IR 05000302/1978005
| ML19319C981 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 03/28/1978 |
| From: | Ewald S, Gibson A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19319C961 | List: |
| References | |
| 50-302-78-05, 50-302-78-5, NUDOCS 8003040912 | |
| Download: ML19319C981 (10) | |
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Report No. 50-302/78-5 Docket No.:
50-302 License No.: DPR-72 Licensee:
Florida Power Corporation P. O. Box 14042 St. Petersburg, Florida 33733 Facility Name:
Crystal River Unit 3 Inspection at:
Crystal River Site, Crystal River, Florida Inspection conducted:
February 28 - March 8, 1978 Inspectors:
S. C. Ewald e
J. H. Davis (
Reviewed by:
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A. F. Gibson, Chief Date Radiation Support Section Fuel Facility and Materials Safety Branch Inspection Summary Inspection on February 28 - March 8, 1978 (Report No. 50-302/78-5)
Areas Inspected: Routine, unannounced inspection of previously identi-fied items, the radiation protectich program including respiratory,
protection and surveys, an unplanned radioactivity release of March 5, 1978, and radiation, protection aspects of the outage commencing March 3, 1978. The inspection involved 85 inspector-hours onsite by two NRC inspectors.
Results:
Of eight areas inspected, no apparent items of noncompliance or deviations were identified in six areas.
Two apparent items of noncompliance were identified in two areas (infraction - failure to follow radiological survey procedures (78-05-01) - paragraph 5; infraction -
failure to follow administrative and operating procedures (78-05-02) -
paragraph 7).
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N RII Rpt. No. 50-302/78-5-1-
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DETAILS Prepared by:
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/ S. C. Ewald, Radiation Specialist Date 4 Radiation Support Section
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Fuel Facility and Materials Safety Branch Dates of Inspection:
eb 28 - March 8, 1978 Reviewed by:
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A. F. Gibson, Chief Date Radiation Support Section Fuel Facility and Materials Safety Branch 1.
Individuals Contacted
- G. P. Beatty, Jr., Nuclear Plant Manager
- P. F. McKee, Assistant Nuclear Plant Manager
- J. R. Wright, Chemical and Radiation Protection Engineer
- J. L. Harrisson, Assistant Chemical and Radiation Protection Engineer
- G. D. Perkins, Health Physics Supervisor
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- G. H. Ruszala, Radwaste Management Supervisor
- R. E. Fuller, Plant Engineer W. A. Cross, Plant Engineer
- J. Cooper, Compliance Engineer
- G. M. Williams, Compliance Plant Engineer
- E. G. Beall, Chief Chemical and Radiation Protection Technician
- W. R. Nichols, Operations Supervisor
- K. O. Vogel, Computer and Controls Engineer i
G. L. Claar, Compliance Auditor
- Denotes those r ending exit interview.
2.
Licensee Action on Previously Identified Items a.
(Closed) Outstanding Item (77-14-04) Decontamination Facility
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An inspector reviewed the results from Test Procedure No. TP-78-1-3 detailing functional tests of the decontamination facility ventillation completed January 31, 1978.
The inspector discussed the test results with the cognizant plant engineer and inspected the installed facility.
During the inspection, the installation of an overhead rail and hoist was completed
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thus allowing the decontamination of large pieces of equipment.
The inspector noted the facility has been used extensively
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i with good results since the completion of test procedures.
The inspector had no further questions..
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b.
(Open) Unresolved Item (77-22-03): Waste Gas Loop Seal Modifi-i cations.
The -inspector reviewed the status of seven Maintenance -
Approval Records (MAR's).
This item is discussed in detail in paragraph 8.
3.
Internal Exposure a.
Air Sampling The inspector examined airborne radioactivity survey results for reactor building entries and special surveys for January and February 1978.
Ihese records showed that particulate radioactive material and radioiodine had been below the most restrictive maximum permissible concentration (I-131).
Discussions with licensee representatives and examination of the records mentioned above indicated that airborne radioactivity concentration levels were measured in areas of potential i
exposure prior to personnel entries into these areas as required by 10 CFR 20.103 and 20.201.
The inspector had no further
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questions regarding air sampling.
b.
