IR 05000302/1976003

IE Insp Rept 50-302/76-03 on 760120-23 & 0203-06. Noncompliance Noted:Charcoal Adsorbers Not Properly Identified in Environmentally Controlled Warehouse Per FSAR Requirements.Adsorbers Not Handled Per Requirements

ML19319D058
Person / Time
Site:	Crystal River
Issue date:	02/25/1976
From:	Robert Lewis, Whitt K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19319D038	List: IR 05000302/1976003 ML19319D037 ML19319D052 ML19319D054
References
50-302-76-03, 50-302-76-3, NUDOCS 8003040973
Download: ML19319D058 (29)

Text

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NUCLEAR REGULATORY COMMISSION

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330 PEACHTREE STREET N. W. SUITE S18

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ATLANT A. GEO RGI A 30303

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IE Inspection Report No. 50-302/,76-3

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l Licensee:

Florida Power Corporation

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3201 34th Street, South

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Post Office Box 14042 St. Petersburg, Florida 33733 Facility Name:

Cryscal River 3

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Docket No.:

50-302 License No.:

CPPR-51 Category:

B1

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Location:

Crystal River, Florida Type of License:

B&W, PWR, 2452 Mwt Type of Inspection: Routine, Announced Dates of Inspection: January 20-23 and February 3-6,.1976

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Dates of Previous Inspection: January 14-15 and 28-30, 1976 (Construction)

Principal Inspector:

K. W. White, Reactor Inspector i

Reactor Projects Section No. 2

Reactor Operations and Nuclear Support Branch (February 3-6, 1976)

Accompanying Inspectors:

R. F. Rogers, Reactor Inspector Nuclear Support Section j

Reactor Operations and Nuclear Support Branch (February 3-6, 1976)

G. L. Troup, Radiation Specialist Radiation Support Section Fuel Facility and Materials Safety Branch (January 20-23, 1976)

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IE Rpt. No. 50-302/76-3-2-

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A. D. Kowalczuk, Radiation Specialist Radiation Support Section-Fuel Facility and Materials Safety Branch

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(January 23, 1976)

N. Jape, Reactor Inspector

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Reactor Projects Section No. 1 Reactor Operations and Nuclear Support Branch

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(February 3-6, 1976)

Other Accompanying Personnel: None

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K.'W. Whitt, Reactor Inspector Date

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Reactor Projects Section No. 2 Reactor Operations and Nuclear Support Branch

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Reviewea by:

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/['l/74 Date R. C. Lewis, Section Leader Reactor Projects Section No. 2 Reactor Operations and Nuclear Support Branch

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IE Rpt. No. 50-302/76-3-3-UT

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SUMMARY OF FINDINGS

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Enforcement Matters

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A.

Infractions

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Contrary to 10 CFR 50, Appendix B, Criterion XIV, Inspec-tion, Test and Operating Status, during the period

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January 20-22, 1976, the inspector observed in the environ-mentally controlled warehouse charcoal adsorbers that were

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not properly identified with respect to tests r' quired by

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FSAR Table 9-15 and Requirements Out11ne-2948 as required

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d by FSAR paragraphs 1.7.6.4.4 and 1.7.6.5.2 and Quality - -

Program Procedure 14.10.

(Details II, paragraph 2)

2.

Contrary to 10 CFR 50, Appendix B, Criterion XIII, Handling, Storage and Shipping, during the period January 21-22,,1976,-

the inspector observed charcoal adsorbers and HEPA filters in the coal yard warehouse that were not handled and stored in accordance with an approved vendor instruction or inspected to verify quality during storage as required by paragraph 1.7.6.5.2 of the FSAR and Quality Program p)

Procedure No. 13.10.

(Details II, paragraph 3)

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II.

Licensee Action on Previously Identified Enforcement Matters Not inspected.

III. New Unresolved Items 76-3/1 Test Procedure for HEPA Filters and Charcoal Adsorbers The procedure for testing of HEPA filters and charcoal adsorbers is inconsistent with accepted practices and guides.

(Details II, paragraph 4)

76-3/2 Fire Water Diesel System Diesel driven fire water pumps and associated components have not been installed and are not covered by plant operational procedures.

(Details V, paragraph 4.C)

IV.

Status of Previously Identified Unresolved Items 75-8/4

. Contamination control in the Hot Machine Shop

/ 'T Controls have not been established.

This item remains h

open..

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IE Rpt. No. 50-302/76-3-4-

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' Instrumentation Inside of Shielded Cabinets

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This item is still under review by the licensee and remains open.

(Details I, paragraph 2)

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.75-8/7 Installation of Primary Sample Coolers

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The licensee's evaluation has~been completed but correc-

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tive actions are incomplete.

This item remains open.

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(Details I, paragraph ~2)

I 75-15/1 Maintenance

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Implementation of the corrective maintenance program for safety-related systems could not be verified. This item remains open.

(Details III, paragraph 2)

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75-15/2 Audits

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Appropriate quality assurance audit. schedules have been developed and the site surveillance audit program has been initiated.

This item is closed.

(Details III, paragraph 3)

75-15/3 Management

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i A prodaction department administrative instruction to describe measures for handling incoming NRC correspondence has been identified, but it has not been developed and

approved.~ This item remains open.

(Details III, paragraph 4)

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75-15/4 Reveiv Responsibility has been established to determine the impact on surveillance and plant procedures resulting

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j from license or technical specification changes. This item is closed.

(Details IV, paragraph 2)

i 75-15/5 Surveillance Testing

Requirements have been established for recording special test equipment necessary for testing and for returning systems to the original configuration following testing.

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This item is closed.

