IR 05000302/1996011

Insp Rept 50-302/96-11 on 960908-1005.Violations Noted.Major Areas Inspected:Licensee Operations,Engineering,Maintenance, & Plant Support

ML20129H731
Person / Time
Site:	Crystal River
Issue date:	10/30/1996
From:	NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20129H725	List: ML20129H720 ML20129H726 ML20129H731
References
50-302-96-11, NUDOCS 9611060004
Download: ML20129H731 (30)

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U.S. NUCLEAR REGULATORY. COMMISSION REGION 2 Docket No: 50-302 License No: DPR-72 1 I

Report No: 50-302/96-1 Licensee: Florida Power Corporation i

I Facility: Crystal River 3 Nuclear Station .j Location: 15760 West Power Line Street- I Crystal River. FL. -34428-6708 Dates: September 8 through October 5. 1996 1 l

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Inspectors: R. Butcher. Senior Resident Inspector '

l T. Cooper. Resident Inspector l B. Crowley. Reactor Inspector, paragra)hs E8.1..M M. Thomas. Reactor Inspector, paragrap1 E F. Wright Senior Radiation S)ecialist. paragraphs l R1.1 R1.2. R3.1. R3.2. and 1 !

Approved by: K. Landis Chief. Projects Branch 3 Division of Reactor Projects V \

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9611060004 961030 PDR ADOCK 05000302 l 9 PDR ,

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t EXECUTIVE SUMMARY Crystal River 3 Nuclear Station NRC Inspection Report 50-302/96-11 This integrated inspection included aspects of licensee operations, engineering, maintenance, and plant support. The report covers a 4-week period of resident ins)ection: in addition it includes the results of announced inspections ]y two reactor inspectors and one senior radiation specialis Doerations A major reorganization occurred effective October 1, 1996. All Directors now report directly to Mr. P. Beard Senior Vice President. Nuclear Operation (paragraph X4.1)

A Violation (50-302/96-11-01) was identified for inadequate work instructions to prevent the inadvertent start of the A emergency diesel generator.

l (paragraph 03.1) l A Non-Cited Violation (50-302/96-11-02) was identified for failure to meet Technical Specification 5.2.2.e requirements for scheduling of work in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a seven day period. (paragraph 06.1)

Maintenance A Violation (50-302/96-11-03) was identified for personnel performing work on the reactor building sump without logging onto a clearance, as required by the L approved Work Request. (paragraph M2.1)

A Violation (50-302/96-11-04) was identified for the reactor building sump not being constructed in accordance with approved construction drawings.

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l A Weakness was identified regarding the lack of coordination of the inspection l effort for the reactor building sump screens. (paragraph M2.1)

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Enaineerina i

! A temporary engineering reorganization was instituted in an effort to control the large engineering backlog. (paragraph E6.1)

Plant Succort A Non-Cited Violation (50-302/96-11-05) was identified regarding the failure to conduct an adequate radiation survey. (paragraph R1.1)

l Licensee efforts to reduce the quantity of radioactive solid waste being generated were proactive. (paragraph R1.2)

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Implementation of the new Chemistry Quality Control Manual was a good program improvement. (paragraph R3.1)

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Overall chemistry analytical capabilities were good. (paragraph R3.1)

Documentation of corrective actions for controls outside limits a)peared to be a weakness in the laboratory Quality Control Program. (paragraph 13.1)

l Understanding of corrective action concepts was a staff weaknes !

l (paragraph R7.1)

i A Non-Cited Violation (50-302/96-11-06) was identified regarding the failure I to follow sampling requirements of the Offsite Dose Calculation Manua (paragraph R7.1)

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l Repcrt Details Summary of Plant Status The unit began the inspection period on September 8.1996 in Mode 5 (Tavg less than or equal to 200 degrees F). The plant was taken off line on September 2.1996 in order to make repairs to the turbine lube oil syste An Unusual Event was declared at 5:10 a.m. on September 19. 1996 when a coin was found in the lube oil filter housing for a right angle gearbox for a cooling fan on the A EGDC. An inspection of the plant did not i turn up any other unexplained discrepancies. The Unusual Event was exited at 3:00 a.m. on September 21, 1996. See paragraph M8.1 for further detail The unit outage was extended, in part, due to the need to resolve the potential tampering event described in IR 50-302/96-13. Additional items delaying restart include the need to resolve potential Unreviewed Safety Questions concerning emergency diesel generator loading concerns and emergency feedwater single failure vulnerabilitie On October 4, 1996 the licensee announced that they planned to remain shutdown for an extended period of time in order to make modifications to several safety systems in order to obtain design margin for accident condition L._ Operations 02 Operational Status of Facilities and Equipment 02.1 Main Turbine Lube Oil Pioina Failure a. Insoection Scope (71707)

Following the discovery of the longitudinal crack in the L0 piping inside LOT-2. as discussed in IR 50-302/96-09, the licensee made the decision to ) lace the unit in Mode 5, Cold Shutdown, to allow repairs to be made to tie syste The unit reached mode 5 at 11:38.p.m. on September 5. 199 The residents followed the licensee's investigation into the cause of the pipe failur b. Observations and Findinaq Thorough examination of the failed piping was conducted by the license Results revealed that the failure was approximately 4-1/2 feet in length, located at the top of the piping. The failure started near the l back stop for the check valve downstream of the oil adductor and rapidly l propagated through the pipe. The piaing failed ra) idly, exhibiting l signs of a large pressure surge in t1e piping, muc1 higher than the system pressure could obtain. The licensee estimates that the total duration of the crack propagation was approximately 2 milliseconds. The

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i 2 i licensee has determined that the crack suddenly stopped growing, without having reached any changes in surface area or material. They concluded that this was the time when the pressure event decreased below the point where rapid failure was occurrin The licensee has speculated that the cause of the failure was hydrogen ignition inside of the piping, igniting at the point where the check ,

valve disk contacts the back stop. A possible source of hydrogen, according to the licensee, is from hydrogen introduced into the oil from the hydrogen gas to seal oil system interface that came out of solution during periods when the L0 system was shut down. This hydrogen would tend to collect in the high point in the piping and could be ignited when the-system-is starte ;

After consulting with Westinghouse.the licensee installed new piping and '

a new arrangement of piping supports in an effort to reduce fatigue cycling of the new piping. In an attem)t to prevent further occurrences of hydrogen accumulation, the licensee las drilled two 1/8 inch holes on the high point of the piping. upstream and downstream of the check valve. Since the pi return to the tank. pe is LOT The inside wasofreturned the LOT any oil leakage to operation will just on September 14, 199 . Conclusions The failed piping was most probably due to collection of hydrogen gas in  !

the lube oil system. Modifications were made to prevent a recurrenc ,

03 Operations Procedures and Documentation 03.1 Inadvertent Emeraency Diesel Generator Start

' Insoection Scooe (71707)

On September 13, 1996. EGDG-1A was tagged out for WR NU 0337713, which was written to verify the fuel rack position reading to support testing to address the EGDG-1A loading concerns. At 2:59 a.m. on September 14, 1996 during the restoration of EGDG-1A, an inadvertent emergency diesel generator start occurred. The residents reviewed the licensee's investigation of-this even Observations and Findinas Normally, when tagging out the uiesel, the clearance would include tripping the fuel racks. For this WR, the racks were not tripped, as this would prevent the measurements being made as part of the tes This fact was noted on the WR. The work instructions directed the  !

i mechanics to return the fuel racks to the as-found position at the completion of the test.

