equipment. The situation was not conducive to good housekeepin Apparently, rc:ent weather conditions had resulted in heavier than normal condensation. The team noted that insulation had been successful in correcting this problem in some specific areas. The licensee stated that although intentions had been to use a generic Modification Approval Record (MAR) to install insulation, outage workforce demands had resulted in that MAR not being implemented. Under the proper plant conditions, the licensee can also utilize a valve alignment which heats up the raw water supplied to the system. This reduced the condensation problem, but that alignment would not be successful due to current plant conditions. The licensee focused efforts on mopping up the condensation and shielding equipment. As the weather changed, the condensation was reduced. The team also observed leakaa of rainwater through the auxiliary building roof. The licensee inspected for leakage and concluded that earlier attempts to correct this problem through a MAR were unsuccessful. The licensee indicated that additional work will be performed to seal around the ventilation exhaust stack The team also noted that auxiliary building floor drain screens were very dirty. Bilge areas adjacent to the reactor building tendons between intermediate building and the seawater room were dirty and contained trash. A few items of trash were identified in the cable spreading room. The interior of the control room cabinets were found to be in good overall conditio __
Enclosure 2
          . - - _ ~ _  _-
 
____-______-_ _ _
 
During numerous plant tours in multiple areas the team observed that plant lighting was poor. In particular, the team noted that the
! secondary plant was dimly lit. On one occasion in the turbine building.
 
L two of the team members noted that five lights were either totally not- .
working or partially-lit. The team discussed with an operator-during rourids if. operators were notifying the Maintenance Department of the ,
lighting deficiencies. The operator stated that Maintenance had informed operators to not document the deficiencies because a preventive - !
maintenance program was in place to routinely replace faulty lights
  -
throughout the plant. The team cencluded that the licensee was not effective in ensuring plant-lighting deficiencies were corrected as '
neede The team noted that control of ladders in the plant appeared to be poo Some areas posted as ladder storage contained no ladders while-ladders were locked or stored in areas not marked as such. The licensee indicated that deficiencies were noted with th.' emergency operating procedure (E0P) equipment and ladders during tne E0P inspection and-corrective actions were i_n progress. By the end of the same day that the team asked about the ladders, although permanent installation arrangements had not yet been--finalized, E0P_ ladders and equipment boxes were prominently labeled and located in the plan The team noted that-in the areas where the restoration painting efforts had been completed such as the 119 foot elevation of the intermediate building. -overall housekeeping and material conditions were good. . Good
  -
conditions were also-noted in the- room containing the control center chillers and ventilation. system '
Throughout_ the observations of field activities, the team observed numerous inconsistencies in equipment labeling. " Magic marker" informal labels were rioted throughout the plant, including inside some safety system control cabinets in the auxiliary building. = Some gages were not=
labeled. The inspectors noted that the recently issued labels were a significent improvement over older tags which did not include functional descriptions. The licensee provided the team a summary and status of the' Plant labeling Upgrade Project. The project-summary indicated that-improvement such as bar codes and color coded borders for safety components are planned. The project has been divided into different phases and priorities with completion dates in excess of a year.


Sincerely, i  Original signed by Johns P. Jaudon Johns P. Jaudon Director Division of Reactor Safety Docket No. 50-302 License No. DPR-72 cc: John P. Cowan. Vice President Nuclear Production (NA2E)
Florida Power Corporation Crystal River Energy Complex 15760 West Power Line Street Crystal River. FL 34428-6708 C. G. Pardee.. Director Nuclear Plant Operations (NA2C)
Florida Power Corporation    0 Crystal River Energy Complex
,
,
Enclosure 2
15760 West Power Line Street
 
! Crystal River..FL 34428-6708 cc continued: See page 2 9903130201 980303
_ . _ _ _ _ _ ...  . . _ _ _ _ _ . . _ . _  . _ _ _ _ ___ _ _ _ _ _
}
 
PDR ADOCK 05000302 G  PDR  l lll ll llllllllllfll ll 270/
J
*


...
  ,
  ,
The team also noted that the control room urveillance log nomenclature
R
  'did not always match the control board labeling. Althouv (he equipment
 
numerical designations did match those in the control r o ogs, a
,
potential for error remaine .
; Conclusions Numerous examples of poor housekeeping were note Lighting was not
  . effectively maintained and some areas of the plant were not well lit.
 
'
Numerous inconsistencies and deficiencies were identified in equipment labeling. The licensee's labeling upgrade program should be continued.
 
.
03 Doerations Procedures and Documentation
.
.
03.1 Doerations Procedures and Documentation i Insoection Scoce (93802)
The team evaluated the availability and currency of normal.-abnormal.
 
and emergency operating procedures in the control room, including alarm response procedures. The process fcc procedure revisions and the 7  backlog of procedure comment status was reviewed. Operators were
'
.
interviewed to determine if the process encouraged identification and
  '
  '
correction of procedure deficiencies. The controls over operator Aids
E FPC. 2 cc: Continued-B. J. Hickle.' Director Nuclear Plant Operations.(NA2C)
      '
Florida Power Corporation
were also reviewed.
'.
 
Crystal River Energy Complex 15760 West Power Line Street Crystal River, FL 34428-6708 Robert E. Grazio. Director Nuclear Regulatory Affairs (SA2A)
, Observations and Findinas The licensee maintained all operating procedures on a computerized
Florida Power Corporation Crystal River Energy Complex 15760 West Power Line Street g Crystal River. FL 34428-6708 James S. Baumstark. Director Quality Programs (SA2C)
  - system known as " View / Print" which ensured controlled copies of procedures were : sed. Sufficient computer terminals were available to operators to access working copies of procedures as they were neede Controlled, hard copies were in the control room for certain procedures such as alarm response and emergency operating procedures. Other controlled hard copies were maintained, depending on the frequency the  ,
Florida Power. Corporation Crystal River Energy Complex 15760 West Power Line Street l Crystal River. FL 34428-6708 l R. Alexander Glenn Corporate Counsel
procedures were used: these procedures were for reference only. The team observed the operators were able to access procedures easily from-the computer system.
 
-
Enclosure 2
;
 
  . _ _ _ _ _ _ _ _ _ _ _ - .
      -_--
21  i The team found that the current copy of the emergency operating procedures (EOPS) in the control room were approved for use but not the procedures that the operators had been trained on over the past several training cycles. The E0Ps were going through an extensive rewrite:  .
therefore, the operators had been trained on draft procedures. The team discussed with operators if they thought having the older, approved procedures in the control room was a problem for accident mitigation and the answer was 'no." One of the SR0s stated that the changes that had been made did not have a significant impact on the plant during Mode 5.
 
The operators indicated that they considered the new procedures to be a notable improvement over the currently approved procedures. The primary feedback from the operators was that the new procedures flowed better.
 
The team discussed with both the procedures supervisor and operators how a controlled procedure user was made aware that the procedure in use was no longer the correct revision when a change was made to a procedure and a copy was already in use. Once procedures were requested for use as working copies. a specific number were issued. When the procedure changes. Document Control informed the associated department, and the user was to be immediately informed to determine '.f the new revision had any effect on the evolution in progress. The team questioned this practice because it might not place appropriate responsibility on the procedure user to ensure the procedure in use is the correct revision.
 
During a review with an SRO of completed shift turnover check lists, one of the inspectors identified that the wrong revision of Al-500. Conduct of Operations. had been used by the shift clerk. The licensee later determined that Document Control had properly notified Operations of the procedure change to AI-500. but appropriate action to notify the procedure user was not performed by Operations personnel. It was subsequently determined by the licensee that use of the wrong revision of Al-500 had no detrimental impact on the procedure use. -A precursor card was initiated to address this issue.
 
On December 12, 1997, the team observed control room operators responding to a loss of the plant computer. The loss was recognized quickly and the operators immediately began the actions required by Abnormal Procedure AP-470. Loss of Plant Compute After most of the as_ ions had been completed, the operators noted that the revision being used was not the latest. The procedure had been revised and issued the previous day. Another book of procedures in the control room contained Enclosure 2
    - _ _ . _-___
 
  . _ _ - - - - - - _ . .-. .. -
 
the latest revision, The operators went-through all steps of the procedure again and ensured that necessary actions were completed. A precursor card was issued to address the issu .
The comment status backlog was reviewed with the procedures supervisor.
 
'
The general trend indicated that the backlog was decreasing. As of December 7. 1997 there were 451 outstanding comments for procedures that
*
affected operators. The team noted that most of these comments were associated with surveillance and oMrating procedure changes that were needed as the result of recently completed modifications. The supervisor stated that the backlog was aggressively being pursued, but the operators continued to suggest procedure enhancements actively which has slowed progress of backlog reductio The team discussed with operators if the process for submitting procedure comments encouraged operator involvement. In general, the team found that operators were familiar with the process and were not hesitant to suggest changer. During these discussions the operators informed the team about the computer system used to document comment The system, known as Nuclear Procedure Observations / Suggestions Tracking (NUPOST), was demonstrated by the operators. The NUPOST system appeared to be an effective means for operators to suggest recommended procedure change On numerous occasions the team observed operators performing evolution These evolutions included operation of an emergency diesel generator both in the field and in the control room, testing activities, inverter alignment, and equipment alignment checklists The procedures were followed step by step with good communications between the operator In general, the team found that operator adherence to procedures was good. Other sections in this report also describe positive observations regarding procedural adherenc During discussions with cperators concerning decay heat removal. Loe team found that several operators did not know how long it would take to uncover the core and boil the core if decay heat removal was lost. The operators pointed out that time to uncover and time to boil curves were available in their operating procedure, but the curves did not address the current operating condition because the plant had been shutdown past the evaluated time. Later, a SRO trainee presented a calculation that had 'oen previously performed that showed the worst case time was 27 Enclo ure 2
 
_ _______ - _ _
 
l l hours:for_ time to boil. The team found that adequate procedural L
'
guidance _for the time to uncover / boil curves was not available. The team considered this as an-area for improvemen .
Operating Instruction 01-17. Operator Aidi, provides guidance fo' the control of operator aids. A list of acts /e operator aids was' included in the Control Center Notebook. The tean questioned what appeared to be i two operator aids which were_not on the list. One was associated-with the radiation monitoring console on a_ control room front panel. The other was on a bbck panel-in the control room Subsequently, the licensee reviewed the aids and determined that they were inaccurat The aids were removed, Conclusions The availability of computerized programs such as NUPOST and View / Print was considered a strength. Procedure adherence and usage was goo Several uncontrolled operator aids were identified. There was no
_ procedural guidance for. time to uncover / boil curves during extended shutdown conditions. Two deficiencies were noted associated with revisions of controlled procedure perator Knowledge and Performance Insoection Scone (938021 The team assessed operator knowledge of principle technical specification requirements. ProDabilistic Safety Assessment (PSA)
-results, and major plant system Observations and Findinas The inspectors observed an adequate level of technical specification-awareness. The TS were considered when appropriate. Low Ten.perature Overpressure Protection and safety system operability requirements were discussed. Although the SRO was responsible for the entering and exiting limiting condu. cs of operation, all licensed personnel were su Ficiently knowledgeable of the requirement Enclosure 2
      -_
 
