ML20215A471

Insp Rept 50-302/87-12 on 870410-0511.Violations Noted:Maint Performed on Control Complex Air Compressor AHP-1C Exceeded Work Instructions Provided in Part II of Work Request W/O Prior Evaluation of Nuclear Planning Coordinator

ML20215A471
Person / Time
Site:	Crystal River
Issue date:	06/03/1987
From:	Stetka T, Tedrow J, Wilson B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20215A432	List: ML20215A429 ML20215A440 ML20215A471
References
50-302-87-12, NUDOCS 8706160673
Download: ML20215A471 (19)

See also: IR 05000302/1987012

Text

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Smtiro UNITED STATES

/ #

o NUCLEAR REGULATORY COMMISSION

[' , REGION 11

,g- y. 101 MARIETTA STREET.N.W.

'* *. ATLANTA, GEORGI A 30323

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Report No: 50-302/87-12

Licensee: Florida Power Corporation

3201 34th Street, South

St. Petersburg, FL 33733 ,

Docket No: 50-302 .

License No.: DPR-72

-Facility Name: Crystal River 3

-Inspection Dates: April 10 - May 11, 1987'

Inspector: k. N M<- - ' dM 7

<T.VF . Stet a, Senior Resident / Inspector. Datd Signed

D

J. E. Tedrow, Resident Inspectof.

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Date' Signed

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Approved by: b A E2

W A. W1Tson, SectroirChief ~f ' Date ' Signed

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Division of Reactor Projects

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SUMMARY

Scope: This routine inspection was conducted by two resident inspectors in the

areas of plant operations, security, radiological controls, Licensee Event

Reports and Nonconforming Operations Reports, 10 CFR Part 21 compliance,

nonroutine operating events, and licensee action on previous inspection items.

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Numerous facility tours were conducted and facility operations observed. Some

of these tours and observations were conducted on backshifts.

Results: One Violation was identified: (Failure to adhere to and have adequate

plant procedures, paragraphs 5.b(8)(a), (c), and (e), 5.b.(9), and 6.b.(3)).

870616067387M$02

ADOCK

PDR PDR

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• J. Alberdi, Assistant Director, Nuclear Plant Operations

• W. Bandhauer, Assistant Nuclear Plant Operations Manager

J. Barrett, Principal Nuclear Mechanical Engineer

J. Brandely, Nuclear Security and Special Projects Superintendent

• P. Breedlove, Nuclear Records Management Supervisor

• C. Brown, Manager, Outages

• J. Cooper, Superintendent Technical Support

B. Hickle, Manager, Nuclear Plant Operations

• M. Jacobs, FPC Public Information

• R. Jones, Nuclear Modifications Specialist

• M. Mann, Nuclear Compliance Specialist

• W. Marshall, Nuclear Shift Supervisor

• P. McKee, Director, Nuclear Plant Operations

E. Renfro, Director, Nuclear Operations Materials and Controls

S. Robinson, Nuclear Waste Manager

• W. Rossfeld, Nuclear Compliance Manager

W. Squires, Air Conditioning Mechanic

K. Vogel, Nuclear Operations Engineer

• R. Widell, Manager, Nuclear Operations Engineering

D. Wilder, Radiation Protection Manager

, *K. Wilson, Manager, Site Nuclear Licensing

Other personnel contacted included office, operations, engineering,

maintenance, chemistry / radiation and corporate personnel.

• Attended exit interview

2. Exit Interview

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

at the conclusion of the inspection on May 11, 1987. During this meeting

the inspectors summarized the scope and findings of the inspection as they

are detailed in this report with particular emphasis on the Violation,

Unresolved Item (UNR), and Inspector Followup Items (IFI).

The licensee representatives acknowledged the inspector's comments and did

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

by the inspectors during this inspection.

3. Licensee Action on Previous Inspection Items

(Closed). Deviation 302/87-01-01: As documented in an Interoffice

Correspondence dated April 3,1987, personnel involved with the decision

to defer the hydrogen monitoring check valve test were counseled on their

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responsibilities to meet NRC commitments. In the response letter dated

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March 27, 1987, the licensee requested a change to the commitment from the

NRC to allow this test to be run prior to startup from the next refueling

outage. This new commitment was accepted by-the NRC in a letter dated

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April 8, 1987.- Followup on this testing completion will be tracked by

open violation (302/86-23-02).