! Clearance 96-09-10 was written to support this work. The fuel rack was

! not on the clearance, in accordance with the WR. The breaker control r

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i handle, the breaker, and the starting air system were on the clearanc !

The tags were numbered, requiring that they be hung and pulled in a specified orde ,

t The work was comaleted and the clearance released on September 14. 1996. I CP-115. Nuclear Plant Tags and Tagging Orders. step 4.9.8. requires that !

when a tagging order is released and no restoration sequence is i specified. tags are to be removed in the reverse sequence in which they were hung. The ins)ectors reviewed the clearance and determined that i

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the operator would lave closed the air start solenoid valves. EGV-53 and i

! EGV-52 and then opened the air start booster isolation valve, EGV-6 '

l With the valves EGV-53 and EGV-52 having been open, the air which j

, normally kept the air supply valves EGV-56 and EGV-57 closed had been l

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bled off. Following this, the operator opened EGV-35 the air isolation '

to the diesel. When this valve was opened enough air was admitted to the diesel to roll it fast enough that with the fuel racks not tripped, the diesel inadvertently started.

, The inspectors reviewed the work recuest, the clearance, and the

statements by the operators. No incications exist that any personnel failed to adhere to the approved instruction that they had received.

l The licensee investigated this inadvertent star Engineering originally thought that when EGV-35 was opened, air pressure should have been adequate to close EGV-56 and EGV-57 prior to enough air being supplied to the EGDG to reach speeds where the combustion process was self sustaining. Tests conducted by the licensee determined that when the EDG is configured with the fuel racks engaged but the starting air isolated, o)ening the isolation valve rapidly can cause the EDG to start, as tie air reaches the EDG prior to EGV-56 and EGV-57 isolatin TS 5.6.1.1. Procedures, states that written procedures shall be established, implemented, and maintained covering the activities in Regulatory Guide (RG) 1.33. Revision 2. Appendix A. February 1978. RG 1.33 requires that written procedures or instructions for maintenance that can affect the performance of safety-related equipment be properly pre-planned and performed in accordance with written 3rocedures, documented instructions, or drawings appropriate to t1e circumstance CP-115. Nuclear Plant Tags and Tagging Orders, step 4.9.8. requires that when a tagging order is released and no restoration sequence is .

specified, tags are to be removed in the reverse sequence in which they )

were hung. The failure of the clearance for Work Request NU 0337713 to l require tripping the fuel racks prior to opening the air supply l isolation valve resulted in the inadvertent start of the A emergency ;

diesel generator and is a violation. VIO 50-302/96-11-01. Inadequate !

work instructions to prevent the inadvertent start of EGDG-1 I

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c. Conclusions One violation was identified for inadequate work instruction i

06 Operations Organization and Administration l

06.1 Ooerations Shift Schedulina I l

a. Insoection Scooe (71707. 92901) l The residents followed up on several licensee identified instances where l

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the limits for overtime were exceeded or scheduled to be exceeded.'

b. Observations and Findinas The inspectors discussed the shift scheduling practices of the licensee's operations group in IR 50-302/96-08. In that report, the potential for degradation in operator performance was identified, due to the routine use of overtime, even though the inspector could identify no instances where the licensee had violated the TS restrictions on overtim TS 5.2.2.e. Unit Staff, requires that the amount of overtime worked by unit staff members performing safety related functions shall be limited and controlled in accordance with approved administrative procedure Licensee procedure AI-100. Administrative Policies. Section 4.10.2, Scheduled Work Implementation, places certain administrative limitations on the scheduling of overtime:

• No work (will normally be scheduled for more than 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br /> per wee * If it becomes necessary to schedule or work more than 60 hours6.944444e-4 days <br />0.0167 hours <br />9.920635e-5 weeks <br />2.283e-5 months <br />, but'less than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, department management approval is require * If more than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> per week needs to be scheduled or worked, it must be approved by the Director. Nuclear Plant Operations (DNPO).

On August 27. 1996. PR 96-340 was issued discussing a case where a

licensed R0 had discovered that he had been scheduled for and had worked l greater than 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a seven day work period without the approval of the DNP On September 17,1996. PR 96-383 was written, documenting two instances where a NSS review of the shift schedule for his crew had determined that there were individuals scheduled to work in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a seven day period without the approval of the DNPO.

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In PR 96-340, where the operator exceeded the overtime restrictions, a

! violation of the TS requirements occurred. This violation was

! identified by the licensee. The licensee has determined that the

primary cause was an erroneous schedule with contributing causes, with

. no formal validation process for the schedules and frequent and  ;

complicated changes made to the schedule following its issuance. The l

licensee has completed the validation of the current schedule and has ;

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s found no additional errors. A formal process is being incorporated into the operations procedures to prevent recurrence. This licensee i identified and corrected violation is being treated as a Non-cited .

Violation consistent with Section VII.B.1 of the NRC Enforcement Policy I and will be tracked as NCV 50-302/96-11-02. Failure to meet Technical l Specification requirements for scheduling of work in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> i in a seven day perio Conclusions One Non-Cited Violation was identified for failure to meet TS requirements for scheduling of work in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a seven day period, without the approval of the DNP LL. Maintenance M2 Maim.enance and Material Condition of Facilities and Equipment -

M2.1 .Bgaccor Buildina Sumo Screens a, Insoection Scooe (62707)

In IR 50-302/96-201. a question was raised by the NRC as to the

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capability of the decay heat system for long term plant cooldown. The

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DH dropline is credited for use to depressurize the RCS during certain SBLOCAs to minimize the LPI pump operation at low flow conditions. One of the outstanding questions concerned the capability of the reactor building sump screens to withstand the forces of draining the RCS to the

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reactor building sum) through the decay heat drop line during the SBLOCA

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scenarios. During t1e outage, engineering prepared to examine the RB sump screens to establish an as found condition. The resident inspectors followed the licensee's efforts in this effor !

, Observations and Findinas l

During the last refueling outage, engineering was requested to determine l what back-flow velocities the RB sump would be capable of sustaining to support various design basis accident scenarios. Analysis performed at the time determined that flow velocities up to 1 ft/sec would not have

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any adverse effect on the RB sump. Following this analysis, concerns l identified in URI 60-302/96-201-01. Long Term Plant Cooldown, with the l potential need to drain the RCS to the RB sump created the need to i cualify the sump for higher back-flow velocities, which could not be

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cone with the existing sump screen configuration and design.

i On September 11, 1996, the licensee conducted an inspection of the RB )

' sump in preparation for upgrading the sump screens. During the process l of removing the old sump screens, it was discovered that the screen i support frame was not fabricated in accordance with the original

construction drawings. The welds anchoring the vertical posts of the

sump screen support frame were never installed, reducing the ability of

the screen support frame to transfer load to the sump wall.

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The licensee decided that before any repairs were completed to the +

posts, a detailed inspection would be conducted to determine if any additional discrepant conditions existed. This inspection was '

originally planned to be completed early on September 13, 199 !

