IR 05000302/1981011
| ML20010J193 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 07/28/1981 |
| From: | Kellogg P, Beverly Smith, Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20010J142 | List: |
| References | |
| 50-302-81-11, NUDOCS 8109290691 | |
| Download: ML20010J193 (17) | |
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o UNITED STATES
N, NUCLEAR REGULATORY COMMISSION
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E REGION ll e,
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101 MARIETTA ST., fl.W., SUITE 3100 AT LANTA, GEORGIA 30303 s
Report No. 50-302/81-11 Licensee:
Florida Power Corporation 320134th Street, South St. Petersburg, Florida 33733 Facility Name: Crystal River Unit 3 Docket No. 50-302
License No. DPR-72 Inspection near Cryst 1 er, Florida
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Inspectors:
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T. F Q etk, Senior Resident Iqbpe,ctor Dhte Signed
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O!5l 7/ADdteSig!I[
ned it), pesident Inspect rf B. W.
Approved by [Me
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W ellogg, Section Chief / Division of Dhte Signed PaulJ.{'entandReactorProject. Inspection Resid SUMMARY Inspection on May 26 through June 26, 1981 Areas Inspected This routine, inspection by the resident inspectors of plant operations, securit,, radiological controls, Licensee Event Reprts (LER's) and Non-Conforming Operations Reports (NCOR's), nonroutine events, licensee action of IE Bulletins, on-site review committee activities, Quality Control (QC) inspector qualification and training, administrative controls developed to prevent defeating of containment purge isolation signals, licensee action on NRR order concerning isolation check valves, and licensee action on previous inspection items. Numerous facility tours were conducted and facility operations observed.
Some of these tours and observations were conducted on back shifts.
In addition, a corporate inspection of the offsite review committee activites was conducted.
The inspection involved 206 hours0.00238 days <br />0.0572 hours <br />3.406085e-4 weeks <br />7.8383e-5 months <br /> onsite and 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> at corporate headquarters by two resident inspectors.
Resul ts
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Three viola <.ius.s were identified (Failure to perform n.mn51y surveillance on pressurizer power operated relief valve and code safety v.lves, paragraph 5.B(9);
Failure of the NGRC to review items as required by the Technical Specifications, paragraph 9.A; Failure of the PRC to have a quorum, to designate alternate members in writing, and to review all Technical Specification violations, paragraph 11.).
h9290691 e10922 '
G ADOCK 05000302
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DETAILS 1.
Persons Contacted Licensee Employees J. Alberdi, Fossil Area Manager P. Baynard, Manager, Nuclear Support Services
- G. Boldt, Technical Services Superintendent
- C. Brown, Nuclear Compliance Supervisor J. Bufe, Compliance Auditor
- J. Cooper, QA/QC Compliance Manager
- S. Coward, Chemistry and Radiation Protection Specialist
- W. Cross, 0prations Engineer B. Crane, Planning Engineer E. Froats, Manager Quality Audits and Engineering
- R. Fuller, Chemistry and Waste Manager
- V. Hernandez, Compliance Auditor
- J. Hicks, Supervisor Material Technology
- J. Hobbs, Executive Assistant to Senior V. P. Engineering and Construction W. Kemper, Plant Training." nager
- K. Lancaster, Quality Assurance Auditor
- J. Lander, Maintenance Superintendent
- T. Lukehaus, Technical Assistant to the Nuclear Plant Manager P. KcKee, Operations Superintendent G. Perkins, Health Physics Supervisor D. Poole, Nuclear Plant Manager G. Ruszala, Chemistry / Radiation Protection Manager
- D. Shook, Principle Electrical Engineer
- D. Smith, Technical Services Superintendent L. Tittle, Performance Engineering Supervisor G. Williams, QA/QC Supervisor
- K. Wilson, Licensing Specialist
- J. Wright, Nuclear Support Specialist, Chemistry & Radiation Protection Other licensee employees contacted included office, operations, engineering, maintenance, chem / rad, and corporate personnel
- Present at the Exit Interview of Jurn 11, 1981
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- Present at the Exit Interview of Jur.e 26,1R 2.
Exit Interview The inspectors met with licensee representatives (denoted in paragraph 1) on numerous occasions during the inspection period.