(Details IV, paragraph 3)

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IE Rpt.I No. 50-302/76-3

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'75-15/6 Quality Assurance Records Duplicate sets of QA~ records will be maintained as an alternative to establishing a permanent records storage

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area. Administrative instructions have been revised to

provide controls for the collection, storage and main-

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tenance of QA records..This item is closed.

III, paragraph 5)

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75-15/7 Receipt, Storage and Handling

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Administrative instructions have been developed and

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approved for the control of receipt storage and handling, but the program described by the instructions has not been implemented. This item remains open.

(Details III, paragraph 6)

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75-15/8

. Document Control Operational and engineering instructions have been prepared

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and approved which describe distribution and control of drawings and drawing revisions.

This item is closed.

(Details III, paragraph 7)

75-15/9 Qualification of Personnel Administrative controls to assdre that minimun educational, experience and qualifications are met by the plant staff personnel have been implemented. A change to FSAR Figure 12.2.1 has been recommended by the plant staff, but the amendment has not been~ submitted.

This item remains open.

(Details IV, paragraph 4)

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75-15/10 Training A training coordinator has been assigned and procedures

l describing his duties and responsibilities established, but procedures implementing formal training on the licensee's

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QA program and the operator retraining program have not been promulgated.. This item remains open.'

(Details IV, I

paragraph 5)

75-16/2 Training Completion and Documentation i

FSAR commitments regarding training have not been completed i

and documented.

This item remains open.

(Details IV, l

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paragraph 6)

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IE Rpt. No'.150-302/76-31-6-

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75-16/3'

Integrated Leak Rate Test

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Project management has recommanded.that the FSAR be changed to allow failure of'certain instrumentation

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during the leak rate test without invalidating the test data, but the amendment has'not been submitted.- This item remains open.

(Details IV, paragraph-8)

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75-19/2 Control of Temporary Modifications and Bypasses

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Jumper log procedures have not b' een revised to address

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the use of approved procedures, independent verification, e,

and functional testing of equipment.

This item remains-

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open.

(Details IV, paragraph 7).

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75-19/3 Core Flooding' System Functional Test

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The core flood system functional test has been revised'to

agree wir.h the provisions of Regulatory Guide 1.79.

This.

item is closed.

(Details IV, paragraph 9)

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I 75-19/4 Testing of Radioactive Waste Sample Lines

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A program for the testing of-the sample lines has not been developed.

This item remains open.

75-19/5 Determination of Discharge Tank Volumes

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The licensee has not comple.ted th'e determination of the discharge tank volumes. This item remains open.

75-19/6 Evaluation of Sampling Media Collection I

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The licensee's evaluation of the collection efficiencies is incomplete. This item remains open.

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75-19/7 Management Approval of Radiation Protection Training

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Program

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The radiation protection training program has not been

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approved by licensee management. This item remains open.

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Unusual Occurrences

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Other Significant Findings

VI.

A.

Project Status

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Fuel loading is scheduled for April 9, 1976. Approximately 94% of the systems have been turned over to generation testing

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approximately 98% of the preoperational test procedures have been approved and about 40% of the tests have been completed.

i Only 21% of the. test results have been approved.

(Details

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III, paragraph 8)

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Deviation

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The ventilation system filter housings have been constructed contrary to the criteria of FSAR Table 9-15 requiring welded seams, differential pressure indication, check valves and

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weight percent of impregnant, (Details II, paragraph 4)

VII. Management Interview O-A management interv'iew was held on January 23, 1976, with Beatty, Plant buperintendent, and other members of the

corporate and plant staffs.

The findings of the inspection relating to radiation protection were discussed.

(Details I and II)

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A second management interview was held on February 6,1976, with Alberdi, Project Manager, and members of his staff.

The findings of the inspection relating to preoperational testing, plant operational procedures, and operational quality assurance were discussed.

(Details III, IV and V)

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IE Rpt. No. 50-302/76-3-I-l

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DETAILS I Prepared by:

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G.L.Troup,RadftionSpecialist Date

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Radiation Support Section.

Fuel Facility and Materials Support Branch

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Dates of Inspectio :

an 20-23, 1976

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Reviewed by:

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A. F.;Gibson,.Section Leader Date

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Radiation Support Section Fuel Facility.and Materials Support Branch

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Individuals contacted

G. P. Beatty, Jr. - Nuclear Plant Superintendent

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D. W. Pedrick, IV - Compliance Engineer

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J. R. Wright - Chemical and Radiation Protection Engineer

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J. L. Harrison - Assistant Chemical and Radiation Protection Engineer

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j G. D. Perkins - Health Physics Supervisor i

E. D. Yochheim - Radiochem'st (B&W)

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L. A. Smith - Nuclear Engineer (B&W)

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Dr. P. Y. Daniels - Nuclear Support Specialist

J. C. Hobbs, Jr. - Manager - Generation Testing l

G. H. Ruszala - Test Engineer E. E. Froats - Manager, Quality' Site Surveillance

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2.

Instrumentation Inside of Shielded Cubicles (75-8/6)

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This item was originally discussed in IE Report No. 50-302/75-8, Details III, paragraph 5, and dealt with the installation i

of instruments inside of shielded cubicles next to potential i

high radiation sources.

Maintenance and calibration of these'

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instruments could result in high personnel exposures, which i

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would be inconsistent with the plant policy of maintaining exposures as low as practicable.

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b.

The original discussion of this item cited three examples of the installation of the instruments.

A licensee representative provided the inspector with a letter from the architect-engineer which indicated that the instruments-cited in the

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examples could not be relocated outside of the. cubicles as they are (1) part of equipment packages, (2) locally mounted instruments without transmitters, ot (3) required to be inside of the cubicle, such as area radiatic-, monitors.

