IR 05000302/1986012
| ML20197J860 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 05/07/1986 |
| From: | Elrod S, Stetka T, Tedrow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20197J820 | List: |
| References | |
| 50-302-86-12, NUDOCS 8605200190 | |
| Preceding documents: |
|
| Download: ML20197J860 (12) | |
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- ATLANTA, GEORGI A 30323 s,...../
Report No..
50-302/86-12 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: March 8 - April 11, 1986 A
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Inspectors:
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Stetka S i Resident Inspector Datb Signed T.
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s a J. E. Tedrow, Residant Inspector Date Signed k
5 Nil, Approved by:
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S. A. Elrod, Section Chief, Datu Signed
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Division of Reactor Projects SUMMARY Scope:
This routine inspection involved 154 inspector-hours on site by two resident inspectors in the areas of plant operations, security, radiological controls, Licensee Event Reports (LERs) and Nonconforming Dperations Reports, facility modifications, 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 backshifts.
Results:
Three violations and one deviation were identified (Failure to adhere to facility procedures, paragraphs 5.b(1), 5.b(9)(a), 5.b(9)(b); Failure to have an adequate procedure for making changes to facility procedures, paragraph 5.b(9)(c); Failure to report an event via an LER, paragraph 5.b(7)(a); Deviation from a commitment to provide roving fire watches, paragraph 5.b(7)(b)).
B605200190 860515 PDR ADOCK 05000302 O
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REPORT DETAILS 1.
Persons Contacted
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Licensee Employees
- P. Breedlove, Nuclear Records / Management Supervisor
- C. Brown, Assistant Nuclear Outage & Modifications Manager
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- M. Collins, Nuclear Safety & Reliability Superintendent
C. Dutcher, Nuclear Contracts Supervisor
- P. Ezzell, Nuclear Chemistry Technician
- J.
Frijouf, Compliance Specialist
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- V. Her.1andez, Senior Nuclear Quality Assurance Specialist
- J. Lander, Nuclear Outage & Modifications Manager
- P. McKee, Nuclear Plant Manager
- W. Neuman III, Nuclear Reliability Supervisor
- R. Pinney, Senior Nuclear Quality Assurance Engineer
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- S. Powell, Senior Nuclear' Licensing Engineer
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- V. Roppel, Nuclear Plant Engineering & Technical Services Manager
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- W. Rossfe'd, Nuclear Compliance Manager '
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- P. 'Skramstad, Nuclear Che'm/ Rad Prctection Superintendent
- D. Smith, Nuclear Maintenance Superintendent R. Thompson, Nuclear Mechanical / Structural Engineering Supervisor
- E. Welch, Nuclear Plant Engineering Superintendent K. Wilson, Manager,. Site Nuclear Licensing
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- R. Wittman, Nuclear Operations Superintendent
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Other personnel contacted included office, operations, engineering, l
maintenance, chem / rad and corporate personnel.
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- Attended exit interview s
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Exit Interview
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' The inspector met with licensee representatives (denoted in paragraph 1) at
.the conclusion of the inspection on April 11, 1986.
During. 'this meeting, i
the inspector summarized the scope and findings of the insp~ection as they are detailed in this report with particular emphasis on the Violations, Deviation, and Inspector. Followup Items (IFIs)'.
The licensee r.epresentatives acknowledged the inspector's comments and did not identify as proprietary any of the materials provided to or reviewed by
- the inspectors during this inspection.
3.
Licensee Action on Previous Inspection Items
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(0 pen) IFI 302/85-05-03: The inspector observed the calibration of radia-tion me..itors RMA-1 and RMA-2. The mid range calibration of these monitors was. satisfactorily completed.
The high range calibrations were also
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compie~ted, however, due to problems with the laboratory calibration
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procedure provided by the vendor, some data may be unacceptable.
The licensee has issued Supplement 2 to Special Report 85-03 which changes the activity completion date to May 30, 1986.
The inspectors will review the licensee's activities to resolve the data / procedure problems.
