IR 05000302/1974011
| ML19319C834 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/05/1974 |
| From: | Kidd M, Robert Lewis, Whitt K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19319C819 | List: |
| References | |
| 50-302-74-11, NUDOCS 8003040796 | |
| Download: ML19319C834 (15) | |
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Fag t . RO Inspection Report No. 50-302/74-11 . Licensee: Florida Power Corporation ' 3201 34th Street, South P. O. Box 14042 St. Petersburg, Florida 33733 - Facility Name: Crystal River 3 - , Docket No.: 50-302 + l License No.: CPPR-51 - ! Category: B1 Location: Crystal River, Florida ! Type of License: B&W, PWR, 2452 Mwe . Type of Inspection: Routine, Unannounced Dates of Inspection: August 13-16, 1974 N.) - Dates - of Previous Inspection: June 18-21, 1974 Principal Inspector: K. W. Whitt, Reactor Inspector Facilities Section ' Facilities Test and Startup Branch Accompenying Inspector: M. S. Kidd, Reactor Inspector Facilities Test and Startup Branch .
Other Accompanying Perso el: None " Principal Inspector: ,./ Y (L.
,, K. W. Whitt, Reactor Inspector Date Facilities Section Facilities Test and Startup Branch Reviewed By: [. C.
k 7//. R. C. Lewis, Senior Inspector Date Facilities Section Facilities Test and Startup Branch .
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T !. . . - (V , - NORpt.No.. 50-302/74-11-2- . , . SUMMARY OF FINDINGS
I.
Enforcement Matters . A.
Violations ' None - ' B.
Safety Items - None
" II.
Licensee Action on Previously Identified Enforcement Matters Not applicable . . III. New Unresolved Items % 74-11/1 Operational Procedures e All required operattonal procedures have no't been identified and developed by the licensee.
(Details I, paragraph 2) - 74~-11/2 Loose Parts Monitoring . Information in the FSAR conflicts with other licensee commit-ments regarding monitoring for loose parts.
(Details I, para- . graph 5) IV.
Status of Previously Identified Unresolved Itema , 73-12/1 Preoperational Test Program Controls There has been no change in the status of this item since the last inspection.
The transition control document and temporary test device control document are still being revised.
(Details I, paragraph 6) V.
Unusual Occurrences None . . n e,,. - - -, -. - - - - - -. - -, - - - - -, - -
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Other Significant Findings . A.
Makeup Pump Recirculation Orifices . . The generic aspects of the problems experienced at other facilities with the makeur pump recirculation orifices were discussed with Florida Power Corporation (FPC) personnel. Management representa- '. .. tives stated thst the Babcock and Wilcox Company (B&W) had informed FPC that replacement Orifices of a new design were being procured ' - for used at Crystal River-3 (CR-3).
(Details II, paragraph 3) B.
Project Status , 1.
General There has been no significant change in the status of testing . since the last inspection.
No preoperational testing has been , performed on safety relac2d systems.
A management committee consisting of two members with two alternates has been esta- ,. blished to oversee the test program.
The committee will review the test program operation on a continuous basis and O report their findings to the Director, Systems Engineering.
According to licensee representatives, this will serve to keep ' upper management informed of test progress and problem areas.
It will also provide for early management involvement in the ' solving of problems.
' 2.
Trrnaition Status Licensee representatives stated that approximately 53% of the plant mechanical equipment and 47% of the plant electrical equipment had been turned over from construction to power test.
3.
Procedure Status
' Class No. Identified No. in Final Draft No. Approved l I 115
4 II 144
6 C.
Personnel Changes The title of the position of operations engineer has been changed to operations supervisor, and Mr. J. K. Jinkenson, formerly a
shif t supervisor, has been assigned the position.
This position -'s was reported as vacant in RO Report No. 50-302/74-9.
Mr. T. H. Wayble has been assigned the shift supervisor position vacated by - Mr. Jinkenson.
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.-. . - -... - - p . . ' ' R0 Rpt. No. 302/74-11-4- . . . VII. Management Interview
, A management interview was held at the conclusion of the inspection on August 16, 1974.
The following licensee personnel participated: - H. L. Bennett - Director, Generation Construction ' P. G. Davis - Manager, Power Testing J. C. Hobbs - Superintendent, Mechanical and Electrical Systems ' C. E. Jackson - Construction Superintendent P. F. McKee - Assistant Plant Superintendent R. W. Slater - Quality Engineer
' G. R. Westafer - Technical Support Engineer ,, A.
Discussed status of preoperational testing (Section VI.B) B.