(Closed) Violation 302/87-01-02: The licensee has completed and the

inspector has verified the completion of the following actions:

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A letter of reprimand, that provided instructions to the

individual involved, was issued on February 11, 1987;

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A Management Review Board was held on January 14, 1987, to review the

cause for failing to follow procedure SP-181 and to determine the

corrective actions that were' necessary. In additfron, a Memorandum

was sent to the supervisor involved to remind him of the plant's

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procedure adherence requirements; *

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The heat-up calculations were recomputed to ensure that Technical

Specification (TS) requirements were not exceeded;

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The release was reported via Non-Conforming Operations Report (NCOR)

< 87-23 and Licensee Event Report (LER) 87-04;

Procedure SP-181 was rerun on January 14, 1987, and the procedure was

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subsequently revised on February 16, 1987;

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Procedure OP-412 was revised into two procedures, OP-412A and

OP-4128, to emphasize procedure intent. The new procedure, OP-4128,

i' which is now used for the tank releases, clarifies the requirement to

check the flow recorder prior to initiating a release.;

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A letter, dated January 20, 1987, was sent to all supervisors from

the Director, Site Nuclear Operations, emphasizing procedure

adherence and reminding that special attention must be paid to

procedure precautions and limitations; and,

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- Procedure SP-422 was revised on April 14, 1987, to clarify how

heat-up and cool-down rates are to be calculated.

(0 pen) IFI 302/87-10-09: A Work Request (WR) has been written to repair

valve CAV-491; however, the licensee has now determined that no

replacement parts are available for this valve. A modification (MAR) is

being developed to replace this valve. As the result of the continuing

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investigation into the leaks in the Intermediate Building (IB) from the

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Post Accident Sampling System (PASS), the licensee has determined that

there appears to be a deviation from the plant's design basis. 10 CFR

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Part 50, Appendix B, General Design Criterion (GDC) 64, requires that

systems that can release radioactive materials to the environs be in an

area so that any of these releases can be monitored. Since the PASS

contains radioactive fluids and has portions of the system in the IB which

has an unmonitored ventilation system, it appears that GDC 64 may have

been violated. The licensee is continuing their investigation of this

event. This item remains open pending identification of the leak source

and completion of the licensee's review into GDC 64 compliance.

(0 pen) IFI 302/86-07-04: The engineering study has determined that the GE

Model 12 CFD relays will need to be replaced. The licensee is developing

MAR 80-09-13-03, EDG Differential Relay Replacement, to replace these

relays. The relays are scheduled to be replaced during the upcoming

refueling outage. This item remains open pending completion of this

modification.

(Closed) IFI 302/86-27-03: The licensee revised procedure SP-312 as

Revision 30 on March 24, 1987 to include a limit for conservative nuclear

instrumentation drift and to provide for an additional check of computer

data with plant instrumentation.

(Closed) IFI 302/84-09-11: Surveillance procedure SP-190 was revised to

include all the local alarm bells in an alarm string. Since this revi-

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sion, procedure SP-190 was subsequently revised so that the procedure is

now broken up into ten separate procedures to allow testing of various

sections of the fire protection system on an individual basis. The latest

version of the procedure was reviewed to verify that testing of all the

local alarm bells was retained.

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(Closed) IFI 302/85-04-06: The licensee revised the applicable emergency

procedures (EM-202, Duties of the Emergency Coordinator, and EM-204(A),

Release and Off-Site Oose Assessment During Radiological Emergencies at

CR-3) so that timely dose release calculations can be made. The ability

to provide a timely dose release calculation should ensure proper radio-

active release reporting.

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(Closed) IFI 302/83-26-02: The licensee implemented an automatic tracking

system in 1984 to track procedure revisions. At that time procedure

revisions were accomplished within a fifteen working day goal. In 1985

and 1986 this goal was shortened to ten working days and the licensee has

been effective since then in keeping the time to accomplish procedure

revisions to ten working days or less.

(Closed) IFI 302/87-01-06: Procedures SP-701, Radiation Monitoring System

Surveillance Program, and SP-442, Special Conditions Surveillance Plan,

have been revised to specify the back up system for the RMA-1 and RMA-2

mid/high range monitors.

(Closed) IFI 302/83-09-02: Procedure MP-412, Fuse Control Program, was

established and implemented to provide fuse installation control. The DC

distribution panel modification was performed under modification (MAR)

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83-06-07-01, AC/DC Fuse Coordination, and this modification has eeen

completed. The _ inspector verified the controlled access storage point

that was established by procedure MP-412, was implemented and contained

the required fuse inventory.

(Closed) UNR 302/85-26-02: Procedure AI-401, Origination of and Revisions

to P0QAM [ Procedures Operating Quality Assurance Manual] Procedures, has

been revised (revision 15) to clarify the Interim Change (IC) revision

requirements. To assure that field personnel are aware that an IC to a

procedure has been implemented, procedure DC/RM-350, Control of Consumable

Procedures, was also revised to require document control personnel to

locate and notify holders of " Working Copy" procedures of the applicable

IC.

(Closed) IFI 302/83-26-03: The licensee implemented a visual surveillance

program of the HFA Relays in accordance with procedure SP-905, GE Type HFA

Relay Spoolpiece Inspection. This inspection was performed periodically

until all the suspect relay coil spoolpieces were replaced. The relay

coil spoolpieces were replaced in accordance with MAR 83-09-28-01, which

was completed in February 1984.

