IR 05000302/1985032
| ML20205C514 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/06/1985 |
| From: | Burnett P, Jape F NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20205C499 | List: |
| References | |
| 50-302-85-32, NUDOCS 8509200292 | |
| Download: ML20205C514 (8) | |
Text
O44 UNITED STATE 3
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9*o NUCLEAR REGULATORY COMMISSION
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REGION 11 n
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101 MARIETTA STREET, N.W.
's ATLANTA, GEORGI A 30323
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? Report No.:
50-302/85-32 Licensee: Florida Power Corporation 3201 34th Street, South St. Petersburg, FL 33733 Docket No.: 50-302 License No.: DPR-72 Facility Name: Crystal River 3 Inspection Conducted:
ugust 8-21, 1985 Inspector: k t, hwM M~
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~Pr T. Burnett-'
Date Signed Approved by:
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F. Jape, Section Chief V
F D~ ate Signed Engineering Branch Division of Reactor Safety SUMMARY Scope: This routine, unannounced inspection involved 112 inspector-hours on site in the area of reviewing and witnessing both pre-and post-criticality tests following the refueling outage.
Results: No violations or deviations were identified.
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
- E. M. Howard, Director Site Nuclear Operations
- P. F. McKee, Nuclear Plant Manager G. L. Boldt, Nuclear Plant Operations Manager J. Kraiker, Startup Manager R. T. Wittman, Acting Nuclear Operations Superintendent
- M. E. Collins, Nuclear Safety and Reliability Superintendent
- J. Alberdi, Manager, Site Nuclear Operations Technical Services
- W. L Rossfeld, Site Nuclear Compliance Manager
- V. R. Roppel, Plant Engineering and Technical Services
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- P. D. Breedlove, Nuclear Records Management Supervisor
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- D. G. Green, Nuclear Licensing Specialist
- J. L Bufe, Nuclear Compliance Specialist
- M. W. Culver, Senior Nuclear Reactor Specialist K. D. Vogel, Nuclear Senior Electrical /I&C Specialist K. R. Wilson, Supervisor Site Nuclear Licensing W. M. Marshall, Nuclear Shift Supervisor Other licensee personnel included shift supervisors, assistant shift supervisors, operators, security force members, chemistry technicians and office personnel.
Other Organization
'1 Babcock and Wilcox Company R. McAndrews, Supervisory Engineer S. T. Robertson, Associate Engineer R. Peterson, Instrument Specialist NRC Resident Inspectors T. F. Stetka, Senior Resident Inspector J. E. Tedrow, Resident Inspector
- Attended exit interview
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2.
Exit Interview The inspection scope and findings were summarized on August 21, 1985, with those persons indicated in paragraph 1 above. The licensee acknowledged the inspection findings.
The inspector identified one followup item requiring no action on the licensee's part.
Two additional inspector followup items reflect commitments made by licensee management at the exit interview.
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a.
Inspector Followup Item 302/85-32-01, Review surveillance and test procedures produced using the writer's guide - paragraph 5.
i b.
Inspector Followup Item 302/85-32-02, Establish technical or j
statistical bases for the rejection of data - paragraph 6.a.
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Inspector Followup Item 302/85-32-03, Application and implementation of
the Chi-Squared test for source range neutron monitors - paragraph 6.c.
Proprietary information was reviewed during this inspection, but is not included
in this report.
3.
Licensee Action on Previous Enforcement Matters Not inspected.
4.
Unresolved Items Unresolved items were not identified during this inspection.
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5.
ComplexSurveillance(61701,71711)
Prior to performance, the inspector reviewed the following test procedures:
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a.
SP-414 (Revision 13), High Pressure Flow Verification Test, issued 08/06/85.
b.
SP-417 (Revision 20), Refueling Interval Integrated Plant Response to Engineered Safeguards Actuation, issued 07/31/85.
This procedure was subject to considerable revision up to the time of performance.
All
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revisions were accomplished through approved interim test changes.
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c.
SP-102 (Revision 14), Control Rod Drop Time Tests, activities were observed both in the control room and at the system cabinets where the recorders were connected to the position indicating system to make the
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measurements.
The inspector witnessed portions of all tests when they were performed. In observing the performance of test data takers and observers for SP-414 and
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SP-417, it was noted that many data and observations were first written on scratch pads, scrap paper, and palms of hands.
In some cases, the first transfer of data or observations was to another temporary record, sometimes after additional manipulation of the data.
The completed test procedures, then,-do not reflect in all cases the raw,
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J unmanipulated data.