The inspector stated that he had compared the existing plant operations organization with' the organization described in - the final safety analysis report (FSAR) and had no questions e at this time.
(Detail I, paragraph 4) C.
Replacement of the makeup pump recirculation orifices b 'J discussed. 'Ihe inspector stated that it was his understanding that the quality surveillance group would prepare a nonconfor-
, mance report on the existing orifices, which'have already been > installed, to insure that the old orifices are replaced by the new design. A licensee representative stated that this was a , correct understanding.
(Details II, paragraph 3) . D.
The inspector stated that he had compared the operational procedures that the plant operations staff had identified with the recommendations of certain identified areas of Regulatory Guide 1.33.
He said that additi0nal procedures were required and that some of the existing procedures needed to be expanded to include recommendations of Regulatory Guide 1.33.
Licensee representatives stated that the necessary actions would be taken in this regard.
(Details I, paragraph 2) , i l E.
Inspector comments on the operational procedures were discussed.
Three of the comments were discussed in detail and licensee commitments for specific action was requested. The remainder of the comments were discussed in general terms, and a licensee representative reaffirmed the FPC commitment to resolve all the comments.
(Details I, paragraph 3 and Details II, para- , graph 2)
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R0 Rpt. No. 50-302/74-11-I-1 , . . . , DETAILS I Prepared By:,'
f /'7%- , I K. W. Whitt, Reactor Inspector Data i Facilities Section r , Facilities Test and Startup Branch.
Dates of Inspection: August 13-16,.'974 ,; e Reviewed By: M d, ,; A k fl.
. R. C. Lewis, Senior. Inspector Date .
Facilities Section . l Facilities Test and Startup Branch 6-l .- i j 1.
Individuals contacted
Florida Power Corporation (FPC) ! P. F. McKee - Assistant Plant Superintendent
R. W. Slater - Quality' Engineer , D. W. West - Chemical and Radiological - ] T Protection Engineer H. L. Bennett - Director, Generation Construction I C. E. Jackson - Crystal River Construction Superintendent C. R. Pope - Administrative Supervisor J. K. Jenkinson - uperations Supervisor J. Heilman - Assistant Nuclear Operator
- P. G. Davis -- Manager, Power Testing T. H. Wayble - Shift Supervisor W. M. Matthews - Shift Supervisor T. C. Luckehouse - Maintenance Engineer C. R. Westafer - Technical Support Engineer.
R. J. Acosta - Results Supervisor
i 2.
Operational Procedural Re amants The operational procedu-that have been identified and prepared by ,
the Crystal River-3 (CR-3) plant staff in the areas listed below were compared with the minimum procedural recommendations of Appendix ' A to Regulatory Guide 1.33, Quality Assurance Program Requirements ~
(operational). Deficiencies were identified as indicated under each ' category of procedures listed.
Action taken by the licensee to resolve the deficiencies will be reviewed during subsequent inspections.
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Administrative Instructions (AI) . (1) An AI.has not been prepared for " Equipment Control." A licensee representative stated that an administrative er . compliance procedure would be prepared for equipment control, t . (2) An AI has not been prepared for control of procedure review and approval.
A licensee representative said AI 400, " Pro- - ' cedure Adherence and Temporary Change Method," would be expanded to include controls for procedure review and approval.
, , . ' I (3) The Bypass of Safety Functions and Jumper Control procedure has not been approved. A licensee representative stated that a procedure covering this subject was presently in - l draft form and would be approved within a few weeks.
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! b.
Emergency and Abnormal Procedures (EP and AP) j ,. . The CR-3 operations staff has prepared two types of procedures I ('N for combating emergencies and other significant events'. These ( ) are emergency procedures and abnormal procedures. The deficien-i cies listed below represent conditons or events that are not . . ~ pr2sently covered by either of these two typ'es of procedures.
. (1) An EP entitled " Electrical Blackout" has been written to
cover loss of all electrical power except the diesel ! . ' generators and the de system.
No procedure has been , prepared for degraded power sources. A licensee l i l representative stated that the " Blackout" procedure would i be expanded to include degraded power sources or a new ' procedure would be prepared to accomplish this purpose.
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(2) An EP or AP has not been prepared to cover the inability l i to drive control rods. A licensee representative stated that EP-110, " Malfunction of Control Rod Drive System," l would be expanded to include stuck control rods.
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' - , (3) No procedure has been prepared for expected transients.
l A licensee representative stated that an EP or AP would
be prepared.