When the inspectors arrived to attend the pre-job briefing, the RP personnel informed them that the sump ' lean-out, which was a prerequisite for the sump inspection, had not been completed, due to i manpower and equipment problems. Engineering personnel decided to conduct the pre-job briefing. in anticipation of completion of the sump !

clean-out. Soon after the briefing began, a maintenance representative arrived and incuired as to the reason for maintenance being unaware of the meeting. Fe also requested a chance to review the work package, since his crew had not had a chance to do so. The briefing was delayed *

until after the review of WR NU 0337687 had been accomplishe l Approximately three hours later. the inspectors attended the second pre-job briefing, which was conducted by the maintenance representativ The meeting was well conducted, with contingency alans and expectations ;

discussed. However, further delays in cleaning tie sump prevented all ;

but two prerequisites being accomplished at that poin Later that day, a meeting was held between the principal participants in l this task: engineering, mechanical maintenance, facility service I operations, radiation protection. outage management, and shift ,

management. At this time, management expressed a strong desire to accomplish the task before the end of the day. Engineering informed management that there were two engineers able to conduct. the inspection, but they were only authorized to work up to 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br /> for the day, and if they were not allowed into the RB in time, the task would not be accomplished until the next da That evening, the inspectors attended another pre-job briefing, this time with a different maintenance shift. This shift had a change to the work scope provided by engineering, which necessitated changes to the prioritization of the task Following the completion of the briefing, the maintenance crew determined that the clearance for the breathing air had never been second verified and that this would have to be accomplished prior to beginning work. They also noted that the WR required a clearance as part of the work request, but the maintenance technicians from the previous shift had not obtained a clearance nor signed onto any existing clearances, even though the SSOD had approved l the start of the work.

l The maintenance personnel discussed among themselves regarding asking permission from the SSOD to N/A the clearance requirement. The inspectors inquired on whether the Tagging order 96-09-046 on the DH i system drop line was applicable to this task. The SSOD had a clearance i i on the DH line, which if it had been released, the workers in the sump '

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would have been at risk. The maintenance personnel concluded that i i Tagging order 96-09-046 was appropriate for the work being performed, however the WR had not been added to the clearance. The licensee ,

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maintenance technicians who had previously performed work on the RB sump  :

had not logged onto any clearances, as required by the W l TS 5.6.1.1. Procedures, states that written procedures shall be  ;

established, implemented, and maintained covering the activities in Regulatory Guide (RG) 1.33. Revision 2. Appendix A.. February 197 !'

, RG 1.33 requires that written procedures or instructions for maintenance l that can affect the performance of safety-related equipment be properly ,

pre-planned and performed in accordance with written arocedures, i documented instructions, or drawings appropriate to tie circumstance f Licensee Control, procedure step 4.3. CP-113 requiresWork that the Request personInitiation performing and Work Package the work i

j complete the activity in accordance with the approved work instructio i Approved work instruction. WR NU 0337687 required that the work be l accomplished under a clearance. Contrary to the above, on September 1 e

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l 1996, cleaning of the reactor building sump and 3 reparation for the RB ( sump inspection was performed by maintenance tec1nicians who failed to j l log onto a clearance. This is a violation. VIO 50-302/96-11-0 :

l Personnel performing work on the reactor building sump without logging.

l onto a clearance, as required by the approved work reques The maintenance crew completed verifying the breathing air clearance and I logged onto the DH clearance. Tagging order 96-09-046. Two PCs were i written by the maintenance supervisor to address the previous problems i with the clearances. By the time the clearances were in order, the  !

engineers did not have enough time to accomplish the ins)ection without 1 exceeding TS overtime restrictions. The inspection of t1e RB sump was  !

delayed until the next day. The maintenance technicians and OC j continued into the sump to take measurements for the fabrication of the l new screens and to perform pts on the existing welds. Continued I problems with coordination of the inspection effort resulted in several delays and revisions to the inspection plans. This is itdicative of weak management oversight and work coordinatio On September 14. 1996. the inspectors witnessed engineering's inspection of the RB sump. Additional welds were found to be missing on the support posts. Also, some of the existing welds on the post and on where the posts attach to the sump liner were noted to be of poor quality. Minor gaps in the screen support structure were noted to exceed the 1/4" maximum screen mesh criteria. Some gaps in the trash screen above the sump were noted to exceed the 1-1/2" allowable gap criteria. The licensee performed a modification to restore the gaps within the acceptance criteri CFR 50. Appendix B. Criterion V requires, in part, that activities l affecting quality shall be 3rescribed by drawings, of a type appropriate to the circumstances, and slall be accomplished in accordance with these

, drawings. L w see drawing S-521-038. Reactor Building Sump Liner, i Screen and Lc, ,

. Sections and Details, provided construction details

! for the reactw building sump screens and supports. Contrary to the

) above. on September 11. 1996, the licensee determined that the safety j related RB sump screens and supports had not been constructed in

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accordance with the approved construction drawing S-521-038. The l failure of the RB sump screen components to have been constructed in  ;

accordance with the approved drawing is a violation. VIO 50-302/96-11-  !

04. Failure to construct the reactor building sump screens and  ;

components in accordance with the approved drawin :

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The licensee prepared for the fabrication of replacement screens by i dedicating two welders and having them practice the welds by producing i screens, from the sa1e materials used in the final screens. The

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preparation and preplanning for 3roducing the screens were well thought out. During the production of t1e final screens, the maintenance i personnel missed the QC hold-point for the measuring of the screen sag  :

prior to the final welds. OC inspected the sag following the welding  :

and found it to be acceptable, successfully dispositioning the hold- l point Repair and restoration efforts were completed on September 21. 1996.

l Three of the five sump screens were replaced with more rugged screens.

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The three re) laced screens were the center screens, which would experience t1e highest loading during a blow-down. The applicable codes for construction of new Sump Screens and repoir of existing Sump and Screen welds are as follows:

Structural Welding (Screen Frames and repair to Sump welds) -

l American Welding Society (AWS) Structural Welding Code D1.1,1984 j Edition

Screen to Frame Welds - AWS Structural Welding Code - Sheet Steel D1.3. 1981 Edition In addition to observation of in-process work as detailed above, the inspectors reviewed the following completed weld records:

Weld Traveler WT 0337756 04, including completed Weld Inspection Plan NU 0337756 for: (1) Post to Filler Plate Weld Nos. STEP Post A. Post B. Post C. and Post D and (2) Cover Plate Welds STEP 7.5 LOC. 1. LOC. 2. LOC. 3. and LOC. 4 j Weld Traveler WT 0337756 02. Weld Nos. Post A. Post B. Post C and

Post D. including completed Weld Inspection Plan NU 0337756 for l Checker Plate Support Weld Nos. STEP 7.6. CHECKER PL SUPPT. Post l "A" Post "B" Post "C" and Post "D"

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L Weld Traveler WT 0337580 01. covering various structural welding-for new screens, including completed Weld Inspection Plan NU 337580 for Weld B1  ;

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j Weld Traveler WT 0337580 02. covering Screen to Frame Welds for l

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! new Screens including completed Weld Inspection Plan NU 0337580