This concern was' raised with plant management, and during subsequent retests of SP-417, it was observed that data were being recorded directly into the procedure.
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The inspector observed that part of the data collection problem stemmed from a lack of or insufficient data and log sheets in the procedures.
In the exit interview, the inspector requested that in the biennial review of procedures postive steps bo taken to assure all procedures contained sufficient and appropriate data sheet to capture all raw data and all calculations necessary to demonstrate satisfying the acceptance criteria.
In the following discussion, the licensee stated that the broad problem of procedures providing insufficient examples and guidance had been recognized and remedial action was underway.
A writer's guide for writing procedures
is in preparation and is expected to be in use by January 1986.
The licensee expects that all of the inspector's concerns regarding procedure quality will be addressed by the writer's guide. The finished guide and its products will be reviewed during a future inspection.
(Inspector Followup
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Item 302/85-32-01, Review surveillance and test procedures produced using the writer's guide.)
No violations or deviations were identified in witnessing the complex surveillance tests.
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6.
Procedure Reviews (72700, 71711)
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The following precritical and zero power physics test procedures were reviewed prior to performance:
PT-100 (Revision 8), Controlling (Procedure for Precritical Testing, was a.
reviewed in concert with SP-102 Revision 14), Control Rod Drop Time.
The latter permits only one rod group at a time to be withdrawn for rod drop time testing, whereas PT-100 allows all rods _ to be withdrawn.
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This inconsistency was acknowledged by the licensee, who gave SP-102 precedence.
Currently the issue is moot, since there is drop time recording capability sufficient only for one group to be measured at a time.
A review of the shutdown margin calculations showed the unit to be sufficiently shutdown by boron, to remain in mode 3, with all rods withdrawn.
PT-100 also addressed a method to obtain the correction factor for each of 10 temperature sensing elements in the reactor system. _ Five temperature observations were made for each clement at steady-state conditions.
Then the high and low values for each were discarded and the remaining values averaged.
An overall average value was obtained and compared with each individual average.
If the difference was greater than twice the squareroot of the individual average, the detector was dropped from consideration.
Otherwise the correction factor for an element was the difference between the element average and the group average. There are no technical or statistical bases for the methods chosen to reject data or to evaluate the difference between
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the individual and group means. Arbitrarily dropping the high and low values may eliminate bias in a figure skating contest, but not in these i
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observations.
The method of calculating what was apparently to be considered a standard deviation was appropriate only for a Poisson distribution.
A normal distribution is expected for these observa-tions.
The calculations being made were not part of any required surveillance, nor are they safety related.
However, as was emphasized when this subject was discussed at the exit interview, the concern here is that the precedent set by this procedure might be carried over into the analysis of data of greater safety significance.
Licensee management then made a commitment to review their bases for rejecting data in general.
(Inspector Followup Item 302/85-32-02, Establish technical or statistical bases for the rejection of data.)
b.
PT-101 (Revision 4), Reactor Coolant Flow Measurement Test at Zero Power, has an equation on page 7 of enclosure 1 that contains a symbol that is not defined, nor is the source of data associated with it identified, c.
PT-110 (Revision 8), Controlling Procedure for Zero Power Physics Testing, contains in step 6.13 a definition of source range nuclear instrument countrate stability as three successive counts falling within two standard deviations of their mean. The inspector suggested that use of the Chi-Squared test would provide a more quantitative determination of stability since it is a test comparing measured variance with expected variance.
In steady state conditions, with a known constant source, the test is a test of proper operation of the counting system.
Early in the deboration process, when the neutron population could be considered constant for a few minutes at a time, the licensee, in response to the inspector's comentary on the procedure, obtained a series of countrate observations and performed Chi-Squared test on each counter.
Their results agreed with those obtained by the inspector, and confirmed that the counters were operating properly.
At the exit interview, the licensee agreed to review the application and implementation of the Chi-Squared test for those periods when safety is particularly dependent on proper functioning of the source range counters (refueling, initial criticality of a new core, and when vessel water level is lowered for maintenance activities increasing the risk of the dilution accident).
This commitment will be tracked as Inspector Followup Item 302/85-32-03, Application and implementation of the Chi-Squared test for source range neutron monitors.
One of the strengths of the procedure is that it tests the functioning of the reactimeter over a wide range of both positive and negative reactivity insertions, and firmly establishes a range of acceptable performance for use in the other physics tests.
d.
PT-111 (Revision 6), Hot Zero Power, All Rods Out Critical Boron Test, was reviewed without commen.
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e.