The inspector

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reviewed the letter and acknowledged that the reasons given appeared valid but also noted that the review was limited to the three examples rather than a serious review of the overal1

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IE Rpt. No. 50-302/76-3-I-2

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i problem.

The inspector further noted that the review.of

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instruments in the reactor coolant bleed tank room discussed

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only*the area radiation monitors and ignored'auch instruments

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as'the indicating temperature transmitters.

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During a tour'of the plant the inspector'noted instances where j

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additional ~1nstruments have been installed inside of cubicles

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One example

noted by the inspector was the installation of a strip chart

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recorder for the concentrated waate tanks and concentrated-

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boric acid tanks temperature inside of the tank room._ FSAR

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figure 11-8 shows this area to be designated as a high radia-

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adjust or replace the recorder paper, ink the pens, etc.

This

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where instruments installed in potential high radiation areas

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but could have been located in other locations which would

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result in lower personnel exposures during the performance of periodic tasks such as routine maintenance, periodic calibra-

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j tion, etc.

d.

The inspector advised licensee management that this item is still open.

The inspector further indicated that the overall situation needs to be reviewed from the standpoint of how instruments can best be installed to accomplish their function and still maintain personnel exposures as low as practicable

rat.her than just considering the particular instruments noted by the inspector, i

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Installation of Primary Sample Coolers (75-8/7)

a.

This item was originally discussed in IE Report No. 50-302/75-8,

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Details III, paragraph 6 and dealt with potential high personnel exposures from unshielded sample coolers in the primary sample room.

This installation appeared to be in conflict with the plant policy of maintaining exposures as low as practicable.

b.

A licensee representative provided the inspector with a copy of a letter from the architect-engineer which stated that a

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review of the design indicated that no shielding is required for the steam generator. sample coolers to maintain the radiation level in the sample room at <l5 mR/hr, which is the design-level.

However, the letter further stated that a minimum of 1-3/4"~of lead shielding is required for the primary sample

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cooler to maintain radiation levels within the design level.

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The letter from the architect-engineer further stated that the

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shielding would be field installed; consequently no installation drawings were available for review.

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The inspector informed licensee management that this item c.

would remain open pending the installation of the shielding for the primary sample cooler.

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4.

Plant Procedures This item was originally discussed in IE Report No. 50-302/75-16, Details I, paragraph 5, and dealt with the need for written procedures

for pocket dosimeter drift checks and for quality control checks oli the contractor providing thermoluminescence dosimeter (TLD) services.

A licensee representative informed the inspector that the requirements for the dosimeter drift check had been incorporated into procedure

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RP-213.

The inspector had previously reviewed a draft of the drift check procedure; comments on the draft had been accepted and resolved by the licensee. The licensee representative also informed the inspector that the quality control checks for TLD's had been issued

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as RP-301.

The inspector reviewed this procedure and advised s_,/

licensee management that he had no further questions on these s

procedures.

5.

catus of Work The following facilities, systems and functional areas were reviewed

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However, as these items were incomplete, the inspector did not complete the inspection.

chemistry and radiation protection facilities, including a.

radicchemistry laboratory, counting room, personnel and equipment decontamination rooms and laundry b.

gaseous, liquid and solid radioactive waste systems, including i

preoperational testing j

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area and process radiation monitors, including installation, j

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I check-out and calibration t

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respiratory protection programs, including training, fitting and maintenance training programs for radiation workers and chemistry.and

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I~~s radiation protection section personnel g

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IE Rpt. No. 50-302/76-3 I-4

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chemistry and radiation protection procedures, including-

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effluent surveillance and control, radiochemistry procedures and work scheduling

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ventilation systems, including filter and absorber installa-g.

tion and testing, fume hood balancing, and fan capacities.

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IE Rpt. No. 50-302/76-03 II-1

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DETAILS II Prepared y:

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OL ' Specialist, Radiation Support s

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Section, Fuel Facility and Materials

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Safety Branch

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Dates of Inspect n:

Ja uary 20-23, 1976

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Reviewed by:A. F. Gibson, Section Leader Date

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Radiation Support Section

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Fuel Facility and Materials

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Safety Branch

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Individuals contacted

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Rich Dorrie - Quality Engineer E. E. Froats - Manager Site Surveillance J. Hobbs, Jr. - Manager Generation Testing Noah Flucard - Test Supervisor

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Jack Chapdelaine - Test Supervisor

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2.

Test Documentation For Charcoal Adsorbers l

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Paragraph 3:03.3.19 of the licenser's Requirements Outline 2948 specifies that the charecal adsorbers used in the Reactor Building Purge System, the control complex emergency filter

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trains and the auxiliary building filter trains shall have removal performance for methyl iodide equal to previously demonstrated performance of two charcoals identified by manu-factures designations and that the manufacturer shall present objective evidence to show that the filters offered can meet the requirement.

Purchase Order File PR3-1921 containing the

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quality documents associated with Requirements Outline 2948 was reviewed by the inspector and the objective evidence j

specified above was not present. - Consultations with management representatives verified that neither test results nor other objective evidence was supplied by the vendor and that no methyl iodide removal performance tests had been performed.

Table 9-15 of.the FSAR states " Specification requires that the

manufacturer present evidence to show how the filter performance on iodine and methyl iodide was determined" in describing the

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" Degree of Compliance" of the Fuel Building (Auxiliary Building)

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and Control Building Systems for filtration and iodine adsorp-tion with paragraph C.6 of Regulatory Guide 1.52.