Bionssays
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Discussions with licensee representatives and examination of urinal-
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ysis and whole body counting results for selected individuals for
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1977 and January - February 1978 revealed that the licensee had
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established a bioassay program as required by 10 CFR 20.103.
d Records for this period verified that body burdens of the most probable radionuclides for these individuals were well below maximum permissible body burdens.
The inspector had no further questions J
regarding the licensee's bioassay program.
4.
Respiratory Protection
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a.
Respiratory Protection Procedures
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Examination of Radiation Protection Procedure RP-102, "Respira-l tory Equipment Manual", revealed that a policy statement had been issued stating licensee management's commitment to limiting
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personnel exposure to airborne radioactivity through the use i
of engineering controls followed by a formal respiratory
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program, as required by 10 CFR 20.103(c) (Regulatory Guide
i 8.15, " Acceptable Programs for Respiratory Protection").
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Further, procedures had been developed which addressed selection, supervision and training of personnel; fitting and testing of respiratory protective equipment; maintenance;
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operational and administrative procedures for control, issuance, Proper use and return of respiratory protective equipment, including provisions for planned limitations on duration of
respirator use for any individual as necessitated by operational conditions, as required by Regulatory Guide 8.15.
b.
Fitting and Testing of Respirators By examination of the fitting and testing section of the licensee's Respiratory Equipment Log, the inspector verified that individuals wearing respiratory protective equipment in January - February 1978 had been fitted and tested as required by Regulatory Guide 8.15.
The inspector noted that the fitting of respirators is performed in conjunction with training and is accomplished by use of a qualitative irritant smoke test.
An inspector participated in respirator fitting activities on March 2, 1978 and had no (aestions.
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c.
Training s
Discussions with licensee representatives and examination of training records for 1977 and January - February 1978 revealed
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I that those individuals requiring respiratory protective devices in January - February 1978 had been trained in respira-j tory protection as required by Regulatory Guide 8.15.
The inspector discussed with licensee representatives the merits of more tLnely entries of documentation verifying training conducted into the individual training files.
The inspector had no further questions pertaining to respiratory protection training.
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d.
Use of Respiratory Protective Equipment Examination of licensee procedures and discussions with licensee representatives revealed that uses of respiratory protective devices for protection against radiological hazards were covered under the radiation work permit (RWP) program.
The inspector compared the RWP file for January - February 1978
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with the entries in the Respiratory Equipment Log, the reactor building entry log, and records of special survey results and
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i found that situations involving a significant potential for
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airborne radioactivity exposure were covered by the RWP program.
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s The inspector discussed with licensee representatives the merits of entering all uses of respiratory equipment into the Respiratory Equipment Log and documenting the degree of radiological hazard or
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the absence of such hazard in the comments column.
Licensee repre-
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sentatives stated that although it had not been their practice to
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enter those uses of respiratory protective equipment for situations involving no significant radiological hazard, they would consider a modification in their approach to include all uses of respiratory i
protective equipment in the log.
The inspector had no further
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questions on the use of respiratory protective equipment.
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Surveys An inspector reviewed Radiation Protection Procedure RP-202 -
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" Radiological Serveys" detailing the routine survey requirements.
The inspector reviewed all daily contamination and radiation level surveys performed from June 30 to September 30, 1977 and from January 1 to February 20, 1978.
The inspector reviewed all weekly surveys for the period October 4,1977 to February 14, 1978 and monthly surveys for the period August 7, 1978 to January 7, 1978.
_y b.
RP-202 Section 2.1.1.1.a specifies surveys of the control point corridor, hot locker room, radiochemical lab, health physics service room, counting room and laundry be performed on a daily basis. An inspection of 144 daily survey records (indicated above) revealed twelve instances where only the control point corridor was surveyed.
In addition, no radiation levels were recorded for surveys performed in six other instances, RP-202 Section 2.1.1.1.b lists the diesel generator building c.
as one of ten areas to be surveyed weekly. A review of 20 weekly surveys indicated above revealed no instances when the diesel generator building was surveyed.
In addition, in three other instances, one or more of the listed areas were not surveyed.
d.
Technical Specification 6.11 requires radiation protection procedures be adhered to.
The inspector stated the above i
examples of failure to follow Radiation Protection Procedure
RP-202, " Radiological Surveys", were in noncompliance (78-05-01) with Technical Specification 6.11.
The inspector noted
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that the majority of the above ommissions occurred in the
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third quarter of 1977.