Exit interviews were conducted on June 11, 1981 at the corporate hee.dquarters and on June 26, 1981 at the plant site.
During these meetings the inspectors-summarized the scope and findings of the inspection as they are detailed in this report.
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During these meetings the violations, unresolved items and inspection followup items were discussed.
3.
Licensee Action on Previous Inspection Findings (Closed) Unresolved Item (302/80-30-04):
Review of the 1979 Corporate Audit on September 8,1980 identified five audit findings that remained open (AFR-6, AFR-8, AFR-15, AFR-B.2(a) and AFR-B.2(c).
The corrective actions on these audit findings, with the exception of AFR-8, were verified as completed on November 26, 1980. Audit Finding Report 8 corrective action has not been completed because the corrective action completion is dependent upon a Technical Specification amendment that has been submitted to NRR.
The licensee's action on this item are considered to be complete.
(Closed) Inspector Followup Item (302/81-02-09): The licensee has submitted corrected reports for LER 80-55 and Special Report 80-03.
These reports identify the manufacturer and model number of the failed relays.
(0 pen) Inspector Followup Item (302/81-05-10): The emergency drill critique was issued on fiay 26 and has been reviewed. The critique indicates that some changes to the Emergency Plan (EM-100) are necessary and that addi-tional personnel training and staffing are required. The critique also indicates that some equipment changes and additicns are required. The licensee is in progress of resolving the critiqi.e iindings. This item remains open pending NRC review of licensee actions.
(Closed) Violation (302/81-05-01): The licensee issued Licensed Event Report (LER) on 81-25 on llay 12, 1981 describing this event and revised SP-39, Emergency Feedwater System Operability Demonstration (Revision 40) to require a signoff to verify completion of all required actions.
In addition the licensee reviewed other operations surveillance procedures to verify that the remaining procedures required a signoff for returning equipment to an operable status. The licensee's action of this item is complete.
(Closed) Violation (302/81-05-02): The licensee has completed all corrective actions with the exception of a revision to procedure RP-101, Radiation Protection llanual, that will implement an RWP violator enforcement policy. The revision to RP-101 will be completed by July 15, 1981 and this item reamins open pending completion of this action.
(Closed) Violation (302/81-05-05): The licensee has revised procedure
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SP-101 Halon System Surveillance, and rerun the test to verify operability of the Halon system. The revised procedure was reviewed and the retesting observed by the resident inspector as satisfactory. The licensee now has a properly reviewed copy of the Fenwal Instruction Manual in the Technical Library.
In addition, the licensee has revised procedure AI-400, Plant Operating Quality Assurance Manual Control Document to require tiiat the latest revision to the manufacturer's Instruction Manual be reviewed with the surveillance procedure.
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(Closed) Noncompliance (302/77-17-01): The licensee has implemented the corrective action as stated in their response letter of November 15, 1977 of assigning reporting responsib*lity to the compliance group.
(Closed) Noncompliance (302/77-17-02): The interlocks to terminate a gaseous release upon failure of a gaseous system monitor have been installed and are operable. The licensee's action on this item is complete.
(Closed) Inspector Followup Item (302/81-02-07): AI-400, Plant Operating Quality Assurance Control Document, has been revised to implement a new method for controlling temporary procedure changes. The inspector's review of the new method indicates the problem identified by this item should be prevented.
(Closed) Inspector Followup Item (302/81-05-04):
Calibration sheets for the incore backup recorders covered by SP-132 have been deleted. The calibration sheets in PH-140 have been revised to reflect an accuracy of
+1 recorder units.
The inspector has no further questions on this item.
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(Closed) Inspector Followup Item (302/81-02-10): The licensee performed relay testing in accordance with SP-130, Engineered Safeguards Monthly Functional Tests, on January 2,1981.
Subsequent to this test performance, test SP-355, Operations ES Monthly Functional Tests, was performed and during this test the relay failed.
The failure was traced to a loose lead on the relay socket. The relay was retested in accordance with SP-355 and was subsequently retested in accordance with SP-130 on February 13.
(Closed) Inspector Followup Item (302/80-42-09): The licensee's investi-gation into the use of incorrect seal material in snubber MSH-248 indicates that h purchasing department error caused the wrong seals to be obtained.
The licensee has revised purchasing department procedures to prevent recurrence. A review of the surveillance data for snubber HSH-248 does not 1,idicate that any seal failure is occurring.