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IE Rpt. No. 50-302/76-03 II-2

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(b)

Paragraph 1.7.4 of the FSAR states that components and systems -

having a vital role ir. the protection against accidents or in mitigation of consequences of accidents are subjected to the Quality Program.

The reactor containment building, the reactor

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auxiliary building, the control complex and Engineered Safe-guards Systems are specifically given as examples of items

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subjected to the Quality Program.

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(c)

Paragraph 1.7.6.4.1 of the FSAR states that the requirements

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for the end product are set down in the design and procurement

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documents.

Requirement Outlines are established as design and procurement documents with quality criteria by Quality Program Procedure 3.10 of the FPC Quality Manual in response to Qual 1~ty Program Policy 3.1 of the FPC Quality Manual.

The stated purpose of Quality Program Policy 3.1 is to establish design control with 10 CFR 50, Appendix B, criterion III and the FSAR as bases for such control.

(d)

Paragraph 1.7.6.4.4 of the FSAR requires " Quality Surveillance" to assure the Quality Program functions properly to produce an.

g, end product which conforms to the design documents and the I

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quality requirements.

Paragraph 1.7.6.5.2 requires that work affecting quality be done in accordance with detailtd written procedures for quality control reporting and inspect.on status and control of material identification. Material anc installa-tion compliance status control is required by Quality Program drocedure 14.10 of the FPC Quality Manual in response to

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Quality Program Policy 14.1 of the FPC Quality Manual.

The stated purpose of Quality Program Policy 14.1 is to establish the requirement for use of inspection, test and operating status indicators to prevent inadvertent installation or use i

of materials, components, parts or equipment with 10 CFR 50,

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Appendix B, Criterion XIV as a basis for such indicators.

(e)

Review of Purchase Order File PR3-1921 by the inspector and J

consultation with management representatives revealed that the charcoal adsorbers had been released for installation without testing specified by'the Requirements Outline and FSAR as a result of inadequate inspection and starne indicators.

This condition could have rasulted in the installation of material o-t conforming to design and procurement documents. The above conditions, in apparent noncompliance with 10 CFR 50, Appendix

B, Criterion XIV, were acknowledged by management. Management indicated appropriate corrective action wculd be taken.

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3.

HEPA Filter and Charcoal Adsorber Warehousing

l (a)

The inspector observed that charcoalLadsorber units for the l

auxiliary building filter trains, the reactor building (contain-

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mene)' purge filter trains and'the control complex filter i

trains were stacked twelve units high in storage.

Each adsorber-

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unit weighs in excess of sixty pounds (FSAR, Table 9-12)..

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i This condition could result in deformation of the lower adsorbers u

due to excessive weight. Deformation of the adsorbers could

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I impair their ability to perform safety related functions (FSAR, Sections 6 and 9).

Observations were made on January 21,

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1976.

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(b)

HEPA filter storage in a coal yard warehouse was observed on l

January 22, 1976.

Some of the KEPA filters were stacked four

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f units high contrary to accepted practice (ORNL-NSIC-65, Appendix ~

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C) in the absence of vendor recommendations.

One pallet of-

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filters, ten units, had been exposed to the weather as evidenced

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by water damages packing cartons, several filter cartons

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j marked fragile had physical damage as evidenced by crushed

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corners on the cartons.

Purchase Order File PR3-1921 and vendor manuals were reviewed by the inspector and management i

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representatives were consulted to locate vendor handling and f

storage recommendations..No handling or storage recommenda-

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tions from the vendor were located and a management represen-

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tative indicated no recommendations had been received from the vendor.

(c) A management representative, accompanied by the inspector, contacted several warehouse and receiving personnel in an

,

attempt to identify the storage location of the HEPA filters.

Warehouse and receiving records were consulted by the personnel

4 contacted but the storage location could not be firmly identi-

,

-

fied and none of the personnel could remember where the filters

l were stored. Over a two day period, January 21-22, 1976, of j

contacting various site personnel and ~ looking in various warehouses, the management representative, accompanied by the

)

inspector, located the HEPA filters in a coal yard warehouse as a result of the' search effort.

'

'

,

(e) The above conditions are contrary to Procedure No. FPC-W8, j

Warehouse functions, which requires in-door storage for ventila-tion system equipment and handling of materials in accordance

'

with markings on crates or boxes and to Quality Program Procedure QP No. 13.10 requiring protection.of equipment from the environ-r ment and elements and regular quality surveillance to-assure

'

that-original quality requirements are maintained. Not adhering

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to the above procedures is contrary to Quality Program Policy

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No. 13.1 which references 10.CFR 50,. Appendix B, Criterion

'

.

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XIIi as a_ basis for the policy and to FSAR paragraph l.7.6.5.2

-

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requiring that work affecting quality-be conducted in accordance -

with detailed written procedures for inspection, handling and

'

' storage of materials, components or systems.

,

(f) Paragraph 1.7.4 of the FSAR states that components and' systems.

having a' vital role in the protection against accidents or in mitigation of consequences of accidents are subjected to the

-

,

Quality Program. The reactor cont-3asnt building, the reactor

,

l auxiliary building, the control co.:

• c and Engineered Safe,,

"

i guards Systems are specifically givea as exacple.s of items

!

i subjected to the Quality Program.

The above conditions, in i-apparent noncompliance with 10 CFR 50, Appendix B, Criterion X7'I, were acknowledged by management.

Management indicated

appropriate corrective action would be taken.

'

i 4.

Variation of Filter Systems from FSAR Statements (a) Test certificates on B-C charcoal lots numbered M-1851, 1 thru i

.