__ _ _ - _ _ _
 
The team interviewed several operators regarding the probabilistic safety assessment (PSA) results. The team considered that operator awareness of PSA results was important for understanding the risks associated with removing equipment from service during power operatio .
Generally, the operators were not aware that the small break loss of coolant accident was the dominant accident type, Furthermore, the most important plant systems from a PSA perspective were not generally know The operators typically thought that the loss of offsite power was the most important accident and the emergency diesel generators were the most important plant components. The team noted that PSA posters were l
subsequently placed in the control room office and work control center areas to better inform operators of PSA results. The team concluded that the PSA posters were a positive initial action, but further training in this area was neede The team interviewed numerous operators at all watch stations to determine their overall knowledge of plant systems and activities. The team found that operators :.nderstood system operation, location of important equipment, and interaction of plant systems to ensure safe plant operations. . Operators were aware of major plant activities including the circumstances surrounding the loss of annunciators discussed in Section 01.1 emergency diesel generator testing and maintenance activities to repair seal leakage on the DH system Train A pum In particular, all those interviewed knew the backup method of providing diay heat removal if the operating DH train was lost, c. Conclusions Operator knowledge of significant PSA information needed to be improve Overall knowledge of Technical Specification requirements and system operations was goo Operations Organization and Administration a, Insoection Scooe (93802)
The team reviewed the Operations Department's use of overtime since January 1997. Administrative Instruction Al-100. Facility Administrative Policies, and records of authorizations to exceed overtime limitations were reviewe Enclosure 2 J
 
__ ._____________-__ _
    .
    . . . . .. .. . ..
25 Observations and Findinas The team found that the Operations Department had routinely scheduled significant overtime for both licensed and nonlicensed operator Since ,
about pay period number 17. the team found that the average number of overtime hours worked for each operator on-shift was about 30 hours or more per pay period or about 15 hours per work week. The team noted that ,
there were 5 cases in which Operations personnel were approved to exceed l l
'
the 72 hour limitation and 29 cases when the 24 hours in a 48 hour  l period limitation was approve The team discussed the use of overtime with the licensee who stated that the Operatiens Department was under staffed but actions had been taken to increase the staff size in 1998. The team was informed that several
,
,
more licensed operators would be available to provide shift manning l
Florida Power Corporation
'
'-
relief. During the inspection, including numerous observations during backshift hours the team did ot observe any indications of significant operatc* #atigu c, . Conclusions Operations personnel worked significant amounts of overtime during the last several months of the extended shutdown. The team did not observe any indications of significant fatigue on the part of the operator The licensee had decided to place personnel experienced in operations into other working groups and will need to continue efforts to obtain more licensed operators to decrease-the required working hour Quality Assurance in Operations 07.1 Doerations Self Assessments Insoection Scoce (93802)
'MAC - ASA P. O.' Box 14042 St. Petersburg. FL. 33733-4042 Attorney' General i. Department'of Legal Affairs
The team reviewed the Operations self assessment prc3 ram described in Administrative Instruction Al-501. Conduct of Nuclear Plant Operations Assessments. One of the inspectors discussed the program with an Operations supervisor extensively involved with the program. Late in the inspection period, the te6:.i reviewed selected completed self Enclosure 2
! The Capitol
,      -
. Tallahassee. FL 32304 Bill Passetti Office of Radiation Control De)artment of Health and.


-. . - - .  - . _ . -. --
Rehabilitative Services 1317 Winewood Boulevard Tallahassee. FL 32399-0700 Joe Myers. Director Div. of Eniergency-Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee..FL' 32399-2100 cc continued: See page 3


assessment forms and a recently completed Operations Readiness for Restart self assessment. The team also reviewed a recently completed self assessment modeled on the Operational Safety Team inspection procedur , Observations and Findinas The Al-5' self assessment fc ms were highly detailed and length For example, one watchstander proficiency assessment form was seven pages long and sked for ratings in about sixty specific observation area With the assistance of an Operations supervisor, one of the inspectors selected a sampling of completed assessment forms from over the last year. The forms were completed as required. with the majority of ratings assigned as a "three" (all expectations met at all times). The inspector noted that some of the assessments contained comments and indicated that the observer attempted to perform a quality assessment.
        -
 
-
Some of the forms contained critical comments and ratings of 1 (Immediate corrective actions needed), and 2 (Deficiencies noted). The assessments completed by peer level individuals were typically not as critical as those performed by supervisory personnel. The reports were reviewed by the Nuclear Shift Supervisor as required by 41-501. The inspector concluded that the highly detailed specific cature of the assessment forms invites a " checklist" approach to the assessment Most of the assessments did not contain discussion of perceived causes or underlying issue The inspector noted that Al-501 does not require periodic reviews of the completed assessments for trends r overall performance evaluatio Additionally, the involvement of e. Nuclear Shift Supervisors seems limited to reviewing completed assessments for their shifts. The inspector was informed that these characteristics had been identified in the Operations Organizational Readiness for Restart self assessment completed in September 1997. The inspector reviewed the report of that assessment and noted that these issues were discussed, The supervisor described corrective actions already in progress which indicated that the self assessment program was being significantly strengthened. Al-501 is being revised. The intention is that Operations management will periodically perform reviews which will incorporate results of completed assessments along with other performance indicators. Additionally.
 
~
Enclosure 2
 
l
 
" focus" areas wil1 ~be developed based on 1he performance trends. The
;1icensee-also plans to strengthen the rob of the iluclear Shift. Managers in the assessment progra .
The team noted that the Operations'0rganizational Readiness for Restart self assessment, completed in September 1997, was highly detailed and self critical. Many issues that the team noted as vulnerabilities or I deficiencies were addressed in that assessmen Operations management routinely monitored a series of performance indicators. The inspector was provided a copy of the indicators _ dated November 14. 1997. Operator / tagging errors per opportunity, number of Operations Precursor cards generated, self assessment results, and overtime hours were included in the indicators tracked. The inspector noted that the percentage of Operations deficiencies documented by Operations was about 65 percent for the most recent month in the repor The-inspector was informed by Operations supervision that this value is typically about 80 percent and was lower that particular month as the
      '
result of a series of quality assurance audits of Operations' The team
    .
noted that 80 percent indicates that, for the most part. Operations is
  -
identifying and-documenting its own problem Throughout the inspection, the-team noted that Operations promptly initiated precursor- cards to address identified deficiencies. The Operations department threshold for initiation of precursor cards seemed appropriate, ' Conclusions-
.The team concluded that the licensee had plans for strengthening of the current Operations self assessment progra OS -Miscellaneous Operations Issues-08.1 Chemistry Succort of Plant Ooerations Insoection Scoce (93802)
The team reviewed the control of chemistry sampling required by Technical Specifications (TS) and the Offsite Dose Calculation Manuai (00CM).
 
.
Enclosum 2
 
. .. ~ _ . . _ _ _ . __  _ _ . _ _ _ _ . ~ _ _ _ . _ _ . _ _ - _ .
t
:
          .
      - 28
          :.
-
  - Observations and Findinos
    '
,
0perations personnel were responsible for. identifying plant conditions-  .
that required sampling. : The identification of such conditions was aided  >
by appropriate steps in the applicable operating procedures and-annunciator response procedures-
$
  :Once notified by operations, chemistry personnel were held responsible
      .
for the sampling, analysis.-frequency and timeliness. Chemistry personnel used. STIs. shift turnover sheets and the. chemistry-laboratory's " white board" to_ track the required sampling. Although L, ,
these methods of sample coordination seemed infsrmal, they also appeared effective. No missed sampling requirements were identifie <
. Conclusions
          '
'
Chemistry sampling required by _ Technical Specifications and _the-Offsite
  ~0ose Calculation Manual was properly implemented.
 
-
  - 08.2 (Ocen) Insoection Followuo Item 50-302/97-14-01) review of-operational-
'
procedures prior to restart. This item was: identified as a result of inspection of the pending changes (NUPOST items)'to Procedures _0P-402
,
for the makeup and purification system and OP-404 for the decay-heat
_
removal syste The inspection determined:that these procedures had a number of pending changes, and the number of changes had recently risen
_
dramatically. As a result, the Inspector Followup Item was opened to
[  review the! status of_ pending: changes for all operations procedures prior F  _to restart of the unit. The team conducted a review'of current pending changes to OP-402 and OP-404.and noted the pending changes had-been
,
reduced to six and five, respectively, as opposed to twenty' two and fourteen.: respectively.- during the earlier initial inspection. The
 
inspection team also revieud the status of_ pending changes to all other
-
operations procedures pruided by the licensee. -The team determined
,
that most of the procedures had very few pending changes: however,
,
approximately fourteen of the procedures hao over ten NUPOST items, t  which indicated a fairly significant need to' revise those procedure From this review the team concluded that the licensee had made some progress toward correcting the backlog of pending NUPOST changes to
'
Enclosure 2 i.
 
9
.._.-________4  . . . _ , . __  . , . , . , ,  _ . .
 