' (4) An EP bas been prepared for earthquakes and an AP has been . prepared for hurricanes which also covers flooding, but no procedure has been prepared for tornados or other i acts of nature. A licensee representative stated that G h i +a ,- - -, , . _, , ._ _ _ _, _ _ _ _ _ _ _ _ ,, _ _ _
q m . - [- '. 'R0 Rpt. No. 50-302/74-11 I-3 . \\ . . . _ FPC would consider writing a procedure for actions to . be taken prior to and during a tornado.
This procedure will also provide for adding instructions to cover other acts of nature as the needs are identified.
. (5) An AP has been prepared for action to be taken in the event the various radiation alarms are annunciated. The emergency' ' plan specifies the actions to be taken if irradiated fuel is damaged.
The AP does_not reference the emergency plan.
A - licensee representative stated that the AP would be revised to direct the operator to the emergency plan for subsequent - action.
' .. 3.
Operational Procedure Review The CR-3 operational procedures coveting the following areas were - reviewed.
The comments which resulted from the review are listed under each category of procedures.
Resolution of the comments by the licensee will be reviewed during future inspections, ,, a.
Administrative Instructions
- (1) AI-400, Plant Operating Quality Assurance Manual Control Document - - The review frequency for some of the procedures shown in Section 6.3 of this instruction is too long.
The frequency
uf procedure review during early plant operation should be at least once each year.
A licensee representative agreed to change the review frequency of the procedures where applicable from once.every three years to once each year during the first three years of plant operations. At the end of the third year of operation, the frequency may be changed to once every three years.
(2) AI-500, Conduct of Operations (a) Section 2.5 states that the plant superintendent or assistant plant superintendent will generally be at the
site or on call at all times, but on occasions when both are unavailable, a section supervisor or shift supervisor ! may be designated to be on call.
The inspector stated I that the person on call during weekends and evenings should be someone having responsibilities and authorities
greater than the shift supervisor.
One shift supervisot-cannot be expected to make management decisions for (' another shift supervisor.
A licensee representative % agreed, and said the procedure would be revised to ' require "on call" personnel to be those who have ! -
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, RO Rpt. No. 50-302-11 I-4 - - . . , , responsibilities and authorities which exceed those of' l the shift supervisor.
, ' (b) This procedure does not identify all the operator.respon-sibilities and authorities provided by ANSI N18.7, Administrative Controls for Neelear Power Plants. A , licensee representative stated that all these responsibi- ' lities and authorities would be added to the AI.
. (3) AI-600, Conduct of Maintenance , s This AI does not require maintenance procedures to identify - inspection hold points.
A licensee representative said that the quality procedures contained a requirement for hold points to be identified, and that AI-600 would be revised to implement ' the quality requirement.. (4) AI-900, Conduct of Technical Support _, Section 3.2 states that setpoint changes and plant modifications must have the approval of the technical support engineer. The inspector explained that such changes and modifications must be reviewed by the general review committee (GRC) as required by - . proposed Technical Specification 15.6.1.B.2.h. (3). A licensee , representative said that all safety related setpoint changes a and plant modifications, would be reviewed by the GRC before they were performed and that AI 000 would be revised to reflect - this requirement.
I (5) AI-1000, Conduct of Compliance i -
(a) This AI discusses purchased material, equipment, and services, but it does not contain a requirem;nt that these be purchased only from qualified vendors. A licensee , ] representative stated that this requirement would ts added to the instruction.
(b) Secti 7 of this AI discusses special processes, but it does specify that welding must be performed by certi-fied pe sonnel using qualified procedures.
A licensee representative stated that this requirenent would be added to the instructions.
. (c) Section 5.15 of this AI discusses quality assurance records, but it does not require a procedure to be ,
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. i prepared for the collection,_ storage, and maintenance. of records.
A licensee' representative stated that - this requirement would be added to the' instruction and that the records procedure would be prepared.
- within a few weeks.
(b) Emergency Procedures .' t (1) EP-103, Loss of Reactor Coolant Flow /RCP Trip -
l This EP does noc follow the normal format for stating - the sympeoms and actions. A table is used in this and
a few other EP's instead of the usual step-by-step statements.
A licensee representative stated that the format would be made consistent for all EP's.
l (2) EP-107, Loss of Boron - One of the actions required by this procedure is to isolate the makeup system except for pump seal coolant.
A subsequent action is to add boron as nee'essary.
The inspector asked how the boron was added if the makeup ' , line was valved out. A licensee representative stated ' ' that the procedure might be in e~rror. He said that a i study would be initiated and the procedure would be revised as necessary.