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Weld Traveler WT 0337687-01. covering welding of Post to Checker Support Angle omitted welds, including completed Weld Inspection Plan NU 0337687-01 Weld Traveler WT 60008, covering repair of Post to Sump Bottom Plate welds, including: (1) Inspection Plan IP-001. (2) NDE Report IP-240. covering Liquid Penetrant (PT) examination of as found welds, and (3) NDE Reports IP-241 and IP-242 covering PT ,

inspection after repairs The analytical a)proach, design calculations, design details, and modification paccage for the new screens have been sent to an independent AE for an independent review. Additional actions planned to address this issue include a review of original construction records in an effort to determine how this incident could have occurred. The licensee plans to revise procedures to recuire a more thorough inspection of the sump and specifically icentify characteristics that are critical to assuring continued sump operability. Engineering is performing an analysis to determine if the sump screen was operable in the as-found condition. This issue will still be tracked under URI 50-302/96-201-01. Long term plant cooldown following a small break LOCA assuming a single failure in the heat drop lin c. Conclusions For the welding activities examined, weld records were in good order and indicated good control and documentation of welding activitie However, two violations and one weakness were identified for failing to construct the reactor building sump screens and components in accordance j with construction drawings, failing to follow procedure for obtaining a ;

clearance prior to beginning reactor building sump ins)ection, and a '

weakness in management oversight and coordination of t1e reactor building sump inspectio M3 Maintenance Procedures and Documentation M3.1 Surveillance Observations (61726)

As part of the follow-up of the potential tampering event, discussed in ,

IP,50-302/96-13. the ins)ectors witnessed the performance of several I surveillances: SP-354A. ionthly Functional Test of the Emergency Diesel Generator EGDG-1A: SP-354B. Monthly Functional Test of the Emergency ;

Diesel Generator EGDG-18: and SP-907A. Monthly Functional Test of 4160V

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ES Bus A Undervoltage Relaying. No problems were observed with the performance of these surveillance test M8 Miscellaneous Maintenance Issues M8.1 Lube Oil Strainer for Gearbox on the A EDG (92902)

On September 19. 1996 at 5:10 a.m. with the plant in Mode 5. the licensee declared an Unusual Event due to evidence of possible tampering l

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with a lube oil strainer on a right angle gear box for the cooler fan on the A EDG. A penny was found in the bottom of the cavity for the i strainer housing. Due to its size, the penny could not enter the i strainer housing except through the opening where the strainer is placed. The Emergency Classification Table of Emergency Plan Implementing Procedure EM-202, Duties of.the Emergency Coordinator, lists under a security threat condition of attempted sabotage that an Unusual Event be declared. As a precautionary measure, the licensee declared an Unusual Event and notified the NRC under 10 CFR 50.72(a)(1)(i). The licensee initiated Problem Report PR 96-038 .

Attempted Sabotage of EDG-1A, for followup action on this even !

The plant has been off line since September 2, 1996 due to unrelated repairs to the main turbine lube oil system. The A EDG was already out of service for maintenance at the time.for maintenance. The licensee i placed security personnel at the two EDGs as an interim measure. This issue will be followed up by a special inspection team and will be covered in IR 50-302/96-1 J1L. Enoineerina  ;

E6 Engineering Organization and Administration E6.1 Enoineerina Backloa Control (37551) '

The licensee has determined that due to the emergent work in all engineering disciplines over the past year the ability of the

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Supervisors to 3rovide adequate management oversight within the AI-100 guidelines has )een severely challenged. This emergent work, along with the large number of design basis issues, has hampered the licensee's ability to successfully reduce the increasing backlo To help address this issue, two temporary supervisor positions will be used to supplement the discipline supervisors in controlling the increasing trend in the backlog for the following activities:

. Reduce the existing backlog of REA's  !

• Assure Problem Reports. Corrective Action Plans. Notes Items and l Precursor Cards are completed in a timely manner '

• Coordinate and approve other documentation with the discipline supervisors to reduce the backlog i e Support initiation and control of the engineering scheduling 3rogram ,

. 3rovide coaching to the discipline supervisors l

The structural design discipline supervisor will be utilized to I supplement the Mechanical / Structural Engineering sections and the  :

nuclear engineering design supervisor will supplement the Electrical /I&C

, Engineering sections. A senior structural engineer will be temporarily stepped up to fill the vacant structural design discipline supervisor I position.

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l The licensee anticipates that this effort will improve the management oversight at the supervisor level, improve their effort to reduce the backlog in NED and reduce the extensive overtime that the supervisors have been required to perform. This temporary reorganization will be evaluated by the licensee in six months to determine its effectiveness.

! E8 Miscellaneous Engineering Issues E8.1 Corrective Action Proaram a. Insoection Scooe (37550. 40500. 92903)

l The purpose of this inspection effort was to review licensee actions in resolving and preventing conditions that degrade the quality of plant operations or safety. This included reviewing the licensee's corrective actions implemented to address the five areas of concern that were identified by the NRC.

, b. Observations and Findinas As a result of previous inspections at CR-3 the NRC identified five general areas of concern where licensee performance has been and continues to be weak. The five areas of concern are:(1) Insufficient Managem.ent Oversight and Involvement: (2) Marginally Effective Engineering Organization: (3) Lack of an Understanding and Knowledge of the Crystal River 3 Design Basis: (4) Lack of Sensitivity to the Need to Comply With Regulations: and (5) Operator Performance. These five areas of concern were first discussed with Florida Power Corporation (FPC)

during a Management Meeting held in the NRC Region 2 office on April 16, 1996, and during subsequent Management Meetings held at the CR-3 site on June 11, 1996, and August 28, 1996. Findings from the NRC Integrated Performance Assessment Process (IPAP) inspection (performed July 8-12 and July 18-25, 1996) were also incorporated into these five areas of concer The inspectors reviewed the implementation of corrective actions outlined in the licensee's Management Corrective Action Plan (MCAP) for the five areas of concern. These corrective actions were discussed in meetings with the NRC on June 11. 1996, and August 28, 199 The inspectorr reviewed the status of.sciected items that were listed in the ,

licensee's MCAP to address four of the five areas of concer !

Documentation and other objective evidence were reviewed to verify that 1 the licensee had completed the specific actions to address the issue Action itencs related to the following four areas of concern were reviewed:

(1) Insufficient Management Oversight and Involvement This area also included the IPAP team findings regarding performance standards, corrective action program, and quality assurance program ineffectiveness. Licensee actions completed or

in progress to address this area included initiation of Phase II l

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I of the MCAP. establishment of a root cause team to determine the root causes of the five areas of concern and changes in the e assessment process by the Quality Programs (0P) Departmen The inspectors noted that the efforts of the root cause team were .

still in progress. Changes in the GP assessment process included '

realigning audits into the four SALP areas and supplementing the audits committed to in the FSAR by assigning two or more auditors '

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to audit continuously each of the four SALP areas. Quarterly audit reports of each SALP area were to be issued to licensee  ;

i managemen Interim update reports for each SALP area were being t

! issued monthly. The new assessment process was implemented in .

July 1996. The inspectors reviewed the July 1996, and August l 1996. monthly OP update assessment reports issued for the SALP l '

areas and noted that OP identified a number of findings during these continuous assessments. The first cuarterly audit report ,

under the new assessment process was scheculed to be issued after

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September 30, 199 In addition to the above changes in the

! Quality Programs organization, the licensee has also named a new i Director of Quality Programs who assu,ad the position on l October 1. 199 i (2) Marginally Effective Engineering Organization l

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Licensee actions implemented to address this area included assigning the Site Vice President as acting Director.of l Engineering. Engineering organization restructured.10-12 new .

! positions and additional contractor support being added to the Engineering organization. Included in restructuring of the Engineering organization was establishment of the Rapid Response Team (RRT) grou This group was established in July 1996, to provide rapid engineering technical support to the Operations.

l Maintenance and Engineering organizations. The RRT consisted of personnel from Design Engineering and System Engineering with l expertise in mechanical. I&C. and electrical engineering. The I

inspectors noted that the RRT was involved in several activities

,

during the month of July to support the plan (3) Lack of an Understanding and Knowledge of the Crystal River 3 Design Basis i Licensee actions implemented to address this area included l establishment of an independent design review panel to perform an inde)endent assessment of the CR-3 design bases and the adequacy of t1e design basis management control processes: review of the cumulative effects of design basis issues (reported via LERs) on

.