11, and M-1817, 1~thru 11, dated July 27, 1972, show the weight percent of impregnant as elemental iodine to be greater than 5% contrary to FSAR Table 9-15 referencing Regulctory Guide-l.52, paragraph C.6a indicating that test results on all charcoal lots should be reviewed.

The test certificates were

.

examined by the inspector on January 21, 1976.

'

(b) Auxiliary building exhaust system filter train housings, control complex emergency filter train housings and the reactor

,

l building purge filter train housing were observed by the inspector on January 20, 1976.

Contrary to FSAR Table 9-15

'

the housings are not of all welded construction and caulking

'

compound is used in nonwelded joints.

FSAR Table 9-15 references Regulatory Guide 1.52 which includes practices delineated in

i-ORNL-NSIC-65.

.

(c) On January 20, 1976, the inspector observed that check valves

I were not installed in housing drains on the control complex and auxiliary building filter trains as specified in FSAR

.

,

'

l Table 9-15.

Also, check valves were not installed in~the.

j reactor building:(containment) purge filter train housing.

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(d)

On January 20, 1976, a management' representative and the

'

inspector unsuccessfully attempted to locate differential

)

pressure indicators in the control room for the control complex

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filter trains. On January 22, 1976, the mana~gement represen-d3T i.

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tative and inspector verified with the system test supervisor

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that such instrumentation did not exist.

This is contrary to FSAR. Table 9-15._

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(e)

The apparent' deviations from FSAR Table 9-15 listed above were acknowledged by management.

Management indicated that appro-

'

priate corrective action would be taken.

.

5.

Review of Test Guide No. TG-000-55-0 (UR 76-03/l)

-

Test Guide Number TG-000-55-0, REPA and Carbon Title In-Place Leak

.

Test, was reviewed by the inspector.- The following inadequacies

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were identified (a) references to Regulstory Guide 1.52, Design, ~

Testing, and Maintenance Criterit for Atmospheric Cleanup System Air Filtration and Adsorption Un2 ; of Light-Water Cooled naclear.

Power Plants; ORNL-NSIC-65, Design, Construction, and Testing of,

-

High-Ef ficiency Air Filtration Systems for Nuclear Application; SRL-DP-1082 (TID-4500), Standarized Nondestructive Test of Carbon Beds for Reactor Confinement Applications and ANSI N510, Testing of Nuclear Air-Cleaning. Systems were not cited by the Test Guide.

?g Failure t use the above references possibly resulted in several of the procedural inadequacies described below.(b) a penetrometer

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range of 1000 times a 1% reading with a threshold sensitivity of 0.003 micrograms per liter _that corresponds to the 1% reading

'

appears inadequate (c) caulking compounds are. recommended for leak repairs when use of such materials is highly undesirable (d) vertical orientation of the HEPA filter pleats is not specified (e) cautioning statements to insure that all sampling line connections are leak i

tight are not used.

In-leakage will invalidate the test results (f) paragraphs 5.2.17 and 5.2.24 specify setting the instrument on

the lowest sensitive scale apparently meaning the highest range scale, i.e. least sensitive scale.

This could be confusing to test

'

i personnel (g) paragraphs 5.2.18 and 5.2.19 require that instrument background readings be taken and do not comment that the background readings could be to high and interfere with test measurements.

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'

criteria must be established to identify what level of background constitutes to high of a reading (h) no provisions are included in j

the Test Guide for DOP scanning of door seals, duct connections,

,

welds and instrument taps on the downstream side of filter and

'

I adsorber banks.

In-leakage at these points will dilute the DOP or

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freon' concentration, could invalidate the test results and is a

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source of bypass leakage (1) the differential pressure across HEPA banks'and adsorber. banks should be recorded after completing all

'

leak testing and repairs (j) precautions are not included in the

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last Guide to insure DOP does 'not contact the charcoal adsorbers

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(k) the DOP testing procedure does not specify retesting following.

unsatisfactory. test results and repairs initiated to improve perfor-i

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mance (1) paragraph 5.3.19.3 should specify a waiting period prior -

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to repeating the freon leak test to allow deadsorption'and clearance

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of freon from the adsorbers.

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IE Rpt. No. 50-302/76-3 III-l'

Z!Z4/76 DETAILS'III Prepared by:

.

,

K. W. Whitt, Reactor Inspector.

'Date Projects Section No. 2

,

Reactor Operations and Nuclear Support Branch

-

Dates of Inspection: ' February 3-6, 1976

,

. w-+M 2/20/7[.

Reviewed by:

[. d.

R. C. Lewis, Section Leader Date

~

Reactor Projects Section No. 2 Reactor Operations and Nuclear

,

Support Branch l.

Individuals Contacted

.

Florida Power Corporation (FPC)

J. Alberdi - Project Manager M. J. Bailey - Compliance Auditor J. Barrett - Compliance Plant Engineer O

C. B. Barbour - Senior Quality Auditor G. P. Beatty - Plant Superintendent E. E. Froats - Manager, Site Surveillance J. C. Hobbs, Jr. - Manager Generation Testing 2.

Maintenance This unresolved item (75-15/1) was identified in IE Report No. 50-302/75-15, Details, paragraph 2.

Six discrepancies were identified in the area of maintenance. All the discrepancies except one have been resolved and the corrective action was reviewed durirg this inspection.

Implementation of the corrective maintenance program for safety related systems could not be verified since sufficient

,

l data had not been developed. This item will remain open until sufficient systems have been turned over to Operations to allow the maintenance program, as described by administrative controls, to be implemented.

3.

Audits This unresolved iter (75-15/2) was identified in IE Report No. 50-

'

302/75-15, Details, p ragraph 3.