The licensee is continuing his i
surveillance of this snubber until the proper seal material is installed during the upcoming refuel outage.
(Closed) Inspector Followup Item (302/01-07-06): The licensee has revised procedure EP-106 and EP-107 on June 5 to include the magnitude of steam generator and pressurizer level changes due to high reacter building temperature.
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4.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations.
New unresolved items identified during this inspection are discussed in
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paragraph 5.b.(10) and 7.b.
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5.
Review of Plant Operations The plant continued with power operations-(Mode 1) until June 16, at which time a plant trip occurred due to lighting striking the startup transformer
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(see section 8 of this report for details). The plant returned to Mode 1 power operations on June 17 and continued in this mode for the duration of the inspection period.
a.
Shift Logs and Facility Records The inspectors reviewed the records listed below and discussed various entries with operations personnel to verify compliance with T.S. and the licensee's administrative procadures.
-Shift Supervisor's Log;
-0perator's Log;
-Equipment Out-of-Service-Log;
-Shift Relief Checklist;
-Control Center Status Board;
-Short Term Instructions;
-Auxiliary Building Operators' Log; and-0perating Daily Surveillance Log.
In addition to these record reviews, the inspector independently verified selected clearance order tagouts.
b.
Facility Tours and Observations Throughout the inspection period, facility tours were conductea to observe operations and maintenance activities in progress.
Some operations and maintenance activities were conducted during back shifts. Also during this inspection period, numerous licensee meetings were attended by the inspectors to observe planning and management activities.
The facility tours and observations encompassed the following areas:
-Security perimeter fence;
-Tur'ine Building;
-Con, al Room;
-Emergency Diesel Generator Rooms;
-Auxiliary Building;
-Intermediate Building;
-Battery Rooms; and,
-Electrical Switchgear Rooms.
During these tours, the following observations were made:
(1) Monitoring Instrumentation - the following instrumentation was observed to verify that indicated parameter: were in accordance
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with the Technical Specifications for the current operational mode:
-Equipment operating status;
-Area, atmospheric and liquid radiation monitors;
-Electrical system lineups;
-Reactor Operating parameters; and-Auxiliary equipment operating parameters.
(2) Shift Staffing - The inspectors by numerous checks that operating shift staffing was in ac:ordance with Technical Specifica+. ion requirerr. ants.
In addition, the inspectors observed shift turnovers on different occasions to verify the continuity of status, operational problems, and other pertinent plant infor-mation was being accomplished.
(3) Plant Housekeeping Conditions - Storage of material and components and cleanliness conditions of various areas throughout the facility were observed to determine whether they and/or fire hazards exist. The general housekeeping conditions are acceptable.
(4) Radiation Areas - Radiation Control Areas (RCA's) were observed to verify proper identification and implementation. These obser-vations included review of step-off pad conditions, disposal of contaminated clothing, and area posting.
Area postings were verified for accuracy through the use of the inspector's own radiation monitoring instrument.
No problems were identified in this area.
(5) Fluid Leaks - Various plant systems were observed to detect the presence of leaks. No problems were identified in this area.
(6) Piping Vibration - No excessive piping vibrations were noted.
(7) Pipe Hangers / Seismic Restraints - Several pipe hangers and seismic restraints (snubbers) on safety-related systems were observed.
No problems were identified in this area.
(8) Securit.y Controls - Security Controls were observed to verify that
!;ecurity barriers are intact, guard forces are on duty and access to the protected area is controlled in accordance with the facility security plan.
In addition, the inspector observed Guard Force weapons qualification on fiay 29, 1981, and attended a Guard Force training session on June 2,1981. No problems were identified in this area.
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(9) Surveillance Testing - Surveillance testing was observed to verify that:
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-Approved procedures were being used; j-Qualified personnel were conducting tha tests;
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-Testing was adequate to verify equipment operability;
-Calibrated equipment, as required, were utilized; and.
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' Technical Specification requirements were-being followed.
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The following tests were observed:
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-SP-354, Emergency Diesel Fuel Oil Quality and Diesel Generator Monthly Tcst (Fast start of A&B Emergency Diesel Generator);
-SP-321, Power Distribution Breaker Alignment and Power Avail-ability. Verification;
-SP-439, Maximum Circulating Water Discharge Temperature;
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-SP-349, Emergency Feedwater System Operability Demonstration (Data review only);
-SP-312, Heat Balance Calculation; and
-SP-130, Engineering Safeguards Monthly Functional Tests (para 6.2).