CR-3 operation:- and identification of plant upgrades on the

? engineering prioritization list to increase design margins.

.

The inspectors reviewed the licensee's actions and determined that

! the independent design review panel efforts were still in i progress. Plant upgrades to increase design margins have been

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included in the top ten priorities for design engineering. Some ,

of the plant upgrades included in the top ten priorities were high pressure injection, diesel generator, building spray pump, emergency feedwater initiation and control, et (4) Lack of Sensitivity to the Need to Comply With Regulations l The licensee identified 19 actions to address regulatory sensitivity. Some of the actions have been completed and others <

were still in progress. Some of the actions im)1emented to '

address this area included reassigning responsiaility for LER 4 preparation, creating the Nuclear Safety Assessment Team, and :

assigning new personnel to site suppor Conclusions The inspector concluded that although the licensee had implemented actions to address the MCAP (including the MCAP Phase II), these actions had not been in place long enough to assess their effectiveness in improving the licensee's performance in these areas of concer !

l lya. Plant Support i i

R1 Radiological Protection and Chemistry (RP&C) Controls i

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R1.1 Radiolooical Surveys Insoection Scooe (83750)

The inspectors followed up on a licensee identified problem concerning inadequate radiological survey and posting activities for a radiation area located outside the licensee's primary Radiological Control Area (RCA). Observations and Findinos On September 6,1996, a radiation survey was made on the exterior l

surfaces of sea-land containers located on the south side of the sit ,

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The containers were located outside the primary RCA but within the licensee's protected area, and held radioactive contaminated equipment i and material used during Re-Fueling Cutages (RFOs). One of the containers, number 69-1044, held contaminated ventilation equipment utilized by the site's Radiation Protection (RP) staff. The RP technician performing the September 6, 1996 radiation survey found the container had a contact dose reading of 14 mrem /hr and radiation level of 2.5 mrem /hr at 100 centimeters. The licensee posted the small area outside the sea-land container as a Radiation Control Area (RCA). The

licensee identified the 3roblem in a Problem Report and notified the

,' Resident Inspectors of tie event. A following survey of the container, made on September 9,1996, identified a radiation level of 5.5 mrem /hr

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at 30 centimeters from the surface of the container, requiring a few ft2 l

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to be posted a radiation area. At that time, the licensee moved the sea-land container back into the primary RCA. The licensee's corrective -

actions on September 9. 1996, eliminated the non-conformance conditio The Radiation Protection Manager (RPM) met with the RP staff during the :

week of September 9,1996 to discuss the inadequate radiation survey on the sea-land container and the needed attention to detai CFR 20.1501(a) states, in part, each licensee shall make or cause to be made, surveys that (1) may be necessary for the licensee to comply !

with the regulations in this part and (2) are reasonable under the '

circumstances to evaluate: (i) the extent of radiation levels: (ii) ;

concentrations or quantities of radioactive material and (iii) the potential radiological hazards that could be presen l 10 CFR 20.1003. defines a radiation area as an area, accessible to !

individuals, in which radiation levels could result in an individual !

receiving a dose equivalent in excess of 0.005 rem in one hour et 30 ;

centimeters from the radiation source or from any surface that the !

radiation penetrate CFR 20.1902(a) states, the licensee shall post each radiatiori area with a conspicuous sign or signs bearing the radiation symbol and the l words " Caution Radiation Area."  ;

The failure of the RP staff to conduct an adequate radiological survey for the detection of radiation at levels requiring the posting as a radiation area was identified as a violation of 10 CFR 1501(a). The !

sea-land container had been moved out of the primary RCA to the berm l l sometime following the RF0 10 which was completed May 17, 1996, and the radiation levels on the container should have been identified at that time. The safety significance of the violation was low in that: the affected radiation area was small (only a few square feet): outside

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normal traffic routes of plant workers: and the radiation dose level was low and just slightly above the levels requiring posting as a radiation area. This licensee identified and corrected violation is being treated i as a Non-Cited Violation, consistent with section VII.B.1 of the NRC i

Enforcement Policy. This is NCV 50-302/96-11-05. Failure to conduct an adequate radiation surve c. Conclusions One Non-cited Violation was identified for failure to conduct an adequate radiation surve No other concerns with the licensee's radiation survey programs were identi fie ,

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15 R1.2 Solid Radioactive Waste Insoection Scooe (86750)

The inspectors reviewed licensee activities associated with the licensee's solid radioactive waste progra Observations and Findinas l The inspectors reviewed the licensee's performance concerning the l

reduction of radioactive waste generation and the licensee's plans to )

l reduce it further. To reduce radioactive waste generation and disposa l

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the licensee established a Radioactive Waste Reduction Task Force in 1993. The licensee had good success in reducing the volume of 1 radioactive waste generated at the site in recent years. The licensee J has also used vendor volume reduction processes to reduce the total .

solid radioactive waste disposal volume. The disposal volume has l

1992-

{

continup:d 224.2 m to decline m:

1993-15 in3 recent yearsmwith 1994-7 the

and following, 1995-12.2 m. levels:

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The total waste generated in 1995 was 4.204 ft' while the total in l calendar year 1996 through the inspection. was significantly higher at

7.979 ft. A condenser tube leak in January had produced approximately i 2.200 ft 3of the waste. An extended RF0 was also a significant l contributor. The licensee also reported that the volume of waste disposed of could increase in the near future with plans to abandon <

,

some volume reduction processes and ship solid radioactive waste l l directly to a disposal site. The change would reduce total cost of I l waste dis)osal but would cause the disposal volume to increase. To j counter tie disposal volume increases the licensee was developing detailed processes to reduce the volume of radioactive waste generate The Radioactive Waste Reduction Task Force had developed plans to identify and control items contributing to the solid radioactive waste stream. The licensee had identified approximately 50 items contributing to the solid radioactive waste. These items were sorted into 5 groups and each item was assigned to a staff membe The assigned staff member l was to evaluate the use of that item and look for methods to reduce its

use and to establish guidelines for it's proper use. The licensee planned to have the project completed and implemented for use prior to the next RF0 Cycl The inspectors toured the licensee's radioactive waste storage areas and I the yard outside the primary RCA boundary. No concerns with I radiological controls for the areas were identified. The primary RCA

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boundary appeared to be adequately posted.

l

' Conclusions The licensee appeared to be taking an active approach to reducing radioactive waste and appeared to have sufficient management support and resources to accomplish the task. The licensee was proactive in

. searching for more effective measures to reduce solid radioactive wast l l

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R3 RP&C Procedures and Documentation i

R3.1 Chemistry Proaram Reviews Insoection Scooe (84750)

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The inspectors reviewed selected chemistry activities to determine whether the licensee was adequately controlling the quality of primary and secondary coolants to ensure long-term integrity of the reactor and secondary coolant pressure boundaries and minimize out-of-core radiation field buildu ! Observations and Findinos The inspectors observed chemistry personnel performing chemistry routines. The inspectors reviewed applicable procedures and observed '

personnel collecting and analyzing reactor coolant system samples. The ins)ectors found the equipment utilized was calibrated and monitored wit 1 appropriate Quality Controls (OCs). The results of the analysis were all well within acceptable ranges for the parameters being measured !