(0 pen) IFI 302/84-09-10: The following activities have been or are being

conducted:

- The licensee has revised Emergency Diesel Generator (EDG) testing

procedures SP-354A and SP-354B to minimize or delay EDG testing

during periods of inclement weather;

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Operator training regarding EDG breaker operation during the event

described in Unusual Operating Event Report (U0ER) 84-01 was con-

ducted; and,

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An engineering study regarding the EDG breaker circuitry concluded

that a modification to the circuitry is required. This modification

(MAR 80-09-13-01) is scheduled to be completed during the upcoming

refueling outage.

This item remains open pending completion of MAR 80-09-13-01.

(0 pen) IFI 302/86-31-04: The licensee has conducted an investigation of

the water contamination found in the oil of the gear cases for the nuclear

services closed cycle cooling pumps (SWP-1A and SWP-1B). The licensee had

previously identified that a heat exchanger head on the gear oil cooler

for SWP-1B was constructed with incorrect dimensions which resulted in

damage to the cooler tubesheet when tested. This problem was identified

during a preinstallation hydrostatic test of the replacement cooler.

Inspection of the original cooler and other replacement cooler heads

indicate that this problem was not generic. The coolers are now consid-

ered to be leaking water due to tube erosion and degradation that occur

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during normal system operation and which results in a shorter cooler

lifespan than previously thought. The licensee has replaced the cooler

'for SWP-1B and has sampled the oil for quality. From these sample results

it appears that the water leakage has been arrested. The licensee is

developing a modification to replace the gear oil coolers with a better

quality cooler which is more resistant to water leakage and will continue

to monitor the oil quality in the. pumps on a monthly basis. The

licensee's evaluation of this problem for 10 CFR Part 21 reportability has

determined that this problem is not reportable. This item will remain

open pending replacement of the gear oil coolers on SWP-1A and SWP-1B.

(Closed) Violation 302/86-12-06: Following notification that the

licensee's housekeeping changes (HKCs) were in violation of the Technical

Specifications (TS), the licensee issued an Interoffice Correspondence

dated March 21, 1986 to their document control personnel to suspend the

use of all HKCs until further notice. On March 11, 1987, an Interoffice

Correspondence was written which stated that procedure AI-401, Origination

of and Revisions to P0QAM Procedures, would be revised to limit HKCs to

only typographical errors. This correspondence was also written to insure

that HKCs were issued only for typographical errors until the new reviced

AI-401 was implemented. Procedure AI-401 was revised and implemented on

April 7, 1987.

(Closed) IFI 302/86-38-14: The final report that documents the results of

the Ultra-sonic Testing (UT) inspection of the main feedwater piping was

reviewed by the inspectors. The report indicates that no pattern of wear

or general pipe wall thinning was occurring.

(Closed) IFI 302/87-04-02: An engineering evaluation regarding the use of

a United Electric (UE) pressure switch for D0-47-PS was completed and

concluded that the switch should be replaced. However, in the upcoming

refueling outage that is scheduled to begin in September 1987, a modifi-

cation will be performed on the domestic water (DO) system which will

result in the removal of this switch. Therefore, in the interim, it has

been determined that the present switch can remain in service until its

removal. This determination was based upon a review of the operating

history of this switch which indicated that no problems with the switch's

calibration or operation have occurred.

(Closed) IFI 302/84-21-02: To insure that procedure changes to procedure

OP-103, Plant Curve Book, are processed expediently, changes to this

procedure will be " walked-through" thus eliminating any delays in the change

process. The licensee also reviewed their administrative procedure that

controls procedure revisions and has determined that this procedure is

adequate to insure timely procedure revision processing.

(Closed) IFI 302/83-07-03: The licensee modified the alarm circuitry for

radiation monitors RMA-3, 4, 5, 7, and 8 such that a loss of power to any

of these monitors would be annunciated. This modification, MAR

83-04-49-01, Failsafe Alarms for RMA's, was completed on August 16, 1984.

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, Procedure . SP-3358, Radiation Monitoring Instrumentation Functional Test

(RML's and Non-Tech. Spec. RMA's), was revised to check monitors RMA-3, 4,

7, and 8 and procedure SP-353, Control Room Emergency Ventilation System

Monthly Test, was revised tu check-the RMA-5 monitor.

(Closed) Deviation 302/86-12-05: The inspector verified that modification

(MAR) 82-10-19-31, RW Pump Flush Water, was completed. The MAR was

completed on March 31, 1986.

(Closed) Violation 302/86-12-04: Licensee Event Report (LER) 85-35, which

was issued on May 6,1987, provided sufficient details to explain the

design error that could have compromised the decay heat removal system.