(Closed) IFI 302/84-30-02:
The licensee has revised procedures SP-177 and SP-179 to clarify the intent of these procedures to ensure that test lineup variations are only performed by properly qualified personnel.
(Closed) IFI 302/85-44-04:
The licensee has revised procedure SP-201 to provide a check for the loose jam nuts.
In addition, the licensee is conducting a 100 percent visual inspection of snubbers during the current outage. Portions of this inspection have been observed by the inspector and the results are being reviewed on an ongoing basis.
(Closed) IFI 302/85-21-05:
The licensee has revised procedure OP-605, Feeuwater System, to establish a vent path for the pump through a valve upstream of the pump discharge isolation valve (EFV-8). The inspector has reviewed the procedure change and considers it adequate to properly vent the pump.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Review of Plant Operations The plant remained in cold shutdown (Mode 5) for the duration of this inspection period.
a.
Shift Logs and Facility Records The inspector reviewed records and discussed various entries with operations personnel to verify compliance with the Technical Specifica-tions (TSs) and the licensee's administrative procedures.
The following records were reviewed:
Shift Supervisor's Log; Reactor Operator's Log; Equipment Out-Of-Service Log; Shift Relief Checklist; Auxiliary Building Operator's Log; Active Clearance Log; Daily Operating Surveillance Log; Short Term Instructions (STIs); and Selected Chemistry / Radiation Protection Logs.
In addition to these record reviews, the inspector independently verified clearance order tagouts.
During a review of the Nuclear Shift Supervisor's Log on April 5, the inspector noted that during the weekly run of the
"B" Nuclear Services Closed Cycle Coolant Pump (SWP-1B) that one of the two pumps (both powered from one electric motor) failed to pump and heated up,
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apparently due to cavitation.
The reason for the pump failure could not be determined. An additional run performed about two hours later, after the pump cooled down, indicated normal pump operation.
The licensee is investigating the pump failure and presently believes that slight differences in the two pumps' head curves (the pumps are in parallel) in addition to the reduced flow status (due to the plant shutdown condition) of the Nuclear Services Closed Cycle Cooling system could be a factor.
Inspector Followup Item (302/86-12-01): Review the licensee's investi-gation into the pumping failure of SWP-1B.
b.
Facility Tours and Observations Throughout the inspection period, facility tours were conducted to observe operations and maintenance activities in progress.
Some of these observations were conducted during backshifts. Also, during this inspection period, licensee meetings were attended by the inspector to observe planning and management activities.
The facility tours and observations encompassed the following areas:
security perimeter fence; control room; emergency diesel generator room; auxiliary building; intermediata building; battery rooms; electrical switchgear roons; and reactor building.
During these tours, the following observations were made:
(1) Monitoring Instrumentation - The following instrumentation was observed to verify that indicated parameters were in accordance with the TS for the current operational mode:
Equipment operating status; area atmospheric and liquid radiation monitors; electrical system lineup; reactor operating parameters; and auxiliary equipment operating parameters.
On March 17, at approximately 11:00 a.m.,
the inspector noted that two reactor building (RB) purge exhaust fans and one RB purge supply fan were running; this is the normal fan lineup with the equipment hatch installed.
Shortly thereafter, however, the inspector noted that the equipment hatch was not installed. The inspector then verified that the RB personnel hatches were also open and notified the control room of these observations. Upon notification, control room personnel secured the RB purge supply fan at approximately 11:45 a.m.
The Offsite Dose Calculation Manual (0DCM), in Representative Sample Method No. 3.1-5 requires the RB purge supply (makeup) fans to be secured whenever both the personnel and equipment hatches are open.
Failure to adhere to the requirements of the ODCM is considered to be a violation of TS 6.8.1.
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Violation (302/86-12-02):
Failure to adhere to facility proce-dures as required by TS 6.8.1.