  . _ _ _ _ _ - - _ _ - _ _ _ _ _ _ _
29  I operations procedures but,some weakness still existed in *.his are This item will require additional followup prior to restart and will
      -
  ' remain ope '
II. MAINTENANCE-This inspection included an assessment of the current status of the licensee programs for Maintenance and Surveillanc M1 Conduct of Maintenance l
r M1.1 Maintenance Observations
- Insoection Stone (93802)
'
The team reviewed maintenance program procedures. observed maintenance in process and examined records of completed maintenance to evaluate the effectiveness of.the licensee *s. maintenance program, Observation and Findinas      -
  - Review of Procedures The team reviewed the following procedures and other licensee-
  -
'
documents during .the observation of maintenance in process and review of maintenance records:
  '
  .
AI-400C Revision 22. New Procedures and Procedure Change Process
  .
Al-500. Revision 96. Conduct of Operations. Operations Department Organization and Administrative
  -
Al-600. Revision 57. Conduct of Nuclear Plant Maintenance
  .
AI-605. Revision 6. Preventive Maintenance Program
  .
Al-607. Revision-2. Pre-Job and Post-Job Briefings
  -
CP-113A. Revision 22. Work Request Initiation and Work Package Control Enclosure 2
'II --
-
  .
  .
  - . . . . .. .
      . ...
      .
_ _ _
_
_ _
_
  - _ _ _ - _ _ _ _ _
    . .. .
      .
      '
  .
  .
  -CP-113B.- Revision 23, Work Request Evaluation / Planning
  ..
      )
FPC    3 cc: Continued Chairman Board of County Commissioners Citrus County 110 N. Apopka Avenue Inverness, FL 34450-4245 Robert B. Borsum Framatome Technologies 1700 Rockville Pike. Suite 525 Rockville. MD 20852-1631 Distribution:
.
L. Raghavan. NRR R. Schin. RII P. Steiner RII B. Crowley RII F. Wright. RII L. Stratton, RII PUBLIC NRC Resident Inspector U.S. Nuclear Regulatory Comm.     !
CP-113C, Revision 5 Inspection Planning-
6745 N. Tallahassee Road Crystal River FL 34428
!      !
        !
      '
i i
-
i OFFICE RII:DR5 *RII:DR5 j RII:DNP 5'"" "
CP-1130. Revision 0. Post Maintenance Testing
h ID rT Y&L - &
-
WNEL F. 15tIGNT C. ML p KLaRulis
CP-116A, Revision 5. Foreign-Material Exclusion (FME)
'
Control program
DATE ffg fin 2/ Ch g yg /95 Z/ /95 Z/ /95 Z/ /95 Z/ /95 wnr - (YEg ND YES /ND) YE5 No YES ND YE5 ND YE5 ND YE5 ND
.
  "
CP-143. Revision 2 Repeat Maintenance Program u Identification, Evaluation, and Tracking
of fICIAL RL ' SED (XIPY DOCLNENT NAfEt G:\ crystal \let ters\cr97 .'*i.ack
!
i .
CP-146, Revision 2 Measuring and Test Equipment Calibration-and Control
-. Nuclear Maintenance _ Manual Revision'13,
.
Crystal River Maintenance Improvement Plan, dated October 27,-1997
.
Task-Performance Manual - Nuclear Electrician, Revision 8
-
Task Performance Manual - Nuclear Mechanic, Revision 13
.
Task Performance Manual - Nuclear Technical Support Technician. Revision:10
.-
: Current TPM Performance Matrix- for the Maintenance Shops In general, the procedures _provided adequate detai~ N the control of maintenance. Although Procedure AI-500 covered the operation of_the Work Control Center for Operations review and approval of maintenance activities, the concept of having work control outside the control room was relatively new, and _the Center--was-not fully staffed (see Sections 01.1-and 01.4). 'The licensee planned to staff the Work-Control center fully as sufficient new Senior Reactor Operators (SR0s) are certifie Enclosure 2 m
 
. . _ . . . _ . _ _ _ _ . _ _ _ _ . . _ _ . _ _ _ _ _ . _ _ _ _ _
d
        >
' :-- Observation of In-orocess Maintenance Selected portions of the following in-process maintenance activities were observed to verify the maintenance was planne . .-
>
controlled, and performed in a manner to. enhance safe operation of the plant:
 
  -. Work Request (WR)'NU 0350053. EqLipment -Tag DHP-1A, Decay-
.
  -Heat Pump 1A - Repair Leaking Mechanical Seal, Replace
,
Rotating Assembly with Spare Unit i
  .- WR NU 0348477, Equipment Tag AH-359A-DPS, Air to EGDG-1A  >
Room Fan AHF-22A Switch - Replace and Calibrate Switches
  .
WR NU 0343807. Equipment Tag EFGV-1. Emergency Feedwater
-
Turbine Driven Pump Governor Valve - Perform PM on EFGV-1
,  Governor Valve
  .
WR NU 0345426. Fire Protection Sprinkler System Piping -
  . Replace Leaking Piping
        .
  . WR NU'0350C90. Equipment Tag DF-2-LS. Emergency Diesel
~
Generator EGDG-1A. Day Tank'3A Level Switch --Determine cause-for DF-2-LS Switch Failure to Control' Level-i     .
  . WR NU 0350405. Equipment Tag EGDG-1A, Emergency Diesel i-  Generator  Perform Engine inspections on EGDG-1A After MAR Functional Testin WR NU 0350608.. Equipment Tag, 'BXS-3C.? Static Switch for i:   Inverter VBIT-1C Auto-Transfer - Troubleshoot / Repair VBXS-3C
-
Problems
  . WR NU 0350651. Equipment Tag SP-23-LSI. EFIC RCSG-1B Overfill Trip Bistable.-Cabinet C - Troubleshoot and Repair p  EFIC Channel C Overfill Circuit
*
  * WR NU 0348706. Equipment Tag NI-5-A13. Uncompensated Ion-
. Chamber Assembly. Perform Performance Test PT-180
:
 
I      Enclosure 2
:
  ,
4. x -
 
  -,  . , - - ,  . -- . c .
 
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ -
-
l L
 
.-
WR NU 03E4760. EGDG 1A Air: Compressor'- Investigate and Repair. Diaphragm'in Unloader.has Ruptured The team reviewed the-following completed WK pCCkages to assess  ,
.the adequacy of documentation of completed work:
-.
WR NU 0341867 Equipment Tag-SWV .200 - Replace Valve Packing-
-
WR NU 0347857 F.quipment Tag EFV-13 --Install / Tighten loos or Missing Fasteners Found on Valve During Testing
.
WR NU 0349491. Equipment Tag.EF-400-JNO - Resolder Lug for-Power SLpply
.
WR NU 0349435. Equipment Tag MTMC-22-1EG. MCC Feed for MUV-58 - Adjust .Swi_tch Linkage to Prevent Breaker from Tripping
-
WR NU 0349426. Equipment Tag MTSW 3G-1B-52. 480V ES Bus 3A Main Feed Breaker-3310 - Troubleshoot the Cause of the Green 4 Light not-Operating Properly
-
WR NU 0347624 Equipment Tag ESCC-3A AT. ES Actuation "A" Channel Cabinet Fan BM-03A - Troubleshoot Reason for' Fan Blowing Fuse
.-  WR NU 0338613. Equipment- Tag BSP-1A . Reactor Building Spray Pump 1A --Remove and Reinstall (after vendor work) Pump-Impeller
.
WR NU 0349421. Equipment Tag RWP-3B DH Service Seawater Pump 3B - Coat Inside of. Pump-Discharge with Belzona
-
WR NU_0349867. Equipment Tag RP A29. RCPM Contact Monitor -
Determine Problem with Optical Isolator for #3 Light on RP-A29(Al-3-4)
-
WR NU 0349933. Equipment Tag ARV-51. CDHE-4B (West) Vacuum Breaker - Troubleshoot ARV-51 Not Stroking From the MCB Enclosure 2
    . .
WR NU 0349985. Equipment Tag RC-1-IB1-1. Pressurizer Level from XMTR 1 NNI Input - Replace the Existing Module with a New Module
.
WR NU 0350074. Equipment Tag RV-14A-EB1, Reactor Coolant
      '
Flow (Temp Uncomp) - Calibrate / Repair RC-14A-EB1
.
NU 0349871. Equipment Tag EFIC-A. Emergency Feedwater Initiation & Control Cabinet A Determine Problem with EFIC
"A" Based on Event Point 2012 Alarm During the above in-process observations of maintenance activities and reviews of completed WRs. the team evaluated the following maintenance program attributes:
.
use of current written and approved instructions detailed enough to perform the intended maintenance and adequately document the maintenance performed.
 
.
appropriate prioritization and timely disposition of maintenance jobs that could affect technical specification limiting conditions for operation of safetv related equipment performance or influence safe operation of the plant.
 
.
appropriate coordination of maintenance activities with control room operations, including appropriate briefings and turnovers with control room operators and appropriate equipment isolation and tagging.
 
.
appropriate training and qualification, including documentation, of craftsmen for level of work being performed.
 
.
control of preventive and corrective maintenance backlogs, including controls of deferrals and efforts to integrate preventive and corrective maintenance to minimized unavailability.
 
.
performance in conducting PM activities on schedule and contr(1 over deferred preventive maintenanc Enclosure 2 I
J1
 
__ _ - _ _ _ .
 
.
trending ')f corrective maintenance history to deal with high maintenance components, including identification and trending repetitive maintenanc appropriate level of engineering input into maintenance
    '
.
activities.
 
.
conduct of OC inspections during the performance of maintenanc including the adequacy and appropriateness of OC hold points.
 
.
performnce of appropriate PMT. including engineering involvement in specifying PMT.
 
.
control of M&TE. including calibrations at required frequencies, tracking equipment, evaluation of past work where M&TE is found out of calibration. control of contaminated M&TE.
 
.
controls for the team for performing immediate or minor maintenance, and
-
appropriate foreign material exclusion practices.
 
For the in-process activities observed and the records reviewed, the team found that maintenance was being performed in accordance with procedures in a quality manner by trained and qualified craftsmen. A_
strong maintenance supervision presence and involvement was evident and all maintenance personnel had a positive attitude about performing maintenance correctly. The team found the training and certification program for maintenance personnel to be comprehensive with detailed multiple task performance training requirements specified for each discipline. The team considered training to be a strength. Activities relative to FME controls. OC hold points, pre-job briefings interface with operations and engineering, post maintenace testing, and control of M&TE were performed in accordance with program requirements and were found to be satisfactory.
 