The quality surveillance audits and site surveillance groups have developed audit schedules and an-audit program has been implemented by the site surveillance group.

This item is closed.

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-Management'

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This unresolved item (75-15/3) was identified'in IE Report No. 50-

)

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302/75-15, Details, paragraph 4.

One discrepancy was initially

'

identified. Administrative instructions did not specify measures

-

'

for handling incoming NRC correspondence. A production department administrative instruction is being prepared to described the-

,

,

method to be used in' the handling of NRC ' correspondence.- The estimated issue date of the instruction is March 1, 1976. This item will remain open until the administrative instruction has been

'

approved by FPC and reviewed by IE Region II.

.

"

5.

Quality Assurance Record

,_

This unresolved-item (75-15/6) was identified in IE Report No. 50-302/75-15, Details, paragraph 7.

Two categories of discrepancies were identified.

One related to the physical facility in which records will be stored and the other concerned administrative -

controls for records retention.

The discrepancies have been H

resc,1ved as follows, a.

Physical Facility

,

A licensee representative stated that the water fire pro-

!

tection system would remain in the records storage area; however, duplicate records will be maintained in separate -

remote locations as an alternative to establishing' a permanent records storage facility. This meets the provisions of Section 5.6 of ANSI N45.2.9, " Requirements for Collection, i

Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants." One set of records is to be' maintained on site, and the second set will be maintained in the cor-

~~~

porate offices in St. Petersburg.

!

b.

Records Control Procedure Locument control procedure (DC) 101, " Drawing and Document Control" has been revised to incorporate instructions to i

correct the discrepancies identified in the Administrative

!

Controls. This item is closed.

i 6.

Receipt, Storage, and Handling This unresolved item (75-15/7) was identified in IE Report No. 50-

,

302/75-15, Details, paragraph 8.

Quality procedure 7.52, " Receiving Inspection - Spare Parts and Supplies," assigns responsibility for

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receipt storage, and handling to' the Department of Materials Systems and Stores. The materials systems and stores department s,

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thas accepted responsibility for this function as indicated by' a memorandum frot the manager, materials systems and stores'to the

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manager, quality programs dated January 23, 1976. The materials-systems and stores department has prepared administrative instruc-tions for the control of the receipt, storage, and handling opera -

.

tions. These instructions were reviewed during this inspection.

Procedures reviewed during this inspection.that were not available during the original audit include:

',

- Quality Operating Procedure (QOP) 1.0, " Organization and

-

Responsibilities" C

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- QOP 6.0, " Receipt, Quality Receiving Inspection and

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Identification"

- QOP 7.0, " Issue and Return of Quality Material"

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- QOP 8.0, " Handling, Storage, and Shipping"

- QOP 9.0, "In Storage Maintenance and Inspection."

'

.

One previously identified discrepancy remains open. The receipt,

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storage, and handling program to be utilized at the time of licensing

'

has not been implemented. A licensee representative stated that the materials systems and stores department will assume responsible

,

for and commence implementation of the program on February 23, 1976.

7.

Document Control

This unresolved item (75-15/8) was identified in IE Report No. 50-302/75-15, Details, paragraph 9.

DC-101, " Drawing and Document Control," now describes the methods to be used by the operating'

j staff in the handling of drawing.

Engineering control procedures describe the process -to be used to distribute as built drawings and-drawing revisions to.the plant staff.. The engineering control procedures (ECP) that were reviewed during this inspect 3an include:

- ECP 31, " Design Development"

- ECP 33, " Design Verification

,

ECP 34, " Document Approval and Control"

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ECP 35, " Design Change Control"

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This unresolved item is closed.

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IE Rpt. No. 50-302/76-3 III-4

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8.-

Plant Status l

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a.

C_onstruction All systems inspected that have been' turned over to generation

'

l testing have exceptions remaining to be zesolved. Approxi-

>

mately 5% of the systems have not been turned over.

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b.

Testing

.

Test procedures identified to be developed include 335 pre-operational test procedures, 3 chemistry test procedures, 25

[

hot functional test procedures, 3 zero power test procedures,

'

33 power escalation test procedures and 1 radiation survey (shield survey) procedure for a total of 389. Test procedures that remain to be approved include 8 preoperational, 9 hot

functional, 3 zero power,18 power escalation, and 1 radiation ~

' ~

survey for a total of 39.

One hundred and thirty two of 335 preoperational tests have been completed.

Sixteen of the completed tests have test deficiencies to be resolved. The

,

'

results of 69 tests have been approved.

Less than ten systems have been turned over to Operations.

c.

Operations

.

Three hundred and twenty six. operational procedures have been

'

identified. Of these, 232 have been approved.

Plant opera-tions has accepted turnover of five systems.

d.

Fuel Load Date

'

April 9,1976, has been established by the licensee as the official fuel loading date.

Plant heatup for hot functional testing is scheduled to commence during the week of February 15, 1976.

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IV-11

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M/23/7[8 DETAILS IV Prepared by:

.

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R. F. Rogers, Reactor Inspector Date Nuclear Support Section Reactor Operations and Nuclear

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Support Brauch j

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Dates of Inspection: February 3-6, 1976 b

MC Y 74

"

Reviewed by:

H. C.-_ Dance, Section Leader

" Date

"

NQclear Support Section Reactor Operations and Nuclear

,,

Support Branch

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1.

Personnel Contacted

,

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G. P. Beatty, Jr. - Nuclear Plant Superintendent E. E. Froats - Manager, Site Surveillance P. E. Griffith - Training Coordinator

!

R. A. Shirk - GAI Test Engineer J. E. Barrett - Compliance Plant Engineer 2.

Review Administrative instructions were reviewed to determine if responsi-bility had been established to determine the impact on surveillance and plant procedures resulting from license'or technical specifica-

,

_

This concern was initially identified as Unresolved tion changes.

Item 75-15/4. Administrative Instruction 400, " Plant Operating Quality Assurance Manual", has been revised and now delineates this responsibility. This item is closed.

3.

Surveillance Testing Administrative instructions were reviewed to determine if require-ments had been established to return systems to norcal following testing and to record special test equipment used in-the conduct of a surveillance test. These concerns were' initially identified as Unresolved Item 75-15/5. Administrative Instruction 400 has been revised to incorporate these requirements. This item is closed.

4.

Qualification of Personnel Licensee documentation and administrative instructions were reviewed g

to determine if administrative controls describing minimum educa-j tional, experience, and qualification requirements had been established.

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The status of uncompleted staff training required by FSAR Figure

12.2.1 was also reviewed.

These concerns were initially identified as Unresolved Item 75-15/9.

Administrative Instruction 200, "Organi-zation and Responsibilities", has been revised to establish minimum

.

qualification requirements and. assure that they will be met.

The required staff training had not been performed. A licensee represen-

',

tative stated that an amendment to the FSAR would modify these requirements to reflect current training status.

This item will

.

remain open, d

5.

Training Administrative instructions were reviewed to determine if formal

.

training associated with the licensee's QA program and operator requalification had been established.

Also, implementing documenta-tion for the training coordinator was reviewed.

These concerns

-

were initially identified as Unresolved Item 75-15/10. A training coordinator bas been assigned and his duties and responsibilities established in Administrative Instruction 200. A draft administra-tive instruction (1200) has been approved to bnplement QA and requalification training. A licensee representative stated that-A/I 1200 would be ready for review at the next inspection.

This item will remain open.

6.

Training Completion and Documentation Operating staff training and documentation of that training were reviewed to determine if the training program described in FSAR Section 12.2 was properly documented.

This concern was initially identified as Unresolved Item 75-16/2.

The training files require further updating to reflect training required by the FSAR.

A licensee representative stated that this would oe done. This item

'

will remain open.

7.

Control of Temporary Modifications and Bypasses

'

Administrat..ve procedures were reviewed to determine if jumper log

controls hai been revised to address the use of approved procedures, independent verification, and functional testing of equipment.

These concerns were initially identified as Unresolved Item 75-19/2-Compliance Procedure 114, " Procedure for Control of Permanent Modifications, Temporary Modifications and Deviations", was in the process of beir2 revised to incorporate these changes.

The inspecto?:

discussed the revision with the responsible licensee representative and will review CP 114 on a subsequent inspection.

This item will remain open.

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8.

Centainment Integrated Leak Rate Test TP 71-150-02 The inspector reviewed the containment integrated leak rate test to

'

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determine-if-it reflected FSAR requirements in maximum test pressure Pc and test instrumentation reliability. These concerns were initially icentified as Unresolved Item 75-16/3. There is still disparity

,

between the FSAR Section 5.6.3 and the test procedure on the above items. Additionally, the half pressure portion of the ILRT has been deleted from the licensee's procedure.

This also conflicts

,]

with the FSAR. A licensee representative stated that an FSAR

,

admandment would soon be issued to correct any disagreements between

,

the test procedure and the FSAR.