(2) Safety Systems Walkdown - The inspector conducted walkdowns of the Domestic Water (00) and Nuclear Services Closed Cycle Cooling (SW)
systems to verify that the lineups were in accordance with license requirements for system operability and that the system drawings and procedures correctly reflect "as-built" plant conditions.
During a review of the procedures and drawings the inspector noted that the D0 system was not listed in procedure CP-115, In-Plant Equipment Clearance and Switching Orders, as being a system that required an independent lineup verification when returned to service from a maintenance condition.
Discussions with licensee representatives indicated that this system was only recently identified as a vital system that could affect the operation of the Nuclear Services and Decay Heat Seawater Pumps (RWPs). This system will be added to the appropriate section of CP-115.
Inspector Followup Item (302/86-12-03):
Review the licensee's progress to add the D0 system to section 5.7.2 of CP-115.
(3) Shift Staffing - The inspector verified that operating shift staffing was in accordance with TS requirements and that control room operations were being conducted in an orderly and profes-sional manner.
In addition, the inspector observed shift turnovers on various occasions to verify the continuity of plant status, operational problems, and other pertinent plant informa-tion during these turnovers.
No violations or deviations were identified.
(4) Plant Housekeeping Conditions - Storage of material and components and cleanliness conditions of various areas throughout the facility were observed to determine whether safety and/or fire hazards existed.
No violations or deviations were identified.
(5) Radiation Areas - Radiation Control Areas (RCAs) were observed to verify proper identification and implementation.
These observa-tions included selected licensee-conducted surveys, review of.
step-off pad conditions, disposal of contaminated clothing, and area posting.
Area postings were independently verified for accuracy through the use of the inspector's own radiation monitoring instrument.
The inspector also reviewed selected radiation work permits and observed the use of protective clothing, respirators, and personnel monitoring devices to assure that the licensee's radiation monitoring policies were being followed.
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No violations or deviations were identified.
(6) Security Control - Security controls were observed to verify that security barriers were intact, guard forces were on duty, and access to the protected area (PA) was controlled in accordance with the facility security plan.
Personnel within the PA were observed to verify that badges were properly displayed and that personnel requiring escort were properly escorted.
Personnel within vital areas were observed to ensure proper authorization for the area.
No violations or deviations were identified.
(7) F!re Protection Fire protection activities, staffing and
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equipment were observed to verify that fire brigade staffing was appropriate and that fire alarms, extinguishing equipment, actuating controls, fire fighting equipment, emergency equipment, and fire barriers were operable.
During a review of the licensee's Appendix R Fire Protection Evaluations submitted to the NRC on December 19, 1985, tFe inspector noted that the licensee had identified a design error involving the bearing flush water for the Nuclear Services Seawater and Decay Heat Seawater pumps (RWPs).
Previous evalua-tions had assumed that bearing flush water was not necessary for RWP operation, however recent findings suggest that such flush water is necessary to prevent pump failure.
To remedy this situation the licensee proposed to modify the RW system (as further discussed in paragraph 7) to provide a backup flush water flow path. In the interim, the licensee committed in the December 19 letter to continue the 20 minute roving fire watches in the affected areas to compensate for the degraded system condition.
As a result of this review the following items were identified:
(a) While the licensee notified NRC licensing (NRR) in the December 19 letter of the potential to lose the RW system, they had failed to issue a Licensee Event Report (LER) as required by 10 CFR 50.73(a)(2)(V)(B).
This statute requires the issuance of an LER for any condi-tion that could prevent the functioning of a system that is needed to remove decay heat.
Failure to issue an LER is contrary to the requirements of 10 CFR 50.73 and is considered to be a violation.
Violation (302/86-12-04):
Failure to issue an LER as required by 10 CFR 50.73.
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(b) The licensee had originally established the 20 minute roving fire watch as a compensatory measure pending completion of wrapping of safe shutdown cables. This cable wrapping was completed and the licensee terminated the fire watch at 2:00 p.m. on March 14.