During review of completed WRs. the team found that, for
" troubleshooting" work in accordance with Procedure MP-531. PMT requirements were not added to the WR until after the corrective actions had been determined. There was a possibility that the added PMT requirements would not receive Operations review and approval as Enclosure 2
 
required by Procedure CP-1130. The team considered this to be a weakness. The licensee immediately issued Precursor Card (PC) 3-C97-8456 to evaluate this weakness and take corrective action During review of WR NU 0349421, which covered coating the discharge
      '
nozzle of the 3B DH Service Water Seawater Pump with bel. ZONA because of
,
co,'rosion, the team noted that the WR package did nnt provide any documentation to show that the nozzle minimum wall thickness was still acceptable. After investigatino, the licensee found that the depth of the corrosion had been measured ar.o the minimum wall thickness verified by ultrasonic inspection. The documentation for these measurements was
,
,
'
in OC inspection records but was not included or referenced in the work packag PC C-397-8357 was issued to evaluate this problem. The inspection records were added to the work package.
!
During the day shift pre-job briefing for WR NU 0350053 (change out of the DH-1A Pump Rotating Assembly), the team noted that Operations was not represented in the briefing. Procedure AI-607 required that Operations be involved in pre-job briefings if the activity could render Emergency Core Cooling System (ECCS) equipment inoperabl This appeared to be an isolated case, since Operations was represented for all other briefings observed where their presence was required, t
including the night shift for the DH Pump 1A work. PC 3-C97-8370 was issued immediately to evaluate this proble The team noted a strong emphasis on control of maintenance backlog The corrective maintenance backlog had been reduced from 433 in August 1997 to 171 at the time of the inspection. The number of overdue (more than 25% past due date) PMs had been reduced from approximately 90 in August 1997 to approximately 10 at the time of the inspection. At the time of the inspection, overdue PMs required completion of extension requests and approval with detailed justification. In addition, overdue PMs were high-lighted for management attention in the " Plan of the Day" on Thursdays, and the total number of overdue PMs was tracked for management review in the Weekly Performance Indicators. For schedulin PMs were included in the new Work Week management Process which implemented a rolling 12-week master schedule, planned to be implemented the first week of January 1998. This process should help assure that PMs are performed on schedule. The team considered the control of maintenance backlogs to be a strength.
<
Enclosure 2 l
_ . . . . - _
36  :
The team found that evaluation of the effectiveness of the PM program-was not a proceduralized process. Although, on a periodic basis, the PM-Coordinator reviews all new corrective maintenance.WRs for impact on the PM program, this was not proceduralized. In addition, it was only accomplished for equipment tags that had established PMs. Also, there *
. was no: evaluation _for repeat maintenance to determine if the PM program
' needed to be changed because of repeated equipment failures. The-team-
      -
considered the lack of a formal evaluation of the effectiveness of the -
PM program -including evaluation of t_he effect of repeated maintenance
  -
on the program, to be a weakness. The licensee issued PC 3 C97-8560 to evaluate this weaknes Relative to repetitive maintenance, the team found that corrective maintenance WRs were being reviewed to determine if equipment _ problems
- were repetitive and the information was being documented and tracked in the equipment history. However, the data were not being used to monitor D and improve maintenance. The team considered this to be a weaknes The licensee pointed out._that a previously issued PC-(3-97-6927) had identified problems with.the repeated maintenance program and that the corrective actions for-this PC would-address the weakness identified by the team. Corrective actions for the PC were not scheduled to be completed until' January _15, 199 The team no'ted that the Minor Maintenance Program was well defined with detailed limitations on-what can be worked under minor maintenance rules. However, the responsibilities of the quick response maintenance -
team-(Gator Team at Crystal' River), the organization responsible for minor maintenance were not formally-proceduralized. The team-considered this-to be a weakness, Further discussions with-maintenance management'. revealed that their Maintenance Improvement Plan, dated October 27, 1997, had identified actions to evaluate and _ define the responsibilities for the Gator Team, Conclusions Overall the Maintenance Frogram was adequate-to support restart of the unit. Maintenance was being performed in accordance with procedures in a quality manner by trained and qualified craftsmen. In general, maintenance procedures provided adequate detail for the control of maintenance. The strong maintenance supervision presence and involvement at the job site was considered a strength. Maintenance Enclosure 2
_
      .. J
  . _ _ - - _ _ - _ _ - _ _ _
    .. .
      -
    '37 personnel had a positive attitude about performing and documenting maintenance correctly.-and procedure use was good.- The maintenance training and certification program, which was comprehensive with detailed multiple task performance training requirements specified for each. discipline, was considered a strength. Corrective and preventive t      '
maintenance backlogs w' .'e hv. and the strong emphasis on control of-maintenance backlogs wo , 4sidered a strength. Activities relative to-FME controls. QC hold points, pre-job briefings, interface with
: operations and engineering post maintenance' testing, and control of
_ _M&TE were performed in accordance with program requirements and were found to be satisfactor The following programatic weaknesses were 1&ntified:
There was a possibility that. for "troublehooting" WRs. the added PMT  ;
requirements would not receive Operations review and approval as required by procedur '
      ;
      ,
.The process for evaluation of the effectiveness of the. PM program, including evaluation of the effect of repeated maintenance-on the program, was not formalize Repetitive maintenance was being documented 'and tracked but was not E .being used.to monitor and improve maintenance of equipmen The responsibilities for tne " Gator Team" (quick response maintenance-team) were not proceduralize .M1.2 Maintenance Rule Imolementation Insoection Scone (62706)
This portion of the inspection was conducted to review the licensee's Maintenance Rule program. The inspection was not intended to establish a baseline for the program but rather was conducted to determine if the licensee's program was adequate to support the restart of Unit 3. The Maintenance Rule Baseline Inspection at Crystal River is currently scheduled for the first half for June 199 Enclosure 2
______
._ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
During this inspection effort. the Team examined the following licensee -
procedures and document .
CP-153A. Revision 0 Maintenance Rule Implementation
        .
.
CP-1538.- Revision 1 Monitoring the Performance of Systems Structures and Components Under the Maintenance Rule
-.
AI-255. Revision 6 On-line System Outage Preparation and Implementation l
.
PM-156. Revision 0 Visual Inspection of Plant Structures -
.
Report R020-97-002. Revision 0 Maintenance Rule Structural l  Baseline Inspections _ Observations and Findinas The inspection in'cluded a review of the following Maintenance Rule areas: Scoping.. goal setting and monitoring, performance criteri Maintenance Rule structural inspections, expert panel activitie Probabilistic Risk Assessment (PRA) basis for the Rule, balancing reliability and unavailability, periodic assessment, risk assessment for on-line removal of-equipment from service, and self assessments of Rule
  -
implementation. The review of these areas was cnnducted as follows:
The team requested the licensee to provide a listing of all structures, systems. 'and' components not included in the Rule. This listing was reviewed to determine _if- there were any obvious omissions. The tea reviewed the' goals and monitoring established when the control room air-handling system was put into-(a)(1) as a result of repetitive maintenance preventable functional-failures. The team also reviewed the-expert panels approval for return of this system to (a)(2) status. A __
_j sample of performance criteria for both risk and not risk significant systems under the Rule was reviewed. The team reviewed the program procedure; the structural-inspection checklist examples of _ inspection deficiencies identified, and the finai Maintenance Rule Structural Inspection Report. Meeting minutes from expert panel meetings held October 24 1997 and November 25. 1997 were also reviewe PRA dCtiVities associated With implementation of the Rule were reviewed to determine if an adequate technical basis for Rule implementation b;d been established. This review included risk ranking, and the P'A basis Enclosure 2
      .. . . . . .. ..
        . __ _ _u
_ _ _ _
for establishment of performance criteria. The licensee had not accomplished a periodic assessment or any balancing of reliability and unavailability, so the licensee's ;. ocedure was reviewed for compliance with NUMARC guidance in these area The team reviewed the licensee's on-line risk _ monitor which-is to be used by the licensee to assess risk
      ,
when removing equipment from service during on-line operations. The team also reviewed the Sargent and Lundy Assessment of the FPC Maintenance Rule dated March 18, 1997, and the Nuclear Quality Assessment's Audit 97-09 dated October 30, 1997, as well as, the status- ,
    '
of corrective actions for these assessment i'
'
The team did not identify any problems with regard to scoping of l structures, systems, and components under the Rule. The goals and monitoring for the control room air handling system were adequate, and ?
the expert panel decision to place the system in (a)(2) status following completion of monitoring was appropriate. The performance criteria reviewed were in accordance with NUMARC guidelines, and there appeared to be an adequate basis for these criteria in PR The licensee's self assessments of implementation of the Rule were comprehensive; howeve corrective actionsifor several of the findings were not complete The licensee had developed and implemented an on-line risk monitor as a tool for assessing risk when removing equipment from service during power operations. The team considered this a strength. The inspections of'
-structures under the Rule were comprehensive and documentation of-deficiencies was excellent. The team did note that the licensee had not evaluated the deficiencies to determine if any structures needed to be placed under (a)(1) of the Rule with goals and monitoring establishe This was considered a weakness. The licensee-reviewed the structural deficiencies during the inspection and determined that no structures needed to be classified as (a)(1). Conclusions The Maintenance Rule Program was adequate to support restart of the Unit. As a result of the self assessment process, the licensee had initiated several program enhancements, which were ongoing during the
  -
inspection Efforts on these enhancements needs to continue. Two strengths and one weakness were observed:
Enclosure 2
Strengths:
.
The licensee had developed and implemented an on-line risk monitor as a tool for assessing risk, when removing equipment from service during power operation '
.
Inspection of structures under the Rule were comprehensive, and documentation of inspection deficiencies including the location and ntent of condition was excellen Weakness:
.
Lneficiencies identified by the structural inspections had not been evaluated to determine if any structures should have been classified as (a)(1) under the Rule with goals and monitoring establishe This weakness was corrected during the inspectio No structures were classified as (a)(1).
l M1.3 Surveillances Insoection Scoce (93802)
The team reviewed surveillance scheduling procedures and computer schedule output, reviewed surveillance performance procedures. observed surveillances in process, examined records of completed surveillances, and interviewed involved plant personnel to evaluate the effectiveness of the licensee's surveillance program. The inspec'.:on concentrated on the surveillances required by the Improved Technical Specifications (ITS) but also included several examples of surveill . ices not required by the IT Observation and Findinas b.1 St,rveillance Schedulina Process The team reviewed the following scheduling-related procedures and interviewed surveillance scheduling personnel to determine the scheduling process:
* SP-443. Rev. 109 Master Surveillance Plan
* SP-440. Rev. 69 Unit Startup Surveillance Plan Enclosure 2
  ,,  ..
      .. - .. _ _ _ -
e SP-441. Rev. 43 Unit Shutdown Surveillance Plan e SP-442. Rev. 69 Special Conditions Surveillance Plan
* CH-400. Rev. 10 Nuclear Chemistry Master Scheduling Program The licensee's actions to assure proper scheduling of surveillances involved both manual and computer actions. The SCATS computer program specified the schedules and performance procedures for surveillances required at specific time intervals (e.g., 92 days) on a calendar basis, with SP-443 as a backup reference. Procedures SP-440 through -442 provided the schedules and the procedures for surveillances required to be performed when shutting down, for startup, or in response to specific plant conditions. Procedure CH-400 specified the schedule for routine chemistry surveillances. The history of performance of each surveillance procedure was maintained in the SCATS databas Surveillance schedulers reviewed completed surveillance procedures upon receipt and updated the SCATS history. Periodically, the surveillance schedulers obtained output listings from SCATS identifying dates
, specified for upcoming surveillances. These dates were manually input to the licensee work schedule. The work schedule was also manually updated to include surveillances required by SP-440 through -442 in response applicable plant conditions. Tolerances on the performance dates for surveillances were determined based on the ITS limits and the dates of last performance given in SCAT The inspectors were informed that a new computer program for scheduling surveillances would be instituted about February 1998. This program would reportedly require fewer manual entries and less monitoring by scheduling personnel than the current program. Both programs would be maintained in parallel initially, until confidence was obtained that the new program operated satisfactoril b.2 Procedures for Imoroved Technical Soecification Surveillances The team conducted a review to verify that procedures had been prepared for performing the surveillance requirements specified in the ITS. A sample of 17 surveillance requirements was selected by the team, the performance procedures were identified by licensee personnel, and the team then verified that the procedures contained the appropriate surveillance requirements and acceptance criteria. In addition. the team verified that the correct surveillance frequency was specified in the procedure dictating the schedule for each surveillance, in some Enclosure 2 I