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During a review of the new technical specification (TS) Surveil-
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lance Requirement on the Pressurizer Power Operated Relief Valve
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(PORV) and Code' Safety Valve position indicators, the inspector.
discovered that a procedure had not been approved and implemented
and that the required monthly channel check had not been performed
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as of June 25, 1981. The monthly channel check became a requirement as of May 5, '1981 as part of Amendment 38 to the TS.
This issue was discussed with the licensee and the inspector's findings were acknowledged.
The inspector was informed that a -
change had been prepared (but not yet approved) to SP-300,
Operating Daily Surveillance Log, in order to include channel-
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checking of the PORY and the Code Safety Valve position indicators I
in this procedure. The licensee agreed to perform and document a i
channel check of these position indicators until'such time the procedure revision to SP-300 is approved and issued.
This channel
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check was performed satisfactorily on June 26, 1981.
Failure to
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channel checking of the PORV and Code Safety Valve position
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indicators is contrary to T.S. 6.8.1 ar.d Regulatory Guide 1.33,
Appendix "A"; and failure to perfonn a monthly channel check on the PORV and Code Safety Valye position indicators as required by i
T.S. 4.3.3.6, table 4.3-7 as of June 25, 1981, are considered a violation.
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Violation (302/81-11-01):
Failure to have a procedure approved and implemented and failure to perform PORV and ' Code Safety. Valve.
position indicator channel check as of June 25, 1981~as required by T.S. and Regulatory Guide -1.33, Appendix "A".
(10) Maintenance Activities - The inspector obsened maintenance activities to verify that:
-Approved procedure were being utilized;
-Work Requests (W/R's), Radiation Work Permits (RWP's), and Fire Prevention Work Permits, as required, were issued and being followed;
-Quality Control personnel were available for inspection activities as required; and-Technical Specification requirements were being followed.
The following maintenance activities were observed:
-Portions of Modification Approval Record (MAR) 80-08-13,.N2-System Modification;
-MSV-10 (Turbine bypass valve) stem and valve seat repair;
-Decay Heat flow indicator switch (DH-43-FIS) calibration;
-Maintenance on Fire Service Water Pump (FSP-2A) suction strainer;
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-Maintenance-on Air Handling Fan (AHV-15B) Motor bearings; and r-Vibration measurements on Raw Water Pump -(RWP-2A).
As a result of those observations, the following were identified:
During the Decay Heat flow indicator switch calibration the
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inspector noted that an " Uncontrolled Copy" of the technical manual was used to make adjustments during calibration. This was brought to the attention of the Nuclear Instrumentation Supervisor. A " Controlled Copy" of the technical' manual was obtained and the calibration adjustments were continued. A check of the two technical manuals indicated the " Uncontrolled Copy" contained the same change number as the " controlled copy".
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training sessions was held with all Instrument and Control Technicians to stress the importance of_ using " controlled copies" of technical manuals when performing safety-related maintenance activities.
l Unresolved Item (302/81-11-02):
Verify that " controlled copies" of technical manuals are being used to perfom safety-related
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In addition, the inspector noted that there was not a method pre',ently in use for controlling lifted leads, jumpers and open'
stetes blocks required during the course of troubleshooting i
maintenance. A recent revision. to CP-114, Procedure for the s-
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Preparation of Permanent and Temporary Modifications, deleted the method for controlling these troubleshooting aids. This issue was discussed with the licensee and the inspectors comments were acknowledged. The licensee agreed to revise CP-113, Procedece for Handling and Controlling Work Requests, to provide a metid for controlling these troubleshooting aids during the performance of n.aintenance activities. This revision to CP-113 will be issued by July 31, 1981.
Unresolved Item (302/81-11-03): Verify effectiveness of new method for controlling lifted leads, jumpers and open States blocks required for maintenance.
6.
Review of Licensee EF t Reports (LER's) and Nonconforming Operations Reports (NCOR's)
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The inspector reviewed Licensee Event Reports (LERs) to verify that:
l-The reports accurately describe the events;
-The safety significance is as reported:
-The report satisfies requirements with respect to information provided i
and timing of submittal;
-Corrective action is appropriate; and,
-Action has been taken.