(Closed) IFI 302/86-38-12: The licensee has completed the short term

protective measures for the sulfur dioxide tank installed at the Unit 1

coal plant. The following actions have been taken:

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A sulfur dioxide monitor equipped with indication and alarm functions

has been installed in the nuclear unit's control room;

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A sulfur dioxide monitor has been installed at the sulfur dioxide

tank which provides an alarm in the nuclear unit's control room

(annunciator window I-1-3, Toxic Gas Detected). This alarm was

installed in accordance with modification MAR 85-02-10-01 and

functionally tested in accordance with test procedure TP-1A;-and,

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Air packs have been provided in the control room. These air packs

have been included in the licensee's preventive maintenance program,

under procedure HPP-502.

4. Unresolved Items

Unresolved items are matters about which more information is required to

determine whether they are acceptable or may involve violations or

deviations. A new unresolved item is identified in paragraph 6 b.(1) of

this report.

5. Review of Plant Operations

The plant continued in power operation (Mode 1) for the duration of this

inspection period,

a. Shift Logs and Facility Records

The inspector reviewed records and discussed various entries with

operations personnel to verify compliance with the Technical Speci-

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

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The following records were reviewed:

Shift Supervisor's Log; Reactor Operator's Log; Equipment

Out-Of-Service Log; Shift Relief Checklist; Auxiliary Building

Operator's Log; Active Clearance Log; Daily Operating Surveillance

Log; Work Request Log; Short Term Instructions (STI); and Selected

Chemistry / Radiation Protection Logs.

In addition to these record reviews, the inspector independently

verified clearance order tagouts.

No violations or deviations were identified.

b. Facility Tours and Observations

Throughout the inspection period, facility tours were conducted to

observe operations and maintenance activities in progress. Some

operations and maintenance activity observations were conducted

during backshifts. Also, during this inspection period, licensee

meetings were attended by the inspector to observe planning and

management activities.

The facility tours and observations encompassed the following areas:

security perimeter fence; central and secondary alarm stations;.

control room; emergency diesel generator room; auxiliary building;

intermediate building; battery rooms; and, electrical switchgear

rooms.

During these tours, the following observations were made:

(1) Monitoring Instrumentation - The following instrumentation was

observed to verify that indicated parameters were in accordance

with the TS for the current operational mode:

Equipment operating status; area atmospheric and liquid

radiation monitors; electrical system lineup; reactor operating

parameters; and auxiliary equipment operating parameters.

No violations or deviations were identified.

(2) Safety Systems Walkdown - The inspector conducted a walkdown of

the safety related portion of the Chillwater (CH) and non-safety

related Appendix R Chillwater systems to verify that the lineups

were in accordance with license requirements for system opera-

bility and that the system drawings and procedures correctly

reflect "as-built" plant conditions.

No violations or deviations were identified.

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(3) Shift Staffing The inspector verified that operating shift

staffing was fn accordance with TS. requirements and that control

room operations were being conducted in an orderly and profes-

sional manner. In addition, the inspector observed shift

turnovers on variou: occasions to verify the continuity of plant

status, operational p*oblems, and other pertinent plant infor-

mation during these tur' overs.

'No violations or deviations were identified.

(4) Plant Housekeeping Conditions -

Storage of material and

components and cleanliness condit ons of various areas through-

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out the facility were observed tc determine whether safety

and/or fire hazards existed.

No violations or deviations were identified.

(5) Radiological Protection Program - Program pretection control

activities were observed to verify that these activities were in

conformance with the facility policies and procedures and in

compliance with regulatory requirements. These observations

included:

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Selected licensee conducted surveys;

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Entry and exit from contaminated areas including stto-off

pad conditions and disposal of contaminated clothing;

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Area postings and controls;

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Work activity within radiation, high radiation, and

contaminated areas;

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Radiation control Area (RCA) exiting practices; and,

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Proper wearing of personnel monitoring equipment,

protective clothing, and respiratory equipment.

Area postings were independently verified for accuracy by

the inspectors. The inspectors also reviewed selected

Radiation Work Permits (RWPs) to verify that the RWP was

current and that the controls were adequate.

The implementation of the licensee's As Low As Reasonably

Achievable (ALARA) program was reviewed to determine

personnel involvement in the objectives and goals of the

program.

No violations or deviations were identified.

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(6) Security Control - In the course of the monthly activities, the

Resident Inspectors included a review of the licensee's physical

security program. The composition of the security organization

was checked to insure that the minimum number of guards were

available and that security activities were conducted with

proper supervision. The performance of various shif ts of the

security force was observed in the conduct of daily activities

to include; protected and vital area access controls, searching

of personnel, packages, and vehicles, badge issuance and

retrieval, escorting of visitors, patrols, and compensatory

posts. In addition, the Resident Inspectors observed the

operational status of Closed Circuit Television (CCTV) monitors,

the Intrusion Detection system in the central and secondary

alarm stations, protected area lighting, protected and vital

area barrier integrity and finally, the security organization

interface with operations and maintenance.