The frequency of these errors appeared
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to be getting smaller, indicating an improvement in the perform-ance of routine surveys.
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s The inspector noted that RP-202 did not address surveys of a.
locked cubicles in the auxiliary building.
These locked areas are usually radiation or high radiation areas and may or may
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not be contaminated.
The inspector noted that radiation work permit procedures would require surveys prior to work in these areas. The inspector expressed concern that these areas could go indefinitely with no surveys performed and thus radiological conditions could change significantly with no recognition of any change.
The Health Physicist acknowledged the inspector's concerns and stated that consideration would be given to developing a routine program for surveys of normally locked areas.
The inspector had no further questions.
6.
Sealed Source Leak Tests An inspector reviewed Radiation Protection Procedure RP-205, " Leak Testing of Sealed Sources" and the results of leak tests performed August 10 and December 12, 1977.
The inspector noted source No. 18 had shown smearable activity in both the August and December tests on the order of 2 x 104pci.
This is well below the limit of 5 x
~3 ci set by Technical Specification 3.7.10.1.
The Health Physics
p Supervisor stated the removable activity was found to be surface contamination from the reactor and not the result of a small source leak.
The inspector had no further questions.
7.
Unplanned Caseous Release March 5, 1978
a.
On March 5, 1978 approximately 128 curies of noble gas were
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released to the auxiliary building and, via auxiliary building ventillation system, to the environment. Licensee analysis of auxiliary building sampling and monitor data indicated the
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release was approximately 5% of the noble gas instantaneous
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release linit specified in Environmental Technical Specifica-tion 2.4.2.A.1.
Licensee estimates, verified by the inspector, based on grab sample data and dose rate ratios, indicated the concentration of radioactive gases in the immediate vicinity of the release point in the auxiliary building may have been as high as 1500 times the concentrations listed in 10 CFR 20, l
Appendix B, Table 2, column 1 (unrestricted ares limits). The release was subsequently reported pursuant to 10 CFR 20.403(b)(2).
The release was determined to have originated from blown loop j
seals on systems vented to the low pressure vaste gas header.
A licensee review determined no personnel were exposed as a result of this release.
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b.
A licensee review revealed the release resulted from overpressuri-zation of the waste gas header during filling of the reactor coolant bleed tanks.
The waste gas header had been isolated
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from the waste gas system as part of a temporary change to Operating Procedure OP-205, " Hydrogen Addition and Degasification."
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Due to recurrent problems with loop seals and the incomplete status of major modifications to the loop seal system (discussed in paragraph 8), a temporary change in degassing procedures was implemented.
This temporary change called for isolation of the waste gas header and loop seals to preclude unplanned releases. An inspector reviewed the temporary change to OP-205 and discussed it Jith the Radwaste Management Supervisor prior to initiation of degassing operations on March 3, 1978.
The inspector verified the temporary change was implemented and approved in accordance with Technical Specification 6.8.3.
c.
The licensee review of the incident revealed the waste gas header was not realigned to the waste gas compressor (normal configuration) at the conclusion of primary coolant degasification as stipulated in the temporary change.
In addition, a review of the operators log revealed thct periodic (hourly) alignment of the waste gas compressors to the waste gas header, as
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stipulated in Section 8.2.5 of the temporary change, was not performed.
This could have precluded the overpressurization of the waste gas header.
An inspection of procedure sign-off sheets revealed incomplete signoffs at numerous steps of the temporary procedure.
Strict adherence to sign-off requirements,
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as stipulated in Administrative Instruction AI-400, Section
5.1, could have revealed the above two examples of failure to j
follow the temporary procedure and thus precluded the release.
i d.
Technical Specification 6.8.1 requires implementation of procedures recommended in Regulatory Guide 1.33, including operating procedures for plant shutdown through cold shutdown
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and administrative procedures.
This includes degassing procedures.
Contrary to the above, the temporary change to OP-205, Section
8, was not followed on March 5, 1978, in that the waste gas i
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system valven were not returned to their normal positions as stipulated in the temporary change and the periodic venting of j
the waste gas header was not carried out as stipulated in the temporary procedure change.
In addition, procedure sign-off sheets were not completed as required by AI-400, Section 5.1.
The inspector stated the above three instances of failure to follow procedures were in noncompliance (78-05-02) with Technical Specification 6.8.1.