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LER 81-11, 81-20, 81-25, 81-28, 81-29, and 81-30 were reviewed. This review identified the following items:
LER 81-30 reported a start failure on Emergency Diesel Generator (EDG)
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B on May 26. Subsequent testirg did not identify the cause of the
failure and the EDG was subsequently declared operable. On June 16, I
the diesel again failed to fast start and at chis time the trouble was (
traced to a misadjusted timing relay in the diesel start circuit. To assure that this failure has been properly identified and that sufficient corrective action has been taken, the licensee has doubled the surveillance frequency. This increased surveillance will be continued until August 15, 1981.
Inspector Followup Item (302/81-11-12):
Review the licensee's increased surveillance testing of EDG B to assure the start failure problem is resolved, b.
The inspector reviewed NCOR's to verify the following:
-Compliance with the Technical Specifications;
-Corrective actions as identified in ti a eports or during subsequent reviews have been accomplished are being pursued for completion;
-Generic items are identified and reported as required by 10 CFR part 21; and i
L-Iteus are reported as required by the Technical Specifications.
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~9 The following NCOR's are reviewed:
81-124 81-189 81-198 81-151 81-190 81-199 81-172 81-192 81-205 81-183 81-193 81-208 81-184 81-194 81-209 81-185 81-195 81-211 81-186 81-197 81-187
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As a result of this review, the following item was identified:
NCOR's81-198 and 81-199 reported an inadequate temporary procedure change to procedure SP-344 Nuclear Services Cooling System Operability.
The temporary change changed the delta P requireuents measured across pump SWP-1A. The change was issued as temporary even though the intent was to leave the new requirements as permanent changes. The licensee has issued an interim change that will expire in sixty days with the intent of issuing a permanent procedure revision prior.to the
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expiration of the temporary change. The inspector reviewed this issue and has no problem with the technical content of this change. The
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incorrect (due to expiration of the change) the next time the procedure was used, will be followed up in subsequent inspections.
Inspector Followup Item '(302/81-11-04): Review procedure SP-344 to
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verify that the permanent procedure revision for SWP delta P has beer completed.
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Review of IE Bulletins The following IE Bulletins (IEB) were reviewed to verify the adequacy of the licensee's actions;
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IEB 80-05, Vacuum Condition Resulting in Damage to Chemical Vol ime a.
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Control System (CVCS) Holdup Tanks (Sometimes called " Clean Water
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Receiver Tanks")
During review of the licensee's actions as described in their June 17, 1980 response to this IEB, the inspector noted an apparent error on flow diagram FD-302-691, Gas Waste System. The drawing indicates there is no connection between the 3 inch main gas header and the 2 inch vent lines from the concentrated waste storage tanks and the concentrated-boric acid tanks. The. licensee _ verified as-built conditions did have
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i such a connection and will revise the drawing accordingly (previous drawing revisions showed this connection).
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Inspector Followup Item (302/81-11-05): Verify drawing FD-302-691 for Gas Waste System is revised to show connection between 2 inch and 3
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inch gas headers.
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IEB 80-06, Engineered Safety Feature (ESF) Reset Controls In their response to this IEB dated June 12, 1980, the licensee stated that they had reviewed schematic drawings of their ESF equipment to verify that reset of the ESF signal will not cause equipment to secure from the emergency operating mode. The licensee's drawing review was also examined by Nuclear Reactor Regulation (NRR) and NRR concurred with the licensee's results.
To verify that actual installed instrumentation and controls were consistent with the schematic drawings, the licensee modified surveil-lance procedure SP-417, " Refueling Interval Integrated Plant Response to Engineered Safeguards Actuation to demonstrate that resetting of the ESF signal did not change equipment from the emergency mode.
This test was successfully completed on August 1,1980.
The inspector's review of SP-417 indicates that the engineer conducting the majority of the test was also the "responsibic supervisor" as defined in procedure AI-400, Plant Operating Quality Assurance fianual Control Document, that reviewed and approved the test as complete and satisfactory. Paragraph 5.6 of AI-400 requires review of tests by a responsible supervisor where this supervisor represents the "second level" of review for a procedure.