On April 28 the inspector noted a person displaying a visitor's

security badge within the protected area without the required

escort. Details of this event and the resultant violation are

delineated in NRC Inspection Report 50-302/87-14.

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

equipment were observed to verify that fire brigade staffing was

appropriate and that fire alarms, extinguishing equipment,

actuating controls, fire fighting equipment, emergency equip-

ment, and fire barriers were operable.

No violations or deviations were identified.

(8) Surveillance Surveillance tests were observed to verify that

approved procedures were being used; qualified personnel were

conducting the tests; tests were adequate to verify equipment

operability; calibrated equipment was utilized; and TS require-

ments were followed.

The following tests were observed and/or data reviewed:

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SP-110, Reactor Protective System Functional

Testing (procedure review only);

- SP-112, Calibration of the Reactor Protection

System (procedure review only);

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SP-113, Power Range Nuclear Instrumentation

Calibration (procedure review only);

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SP-216, Sample Line Leak Rate Test;

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SP-300, Operating Daily Surveillance Log;

- SP-312, Heat Balance Calculations;

- SP-317, RC System Water Inventory Balance;

- SP-320, Operability of Boron Injection Sources

and Pumps;

- SP-321, Power Distribution Breaker Alignment and

Power Availability Verification

(procedure review only);

- SP-326A, Toxic Gas Detection System (Weekly);

- SP-3350, Radiation Monitoring Instrumentation

Functional Test (Tech Spec RkA's);

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SP-354A, Emergency Diesel Fuel Oil Quality and

Diesel Generator Monthly Test (procedure

review only);

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SP-421, Reactivity Balance Calculations;

- SP-702, Rea: tor Coolant and Decay Heat Daily

Surseillance Program; and,

- SP-712, Core 'lood Tank "B" Monthly Surveillance

Program.

As the result of these -oviews, the following items were

identified:

(a) On April 10 while observing the performance of procedure

SP-216, the inspector notad the following:

- While aligning valve. in step 9.1.1.1, valve CAV-2

would not open. In as, attempt to open this valve,

previously checked closed valves BP-1 and BP-2 were

opened to equalize pressure across CAV-2. The opening

of these two valves restited in the opening of CAV-2

but also caused radiation raonitors RMA-7 and RMA-4 to

alarm and monitor RMA-2 to go into the warning state.

This evolution was not covered by procedure SP-216 and

was apparently done incorrectly resulting in the

alarming of the various radiation monitors.

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Procedure steps were performed out of sequence in that

step 9.1.1.7 was performed before step 9.1.1.6;

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When section 9.1.1, the high pressure portion (2150

psig) of the procedure, was completed, the procedure

did not provide for a restoration of the system prior

to commencing section 9.2.2, the low pressure portion

(125 psig) of the procedure; and,

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In procedure section 9.2.2, gauge PI-6 was removed, a

"T" fitting installed, and PI-6 was reinstalled so

that a hydro test pump could be installed even though

the procedure did not provide for this installation.

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As the test proceeded the inspector discussed these

apparent procedure problems with test personnel with

particular emphasis on the failure of the procedure to

restore the system. Test personnel responded that the

system restoration was adequate and continued on with the

test.

After connecting the hydro test pump in section 9.2.2 of

the procedure, the appropriate valve was opened. Though

the hydro test pump had not been started, the pressure in

the system rapidly increased and went beyond the 125 psig

allowed and water began leaking onto the floor through a

leak on the hydro test pump. Maximum pressure reached was

about 160 psig due to the lifting of a relief valve (at

approximately 150 psig) thus preventing any further

pressure increase.

Test personnel immediately began closing other valves in an

attempt to isolate the pressure source. After the pressure

source was isolated, and with the valve lineup in an

undetermined state, test personnel intended to proceed with

the test. The inspector objected to test continuance and

the test was stopped.

As personnel were securing from the test it was determined

that the leak on the hydro test pump was causing radio-

active fluid to flow outside of the designated contaminated

area. This resulted in personnel contamination.

As the result of these observations, the inspector deter-

mined that personnel failed to adhere t1 procedure condi-

tions and that the procedure was inadequate to perform the

test.

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Failure to adhere to the requirements of procedure SP-216

and failure of SP-216 to be adequate to perf em the neces-

! sary testing is contrary to the requirements of TS 6.8.1

and is considered to be a Violation.

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Violation (302/87-12-01): Failure to adhere to the

requirements of and have an adequate surveillance procedure

as required by TS 6.8.1.