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - -
instances the same surveillance requirement was contained in more than one procedure (e.g.. to cover A and B : rains). In most cases the team only reviewed the requirement in one o' the procedures. The surveillance requirements (SRs) selected and implementing procedures ,
reviewed were as follows:
SR    Procedure I 3.1. SP-333. " Control Rod Exercises". Rev. 26 3.1. SP-424 ' Physics Testing Hourly Surveillance Log". Rev. 7 3.2. SP-300. " Operating Daily Surveillance Log". Rev. 139 3.3. SP-112. ' Calibration of tte Reactor Protection System",
Rev. 57 3.3. SP-907A. " Monthly Functional Test of 4160V ES Bus A Undervoltage and Degraded Grid Relaying ' Rev. 19 3.4.1 SP-370. 'Ouarterly Cycling of Valves". Rev. 69 3.5. SP-300. " Operating Daily Surveillance Log'. Rev. 139 3.5. SP-347. "ECCS and Boration Flow Paths". Rev. 45 3.5. SP-347. "ECCS and Boration Flow Paths'. Rev 45 3.5.2.7- SP-175. Containment Sump Level and Flood Mnnitoring System Calibration". Rev. 26 3.8. SP-137, " Engineered Safeguards Actuation System Time Delay Relay Calibration'. Rev. 12 3.8. SP-3548. " Monthly Functional Test of Emergency Diesel Generctor EDGB-1B". Rev. 45 3.8. SP-522. " Station Batteries Inspection and Battery Charger Load Test". Rev. 19 3.8. SP-523. ' Station Batteries Service Test'. Rev. 30 3.9. SP-335C. " Radiation Monitoring Instrumentation Functional Test'. Rev. 18 5.6.2.11a CH-400. " Nuclear Chemistry Master Scheduling Program".
Rev. 10: and CH-450 " Secondary Water _ Chemistry Startup and Shutdown Guidance." Rev. 16 5.6.2.14c SP-746A. ~ Diesel Fuel Oil Testing Surveillance Program:
Emergency Diesel Generator fuel Storage Tank DFT-1A" Rev. 0 While selecting surveillance requirements from the ITS. the team questioned that the ITS contained no " Low Pressure Overpressure Protection" (LTOP) requirements. In response, the licensee provided a copy of a letter to the NRC dated October 23. 1997, which submitted Technical Specification Change Request Notice 213. Rev.1. to add LTOP Enclosure 2
__
- _ _ _ _ - - ___ _ _ - - _____ _______
requirements. In addition, the licensee-provided another letter to the NRC dated November 21, 1997. which described commitments for LTOP that would be implemented until the ITS change was approved. The team was-shown a draft surveillance procedure being prepared to implement LTOP surveillance requirement '
b.3 Records of Imoroved Technical Soecification Surveillances The team selected a sample of ITS surveillance requirements and reviewed l:  the last completed procedure records. These records were reviewed to l  - verify that the surveillances were current (based on plant condition and-l~  required frequency) and that they had been satisfactorily performed and l  documented. The requirements and procedures, including performance dates were as follows:
SR    Procedure 3.5.2.7_  SP-175. " Containment Sump Level and Flood Monitoring System-
. Calibration". Rev.- 25 W4 month frequency) - last performed 4/24/96 -
'
  -3.8. SP-137. " Engine.ered Safeguards Actuation System Time Delay
        -
Relay Calibration". Rev.12 (24 month frequency for modes 1-4) - last_ performed 10/21/97 3.8. SP-301. " Shutdown Daily Surveillance Log".. Rev. 103 (monthly - 4 frequency) --last performed 12/6/97 3.8.4 5  SP-522. " Station Batteries Inspection and Battery Charger Load Test". Rev. 19 (18 month frequency for modes 1-4)--last-performed 10/7/97 (for "A" battery)  _ _
        '
3.8.4.'7_  SP-523. " Station Batteries LService Test". Rev. 30 (24 month frequency for modes 1-4)'- last performed 8/18/97 3.9. SP-335C. " Radiation Monitoring Instrumentation Functional Test". Kev. 15 (24 month frequency) - last performed 2/20/96 5.6.2.11a  CH-450. " Secondary Water Chemistry Startup and Shutdown Guidance." Rev. 16: and Short-Term Instruction 97-067 -
currently being performed at frequencies specified in the
_
Short-Term Instruction 5.6.2.14c  SP-746A. " Diesel Fuel Oil Testing Surveillance Program:
Emergency Diesel Generator Fuel Storage Tank DFT-1A". Rev. 0 (quarterly frequency - last performed 11/12/97 Enclosure 2
5.6.2.14c SP-7461 " Diesel Fuel Oil Testing Surveillance Program: New ,
Diesel Fuel-Receipt, Rev. 0 (performed on receipt) - last
_
performed 9/30/97 The team also selected a sample of surveillance procedures which the '!
SCATS program indicated would require performance within the next two months and verified that the dates scheduled were consistent with the specified frequency and last performance for each entered in SCATS. The-sample was as follows: SP-108, SP-110, SP-150, SP-157. SP-187. SP-29 SP-320, SP-335C. SP-340, SP 349, SP-408. SP-421, SP-521, and SP-672, b.4 Observation of Surveillances The team observed all or portions of the performance of the following surveillance procedures and verified that required approvals were
- obtained, personnel-were properly qualified, currently approved procedures and calibrated equipment were used, procedures were adequate to satisfy the surveillance requirements, test discrepancies were properly resolved.-and that the surveillances were performed satisfactorily within the specified frequencies:
(' * SP-169F, Rev.- 4: observed calibration of decay heat closed cycle cooling water surge tank 3A level instrumentation (ITS 3.7-8) .
* -SP-340A, Rev. 37:- observed beginning of raw water pump 3A test-(ITS.S 6.2.9)
e SP-907A. Rev. 19: oMerved first level undervoltage relay test (ITS 3.3.8)
e SP 502. Rev. 18: observed all fire pump diesel batterie'. weekly checks (Fire Protection Plan table 6.2b.8a)
* SP-520. Rev. 21: _ observed all weekly checks on A and B batteries (ITS 3.8.4.1, 3.8.5.1 and 3.8.6.1)
e PT-542, observed _ weekly _ checks performed on batteries up to entry of electrical cabinet, the surveillance was delayed at that point due to unavailability of safety gloves (Non-1E batteries, no ITS cr other nuclear. safety requirement applicable)
During their observations, the team noted that pre-job briefings for the surveillances were thorough and well-presented. They also observed that procedures were adhered to stringently, except in one instance. In that case (SP-907A) the responsible individual inadvertently skipped a pag After quickly completing two steps on the wrong page. he recognized his Enclosure 2
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i    45
;  error.- appropriately stopped the test and informed supenision, p  Operations was notified of the error as soon as it was recognized. Upon j-  completion of a review of the error, appropriate test' conditions were re-established and the test was satisfactorily completed. The error did '
,  -not adversely affect equipment or personneh (b,5 Review of Records for Non-Technical Soecification Surveillances The team selected and reviewed the related records for the last
    ~
j-  performances of two non-technical specification surveillances and d
  : verified that they were appropriately completed and_ documented. The surveillances and the team's findings are described below:
  -(1) Reactor Vessel Material Surveillances
'
-
These surveillances were required by 10 CFR 50. Appendix H, and involved
'
tests on irradiated coupons to monitor changes in the fracture toughness j_  of reactor vessel materials. Report BAW-2049. " Analysis..of Capsule CR3-
]  F' dated September 1988. documented the results of the final tct for
:  Crystal River. The team verified that the licensevs February 25, 1993,
[  letter to the NRC: documented submittal of this report, Surveillance
,  coupons for othor.' licensees continued to be irradiated in the Crystal l"  River reactor, based on a program developed by the industry and_ approved by the NRC. NRC approval of the current program (including schedule)
i  was provided in a letter from the NRC to the Babcock and Wilcox (B&W)
,  Owners Group dated-July 11, 1997 1The program showed that all tests
:  were complete for. Crystal Rive _
l  (2): Examinations of Hich Pressure Iniection Thermal Sleeves and Pinina i  The-industry identified cracking in the high pressure injection thermal E  sleeves and piping at Crystal River and other B&W nuclear plants in-1982. This cracking was documented in NRC Information Notice-82-09.
E  Generic Letter 85-20 specified use of industry-developed examinations-and repairs to address the cracking. The. examinations consisted of l-  ; periodic radi_ographic tests (RT) to determine if thermal sleeves'were loosening (considered a precursor to cracking) and ultrasonic tests (UT)
. to detect cracks. In 1997,-additional examples of this cracking occurred at the Oconee nuclear plant' and resulted in an unisolable
reactor coolant leak. This was documented in Information Notice 97-46.
;  Oconee had performed the examinations approved by Generic Letter 85-20 i      Enclosure 2 i
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      .
but, due to inadequate examination criteria, failed to detect prior evidence of potential cracking until the leak occurred. Both Oconee's RT and UT criteria had been inadequat '
In the current inspection, the team reviewed the records (UT reports and RT film) of the last examinations performed to detect cracking in high pressure injection piping and thermal sleeves at Crystal River. These examinations were performed and documented during the current outage through Work Requests 346054, 346056, 346424. and 346426. Based on their review of the records and discussions with the enminers, the team found that the examiners were thoroughly aware of the recent industry experience at Oconee and had performed appropriate examinations to assure the condition did not exist at Crystal River. However, the team identified a weakness in the licensee's written examination criteria l which could impact future examinations. Specifically, the criteria for l identification of gap associated with sleeve loosening were unclear.
'-
The licensee initiated a precursor card (PC 3-C97-8482) to address the weakness, Conclusions The licensee's surveillance program was acceptable for plant operatio Surveillances were satisfactorily scheduled, proceduralized, performed and documente IV. Plant Succort R1 Radiological Protection and Chemistry Controls The inspection included reviews of records and procedures, interviews
- with licensee personnel and observations of work activities in progres The inspectors made observations in the Reactor Building. Auxiliary Building and yard areas within the Radiation Control Area (RCA).
R1.1 Personnel Contamination Controls. Occucational Radiation Exoosure and Occuoational Safety Team Insoection Insoection Scoce (83750. 93802)
The purpose of this inspection effort was to verify that Radiation Protection (RP) activities for work in contaminated areas met applicable regulatory and licensee requirement Enclosure 2
,
l
__ ._ _ _ _ _ _ ._ _ . _ _ . _ _ . _ _ _ _ . _ _ _ . . _ . _ . __
l
l
47 i
Contamination control procedures, contamination monitoring  i instrumantation, and personnel contamination documer.tation were reviewed during the-inspection, Observations and Findinos    *
l Personnel Contamination Events (PCEs)
The inspector,, reviewed the numbers of PCEs documented at the site in re';nt years for trends. The licensee reported the following informat' ion concerning numbers of PCEs generated. lothing contaminations were included in the annual totais.
)  Personnel Contamiaation Events Year Number 1992 232
1993 116 1994 218
^
1995 21
    -
1996 340 The number of PCEs generally increased in years having a Re Fueling l
Outage.(RF0) as seen in years 1992, 1994, and 1996. The licensee did not have any outages in 1995 and the number of PCEs documented were much lower that year. The number of PCEs increaseo significantly in 1996 and the licensee attributed the increased number of PCEs to increased contamination levels found in the 1996 refueling and the extended maintenance outag The licensee had recently conucted a survey of other nuclear power facilities to determine typical contamination level' thresholds for documenting PCEs. l.icensee personnel reported the typical threshold-found in their survey was greater than 500 counts per minute (cpm)/ area under probe (aup). Following the survey the licensee revised Health Physics Procedure (HPP)-104. Personnel Monitoring and Decontaminatio Revision 13. dated June 2. 1997, to require documentation of PCEs when '
contamination levels were greater than 500 cpm /aup. Prior to the change the licensee had documented PCEs whene e contamination levels were Enclosure 2
_ _ _ _ - - _  _ _ _ _ . _ . _ _ _ .. _ _ _ _ ___ _ _ ._- __
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; greater than 100 cpm /aup. The inspectors found the procedure change decreased the number of PCE's generated without improving RP program performance.
,
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While reviewing Revision 13 of HPP 104, the inspectors found the procedure had conflicting guidance concerning the criteria for documenting personnel contaminations. Section 3.4 of the procedure required the user complete the Personnel Clothing /3'.In Contamination  .
form when personnel contaminations ;ere greater than 100 counts per minute cpm /aup beta gama as directed by the Health Physics (HP)
Supervisor. However Section 4.4. of the same procedure provided the following guidance:
  "The HPs will detarmine when the Personnel Contemination Form will be completed for cortamination <500 cpm /aup beta gamma. The form must be completed when contamination levels are >500 cpm /aup beta gamma and when there is a potential for ingestion or inhalation with contamination levels >100 cpm /aup beta gamma."
The inspectors found the procecural guidance in Section 3.4 and Section 4.4 were conflicting and failed to provide clear guidance for HP personnel implementing the procedure. Additionally, the procedure did not provide clear criteria for documenting PCEs having " potential for ingestion or inhalation." Failure of the licensee to have adequate written procedures for the documentation of personnel contaminations was identified as a violation of the licensee's Technical Specifications (TS). V10 50-302/97 20-01, failure To Provide Adequate Written Instructions For Documenting Personnel Contamination The inspectors reviewed PCE documentation completed in 1997. The HPP-104 procedure required the person completino the Persohnel Clothing / Skin Contamination form to include the next ennst.cutive " Radiological Survey Number." The statement implied that each personnel contamination report would have a unique number. However, the inspectors found that the licensee gave a unique number to a contamination event and an event could involve several personnel contaminations. When reporting a quantity of PCEs one PCE could be reported that actually resulted in six personnel becoming contaminated. The inspectors requested access to all PCEs completed in 1997 for the reviem The inspectors were provided a binder having an index and copies of PCEs initiated in 1997. The inspectors counted approximately 73 personnel contaminations for the Enclosure 2