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On Monday, March 17, while on a plant tour, the inspector noted that no fire watch had been established in the area of the RW system and subsequently verified that the modification to the RW system had not been completed. The licensee, when notified of these observations, established a fire watch in the affected area and subsequently restored the roving fire watch.
Failure to maintain the roving fire watch until completion of the RW system modification is considered to be a deviation from a commitment made to the NRC.
Deviation (302/86-12-05):
Failure to maintain the roving fire watch in the RW system area as committed to in the December 19, 1985, Appendix R Fire Protection Evaluation letter.
(8) Surveillance - Surveillance tests were observed to verify that approved procedures were being used; qualified personnel were conducting the tests; tests were adequate to verify equipment
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operability; calibrated equipment, as required, were utilized; and TS requirements were followed.
The following tests were observed and/or data reviewed:
SP-179, Containment Leakage Test-Types "B"
& "C"
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(For valves CFV-25 and CFV-42);
- SP-344, Nuclear Services Cooling System Operability (For Nuclear Services Closed Cycle Cooling Pump "1B");
- SP-3548, Emergency Diesel Fuel Oil Quality & Diesel Generator Monthly Test;
- SP-523, Station Batteries Service Test; and
- SP-701, Radiation Monitoring System Surveillance Program (For radiation monitors RMA-1 and RMA-2 Mid and High Range monitors).
No violations or deviations were identified.
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(9) Maintenance Activities The inspector observed maintenance
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activities to verify that correct equipment clearances were in effect; work requests and fire prevention work permits, as required, were issued and being followed; quality control personnel were available for inspection activities as required; and TS requirements were being followed.
Maintenance was observed and work packages were reviewed for the following maintenance activities:
- Disassembly and bearing replacement on the turbine driven Emergency Feedwater Pump (EFP-2) in accordance with procedure MP-124; Bearing replacement on the turbine driver for EFP-2 in
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accordance with procedure MP-162; Test run of EFP-2 in accordance with Work Request (W/R)
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- 075920 and work instructions;
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- Disassembly and reassembly of check valve RWV-117 in accordence with procedure MP-149;
- Testing of vital bus inverter 3B in accordance with a W/R and work instructions;
- Check of various Reactor Protection System (RPS) modules for broken or loose hold down clips in accordance with W/R
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- 77114;
- Rebuild and subsequent testing of hydraulic snubber #760135 in accordance with procedures MP-174 and PT-130 respectively;
- Boring of drive pin holes in the impeller of the "D" Reactor Coolant Pump (RCP) in accordance with W/R #77146 and work instructions;
- Adjustment of the position indicating limit switches on valve CFV-42 in accordance with a W/R; Troubleshooting of the anti-jamming - circuit on radiation
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monitor RMA-2 in accordance with a work request; and
- Troubleshooting of the local valve position indication on valve EFV-11 in accordance with procedure MP-531.
As a result of these reviews and observations the following items were identified:
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(a) Step 7.4 of the work instructions of W/R #075920 required that vibration readings be taken during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test run of EFP-2. Step 5.2 of these work instructions furthermore required that if the vibration readings exceeded the " alert" limits specified, that the test be stopped. On March 10-11, while observing the test run and reviewing the test data, the inspector noted that the vibration readings for bearing position "D" had exceeded the alert limit at least a dozen times and that the test was not stopped.
Failure to adhere to the requirements of work instructions is contrary to the procedure adherence requirements of TS 6.8.1 and is considered to be a violation.
This violation is another example of the procedure adherence violation discussed in paragraph 5.b(1) of this report.
(b) Procedure MP-149, Check Valve Cap Removal and Reinstallation, Step 7.2.9, requires lubrication of the cap studs prior to initial torquing.
While observing the reassembly of check valve RWV-117 on March 14, the inspector noted that the valve cap was initially torqued without lubricating the cap studs.
Failure to adhere to the requirements of procedure MP-149 is contrary to the procedure adherence requirements of TS 6.8.1 and is considered to be a violation.
This violation is another example of the procedure adherence violation discussed in paragraph 5.b(1) of this report.