(b) During the review of procedure SP-321, the inspector noted

that while the procedure checked the circuit breaker lineup

to the "A" and "B" Engineered Safeguards (ES) busses, it

did not check for cross-ties to the non-safety Unit busses.

This finding was discussed with licensee representatives.

The licensee stated that while the closure of these

cross-tie breakers would provide a alarm to alert operators

to this fact, the circuit breakers in question, breakers

3207 and 3208, would be added to procedure SP-321 to insure

that these breakers are periodically checked.

IFI (302/87-12-02): Review the revision to procedure

SP-321 to add circuit breakers 3207 and 3208 to the

procedure.

(c) On April 10, during a routine observation of the control

room instrumentation, the inspector noticed that fan

AHF-22A was running and that the control switch for fan

AHF-228 was in the " pull-to-;ock" position preventing this

fan from operating. Fans AHF-?2A and AHF-22B supply air to

the "A" Emergency Diesel Generator (EDG-1A) room and the

control switches are normaliy maintained in the

" normal-af ter-stop" position so that the fans will start

automatically when EDG-1A starts.

To determine why the switch for AHF-22B was in the

pull-to-lock position the inspector reviewed the shift

supervisor's log and discussed this situation with the

nuclear shift supervisor. Although no explanation was

offered for the switch being in this position, it was

determined that procedure SP-354A had recently been

performed on EDG-1A for routine testing. Review of this

completed procedure revealed that section 9.8, Engineered

Safeguards (ES) Standby Mode for Auto Start, step 9.8.9

required the control switch for fan AHF-22B to be placed in

the normal-after-stop position upon completion of the test.

This step had been signed off as complete on April 9. When

informed of this finding, operations personnel immediately

placed the fan's control switch in the normal-after-stop

position.

Failure to adhere to the requirements of procedure SP-354A

to place and maintain the control switch for fan AHF-228 in

the correct position is contrary to the requirements of TS 6.8.1 and is considered to be another example of the

violation discussed in paragraph 5.b(8)(a) of this report.

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(d) During the review of procedure SP-300 the inspector

questioned the licensee's operating personnel on the

inconsistent methods used to perform channel checks on the

Reactor Protection System (RPS) instrumentation. Specifi-

cally TS 4.3.1.1.1 requires that a shiftly channel check be

performed on the low Reactor Coolant System (RCS) pressure,

high RCS pressure, variable low RCS pressure, high reactor

containment pressure, and high shutdown bypass RCS pressure

channels. Procedure SP-300 only requires the operator to

compare the RCS pressure indication inside the RPS cabinets

to check satisfactory channel operation and does not

require the operator to observe the bistable status lights

of this instrumentation. On RPS instru-mentation which

lacks indication inside the RPS cabinets, the procedure

requires the bistable status lights to be observed to check

satisfactory channel operation.

In addition, this procedure requires all power range

neutron flux channels on the control console to agree plus

or minus 2%. However, the procedure does not specify the

reference point for the 2% deviation, i.e., from the

average or mean value of neutron flux indication or a 4%

. total band from highest to lowest neutron flux indication.

The operators presently use a 4% total band acceptance

criteria to determine satisfactory channel behavior.

These matters were discussed with operations management

personnel who stated that they would review the channel

check issue and clarify the nuclear flux channel acceptance

criteria.

IFI (302/87-12-03): Review the licensee's activities to

revise SP-300 for neutron flux acceptance criteria and

method used to perform RPS channel checks.

(e) During the review of procedure SP-317, performed on May 1,

the inspector noted that the identified and unidentified

Reactor Coolant System (RCS) leakage rates were calculated

incorrectly. This procedure determines the RCS leakage

rates by collecting data for at least 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> (480 minutes)

and calculating a leakage rate based on the net change in

volume of water during this time period. Data collection

was started at 8:50 p.m. on April 30 and completed at

6:50 a.m. on May 1 for a period of 10 hours1.157407e-4 days <br />0.00278 hours <br />1.653439e-5 weeks <br />3.805e-6 months <br /> (600 minutes).

However, instead of using the 600 minutes as the time

period for data collection, the operators used 480 minutes.

Although no TS limits were exceeded, this error resulted in

the RCS unidentified leakage rate being underestimated and

ronconservative. This error was not discovered during the

_ _ _ _ _ _ _ _ _ _ _ _ . _ ___ ____________________-___-__ ______________- ________________ _ ____ - ___-_____________

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14

post reviews of the completed procedure by a second

licensed reactor operator and the assistant nuclear shift

supervisor.

Failure to implement procedure SP-317 correctly is contrary

to the requirements of TS' 6.8.1 and is considered to be

another example of the violation discussed in paragraph

5.b(8)(a) of this report.

(9) Maintenance Activities - The inspector observed maintenance

activities to verify that correct equipment clearances were in

effect; work requests and fire prevention work permits, as

required, were issued and being followed; quality control

personnel were available for inspection activities as required;

and, TS requirements were being followed.