,. - - . . - . .. .- - . . . - _ - - .
_ _ _ _ - _ _ _ - _ _ _
_
i
site through December of 1997. The numbers were not excessive considering the licensee had been in an extended outage all year and all PCEs the inspectors had reviewed included some having less than 500 cpm /aup. Each of those reports were assigned a survey number. That assessment was discussed with the Radiation Protection Manager. Later  *
in the inspection, the inspectors picked up a binder in a lab to review any additional PCEs that may have been generated since the inspector's review. The inspectors noted that the index in the binder was not the I
same index that had been reviewed earlie The binder included another set of PCEs. The inspectors learned that the licensee had started another index of PCEs when the primary RCA access had beer aved several months earlier. The second index listed personnui having contamination greater than 100 cpm /aup but unlike the first. survey numbers had not been assigned to all personnel contaminations having less than 500 cpm /au Some of the PCEs on the second index were on the first index but not all. An additional 44 personnel contaminations were identified from the review of the second index raising the total number of PCEs documented by the licensee to 11 The PCEs were logged on a Persor.nel Clothing / Skin Contamina' tion index form. Information along the bottom of the index form indicated a survey number was not applicable for skin contaminations <500 cpm /au However. Section 4.4.1.1 of HPP 104, required the Personnel Clothing / Skin Contamination form include a " Radiological Survey" numbe The inspectors found some of the personnel contamination farms for personnel contaminations having <500 cpm /aup included survey numbers and others did not. The guidance on the bottom of a form and the written procedure-did not agre That procedural discrepancy was also identified by the Quelity Assurance (0A) staff during the inspection and a Precursor Card (3 C97-8077) was initiated by 0A personnel. Failure of the licensee to have adequate written procedures for logging PCEs was identified as a second example of inadequate procedures and a violation of the licensee's TS, VIO 50 302/97 20 01. Failure To Provide Adequate Written Instructions for Documenting Perr-H Contaminations. The inspector concluded the licensee's numbering process utilized for logging personnel contamination records did not help control the PCE records and could be misleadin The inspectors found the Personnel Clothing / Skin Contamination forms were not being completed as described in HPP 104. Steps 4.4.2.3 and
- - - -
-4.4.3.2 of HPP 104 required the preparer to " Instruct the individual Enclosure 2
  . - _ _ _ _ _ .
    .. . .
      .
involved in the contimination event to complete the Event Descript %n portion ant. tign the form." The purpose of the process was to capture the workers perspective on how they may have became contaminated. in some circumstances the contaminated worker can provide the best information concerning actual work conditions and possible contamination *
causes. The input can be valuable information when attempting to determine the probable causes and corrective actions to prevent l
recurrence. However, in the review of approximately sixty Personnel Clothing / Skin Contamination forms, the Event Description section of the form was blank on about ten forms and another three had partial information in the section. None of the thirteen forms were signed by the contaminated worker. Failure of licensee personnel to follow written procedures for documenting event descriptions on the Personnel Clothing / Skin Contamination forms was identified as a vic atir of the licensee'.1 TS VIO 50 302/97 20 02. Failure To Follow Radiation
'
Protection Program Procedures For Documenting Personnel Contamination Event While reviewing the 1997 personnel contamination records the inspectors founo the licensee was using three different forms. The three forms were titled " Personnel Clothing / Skin Contamination:" " Personnel Clothing Contamination:" and " Personnel Skin Contamination." The current revision of HPP-104 (Revision 13) did not addrecs all the forms being utilized. The inspectors reviewed recent revisicas to HPP-104 end determined that prior to revision 12 of HPP 104 dated February 20, 1996, the licensee had utilized two forms to document personnel contaminations. There was a Personnel Clothing Contamination form and a Personnel Skin Contamination form. However, when revision 12 of HPP 104 was issued the two forms had been combined into the Personnel Clothing /Skir. Contamination form. The individual forms for skin and clothing contaminations were not addressed by the procedure after February 20. 1996. Licensee personnel reported the old contamination forms should have been removed from the lab. However, during the review of the 1997 PCEs the inspectors found technicians had used six of the l
deleted forms to document one skin and five clothing contamination Failure of licensee personnel to utilize the correct form-for documenting personnel skin and clothing contaminations in 1997 was identified as a second example of failure to follow written procedures for the documentation of personnel contamination events and was Eulosure 2
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identified as a violation of the licensee's TS VIO 50 302/97-20 0 Failure To Follow Radiation Protr.ction Program Procedures For Documenting Personnel Contamination Event The forms used by the radiation protection staff were not included in '
the written procedures and the staff could not go to the Health Physics
, (HP) implementing procedures to verify a form was current. The l inspectors concluded that failure to include the proper personnel contamination form in the written procedures contributed to the improper use of discontinued personnel contamination forms and was a program weaknes Section 3.3.3 of HPP-104. Personnel Monitoring and Decontamination.
,
Revision 13. dated June 2.1997. required HP Supervision be responsible f
'
for reviewing personnel contamination records for applicability wich regards to personnel exposure evaluations and documentation. The HP supervisors reviewing the personnel contaminatioqs that were improperly documented on deleted forms failed to identify and correct the procedural discrepancies. Failure of the HP supervisors to follow written procedures for the review and verification of procedure compliance was identified as a third example of failure to follow written procedures for documentation of personnel contaminations and a violation of tne licensee's TS VIO 50 302/97-20 02. Failure To Follow Radiation Protection Program Procedures For Documenting Personnel Contamination Event The licensee's procedures and forms did not require the HP staff to determine a cause or probable cause of the personnel contamination for tracking, trending, or corrective action purposes. There was a section on the form for remarks that could be used to identify a possible cause however, the remarks section was blank on 36 of 60 PCE records reviewe The inspectors found that the licensee was not actively tracking and trending PCE causes and that was identified as a second weakness in the licensee's contamination control progra The inspectors discussed causes of personnel contaminations with RP staff and found that the licensee had identified causes of some personnel contaminations. For example, the inspectors noted that for an event in which four personnel were contaminated in a clean area, the HPs had investigated the event and determined the cause to have resulteo from an inadequate post decontamination survey. HP management issued a Enclosure 2
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4      i
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  -    i HP Supervisor Information Notice in October,1997, directing the HP i staff to be more thorough in post decontamination survey i
!      !
The inspectors reviewed personnel exposure records for personnel having exposure to skin contamination to verify the licensee was including the -
      '
!      ;
j skin dose on the radiation worhrs exposure _ reco_rds.- The inspectors i J found the licensee was properly updating radiation workers occupational
: radiation exposure records, i
; - The inspectors found that the licensee's technical basis for conversion- ,
factors for determining shallow dose equivalent to low level
_
      ;
      '
4 contamination were not defined in a controlled document. The licensee's Personnel Clothing / Skin Contamination Form included a factor for converting gross contamination activity to shallow skin dose rates. The inspectors asked to see the technical basis for the factor being utilized. The licensee reported that the basis for the factors had been documented in a letter that could not be located during the inspectio The inspectors reported that the issue would be reviewed in a future inspection as an Inspector Followup Item (IFI) 50-302/97-20-03, Review Technical Basis Documentation for Radioactive Contamination Dose Conversion Factors,-
Contamination Control Observations Radiation Safety Procedure (RSP)-101, Basic Radiological Safety Information and Instructions for Radiation Workers, Revision 24, . dated July, 9 -1997, required Florida Power Corporation (FPC) supervision be responsible for assuring all individuals under their direction are aware of and comply with applicable radiological controls and radiological safety instructions, procedures, guidelines, good .nract1ces, and
  .
-policies. Section:4,9. provided radiation workers guidance on removing protective clothing. The procedure required each item of used protective clothing be carefully deposited in the appropriate receptacle-(1.e. waste _ items in waste receptacles and reusable items in receptacles designated as such).
During the inspection the inspectors observed radiation workers in the Radiation Control Area (RCA). While on a tour in the Auxiliary building-the~ inspector came upon some radiation workers (Painters) exiting a contaminated area (Waste Transfer Valve Alley). The Step Off Pad (50P)
~
was set at the door frame into the room. The used protective clothing Enclosure 2
_ _ . _ . _ . _ _ . _  _. _ _ _ _ _ _ _ ___ _
_ _ _ _ _ _
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container was. located outside the contaminated area and full. When the  )
workers began removing the protective clothing the container was already  ,
overfilled. The inspector observed a worker throw his used pr tective
;  - clothing'to the container. - Some of the potentially contaminated
        '~
protective clothing missed the container landing on the clean floo which was a high traffic walkway. . A worker outside the room picked up the clothing with his bare hands and placed it on top of the alread/
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overflowing container. There were several workers in line waiting to remove their protective clothing. The inspectors called for an HP to come to the site to regain control of the activity and to conduct a  i contamination survey of the clean areas around the 50P. The HP stopped the workers from exiting the area until a empty container was found and moved to the 50P. The workers were then permitted to complete their removal of the used protective clothing. The work 9r that picked up the  ,
contaminated clothing was not contaminated and no' contamination was found in the clean areas surrounding the 50P. Failure of the radiatio workers and their supervision to ensure the radiation control practices for contamination control were properly implemented was identified as a violation of the licensee's contamination control program procedures and  ,
a violation of the licensee's TS VIO 50 302/97 20 04. Failure of Radiation Workers To follow Contamination Control Procedure ,
The inspectors also observed water crossing the contamination control boundaries on posted contami_nated areas throughout the Auxiliary  ,
        '
.  -Building. The source of the water appeared to be from condensation dripping off piping above the contam1_nated areas. Licensee personnel reported that the contamination levels in most of the posted areas were
  .l ow. The licensee reported that the aren where' condensation was problem were surveyed and mopped frequently. The inspectors did not identify anj spread of contamination resulting from the condensation problems. The inspectors discussed with responsible management the undesirable conditioning of radiation workers to accept water crossing contaminated area boundaries. No violations were . identifie . Enclosure 2 r
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54 Conclusions Personne1' Contamination Events-      ,
        '
The inspectors concluded the licensee's overall process for documenting  -
and investigating personnel contamination was deficient. The licensee-
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raised the contamination level threshold for documenting PCEs for the purposes of reducing the number of PCEs requiring documentation. The    ;
,  procedure describing the PCE documentation was inadequate in that it
,  contained conflicting-instructions concerning levels requiring    '
documentation. HP personnel documenting the PCEs were not following the
:  procedures and using old and-deleted forms. In some cases when the correct form was used it was not completed as required by the procedur ,
*
The failure to include the current forms in HP procedures was identified
'
as a program weakness. The inspectors found that HP supervisors were reviewing the incomplete and inadequate personnel contamination 1-  documentation without verifying procedural compliance and requiring
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corrective actions. The licensee was not actively determining contamination causes for corrective actions on most-contamination events-
;  and was not trending the activity for performance monitoring,
-
The licensee had identified a probable cause of personnel contaminations  -
in a clean area and had emphasized the importance of thorough post decontamination surveys to the staf !
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Contamination Control Observations
,
Inadequate' contamination control practices were identified as a violation of the . licensee' contamination control program procedure Poor contamination control practices were observed in areas having clean-