It appears in this case that the
"second level" of review was compromised since the responsible supervisor was also the engineer conducting the test.
This issue was discussed with licensee representatives and the inspector's findings were acknowledged.
The licensee will review their procedures for supervisory review and modify these procedures to ens re that the review by a responsible supervisor is independent of the engineer conducting the test.
This review and necessary procedure changes will be completed by July 31, 1981.
Unresolved Item (302/81-11-06):
Review procedures describing methods for surveillance procedure post test review to assure that the second level of review is clearly identified.
c.
IEb 80-23, Failure of Solenoid Valves Manufactured by Valcor Engineering Corporation With the exception of the Inspector Followup Item for IEB 80-05 and Unresolved Item for IEB 80-06 no inadequacies were identified and the licensee's actions on these Bulletins are considered to be complete.
8.
Nonroutine Events a.
Loss of Offsite Power / Reactor Trip On June 16, at 2340 the reactor tripped following a loss of offsite power.
The offsite power loss occurred when lighting struck the 230 KV feeder line supplying the Unit 3 startup transformer causing protective
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switchyard breakers to trip. The loss of the startup transformer caused a loss of power to all secondary system pumps, both Engineered Safeguards (ES) buses, and the reactor coolant pumps.
The "A'? Emergency Diesel Generator (EDG) fast started and provided power to the "A" ES bus. The "B" failed to start and the operators provided power to the "B" ES bus from the Fossil Fired Units 1 and 2 Startup transformer. The "B" EDG was manually started by the operators and _ allowed to idle unloaded as a backup to the Unit 1 and 2 startup.
transformer.
The reactor was stabilized in Mode 3 (Hot Standby) using natural circulation in the reactor coolant system (RCS) with heat removal being accomplished by feeding the steam generators with an emergency feedwater pump and steaming the generators to atmosphere. Plant-instrumentation remained operable during the event. Pressurizer level remained onscale with a minimum RCS pressure-of 1875 psig and a minimum subcooling margin of 65* F.
The Unit 3 startup transformer wes returned to service at 0420 and plant systems were gradually restarted.
The problem with the "B" EDG was traced to a setpoint drift on a time delay relay in the diesel start circuit. The relay was readjusted and the EDG declared operable at 1827 on June 17..
The reactor was made critical at 0402 un June 18 and entered power operation (Mode 1) at 0555 on the same date.
The resident inspector responded to the site during the event and observed the licensee's activities. All systems operated 'as designed with the exception of
"B" EDG and the inspectors reviewed the licensee's activities to repair the start failure.
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The inspectors have no further questions on this item at this time.
b.
Reactor Building Purge Valve Design Deficiency On June 24, 1981, the licensee was notified by Henry Pratt Company that-the 65 degrees from full open position for the containment purge supply and exhaust air handling valves (AHV-1A, 1B, 1C, and 1D) was such that the aerodynamic torque generated during closure for a LOCA condition-would be in excess of what is considered acceptable for safety-related applications. A detailed analysis performed by Henry Pratt Company indicates that the maximum opening for the Limitorque operated valves (AHV IB & IC is -35 degrees from full closed and for'the pneumatic Bettis actuated valves (AHV-1A & 10) is 50 degrees from full closed.
Based on this information, the licensee declared the valves inoperable, secured purging operations and closed the valves. Modifications were-made to the valves -to limit the opening of AHV-1B & 1C to 35 degrees
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from full closed and-AHV-1A and ID to 50 degrees from full closed.
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Leak rate testing on these valves, to prove operability subsequent to the modifications, indicated that QHV 1C was leaking greater than acceptable ;imits. The purge supply and exhaust valves are presently being maintained closed pending repair to AHV-1C during the next plant shutdown.
Licensee act;ons with respect to the reactor building purge valves will be tracked in accordance with outstanding Inspector followup item (302/81-10-06).
9.
Review of Nuclear General Review Committee (NGRC) Activities '
The activities of the NGRC, the licensee's offsite review committee, were reviewed to verify the following:
-Review group membership and qualifications are as required by Technical Specifications (TS);
-Review group meetings convened during the previous year were held at least once per six months and were attended by sufficient NGRC members to assure the TS quorum was satisfied;
-Sufficient expertise was available at each meeting to assure proper review
of the items on the agenda; and,
-The connittee reviews included all activities required by the TS.