This item will remain open.

..

9.

Core Flooding System Functional Test TP 71-201-3

'

This procedure was reviewed for conformance to Regulatory Guide l.79 "Preoperational Testing of Emergency Core Cooling Systems for'

Pressurized Water Reactors." Concerns over lack of conformance to RG 1.79 regarding hot and cold flow checks was initially identified as Unresolved Item 75-19/3.

The procedure has been acceptably revised and approved.

This item is closed.

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DETAILS V Prepared by:

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F. Jape, Reactor 16sfector Date

-

Reactor Projects Section No. 1 Reactor Operations and Nuclear Suppert Branch-

-

Dates of Inspection: Febr y 3-6, 1976 F-

,

.

.

.

'g (

z.[7[7g, Reviewed by:

W. C. Seidle,L4ection Leader

'Date

"

~

Reactor Projects Section No. 1 Reactor Operations and Nuclear Support Branch

,

1.

Individuals Contacted

.

Florida Power Corporation (FPC)

C. R. Pope - Administrative Supervisor B. Chastine - Data Collection Engineer O

T. C. Luckehaus - Maintenance Engineer P. F. McKee - Assistant Plant Superintendent G. P. Beatly - Plant Superintendent W. R. Nichols - Operations Supervisor 2.

,Preoperational Test Results Review The test results of completed preoperational tests were reviewed to determine that:

a)

The licensee is evaluating the test results.

,

b)

The data are within previously established acceptance criteria.

c)

Deviations and test changes are properly dispositioned.

d)

Deficiencies identified during the conduct of the test have been corrected and retesting completed as necessary.

e)

The licensee has reviewed and accepted the test results.

The tests selected for review dealt with the plant emergency power system and the reactor coolant system hydrostatic test.

F r the tests examined, there were no discrepancies identified.

""ur of the six tests reviewed had not been through the complete review and acceptance as described in Section 13.2.6.3 of the FSAR.

The tests examined are listed below:

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.IE'Rpt. No. -50-302/76-3-V-2-

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,a)

TP451 1, " Cleaning and Flushing Emergency Diesel' Fuel Oil Supply System."

b)

TP451 2,."Clesning and Flushing Emergency Generator Startup'

Air System."

• c)

TP451 15, "480 Volt Engineered Safeguards Switch Gear."

• d)

TP451'20, " Pressure Test of Emergency. Diesel Generator Startup-

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Air System."

• e)

TP451 23, " Station Batt'ery High Voltage Equalization."

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• f)

Tp 200 4, "RCS Hydrostatic Test."

.

• Review and acceptance of these tests, by the licensee was not completed'

'

during the inspection period.

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3.

Fire Prevention and Protection

,_

A followup review of work control procedures for the prevention of'

andprotectionagainstfireswasegducted.

The status of items previously reported as incomplete - were found to be as follows:

a)

Controlling use of open flame and welding in certain plant areas by using a special work permit.

A draft procedure entitled, CP 118, " Cutting, Welding and Grinding Permit," has been prepared. NRC may review this'

procedure after it has been approved aud issued.

b)

Establishing a fire watch'for certain activities.

I Requirements for a fire watch is to be included in CP 118.

I c)

Determining a policy regarding use of water to extinguish fires involving electrical equim ent.

License representative stated that an emergency procedure will be developed, but has not been drrfted yet.

,

.

I d)

Reviewing emergency procedures or plans covering fires to include alternate methods for reactor cooldown in case of l

loss of normal or preferred method.

i Status is same as c) above.

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1/ IE Report No. 50-302/75-16, Details VI, paragraph 3.

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Establishing an audit program to verify that control measures

are being properly Laplemented.

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An aud'it check list has been provided by the Compliance -Engineer -

which satisfies this item.

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The status of these items was discussed at the management meeting

'

at.the conclusion of.the inspection.

Licensee' management was

',

informed that these items are expected to be fully resolved prior

.

'

to licensee issuance. Licensee management acknowledged this under--

standing.

.

"

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4.

Review of Operational Procedures

,

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l Procedures for the operation of plant structures, systems and-components were reviewed using the guidance of ANSI N18.7-1972.

The inspector's comments were discussed with licensee management.

.

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These are summarized below:

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OP 207, " Fire Protection Systems"

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Item 4.4 under Limits and Precautions and Section 9.8.1.1 of j

-

the FSAR refers to the Freon fire suppressant system in the-i l

cable spreading room.

It is our understanding that the. Freon Which l

system ha. been replaced with Halon fire suppressant.

j fire suppressant will be used and if Halon is to be used, will'

I the operating procedure and the FSAR be revised to agree with the as-built plant?

Licensee Management stated that this comment will be reviewed t

,

and appropriate corrections will be made.

i b)

OP 305, " Reactivity Balance Calculation" i

This procedure describes calculations for estimating critical

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i rod positions and determining shutdown margins.

The procedure

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does not require a signature of the operator making the calcula-tions and does not require double verification.

Shouldn't.

this be incorporated into the procedure?

Licensee management stated that the entire procedure is being g

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I rewritten and inclusion of the comment will be considered.

c)

'OP 707, " Receiving Diesel Fuel"

- The objective of this procedure is to describe receipt of l'

diesel fuel'for the emergency diesel generators and the diesel fire' water pumps..However, in the body of the procedure,

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IE Rpt. No. 50-302/76-3 V-4

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'these are no' action items covering the diesel storage tanks for the fire water diesel pumps.. Where will this subject be covered 7*

Licensee Management stated that the installation of the storage-tanks for the fire water diesel pumps has not been completed.

.

Upon completion of this work, the procedure will be revised to incorporate the subject.

The inspector stated that complete

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installation and preoperational checkout of the diesel water system is required prior to license issuance.

This item will be carried as unresolved item 76-3/1.

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d)

OP 706, " Emergency Power - Diesel Generators"

Step 5.7 presents a minimum on-site diesel fuel supply of 40,600 gallons. This limit appears to be inconsistent with Technical Specification 3.8.1.2 b. 2.

In addition, the diesel fuel transfer operations from the storage tank to the day tank are not covered by this or any other series 700 procedure.

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Licensee management stated that the procedure would be revised to be consistent with Technical Specifications and transfer operations will be covered in an appropriate procedure.

d e)

FP 201, " Refueling Operation Sequence of Events" No comment.

f)

FP 302, " Fresh Fuel Unpacking, Inspection and Storage" No comment.

g)

FP 401, " Reactor Vessel Closure Head Removal and Replacement" Step 5.10 stated that ".

.only Neolube.

." should be

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used,'and step 6.14 refers to Moly Kote-G lubricant.

This appears to be inconsistent.

Licensee Management stated that this item would be reviewed and corrected.

h)

FP 402, " Reactor Vessel Closure Head Stud Removal and Replacement" Step 5.6 requires studs to be lubed, but it is not clear if

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Moly Kote-G, Lubra Seal or Neolube is to be used.

Licensee management stated that this item will be reviewed and

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fsg corrected.

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1)

FP 501, " Reactor Interna s Removal and Replacement"

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No comment.

j)

FP 601, " Fuel Handling Equipment Operations"

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Action steps 6.0, 7.2 through 7.4, 8.3 through 8.10 and 9.1

through 9.7 do not have sign-offs.

Shouldn't these steps be

,

initiated'and dated?

,

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Licensee management stated that this procedure will be reviewed

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and corrected as necessary.

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k7 FP 901, " Primary Neutron Source Receipt, Inspection, Storage--

and Installation" No comment.

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5.

Followup on Previous Comments In a previous report,

/ comments on OP 401, " Core Flooding System"

were discussed.

Follow-up on these comments revealed that all have-been incorporated within the procedure.

No-additional review of this procedure is planned at this time.

If IE Report No. 50-302/75-16, Details VI, paragraph 2.(a).

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