Maintenance was observed and work packages were reviewed for the

following maintenance activities:

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Repair of a vital area security door in accordance with

procedure PM-135 and modification MAR 87-04-08-01, Card

Reader Interchange;

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Replacement of the absolute position indication meter for

control rod number 1 in rod group number 1;

-

Replacement of a drive belt for the "C" control complex

HVAC air compressor (AHP-1C);

-

High potential testing and inspection of the electric motor

for the "A" Nuclear Services Seawater Pump (RWP-2A) in

accordance with procedure PM-105;

-

Calibration of the power range nuclear instrument recorder

(NI-5-NR);

-

Troubleshooting and repair of the "B" Ammonia Toxic Gas

Detector (AN-651-CE) in accordance with procedure MP-531;

-

Troubleshooting and repair of the nitrogen regulator valve

for the nuclear services closed cycle- cooling surge tank

(SWV-281); and,

-

Inspection and alignment check on the "A" high pressure

injection pump (MVP-1A) in accordance with procedures

PM-121, PM-133, and MP-126.

While observing the maintenance performed on AHP-1C the inspec-

tor noted that the work which was actually performed did not

agree with the work instructions provided in section II of the

Work Request (WR#84594 dated April 13, 1987). Specifically the

.

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WR directed the worker to adjust the drive belt tension as

necessa ry. These instructions were reviewed by the licensee's

Quality Systems group to determine appropriate inspection

requirements. The actual work accomplished included the

replacement of the drive belt with a new belt. In addition the

work package lacked any quality documentation for the new drive

belt. The shop supervisor was contacted who provided the

inspector with the proper quality documentation for the replace-

ment part and agreed that the work package should have been

routed to the planner when the actual work to be done deviated

from part II of the WR.

Compliance Procedure CP-113, Handling and Controlling Work

Requests and Work Packages, paragraph 5.4.1.C requires that

whenever the scope of the work exceeds that specified in the

work instructions provided in part II of the WR, that the entire

work package be returned to the Nuclear Planning Coordinator for

further evaluation. This step ensures that the work to be

performed will receive the necessary quality system review.

Failure to adhere to the requirements of procedure CP-113 is

contrary to TS 6.8.1 and is considered to be another example of

- the violation discussed in paragraph 5.b(8)(a) of this report.

(10) Radioactive Waste Controls - Solid waste compacting and selected

liquid releases were observed to verify that approved procedures

were utilized, that appropriate release approvals were obtained,

and that required surveys were taken.

No violations or deviations were identified.

(11) Pipe Hangers and Seismic Restraints - Several pipe hangers and

seismic restraints (snubbers) on safety-related systems were

observed to insura that fluid levels were adequate and no

leakage was evident, that restraint settings were appro priate,

and that anchoring points were not binding.

No violations or deviations were identified.

6. Review of Licensee Event Reports and Nonconforming Operations Reports

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

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

appeared appropriate. Events, which were reported immediately, were

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

were reviewed in accordance with the current NRC Enforcement policy.

LERs 84-06 and 85-35 are closed.

(Closed) LER 84-06: Due to changes in the Technical Specifications,

the event reported in this LER is no longer reportable and therefore

the licensee will not issue a Supplementary LER. The licensee has

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counseled. personnel ' involved in the event . as discussed in - the

corrective action- section of the LER. In: addition the EDG surveil-

> 1ance procedures, SP-354 A & B, have been- revised to assure that z

I appropriate circuit breaker lineups are conducted as required.

5

LERs 86-15 and 87-03 remain open for the following reasons:

(Open)[LER 87-03: This!LER reported that a TS surveillance require- ~

ment,- involving a test of' the : manual initiatier of the containment

purge ' and exhaust isolation during plant refueling, -was not con-

ducted. This descrepancy was discovered during a bien'nial review of

surveillance procedure SP-346. The licensee has initiated a revision

to procedure SP-346 and changed their method of handling procedure

revisions to insure that previous commitments _or require-ments are

not inadvertently omited. ' This LER remains open :pending , completion .

, of the revision-to procedure SP-346. This item is considered to be.a

licensee. identified violation -in which prompt corrective action was

. ~taken.

'!.

-(Open) LER 86-15: The original LER reported the . failure to ade--

quately test' the 480 volt engineered safeguards bus ' load shedding

capability. During further review of this event, the licensee

.

determined that an additional load (chiller CHHE-2 [ Chi 11 water Heat

Exchanger] which was added -to meet the requirements of Appendix-R)

'

could be loaded on the "A" Emergency Diesel Generator. (EDG). To

document this latest-determination, the. licensee issued a supplement

to the LER (86-15-01) dated May 1, 1987. Procedure SP-417 will be

revised to incorporate this latest finding by July 15,- 1987. This

LER' remains open pending completion of. the revision to procedure

SP-417.