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8.
Waste Gas System Modifications (Unresolved Item 77-22-03)
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Discussions with licensee representatives revealed seven a.
Maintenance Approval Records (MAR's) were generated to implement the recommendations of an engineering study performed in i
September 1977, A review of the status of these modifications i
revealed all had received required apr-r $1s and had been assigned work request numbers. Four of te seven were scheduled for implementation during the current outage and a fif th could be implemented if the outage extended several weeks. The remaining two MAR's were currently awaiting receipt of materials before implementation could proceed.
These last two MAR's (77-10-3 and 77-10-3A) involved increasing the venting capacity j
of the Reactor Coolant and Miscellaneous Waste Evaporatore and installation of surge tanks to these vent lines, i
b.
Discussions with licensee representatives and a review of records revealed that : mall unplanned releases resulting from blown loop seals were continuing to be a problem.
Records indicated that on four occasions in February 1978, blown loop seals resulted in releases that tripped the auxiliary building
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ventilation monitor.
The inspector expressed concern about
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the recurring nature of this problem to licensee management and requested a completion date for the waste gas system modifications be submitted in response to this report.
Licensee
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Management acknowledged the inspectors concern and agreed to supply the requested information.
Licensee Management stated efforts would be made to implement all modifications as soon as possible.
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9.
Current Outage At midnight March 3,1978, the plant began shutting down to a.
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investigate the source of noise detected by a loose parts monitor associated with the "B" once through steam generator (BOTSG).
The inspector discussed preparations for this outage with Chem / Rad staff.
These preparations included use of a
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contract laundry facility onsite, provisions for onsite reading of thermoluminescent dosimeters (TLD's), acquisition of various
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supply items (protective clothing, gloves, boots, paper products, etc.) and training of on and off site personnel in radiation protection and respiratory protection (including fitting of respirators).
The inspector discussed contamination control with chem / rad staff and noted the use of a hand and foot monitor plus a frisker at the containment step off pad.
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Preparations for inspection of the upper BOTSG tube sheet included installation of auxiliary ventilation include HEPA
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filters and construction of access tents for contamination control. Licensee representatives stated, after a complete radiological survey, the initial entry to the BOTSG would be
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for installation of a television camera to allow remote identi-fication and analysis of loose parts and damage.
The inspector noted that all personnel entering the tent would be required to wear plastic suits and air line respirators.
b.
The inspector observed the completed tent and installed venti-lation on the BOTSG prior to opening of the manway on March 6.
As a precaution, in the event of airborne activity, containment was evacuated during the removal of the manway diaphragm and initial survey of BOTSG.
The inspector observed the debriefing of chem / rad personnel performing these operations.
This.
debriefing resulted in the tentative identification (later confirmed) of the loose parts as a burnable poison rod coupling assembly.
Survey results showed radiation levels of six to 7 -%s ten rem / hour in the general area above the upper tube sheet.
Later on March 6, a television camera was placed on the tubesheet
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just inside the manway and a videotape scan of the upper tube sheet was made. The inspector reviewed the videotapes on March 7 and 8 and noted significant tube end damage and confir-mation of loose parts identification.
On March 7, the inspector entered the BOTSG tent and observed c.
the loose parts and tube end damage immediately prior to removal of the loose parts.
The inspector observed the removal of the loose parts. This operation involved an individual entering the aanway and placing the loose parts into two
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buckets.
The buckets were subsequently loaded into a shielded 55 gallon drum on a cart for removal from containment.
The parts were temporarily stored in the decontamination room and appropriate posting and controls established.
Doses received by personnel included approximately 200 arem '(whole body) and 300 mrom (extremities) to the individuals who entered the BOTSG and 20 to 50 arem to other support personnel. Tentative plans for shipping the loose parts to the vendor for analysis were under consideration.
d.
The inspector reviewed ten Radiation Work Permits (RWP's) and associated surveys generated in conjunction with the outage including those for BOTSG entry.
The inspector had no questions.
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10.
Exit Interview i
At the conclusion of the inspection on March 8, 1978, the inspector
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met with management representatives (denoted in paragraph 3.).
The inspector summarized the scope and findings of the inspection.
Items discussed included two items of noncompliance, plant managements agreement to supply a completion date for the waste gas system j
j modifications, and current status of the present outage.
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