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water traveling through and out of posted contaminated areas. The conditions were widespread, tolerated, and de sensitizing radiation    ,
workers to the. potential consequences of uncontrolled contamination transpor .- d Enclosure 2
_,_ - _ . _ -- _ _-_.,___. _ , _  ._ _ _ . ,._, _ _ . _
__.____ _____      _ _ _ _ . _ _ _ _ . _ _ _ . _ . _ _ _
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R2  Status of Radiation Protection and Chemistry Facilities and Equipment.
;
  - R2.1 Radiation Monitorina System Radioactive Waste Treatment and Effluent
}    and Environmental Monitorina. Doerational Safety Team Insoection
            *
' Insoection Scone (84750.93802)
This review was made to determine the quality of the licensee's System-
:
Readiness Review (SRR) of the licensee's Radiation Monitoring System
;    (PfiS) . Obser*J3tions and Findinas i
Inspectors found the licensee had spent considerable resources to determine and verify that the RMS was meeting commitments and regulatory requirements.
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The licensee had performed detailed reviews of the plant RMS for compliance with 1pplicable standards and commitments. The review i    considered, in part, the followir.g requirements, guidance, and    '
. references:
#
o 10 CFR Part 20 S+andards for Protection Against Radiation:
o Final Safety Ana;ysis Report (FSAR):
o Design Basis Documents: RMS, Safety Parameter Display System, Post Accident Sampling and Meteorological Monitoring:
o improved Technical Specifications (ITS):
,
o NUREG 0737. Clarification Of Three Mile. Island-(THI) Action Plan 4    Requirements:    _
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o Regulatory Guides 1.97 Instrumentation For Light Water Cooled
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Nuclear Power Plants To Assess Plant And Environs Conditions During And Following An Accident: and 1.45 Reactor Coolant h    Pressure Boundary Leakage Detection Systems c- Off-Site Dose Calculation Manual o Operation; Procedures o Training Lesson Plans o Plant Drawings
_ . -
4 Enclosure 2 l
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            $
J
- - -'E-- ,.-..-.,,.-,,_ewm,  . , . . . _ + . . . , . . . -....,,-,_,--e%,,  y--.,. n.., . .%rm._, , e,~.' ,,
. - ._- _ -__. - - .._- - _ _- . . - _ _ - - - . -._ _ The licensee found the RMS was adequately monitoring the parameters and correctly processed effluent discharge terminations when high setponts were reache The review also reported that a majority of the original system was in a fair to degraded state of material readiness but still '
functioning as required. A recommendation was made for replacement in the near ter The system had exhibited a significant number of spurious alarms and trips beginning before initial plant startup. These were attributed to incorrect system grounding in the original system.
'
Several discrepancies were identified in the FSAR, RMS Design Basis Document (DBD) and affected system DBDs and other system documentatio A list of items for closure prior to restart was developed in the system readiness review. The list also included some issues identified prior to the system review. The SRR reviewer generated 41 open items that included 37 Precursor Cards (PC) and 4 Work Request (WR). Documents written outside the SRR process were also inspected by the SRR reviewe The number of issues identified for restart consideration out of that review included 1 PC 74 WRs. and 12 Requests for Engineering Assistanc Following the initial assessment the licensee began working and monitoring the progress of corrective actions for the identifieu deficiencies. At the time of the review the licensee was finishing work on the remaining items designated to be completed prior to restart of the Unit 3 reacto The System Engineer for the RMS began a RMS outage on December 6, 1997, to work on equipment grounding problems in the RMS cabinets in the Unit 3 Control Room. The outage lasted several days and the licensee repaired and replaced instrument cables, performed rignal grounding
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upgrades, and improved maintenance access in the cabinet. The decision to have a RMS outage proved to be a good initiative, During the maintenance two cables were discovered to be unterminated. Cables WSE 75 and WSE 80 which carry an output signal from RM A2 (Auxiliary Building Exhaust Duct) and RM Al (Reactor Building Purge Duct) Low Range Noble Gas ratemeters to the Low Medium, and High Valve Controllers were not lande Enclosure 2
._,  .--  - -  - -
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Following the accident at Three Mile Island, NUREG 0737. Three Mile Island (THI) Action Item II.F.!, required noble gas effluent monitors be installed with an extended range designed _to function during accident conditions as well as during normal operating conditions. Multiple
      *
monitors were considered necessary to cover the ranges of interes _ System designs were required to accomodate a design basis release and then be capable of following decreasing concentrations of noble gase The licensee's system was capable of routing monitoring air for RM Al-and RM A2 monitors through three different detectors automaticall When the low range monitor approached full scale a signal was sent to a valve controller to route the air to the mid or high range detectors as needed. However, the unlanded cables would have prevented the noble. gas monitors from automatically switching to mid and high range monitorin The licensee's surveillance, Preventative Maintenance (PM)-292, Checkout of the PASS Noble Gas Hid and High Range Detector Valves and Valve Controllers, Rev, 5, dated November 3,1997, for testing the operability of the controllers did not require the input signal originate from the low range ratemeter in the control room. Instead a signal was feed directly into the controller and the cable from the control room was not tested. The monitor was set up to permit manual control of the valve controllers from the control room, therefore, it would have been possible to make the monitor operable. However, the intended
. operability of the system would not have occurred.- The issue is still under review by the licensee and resident NRC staff. A PC 97 8333 was initiated to cause corrective actions. The licensee planned to land the connectors on the proper terminals, revise PM 292 to test the complete circuit. and complete the revised P The RMS Engineer also found a gap in the cabinet and cantrol room floor that had not been seen due to a grounding bar in the cabinet base. A PC was initiated to seal the penetration.
c, Conclusions The RMS review was thorough and numerous discrepancies were identifie The corrections made should improve the equipment operability, ensure equipment was capable of performing intended functions, and improve quality of supporting and administrative documentation for the equipment. There were no outstanding issues concerning the RMS that= -
would delay restart of Unit Enclosure 2
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ - -
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R2.2 Whole Body Counters. Occuoational Radiation Excosure (83750). Insoection Stone The inspectors reviewed the licensee's Whole Body Counter (WBC)
      '
maintenance to determine if it was being properly calibrated and-maintained, i Observations and Findinas The inspectors reviewed the licensee's calibration procedures for the WBC and verified that the monitor was properly calibrated in accordance
_
with the licensee's procedures.. The quality controls for the system were also reviewed and verified to be in compliance with the procedure requirements, Conclusions The inspectors verified that the Whole Body Counter was properly
_
calibrated, monitored, and maintaine R2.3 Whole Body Contamination Monitors. Occucational Radiation Exoosures (83750). Doerational Safety Team Insoection (938021 Insoection Scoce The inspectors reviewed the licensee's maintenance of.whole body
- personnel contamination monitors to determine if they were being--
properly calibrated and maintained, b .- Observatics and Findinos The inspectors revieweC the licensee's calibration procedures for the whole body personnel conccmination monitors and verified that the contamination monitors were properly calibrated in accordance with the licensee's procedures. The quality contro's for the system were also reviewed and verified to be in compliance with the procedure requirement ._ _      _
Enclosure 2
__. .____ __ _ ________-__.___ _ ___ _
59 Conclusions          ,
  - The inspectors verified that the licensee's whole body contamination monitors were being properly calibrated, monitored and maintaine *
            ,
R8 Miscellaneous Operational Issues R (Closed) IFI 50-302 97-13-06- Reviaw Accuracy of Gaseous Effluent itelease start Times and Volumes a. -Insocction Scone (92904)        !
The inspectors reviewed this item to determine if Reactor Building Purge start and stop times and volunes of gaseous releases were accurat '
, Observations and Findinas In a previous inspection of effluent release activities. the licensee      i reported a concern had been identified concerning the accuracy of      '
Reactor Building purges when surveillances were performed during a release. The concern was that operations might not be accounting for the total purge time due to their actions in implementing a surveillance requirement and that the actual volume of the release could be greater      .
than documented. The concern was raised August 21. 1997 and documented
            '
in Precursor Card 97-614 The licensee. selected eight previous releases and pulled the purge fan -
_
strip charts for each to verify the fan operation times matched the      -
release times on the release permits. The licensee found that the Reactor Building Purge Fans started at the same time as or after the      ;
time recorded on the purge permit. The inspectors reviewed the licensee's documentation of the review and found that the release times generally matched the fan operation times. The inspectors determined that the licensee procedures had been revised to indicate release start times clearl c. . Conclusions The inspectors concluded the reactor building purge release times and
_
volumes were accurate.--
    -
.
Enclosure 2
            ,
nm, , .-. - - - , , , , . - - , . _ . - .-.-.,,c , - - . , - , ,,-~,,,,,------,,c, ---m.--. . , , - - - , , - - - . - - _ _ - - _ , - - -
_ _ _ _ _ _ _ _ _ _ - - _ _ -
NANAGEMENT MEETINGS XI - Exit Meeting Summary The Team Leader discussed the progress of the inspection with licensee  *
representatives on a daily basis, An interim results summary was presented to license management regarding results of Health Physics _
inspections on December 11, 1997. An exit meeting presented the results to members of licensee management and staff at the conclusion of the inspection on December 16.- 1997. The licensee acknowledged the findings presented, Proprietary information was examined during this inspection but none is included in this repor PARTIAL LIST OF PERSONS CONTACTED Licensee A. Auner, Instrumentation and Control Shop Manager J. Baumstark, Director. Quality Programs D. Brass, Minor Maintenance Manager J. Cowan, Vice President, Nuclear Production    *
R. Davis, Assistant Plant Director, Operations and Chemistry R. Grazio, Director, Nuclear Regulatory Affairs G. Halnon. Assistant Plant Director, Nuclear Safety B. Hickle. Director, Restart J. Holden. Director, Site Nuclear Operations 0, Kunsemiller, Manager, Nuclear Licensing
. Pardee Director Nuclear Plant Operations R, Pepin, Supervisor. Mechanical Maintenance W. Pike. Manager, Nuclear Regulatory Compliance M. Rencheck, Director, Nuclear Engineering M. Schiavoni, Assistant Plant Director, Maintenance T. Taylor Director, Nuclear Operations Training D. Wilder, Health Physics Chemistry Manager
- = =  __  _
_
Enclosure 2 l
_ . _ . _ _ . _ _ _ _ . _ . _ _ _ . _ . - . . _ . . _ _ - _ _ _ _ _ . . . _ _  -
_ _ _ . _
-
            ,
t
            !
            '
EC S. Cahill Senior Resident Inspector        '
T. Cooper. Resident Inspector J. Jaudon. Division Director. DRS
            ,
S. Sanchez, Resident Inspector
            :
LIST OF INSPECTION PROCEDURES USED IP 83750:  Occupational Radiation Exposure IP 84750:  Radioactive Waste Treatment and Effluent and Environmental Monitring        -
            -
t IP 93802:  Operational Safety Team Inspection (OSTI)
IP 62706:  Maintenance Rule ITEMS OPENED CLDSED. AND DISCUSSED OPENED'
Iyne Item Number    Status Descriotion and Reference VIO 50 302/97-20-01  OPEN  Failure To Provide Adequate Written-Instructions For Documenting Personnel Contaminations. (Section R1,1)
            :
            '
VIO . 50-302/97-20 02    OPEN  Failure To Follow Radiation Protection Program Procedures For Documenting Personnel Contamination Events. (Section R11)
IFIL 50'302/97-20
  -
03  OPEN  Review Licensee Technical Basis Documentation For Radioactive Contamination Shallow Dose  ,
Conversion Factors. (Section RI.1)
VIO - 50 302/97 20 04  OPEN  Failure Of Radiation Workers To follow Contamination Control Procedures. (Section R1.1)
Enclosure 2
:
P
<- - = . - - - - , ,c, 2--.-..-,,,--,-,n,-.---  .,-,--,-e ,,-,.v., -
        ,,rr-,ev. ..,o -.e,, , < , , . ,m-,, ---..-n,,--
_ , - - -
_
t Closed IFI- 50 302/97 13 06 CLOSED Review Accuracy of Gaseous Effluent Release Start Times and Volume *
    (Section R8.1)
Discussed
  '
IFI_ 50 302/97-14 01 OPEN Review of Operational Procedures Prior to Restart (Section 08.2)
LIST OF ACRONYMS USED Al Administrative Instruction AP Abnormal Procedure AUP Area Under Probe CFR- Code Federal Regulations CPM Counts Per Minute DAD Digital Alarming Dosimeter DBD Design Basis Document
,
DH Decay Heat System, FME- Foreign Material Exclusion FPC Florida Power Corporation FSAR Final Safety' Analysis Report HPJ Health Physics
-
HPP- Health Physies Procedure I&C Instrumentation and Control IFI -Inspector Followup Item
  .lP- : Inspection Procedure-ISI In-Service Inspection ITS .lmproved Technical Specifications MAR ~ Hodification Approval Record mrem Hilli-Roentgen Equivalent Man hRC Nuclear Regulatory Comission 01 _ Operating Instruction
  -
OP- 0perating Procedure-OSTI Operational Safety Team Inspection PC Precursor Card-PCE Personnel Contamination Event P . Preventive Maintenance PMT Post Maintenance Test Enclosure 2
j  63 PT Liquid Dye Penetrant Test QA Quality Assurance rad Radiation Absorbed Dose RCA Radiation Control Area Request for Engineering Assistance
    '
REA RF0 Re Fueling Outage RMS Radiation Monitoring System RP Radiation P otection RSP Radiation Safety Procedure  i SP Surveillance Procedure SR Surveillance Requirement SRR System Readiness Review S0P Step Off Pad THI Three Mile Island VIO Violation WBC Whole Body Counter WI Work Instruction WR Work Request Enclosure 2
  . - _ . _ .
}}
}}