The inspectors reviewed records, interviewed several NGRC members, and attended the NGRC meeting of June 3,1981. The record review included:
-Resumes of NGRC members and consultants;
-NGRC Meeting Minutes 71 (4/30/81) through 85 (5/13/81); and-Selected audits reviewed by the NGRC.
As a result of this review, the following items were identified:
a.
The NGRC has established one man subcommittees that are assigned specific review responsiblities.
Examples of these assignments follow:
Member Expertise Review Assignment (TS 6.5.2.8 items)
(1) Metallurgy & Non-(a) The safety evaluations for 1)
Destructuve Testing changes to procedures, equipment or systems and 2) tests of'
experiments completed under the l
provision of Section 50.59, 10 CFR, to verify that such actions did not constitute an unreviewed safety question.
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(b) Proposed changes to procedures, equipment or systems which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.
(c) l'roposed tests or experiments which involve an unreviewed safety question as defined in Section 50.59, 10 CFR.
(2) Vice Chaiman -
(d) Proposed changes in Technical Nuclear Engineering Specifications or this and Operations Operating License.
(e) Violations of codes, regulations, orders, Technical Specifications, license requirements, or of internal procedures or instructions having nuclear safety significance.
(g) Events requiring 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> written notification to the Comission.
(3) Chaiman -
(i) Reports and meetings minutes Nuclear Engineering of the Plant Review Comittee.
(4) Outside Consultant (f) All recognized indications of (Expertise - Reactor an unanticipated deficiency Operations / Reactor in some aspect of design or Physics)
operation of safety-related structures, systems, or components.
(h) Significant operating abnormalities or deviations from normal and expected performance of plant equipment that affect nuclear safety.
The results of these reviews were presented to the full committee in a summarized form generally consisting of a one page memorandum listing the titles of the items reviewed. The comittee then voted on acceptance of this review. The information reviewed by the subcommittee was not transmitted to other comittee members and therefore these other members did not have the opportunity to review the issues for problems in their areas of expertise.
This method of NGRC review of specific items was observed by the inspectors during the June 3 meeting.
Each subcomittee member presented a summarized listing to the full committee and the committee
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accepted the subcommittee reports without any discussion of report
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The intent of the review requirements of TS 6.5.2.8 is to require a committee review of the delineated items thus ensuring that the necessary expertise is available and that all facets or the review are addressed.
Failure to provide this review is considered a violation.
This violation was identified, in part, as a potential enforcement -
finding during the Management Appraisal (PAS) inspection conducted in February,1981.
Violation (302/81-11-07):
Failure of the NGRC to comply with the review requirements of TS 6.5.2.8.
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The plant staff develops Unusual Event Reports that describe in detail the causes of plant trips and the corrective actions taken to prevent recurrence. The inspectors noted that the NGRC did not receive these reports ar.d that review of these reports could be considered as part of the NGRC review of " operating abnorma:ities or deviations from normal and expected performance of plant-equipment" as described in TS 6.5.2.8F.
The licensee will ensure the NGRC is placed on distribution for these reports.
Inspector Followup Item (302/81-11-08):
Verify NGRC is receiving and reviewing Unusual Event Reports.
10.
Review of Quality Control (QC) Inspector Qualifications and Training The inspector reviewed the qualifications and training of the facility QC inspectors to verify that these inspectors met the requirements outlined in 10 CFR Part 50, Appendix B.
Procedure AI-900, Conduct of Quality Assurance and Quality Control Compliance Program, delineates the qualifications and training of QC personnel. The inspector reviewed this document and compared the procedure requirements with the qualification records of four QC inspectors.
No inadequacies were identified.
The inspector then reviewed procedure QC-200, Training and Qualification of Nuclear Quality Assurance / Quality Control Inspection Personnel, to determine the status of training for these same inspectors. The inspector noted that none of the QC inspectors had completed the training program and that no time for training completion was established. The licensee will revise QC-200 to specify a two year time limit for completion of training.
Inspector Followup Item (302/81-11-09):
Verify QC-200 is revised to specify a two year time limit for completion of QC inspector training.