! i (c) Summary FPC has identified eleven (11) administrative procedures, thirteen (13) emergency procedures, and eighteen (18) abnormal procedures. All of these procedures have been l approved except one abnormal procedure. This one unap-j proved procedure, when completed, will contain all the alarm procedures.
The inspector's review included all the i the administrative procedures, all-the emergency procedures, and all the abnormal procedures that were approved.
4.
Organization , I The existing operation organization was reviewed and compared with the
organizational description in the FSAR.
The organization was discussed with all section supervisors and a number of their subordinates.
Indivi- . ' l duals were asked to describe their concept of the organization and how i they fit into that concept.
They were also asked to define their responsibilities and authorities.
In all cases, the-information provided agreed closely with the FSAR description.
The inspector has no further . e -- - --....---,,4.
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.. questions concerning plant organization at this time.
This review.did not include the quality assurance organization.
' , 5.
Loose Parts Monitoring . t During discussion with licensee management personnel, the inspector , was assured that a loose parts monitoring program was planned at ' CR-3.
They explained that the equipment was being purchased and would be installed and tested prior to hot functional testing.
The - ' inspector noted that table 13.2 of the FSAR needed to be revised since i it specifically states that the test program does not include a loose c , parts monitoring system for reactor internals. A licensee representa-
4 ' tive said that the FSAR.would be amended.
This commitment was - reaffirmed at the management interview at which time the inspector stated that this would be carried as an unresolved item until the FSAR was amended.
, . 6.
Preoperational Test Programs Controls
This unresolved item (73-12/1) was initially reported in RO Report No.
~ 50-302/73-12, Details I, paragraph 3, and subsequently dis' cussed in RO Report Nos. 74-2, 74-6, and 74-9.
The Transition Control Procedure
, and the Temputary Test Device Procedure are still being revised. This ! item will rer.ain open until the revision to the procedures have been l approved.
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- . . s , ',) R0 Rpt. No.~50-302/74-11 II-l - s . . , DETAILS II Prepared By: (.A /1 ' - [-24-7[ ' M.'S. Kid'd,.Rea'ctor Inspector Date ~~ Facilities Section Facilities Test and Startup Branch . Dates of Inspection: August 13-15, 1974 , [*C.
3/7f Reviewed By: R. C. Lewis, Senior Inspector Date ' Facilities Section
Facilities Test and Startup Branch .- 1.
Persons Concacted The following persons were contacted by the inspector during this inspection: - Florida Power Corporation (FPC) . Systems Operations . P. F. McKee - Assistant Plant Superintendent . J,. K. Jenkinson - Operations Supervisor Generation Quality and Standards R. W. Slater - Quality Engineer - 2.
Review of Procedures a.
General Selected procedures from those written to meet the recommendations of Regulatory Guide 1.33, " Quality Assurance Program Requirements (Operation)," Appendix A, were reviewed and discussed with licensee personnel.
The procedures reviewed were of two types; general plant operating procedures, and procedures for startup, operation, and shutdown of safety related systems.
RG 1;33, Appendix A, parts B-d C, itemize the procedures normally needed for these functions.
Section 5.3 of ANSI N18.7, " Standard for Administrative Controls for Nuclear Power Plants," (Draft-1972) was used as a basis . ! for review of these procedures to determine if the general format and content were as recommended by that standard. With minor /'~'g exceptions, the inspector found that the procedures were written (,/ to conform with the intent of ANSI N18.7. The procedures reviewed _ and their purposes are as follows: { ' , , . .. - - . ..-- , - -.. - . - -
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" RO Rpt. No. 50-302/74-11 II-2 .
(1) General Plant Operating Procedures (a) OP-201 - Plant Precritical Check ' This procedure provides checklists for all items to be completed prior to heatup and prior to criticality.
It lists, , directly or indirectly, all appropriate Technical Specification requirements.
, (b) OP-202 - Plant Heatup . ' This procedure provides the steps needed to take the, plant.
from cold shutdown / refueling shutdown to hot shutdown conditions.
, (c) OP-203 - Plant Startup (Hot Shutdown to Minimum Load) This procedure provides instructions for taking the reactor ~ from hot shutdown conditions to 15% power operation with the generator synchronized on line.
. (d) OP-204 - Power Operation - . This procedure describes the operation of the plant above 15% rated power, including load changing, stable operation and surveillance of operations.
. (e) OP-206 - Recovery From Reactor Trip This procedure provides steps for trip recovery, including documentation of the cause and corrective actions and the granting of permission to return to power.