and the results were documented in accordance with licensee procedure The results of the licensee's particip6cion in an interlaboratory cross check program was reviewed for the three previous quarters. Overall, the licensee's analytical performance during that period was good.

l The inspectors reviewed the feedwater quality parameters described in Table 4-11 of the licensee's FSAR and found all 3arameters were well within the limits described. No concerns with clemistry parameters were identifie The inspectors reviewed the licensee's Nuclear Chemistry Quality control Manual issued January 18, 1996. Overall, this document adequately described the licensee's OC program and should help the staff maintain f and demonstrate proper analytical processes. The inspectors discussed l the licensee's processes for documentinc and taking corrective measures l when quality control checks revealed potential problems. The inspectors '

l inquired about the specific actions taken for specific control

! measurements outside their associated control limits. In some cases it was difficult to determine what actions the licensee had taken to re-check or correct non-conformance conditions due to a lack of documentation. The licensee had an electronic logbook in the lab but it did not appear to have sufficient space to permit technicians to clearly and adequately describe specific corrective measures taken. The inspectors discussed the issue with the QC coordinator. The QC manual did not provide the laboratory technician with any guidance on the proper level of documentation needed to demonstrate that a quality

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control problem was appropriately resolved. This probiem was also identified by the Quality Assurance (QA) department in it's audit report 96-03-CREW (see paragraph R7.1), and a Problem Report was generated to address the auditors concern. The response to the Problem Report acknowledged that there was insufficient space on the action line in the

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QC software to provide all the necessary detail when documenting follow up of QC 3roblems. The Problem Report response stated that there was not enougl room on the action line in the QC software to reference an instrument logbook entry on the action line, and document the corrective actions in the instrument logbook. That was discussed with the technicians in the lab. However, the licensee did not modify any written procedures to describe the desired documentation process for controls outside limit c. Conclusions The inspectors found the Chemistry personnel contacted were well qualified and knowledgcable of the chemi.stry procedures. The licensee has taken steps to improve QC measures in the Chemistry Laboratory with the newly issued QC manual. The inspectors concluded that failure to adequately describe the corrective action documentation process in written procedures was a QC program weaknes Obtaining sufficient documentation to clearly demonstrate corrective actions for controls outside limits remained a challenge. No additional concerns were identified by the inspector R3.2 Transoortation of Radioactive Waste and Material a. Insoection Scooe (86750. TI 2515/133)

The inspectors reviewed the licensee's transportation arocedures for compliance with applicable requirements and verified tlat the licensee had provided training to all radioactive waste technicians, b. Observations and Findinas The licensee had hired a contractor to re-write the transportation arocedures incorporating the revised Department of Transportation and 1RC transportation regulations for the shipments of radioactive materials. The inspectors reviewed selected portions of the licensee's transportation procedures and found they adequately incorporated the regulatory change c. Conclusions The reviewed transportation procedures adequately incorporated the revised regulatory requirements for shipments of radioactive materia R7 Quality Assurance in RP&C Activities R7.1 Procram Audits and Corrective Actions a. Inscection Scooe (83750. 84750 and 86750)

The inspectors reviewed the recently completed chemistry, environmental, radioactive waste and radiation protection audits to verify the licensee

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was performing periodic assessments of the programs and to verify the l licensee was correcting identified audit deficiencie l Observations and Findinas

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The inspectors reviewed licensee audit 96-03-CREW. Audit Report of l Chemistry, Radiation Protection. Environmental Monitoring and Waste,

conducted during the period of February 19 through June 6.1996. The audit report was issued August 7, 1996. The scope of the review was large and six findings and thirty-seven weaknesses were identified. The audit report format listed the audit questions and the associated auditors findings. While questions were grouped by program area. the overall assessment of a program area was left up to the reader to interpret as the audit report did not summarize the assessment by program areas. The findings were placed into the licensee *s corrective action program through the generation of Problem Reports. The weaknesses were documented on Precursor Card Precursor Cards were

,

written to identify weaknesses that could lead to additional problems if l not corrected.

L The inspectors selected several issues identified in the audit report to

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review and to see that corrective actions were adequate and timely to l prevent recurrence. In general, issues identified in Problem Reports were being corrected. However, the inspector found that the response to i

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Precursor Cards did not always address the identified problem and the

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completed corrective actions were not always documented. The Precursor Card responses also did not address corrective actions to prevent recurrence. Most of the reviewed Precursor Cards described returning a non-conformance condition back into a conformance state. The Precursor Cards did not' appear to be an effective corrective action process.

l There also seemed to be a general lack of understanding concerning l corrective action concepts among the staff beyond returning a non-conformance condition to a conformance condition.

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l During the review of issues identified in the licensee audit 96-03-CREW, l the inspectors determined that the licensee's auditors had identified a sampling deficiency of Offsite Dose Calculation Manual (ODCM)

requirements.

l Technical Specification (TS) 5.6.1 states, in part, written arocedures shall be established, implemented, and maintained covering tie programs specified in TS 5.6.2. Section 5.6.2 states, in part, the ODCM shall be established, implemented, and maintaine ODCM Table 2-1. " Radioactive Liquid Effluent and Process Monitoring Instrumentation." recuired the Decay Heat Closed Cooling Water System (DHCCWS) Monitors (RF-L5 and RM-L6) be operable in all modes. Action i statement 24 permitted plant operations with no channels operable

! arovided grab samples were collected and analyzed at least once every 24 1ours.

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Contrary to the above, during the period of May 15 through June 13, 1995 (Approximately 29 days) the RM-L5 monitor was out of service and the licensee failed to take the daily grab samples of DHCCWS on [

approximately 22 of those day As documented in the 96-03-CREW audit report, the auditors determined that the Chemistry Department had failed to take daily grab sample during 1995, when the monitors were out of service. The Chemistry staff I had taken weekly surveys of the DHCCWS during that period. The issue was brought to the attention of the Chemistry Department during the i audit, which began a review of the problem. The Chemistry staff '

acknowledged the weekly sampling frequency of the DHCCWS during May and June of 1995 differed from the daily requirements specified in Table 2-1 of the ODCM. The Chemistry Department reported to the auditors that the ,

DHCCWS was not normally an operating system, and the monitors (RM-L5 and ;

. RM-L6) were not effluent monitors but process monitors. Thu interpretation of the sampling requirements from daily to weekly had been made based on those considerations. The OA auditors expressed i concern with the Chemistry Department's lack of regard for compliance i with the ODCM requirements to the Chemistry Department Manage !

Following that discus.sion the Chemistry Department initiated a Problem ;

Repor !

The inspectors discussed the issue with members of the licensee's ;

Chemistry staff. At some point in time the Chemistry Department had ;

interpreted the applicability of action statement 24 of Table 2.1 for RM-L5 and RM-L6 to require a daily sample when the DH CCW was operating, ,

and a weekly sample when the system was not in operation. Since the !

system was not normally in operation, operations was required to start and recirculate the system for the sample collection. The inspectors !

asked the licensee when and how that interpretation had been determine !

documented and approved. The licensee representatives reported that they did not know when the exact time that interpretation had been made

or specifically who had made it. However, the licensee re)orted that interpretation had been used during the last two years. T1e licensee revised the ODCM in August 1996 to require the daily sample of the '

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L DHCCWS when the system was operating, and weekly when it was not operating. The inspector verified that the licensee had completed a ,

formal review of the ODCM chang !

l The inspectors stated that the failure of the Chemistry Department to L adhere to the requirements of the ODCM was a violation of the licensee's j TS requirements. This licensee identified and corrected violation is i

being treated as a Non-Cited Violation, consistent with section VII.B1 of the NRC Enforcement Policy. This is NCV 50-302/96-11-06. Failure to !