PT-112 (Revision 6), Hot Zero Power Rod Group Worth and Differential Boron Worth Measurement, did not contain a description of a reactimeter chart trace or how it was to be analyzed.
f.
PT-114 (Revision 10), Moderator and Temperature Coefficients Determina-tion at Hot Zero Power, uses only a part of the data collected to determine the coefficients. Only the results of the 10-degree temperature change are used.
The results of the preceeding and succeeding 5-degree changes are not a part of the result.
Use of a weighted average would add precision to the final value.
To the licensee's credit, the temperature swings used are larger than used at other facilities, and that adds precision to the measurement.
g.
PT-115 (Revision 7), Hot Zero Power Ejected Rod Worth Measurement, was reviewed without comment.
h.
PT-116 (Revision 5), Sensible Heat Determination, was reviewed without comment.
With the exception of section 9 of these procedures, which provided a detailed description of setup and application of test instrumentation, the overall impression was that they were not user friendly, and it would be difficult for someone to perform them without prior use.
The licensee believes that use of the procedure writers guide, once complete, will lead to improvemer.ts in these procedures.
The comments on these procedures were provided to the licensee staff prior to performance of the procedures.
7.
Zero Power Physics Test Witnessing (72700, 71711)
The following zero power physics test were witnessed in whole or in part:
a.
Initial criticality was attained under the control of PT-110.
Following full withdrawal of control rod groups 1-6 and partial withdrawal of group 7, deboration was begun.
Inverse multiplication, as measured by the two smrce range monitors feeding individual scaler-timers, was plotted against boron concentration to obtain a continuing prediction of criticality.
The boron concentration in the reactor ccolant system (RCS) was measured every half hour.
The concentrations in the pressurizer and makeup tank were measured hourly.
The inspector witnessed the drawing of the water samples and the analysis of the RCS samples for two successive measurements.
The chemistry technician appeared to be well versed in the procedure in use.
As deboration continued, both source range channels were in close and reasonably consistent agreement on the boron concentration for criticality.
The licensee ceased dilutien in a timely manner, and criticality was achieved as the coolant mixed.
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b.
Subsequently, the inspector witnessed the determination of the all-rods-out critical boron concentration using PT-111.
The test result of 1582 ppmB was in excellent agreement with the predicted value of 1581 ppmB.
c.
Also, a portion of the calibration of the reactimeter, a part of PT-110, was observed.
At least two independent measurements of stop-watch period were obtained for each reactivity transient for comparison with reactimeter results, d.
The measurement of the all-rods-out isothermal temperature coefficient, using PT-114, was witnessed.
The coefficient was not much different from zero, and an extended period of data collection was required to discern the change in reactivity in the presence of the noise on the reactivity recorder trace.
e.
Performance of PT-115, Hot Zero Power Ejected Rod Worth Measurement, was witnessed in part.
No violations or deviations were identified during the witnessing of startup test performance.
8.
Review of Completed Startup Test Procedures (72700)
The following completed startup test procedures were reviewed shortly after
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data analysis for each was complete.
In most cases, this review preceded that by licensee management.
a.
PT-110, including the portions not previously witnessed.
Acceptable overlap between source range and intermediate range neutron detectors was confirmed.
b.
PT-112 was used to measure control group reactivity worths.
In reviewing the traces of reactivity and rod position versus time from
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the reactimeter, the inspector noted some difficulties in determining
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rod group position.
The fullout position was offscale and the fullin position was offset from the zero line.
Also the test log indicated that the rod position scaling factors were not all the same.
These factors had not been considered in determining rod position from the chart record. All reactivity increments were independently analyzed by the inspector.
The differences from the values recorded by the licensee were more frequent and larger than previously experienced at this and other facilities.
Given these observations, the licensee agreed to review the data analysis.
The inspector used a spreadsheet from the SUPERCALC 3 (Release 2) microcomputer program to record and correct the raw data taken from the chart records and to create differential and integral rod worth tables and curves.
These results will be compared with the licensees revised results during a future inspection.
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l The errors in rod position affect only the differential worth of the rods.
Errors in reactivity increments affect both differential and integral worth.
However, the revised values are not expected to violate the acceptance criteria on integral worth.
Noisy reactivity traces and a narrower than necessary reactivity span contributed to the difficulty in analyzing the reactivity increments.
The lack of descriptive guidance on trace analysis in the procedure may have also been a contributing factor.
The quality of procedures is addressed in Inspector Followup Item 302/85-32-01.
No violations or deviations were identified in the review of completed test
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procedures.
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