'

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

,

veri.fy the following: compliance with the TS, corrective actions as

4

identified in the reports or during subsequent reviews have been

,

accomplished or are being pursued for completion, generic items are

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

'

l reported as. required by TS.

All NCORs were reviewed in accordance with the current NRC Enforce- -

1 ment Policy. .

As a . result of these reviews the following items were identified:

(1) NCOR 87-73 reported that the battery charger located at the

Unit 2 fossil plant was replaced with a battery charger that was

'

not tested. This battery charger keeps the backup batteries

that provide control power for the 230 kilovolt (KV) circuit

breakers charged. These circuit breakers supply off-site power

.

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to Unit 3, therefore, loss of this charger placed Unit 3 in a TS

Action Statement. When this . problem was discovered, , the

untested charger was replaced with a tested charger and the

1 plant was able to exit the action statement.

The licensee has had continuing problems controlling activities

at Unit 2 that affect Unit 3. In an attempt _ to gain control

over.these activities, meetings with fossil plant personnel have

been held and procedure AI-1300, Crystal River Units 1 and 2-

Interface with Crystal River Unit 3, was developed.

These activities do not appear to be effective since an apparent

lack of control over the fossil plant personnel and activities

still occurs. The licensee has held meetings and established a

different type of equipment control for Unit 3 dependent equip-

ment located at Units 1 and 2. These new equipment control

procedures will be implemented by July 1, 1987.

Unresolved Item (302/87-12-04): Establish and implement proce-

dures that will provide positive control over fossil plant

activities that affect CR-3.

(2) NCOR 87-64 reported a potential deviation from the plant's

design basis. During an investigation into the unmonitored

radioactive release path from the Intermediate Building (IB) due

to the Post Accident Sampling System (PASS), it was determined

that a design that has systems that contain radioactive fluids

in a building that does not have 'a filtered and monitored

ventilation exhaust system (like the IB) may not be in confor-

mance with 10 CFR 50, Appendix A, Criterion 64. The

licensee's investigation is continuing. This item will be

tracked in accordance with open IFI (302/87-10-09) as discussed

in paragraph 3 of this report.

(3) NCOR 87-72 reported that personnel failed to comply with the

requirements of procedure SP-335C, Radiation Monitoring

Instrumentation Functional Test (Tech Spec RMA's). On April 22

section 9.4 of this procedure, RMA-11 Functional Tests, was

performed concurrently with section 9.2, RMA-2

s Functional tests. Concurrent performance of these two sections

3' g' effectively aligned the radioactive waste gas system such that a

s flowpath for radioactive gas in the Waste Gas Decay Tanks (WGDT)

Co radiation monitor RMA-11 and the plant's ventilation stack

s was created. When this radioactive gas was sensed by monitor.

,

RMA-11, it responded immediately by automatically closing the

outlet valves on the WGDT's and isolating any potential

'

radioactive gas release to the environment.

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Procedure SP-335C, step 7.7, requires that before starting a new

section of the procedure, the section previously in progress

must be completed. If this step had been followed then no

flowpath for radioactive gas would have existed to challenge the

automatic interlocks associated with monitor RMA-11. Failure to

adhere to the requirements of procedure SP-335C is contrary to

TS 6.8.1 and is considered to be another example of the viola-

tion discussed in paragraph 5.b(8)(a) of this report.

Although this matter was identified by the licensee via the NCOR

process, it is being cited as an example of a violation due to

the self disclosing nature of this event.

7. Review of the Licensee's Compliance with 10 CFR Part 21

The inspector reviewed the licensee's procedures for implementing the

posting requirements, procurement documentation, and resolution of iden-

tified deviations for compliance with 10 CFR Part 21. Required postings

and selected purchase orders were verified to ensure that statements

regarding 10 CFR Part 21 applicability were included. The following

licensee procedures or manuals were reviewed: s

-

Nuclear Licensing Procedure NL-06, Resolution of Safety Concerns;

-

Nuclear Procurement and Storage Manual; and,

- Administrative Instruction AI-900, Conduct of Nuclear Compliance.

In addition the inspector reviewed a March 13, 1987 10 CFR Part 21

licensee evaluation on the oil coolers for pump SWP-18.

No violations or deviations were identified.

8. Non-routine Operating Events

On April 29, at 5:55 am control rod #2 in rod group #2 dropped from 100%

to 10% withdrawn. The licensee began a power reduction and reached 55%

power at 6:20 a.m. The licensee was subsequently able to withdraw the rod

back to the group average position and began increasing power at 7:05 a.m.

The inspector arrived in the control room shortly after the power

ascension was begun and verified the licensee's compliance with the TS and

abnormal procedures. Full power operation was resumed by 4:00 p.m. on

April 29.

No violations or deviations were identified.