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follow sampling requirements of the ODC Conclusions l l

' The licensee's audit staff identified numerous issues for program i improvements. However, the audit report format was difficult to read ;

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and did not do a good job of reporting overall program performance. The !

Precursor Cards did not always result in corrective actions and  ;

documentation of completed corrective actions was sometimes poo The

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staff knowledge of corrective action concepts appeared wea i <

The ODCM violation was another example of the licensee's failure to instill strict adherence to the regulatory requirements, and raised concerns about the staff's ability to properly review TS program change ,

l S8 Miscellaneous Security and Safeguards Issues l S8.1 Security Watch Posted For Emeraency Diesel Generators (71750)

On October 3. 1996 at approximately 12:33 p.m; operators performing a l

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surveillance in the A EGDG fan room found two pennies lying on the floor. The pennies were lying on the floor between a fire service water pipe and a tool storage box. The SS0D notified the NSM. Security, the resident inspectors, and the Acting DNPO. Upon further ins)ection, the ANSS found a quarter under the tool bo Security posted t1e EGDG ;

rooms, took pictures of the area, and took possession of the coins. The '

system engineer and an SR0 made a walkdown and inspection of both EGDGs and their associated equipment for any sign of tampering. Nothing unusual or abnormal was found. The location of the coins indicated that they could have been lost out of a persons pocket if they were to sit i down on the tool bo Based on the investigation and evidence presented. this incident was classified as a non-malicious accidental loss of personal property and the security watch was suspende L. Manaaement Meetinas X1 Exit Meeting Summary The inspection scope and findings were summarized on October 7.1996.

! The inspectors described the areas inspected and discussed in detail the inspection results listed below. Proprietary information is not L contained in this report. Dissenting comments were not received from j

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the licensee.

i X4 Management Changes X4.1 Personnel Chanaes j Effective October 1. 1996. Mr. R. Yost assumed the position of Manager, ,

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t Quality Assessments.

l l Effective September 23. 1996. Mr. D. Watson assumed the position of

Manager, Nuclear Security.

[ Effective October 1.1996, all Directors started reporting directly to  !

! Mr. P. Beard. Mr. G. Boldt will continue to act as the Acting Director

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. of Engineering.

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Effective October 1. 1996. Mr. P. McKee joined the Operations Department as Manager. Nuclear Plant Operations Support, reporting to Mr. R. Davis.

I Effective October 1. 1996. Mr. B. Lagger was appointed Acting Manage Radiation Protectio Effective November 19. 1996. Mr. J. MacKinnon will replace Mr. P. McKee'

as' Chairman of the NGR PARTIAL LIST OF PERSONS CONTACTED y Licensees l

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L K. Baker. Manager. Nuclear Configuration Management l J. Baumstark. Director. Quality Programs i

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P. Beard Senior Vice President. Nuclear Operations G. Boldt Vice President Nuclear Production J. Cam 3 bell Assistant Plant Director. Maintenance and Radiation Protection W. Con (lin. Jr.. Director. Nuclear Operations Materials and Controls i R. Davis. Assistant Plant Director. Operations and Chemistry l D. DeMontfort. Manager. Nuclear Operations l M. Donovan. Supervisor Rapid Engineering Response Team l R. Fuller. Manager Nuclear Chemistry B. Gutherman. Manager. Nuclear Licensing l l G. Halnon. Assistant Director. Nuclear Operations Site Support J B. Hickle. Director Nuclear Plant Operations '

L. Kelley. Director Nuclear Operations Site Support H. Koon. Manager. Nuclear Production and Nuclear Outage K. Lancaster. Manager Nuclear Projects J. Maseda Manager. Engineering Programs P. McKee. Manager Nuclear Plant Operations Support l R. McLaughlin, Nuclear Regulatory Specialist  !

W. Rossfeld. Manager. Site Nuclear Services J. Stephenson, Manager. Radiological Emergency Planning l F. Sullivan. Manager. Nuclear Engineering Design '

P. Tanguay. Director. Nuclear Engineering and Projects J. Terry, Manager. Nuclear Plant Technical Support D. Watson, Manager Nuclear Security l R. Widell Director Nuclear Operations Training

- D. Wilder. Manager. Safety Assessment Team K. Wilson. Principle Engineer. Nuclear Operations NRC l

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B. Crowley. Reactor Inspector. Region II (September 16 through 20. 1996 and i September 23 through 25. 1996)

l P. Harmon. Reactor Inspector. Region II (September 9 through 13, 1996) !

l L. Raghavan. Project Manager NRR (September 9 through 11. 1996)

L. Stratton. Physical Security Specialist. Region II (September 23 through 25.

1996) l i

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i 1 22 M. Thomas. Reactor Inspector, Region II (September 16. through 20, 1996)

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F. Wright, Senior Radiation Specialist. Region II (September 9 through 1 )

INSPECTION PROCEDURES USED

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IP 37550: Engineering IP 37551: Onsite Engineering IP 40500: Effectiveness of Licensee Controls in Identifying, Resolving and

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Preventing Problems )

IP 61726: Surveillance Observations l IP 62707: Conduct of Maintenance l

! IP 71707: Plant Operations l IP 71750: Plant Support Activities l IP 83750: Occupational Radiation Exposure IP 84750: Radioactive Waste Treatment and Effluent and Environmental Monitoring IP 86750: Solid Radioactive Waste Management and Transportation of Radioactive Materials IP 92901: Followup - Plant Operations l IP 92902: Followup - Maintenance ,

l IP 92903: Followup - Engineering l l IP TI 2515/133: Implementation of revised 49 CFR parts 100 - 179 and part 71 i ITEMS OPENED, CLOSED, AND DISCUSSED

Opened Typ_e Item Number Status Descriotion and Reference l VIO 50-302/96-11-01 Open Inadequate work instructions to l

, prevent the inadvertent start of the A emergency diesel generato (paragraph 03.1)

VIO 50-302/96-11-03 Open Personnel performing work on the reactor building sump without logging onto a clearance, as required by the ap3 roved Work Request. (paragrapa M2.1)

VIO 50-302/96-11-04 Open Reactor building sump not being constructed in accordance with approved construction drawing (paragraph M2.1)

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Closed ,

Iype Item Number Status Descriotion and Reference

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NCV 50-302/96-11-02 Closed Failure to meet Technical Specification 5.2.2.e requirements for scheduling of work in excess of 72 hours8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> in a seven day perio (paragraph 06.1)

NCV 50-302/96-11-05 Closed Failure to conduct an adequate radiation survey. (paragraph R1.1) ,

'NCV 50-302/96-11-06 Closed Failure to follow sampling requirements of the Offsite Dose Calculation Manual. (paragraph R7.1)

Discussed 5 i

Iyp_g Item Number Status Descriotion and Reference

! URI 50-302/96-201-01 Open Long term )lant cooldown following a

, small breat LOCA assuming a single failure in the heat drop line.