Review of Plant Review Committee (PRC) Activities The activities of the PRC, the licensee's onsite review committee, were reviewed to verify that the review and audit requirements of Technical
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l Specification (TS) 6.5 are being completed. To verify these activities the l
inspectors reviewed the following:
-Procedure AI-900, Plant Review Connittee Charter;
-PRC Meeting Minutes for the period June 1980 through May,1981 consisting of numbers 80-25, 80-27 through 80-42, 80-47 through 80-51, 81-1 through 81-12, 81-15, 81-17, and 81-18; and,
-Letters designating assignment of members and alternates.
In addition the inspectors attended PRC meetings to observe meeting activities.
As a result of these reviews and observations the inspectors identified three areas that the licensee was in violation of the TS.
Paragraph 6.5.1.3 requires alternate members of the committee to be appointed in writing by the PRC chairman and that no more than two such alternates shall participate as voting members in PRC activities at any one time.
Paragraph 6.5.1.5 requires each PRC meeting to have a quorum consisting of the chairman or his designated alternate and four members including alternates. The inspectors'
review of PRC Meeting minutes 80-41 through 81-18 indicated that quorum requirements were not met for meetings 80-41, 80-47, 81-1, 81-2, 81-5, 81-6, 81-7, 81-8 and 81-18 in that personnel designated as alternates were not designated by letter identifying what member they werc replacing as an al ternate.
In addition the meeting minutes listed numerous personnel as alternates giving the appearance that more than two alternates participated as voting members in committee activities.
Paragraph 6.5.1.6.e requires the PRC to investigate all TS violations including an evaluation of the reports issued to prevent recurrence.
Review of the.PRC minutes for the period June 1980 through May 1981 indicates that the FRC has not reviewed 'nu TS violations identified by NRC Inspection Reports.
In addition, tne iRC failed to review a TS violation identified by an internal quality programs audit (QP Audit 194) conducted in July, 1980.
Failure to meet the requirements of TS 6.5.1.3, 6.5.1.5, and 6.5.1.6.e are considered to be a violation.
This violation was identified, in part, as a potential enforcement finding during the Management Appraisal (PAS) Inspection conducted in February, 1981.
Violation (302/81-11-10):
Failure to PRC to meet quorum, alternate member, and TS violation review requirements in accordance with TS 6.5.1.3, 6.5.1.5, and 6.5.1.6.e.
12.
Licensee Action taken in Rosponse to NRR Order for tiodification of License Concerning Primary Coolant System Pressure Isolation Valves
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On April 20, 1981, the licensee was issued an " Order For Modification of License Concerning Primary Coolant System Pressure Isolation Valves". This order included a revision to the Technical Specifications that require the licensee to periodically test check valves CFV-1, CFV-3, DHV-1, and DHV-2 for leakage. The Order required licensee action within 30 days of the date of the order which included either testing of the valves, securing of other isolation valves until testing was performed, or plant shutdown.
The licensee was initially notified of the pending order about the end of February,1981.
Since the plant shutdown at this time for other maintenance, the decision was made to test these valves. A description of this testing and the results were discussed in paragraph 7 of NRC Inspection Report 50-302/81-02.
The licensee is developing periodic surveillance procedures that will encompass this testing. The original testing was performed in accordance with test procedures PT-128 and PT-129. The licensee is developing periodic surveillance procedures (SP-405 and SP-603) that will encompass the original testing performed in accordance Performance Test Procedures PT-128 and PR-129. These procedures will be issued by August 31, 1981.
Inspector Followup Item (302/81-11-11):
Verify completion of revision to SP-405 and development of SP-603 to test core flood and decay heat check valves.
13. Verification of Administrative Controls on Defeat of Safety Actuation Signals During Containment Purging In their responses dated January 10, 1979, to the Nuclear Reactor Regulation (N?R) generic letter dated November 29, 1978 entitled " Containment Purging During Normal Plant Operation", the licensee reviewed the design of their safety actuation signal circuits to assure that these signals cannot be manually defeated during containment purging.
In addition, the licensee reviewed various applicable Abnormal Operating Procedures, Operations Procedures, and Surveillance Procedures to insure that these procedures provide sufficient testing and controls to verify that all safety actuation signals required to terminate containment purging are operational.
The inspecter discussed these reviews with licensee representatives and reviewed the various applicable procedures. The inspector concurs with the licensee's findings and has no further questions on this item at this time.
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