(f) Of-208 - Plant $hutdown (Minimum Load to Hot Shutdown) This procedure itemizes actions required to bring,the plant from 15% power to hot shutdown conditions.
(g) OP-209 - Plant Cooldown ! This procedure provides the steps to take the plant from - hot shutdown to cold shutdown conditions using both (or l one) steam generators and then the decay heat removal - system.
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(2) Systems Operating Procedures (a) OP-304 - Soluble Poison Concentration Control' . This procedure p'rovides the equations "used to determine time and volume requirements for borating and deborating , the reactor coolant system (RCS) in order to adjust and - maintain the boron concentration.
, ' (b) OP-404 - Decay Heat Removal System , , This procedure provides instructions, including valve lineups, for filling and venting, startup, shutdown, operating, and-placing the decay heat system in the standby mode for low pressure injection (emergency function).
. . (c) OP-417 - Containment Operating Procedure ' -' This procedure provides instructions for startup, operation, . and shutdown of containment systems such as ventilation, purging, and isolation.
It also provides for documentation of containment integrity.
! b.
Comments on the Procedures Specific comments on the procedures were of three types: (1) References to other procedures which provide detailed instruc-tions for completing a task were not made in several cases.
. Examples: Steps 6.2 through 6.4 of OP-201 and Step 4.14 of OP-202 call for the completion of a specific job using more detailed procedures, which were not referenced.
During the discussions with licensee personnel on this matter, the inspector noted that examples of needed references had been found in the majority of procedures that he had reviewed.
Licensee representatives stated that the specific examples discussed would be added and that all operating procedures would be reviewed to assure that references had been made where appropriate.
This commitment was reaffirmed in the management interview.
. (2) In certain cases, changes to Technical Specifications had affected procedures, necessitating revisions to them.
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. Licensee personnel agreed.that these limits would hnve ta be referenced in the preheatup section of OP-201. They also- ' agreed to revise other procedures similarily affected by-recent specifications changes which were discussed. A licensee representative stated that all procedures would be - reviewed again before licensing and that changes to Technical Specifications would be considered in that review.
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(3) In certain instances, more detailed instructions or clar'ification of instructions were needed.
- - . . Frample: OP-417 did,not address the shutdown of the reactor-
building cooling fans an'd associated industrial coolers-t (during plant shutdown ), .- Licensee personnel agreed with the inspector on al.1 items of this type discussed and stated that the~ necessary changes or additions to the procedures would be made. This commitment . , was reaffirmed in the management interview.
c.
Other Comments . During discussions on the procedures above, the following comments - were also discussed: (1) Several procedures contained incomplete instructions where
quantitative values had not been available when the procedures.
were written. The inspector asked how this was being tracked I to assure all misc?.ng information would be inserted into rbe procedures before they are used, noting that the procedu'.es ' , i had already been approved.
! A licensee representative stated that the normal review process l l should catch this type of item before the procedures are used, but that a punchlist of all needed information would be made and used to assure that the procedures are ready for use at the proper time. This' commitment was reaffirmed during the management interview.
(2) Procedures OP-201 and 202 discuss the status of nuclear instruments in preparation for startup. The inspector asked . j ' .if the procedure which places the instruments in an operable j ' status should not be referenced.
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) "" R0 Rpt. No. 50-302/74-11 II-5 - _, . . . . - Licensee personnel stated that if other procedures covered that-function, they would be referenced or instructions for determining that the instruments are operable would be inserted into OP-701 and OP-202.
- 3.
Makeup Pump Recirculation Orifices , i Each makeup and purification pump is equipped with a recirculation ~
line to prevent deadheading the pump for low makeup flow conditions or when the discharge valves are closed. Each recirculation line contains
an orifice for flow control and pressure reduction. At other B&W ' facilities, these orifices have experienced erosion, thus the ' ,., inspector questioned the status of the orifices at CR 3.
The' inspector - was informed that FPC had been notified of the problem by B&W via a . letter from C. E.' Barksdale, Project Manager to W. A. Szelistowski, ~ Director - Generation Engineering, dated Apr11 16, 1974.
The letter states that redesigned orifices are being procured for use at CR 3.
The inspector asked what controls FPC had placed on the use of existing orifices and replacement of them. A licensee representative stated / the orifices would be replaced via a field change from B&W. after review by FPC Engineering. Also, a non-conformance status would be place'd
on the old orifices to be resolved upon installation of the redesigned ones., Licensee personnel were not familiar with the schedule for replacement at the time of the inspection.
The inspector stated that he had no further questions at that time but would be interested in the surveillance program, if any, which FPC would use to monitor the new orifices.
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