(paragraph M2.1)

l LIST OF ACRONYMS USED ac - Alternating Current

'ADI - Absolute Drift Indications

! AE - Architect Engineer AHD - Air Handling Vent and Cooling Damper AHV - Air Handling Vent and Cooling Valve

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AI - Administrative Instruction i

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ALARA - As Low as Reasonably Achievable ANSI - American National Standards Institute ANSS - Assistant Nuclear Shift Supervisor ,

APC - Alternate Plugging Criteria '

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ASME - American Society of Mechanical Engineers ASV - Auxiliary Steam Valve i AWS - American Welding Society l

B&PV - Boiler and Pressure Vessel B&W - Babcock & Wilcox BS - Building Spray BSP - Building Spray Pump

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BVT - Below Voltage Threshold BWST - Borated Water Storage Tank l CAL - Confirmatory Action Letter d

CCTV - Closed Circuit Television ,

CCW - Component Cooling Water j CFR - Code of Federal Regulations

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CFT - Core Flood Tank CFV - Core Flood Valve CP - Compliance Procedure CREVS - Control Room Emergency Ventilation System CR3 - Crystal River Unit 3 CST - Condensate Storage Tank dc - Direct Current DC - Decay Heat Closed Cycle Cooling DCHE - DC Heat Exchanger DEV - Deviation DFP - Diesel Fuel Pump DH - Decay Heat DHCCWS - Decay Heat Closed Cooling Water System DHHE - Decay Heat Heat Exchanger DHP - Decay Heat Pump DHR - Decay Heat Removal DHV - Decay Heat Valve '

DNP0 - Director. Nuclear Plant Operations dp - Differential Pressure EA - Enforcement Action ECCS - Emergenc_y Core Cooling System (s)

EDBD - Enhanced Design Basis Document EDG - Emergency Diesel Generators EEI - Escalation Enforcement Item EFIC - Emergency Feedwater Initiation and Control EFP - Emergency Feedwater Pum)

EFT - Emergency Feedwater Tanc EFW - Emergency Feedwater i

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EFV - Emergency Feedwater Valve EM - Emergency Plan Implementing Procedure E0P - Emergency Operating Procedure EP - Emergency Preparedness ES - Engineered Safeguards

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ESF - Engineered Safeguards Feature ESAS - Engineered Safety Actuation System ET - Eddy Current Test EVS - Emergency Ventilation System F - Fahrenheit FPC - Florida Power Corporation FSAR - Final Safety Analysis Report l FWP - Feedwater Pump l FWV - Feedwater Valve l GL - Generic Letter

- Gallons Per Minute

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gpm HELB - High Energy Line Break HP - Health Physics '

HPI -

High Pressure Injection in. Hg - Inches of Mercury I&C - Instrumentation and Control

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ICC - Inadequate Core Cooling ICS - Integrated Control System IEEE - Institute of Electrical and Electronics Engineers

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f f

IFI - Inspection Followup Item  :

INPO -

Institute of Nuclear Power Operations IP -

Inspection Procedure  ;

IPAP -

Integrated Performance Assessment Process  ;

IR - Inspection Report  !

ISA - Instrument Society of America .

1 ISI - Inservice Irspection j 150 - Isometric Drawing .

IST- - Inservice Test <

ITS - Improved Technical Specification  !

JC0 - Justification for Continued Operation i JPM - Job Performance Measure ,

Kv - Kilovolt i Kw - Kilowatt '

LCO - Limiting Condition for Operation i LER - Licensee Event Report '

LOCA- - Loss of Coolant Accident l l

LOOP - Loss of Offsite Power i i LPI - Low Pressure Injection LTE -

Lower Tube End LTS - Lower Tube Sheet '

MAR - Modification Approval Record MCAP - Management Corrective Action Plan l MCB - Main Control Board '

MCC - Motor Control Center .

MFW - Main Feedwater MOV - Motor Operated Valve  !

M0 VATS - Motor Operated Valve Analysis and Test System MP - Maintenance Procedure MRP - Management Review Panel ]

i MSV - Main Steam Valve  :

l MT - Magnetic Particle Testing l MU - Make Up ].

l MUP - Make-up Pum)

i MUT - Make-up Tan (

MUV - Make-up Valve

- Megawatt

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MW NCV - Non-cited Violation

, NDE - Nondestructive Examination l NED - Nuclear Engineering Design

- Nuclear Engineering Procedure

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NEP NGRC - Nuclear General Review Committee N00 - Nuclear Operations Department NOV' - Notice of Violation NPSH - Net Positive Suction Head NOI - Non-Quantifiable Indication t NRC -

Nuclear Regulatory Commission-NRR - Office of Nuclear Reactor Regulation l NSM - Nuclear Shift Manager i NSSS - Nuclear Steam System Supplier

NUREG -

NRC technical report designation OCR - Operability Concerns Resolution

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ODCM .- Off-Site Dose Calculation Manual E OP - Operating Procedure OSB - Operations Study Book OTSG - Once Through Steam Generator

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PM Preventive Maintenance '

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PORV - Power Operated Relief Valve nb --Parts Per Billion .

31 - Problem Report '

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PRC - Plant Review Committee '

PSI - Preservice Inspection

, asig -

aounds )er square inch gauge i

)T -

_iquid )enetrant i PTLR - Pressure and Temperature Limits Report OC - Quality Control  ;

OA- --Quality Assurance OAP - Quality Assurance Procedure OC - Quality Control OP - Quality Programs 1 RB --Reactor Building

! RC - Reactor Coolant 4

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RCA - Radiation Control Area '

RCP - Reactor Coolant Pump (' RCPPM - Reactor Coolant Pump Power Monitor i RCS - Reactor Coolant System )1 l

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REA - Request for Engineering Assistance RF0 - Refueling Outage RG - Regulatory Guid Radiation Monitor

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RM '

! R0 - Reactor Operator i

! RP - Radiation Protection i RPC - Rotating Pancake Coil

, RP&C- - Radiological Protection and Chemistry l RPM - Radiation Protection Manager l RRT - Rapid Res)onse Team ,

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RT - Radiograplic Inspection i RW - Nuclear Services and Decay Heat Seawater RWP - Nuclear Services and Decay Heat Seawater Pump l RWV - Nuclear Services and Decay Heat Seawater Valve l SALP - Systematic Assessment of Licensee Performance SAT - Systems Ap3 roach to Training SBLOCA - Small Brea( Loss of Coolant Accident SDT - Station Drain Tank SER - Safety Evaluation Report SFPD - Safety Function Determination Program SG - Steam Generator SOER- - Significant 0)erating Event Report

SP - Surveillance )rocedure

SR - Surveillance Requirement

! SS00 - Shift Supervisor on Duty

STI - Short Term Instruction

SW - Nuclear Services Closed Cycle Cooling System i SWHE - SW Heat Exchanger l

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. - _ . . . . . - _ _ _ SWP - SW System Pump SWV - SW System Valve

- Cold Leg Temperature T}

T - Temporary Instruction TMAR - Temporary Modification Approval Record TMI - Three Mile Island TS - Technical Specification TSC - Technical Support Center TSCR - Technical Specification Change Request TW - Through Wall UAf - A measure of heat exchanger effectiveness UHS - Ultimate Heat Sink URI - Unresolved Item USAS - United States of America Standards UT - Ultrasonic Test VIO - Violation VOTES - Valve Operation Test and Evaluation System V)p - Volts point-to-point WR - Work Request

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