Latest revision as of 06:51, 18 December 2021

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-302/97-20.Response Meets Requirements of 10CFR2.201
ML20216B844
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 03/03/1998
From: Jaudon J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To: Richard Anderson
FLORIDA POWER CORP.
References
50-302-97-20, NUDOCS 9803130201
Download: ML20216B844 (3)
v • d • e


Text

i e

March 3, 1998 l Florida Power Corporation l Crystal River Energy Complex

! Mr. Roy A. Anderson-(SA2A)

l- Sr. VP. Nuclear Operations 4 l

'

ATTN: Mgr.. Nuclear Licensing I 15760 West Power.Line Street

. Crystal River. FL 34428-6708 SUBJECT: NOTICE OF VIOLATION (NRC INSPECTION REPORT NO. 50-302/97-20)

Dear Mr. Anderson:

Thank you for your response of February 13, 1998, to our Notice of Violation issued on January 16. 1998. concerning activities conducted at your Crystal j River facility. We have evaluated your response and found that it meets the i requirements of 10 CFR 2.201. We will examine the implementation of your l l corrective actions during future inspections. {

We appreciate your cooperation in this matter.

Sincerely, i Original signed by Johns P. Jaudon Johns P. Jaudon Director Division of Reactor Safety Docket No. 50-302 License No. DPR-72 cc: John P. Cowan. Vice President Nuclear Production (NA2E)

Florida Power Corporation Crystal River Energy Complex 15760 West Power Line Street Crystal River. FL 34428-6708 C. G. Pardee.. Director Nuclear Plant Operations (NA2C)

Florida Power Corporation 0 Crystal River Energy Complex

,

15760 West Power Line Street

! Crystal River..FL 34428-6708 cc continued: See page 2 9903130201 980303

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E FPC. 2 cc: Continued-B. J. Hickle.' Director Nuclear Plant Operations.(NA2C)

Florida Power Corporation

'.

Crystal River Energy Complex 15760 West Power Line Street Crystal River, FL 34428-6708 Robert E. Grazio. Director Nuclear Regulatory Affairs (SA2A)

Florida Power Corporation Crystal River Energy Complex 15760 West Power Line Street g Crystal River. FL 34428-6708 James S. Baumstark. Director Quality Programs (SA2C)

Florida Power. Corporation Crystal River Energy Complex 15760 West Power Line Street l Crystal River. FL 34428-6708 l R. Alexander Glenn Corporate Counsel

,

Florida Power Corporation

'-

'MAC - ASA P. O.' Box 14042 St. Petersburg. FL. 33733-4042 Attorney' General i. Department'of Legal Affairs

! The Capitol

. Tallahassee. FL 32304 Bill Passetti Office of Radiation Control De)artment of Health and.

Rehabilitative Services 1317 Winewood Boulevard Tallahassee. FL 32399-0700 Joe Myers. Director Div. of Eniergency-Preparedness Department of Community Affairs 2740 Centerview Drive Tallahassee..FL' 32399-2100 cc continued: See page 3

-

.

.

..

FPC 3 cc: Continued Chairman Board of County Commissioners Citrus County 110 N. Apopka Avenue Inverness, FL 34450-4245 Robert B. Borsum Framatome Technologies 1700 Rockville Pike. Suite 525 Rockville. MD 20852-1631 Distribution:

L. Raghavan. NRR R. Schin. RII P. Steiner RII B. Crowley RII F. Wright. RII L. Stratton, RII PUBLIC NRC Resident Inspector U.S. Nuclear Regulatory Comm.  !

6745 N. Tallahassee Road Crystal River FL 34428

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