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(c) While observing the rebuilding of hydraulic snubber #760135 on March 20, the inspector noted that his copy of procedure MP-174, Power Piping Snubber Rebuild Procedure, Revision 7, was different than the MP-174, Revision 7, that was being used in the field.
Specifically, the inspector's copy had additional signature blanks added to steps 7.2.19 and 7.2.21 (which were duplicates of existing signatures in the procedure) and a quality control " HOLD POINT" added to step 7.2.31 (which was a new HOLD POINT).
Further investigation indicated that the change to the inspector's copy of the procedure was called a " Housekeeping Change" (HKC).
Step 4.1.16 of Administrative Instruction (AI) 401, Origination of and Revisions to P0QAM Procedures, allows HKCs to be made as follows:
"Any change in format. Corrections of typographical errors and/or spelling.
Correction of figures, tables, graphs, (e.g., updating OP-103, Plant Curve Book) data sheets, and updating references.
Correction of
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obviously incorrect valve lineups, out of order proce-dure steps, and instrument identification."
Subsequent discussions with licensee management personnel indicated that the licensee intended to make changes to various plant graphs and tables (e.g., reactivity balance curves, rod worth curves, etc.) as HKCs.
The inspector stated that making such changes circumvented the procedure review and approval process as required by TS 6.8.2.b and in fact had resulted in such an occurrence with the change to procedure MP-174. There were numerous examples of HKCs which circumvented TS 6.8.2.b in changing the curve book, OP 103:
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4/16/85 changed curves for radiation monitors (air samplers) RM-A6, RM-A7, RM-A8; and 5/29/85 changed the curve for Reactor Building Radia-
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tion Monitor RM-A1.
The curve book was subsequently restructured into several procedures, OP 103 A, B, C etc. with additional HKCs as follows:
1/1986 changed the curve in OP-103G for Reactor
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Building Radiation Monitor RM-A1; 2/3/86 changed the curve in OP-103G for the Auxiliary
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Building Liquid Release Monitor RM-L2;
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2/20/86 changed the curves in OP-103G for RM-Al and RM-L2; and
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3/31/86 changed three curves in OP-103B heatup/
cooldown curves.
The requirements of procedure AI-401 are considered to be contrary to the requirements of TS 6.8.1.a and therefore inadequate for the cause.
This item is considered to be a violation of TS 6.8.1.a.
Violation (302/86-12-06):
Failure to have an adequate administrative procedure directing changes to facility procedures.
(d) While observing work on EFP-2 in accordance with procedures MP-124, Disassembly and Reassembly of Emergency Feedwater Pumps, and MP-162, Disassembly and Reassembly of Emergency Feedwater Pump Turbine Bearings, the inspector noted that the procedures did not contain specifications and tolerances for aligning the pump to the turbine.
When the inspector queried the maintenance personnel about these alignment specifications they were produced from a file in the shop.
Licensee representatives informed the inspector that these specifications would be added to both procedures.
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Inspector Followup Item (302/86-12-07):
Verify addition of alignment specifications to EFP-2 procedures MP-124 and MP-162.
(10) Radioactive Waste Controls - Solid waste compacting and selected liquid releases were observed to verify that approved procedures were utilized, that appropriate release approvals were obtained, and that required surveys were taken.
No violations or deviations were identified.
(11) Pipe Hangers and Seismic Restraints - Several pipe hangers and seismic restraints (snubbers) on safety-related systems were checked to insure that fluid levels were adequate and no le:kage was evident, that restraint settings were appropriate, and that anchoring poirts were not binding.
No violations or deviations were identified.
6.
Review of Licensee Event Reports and Nonconforming Operations Reports a.
Licensee Event Reports (LERs) were reviewed for potential generic impact, to detect trends, and to determine whether corrective tctions appeared appropriate.
Events that were reported immediately were reviewed as they occurred to determine if the TS were satisfied.
LER 86-003 was reviewed in accordance with current NRC enforcement policy and is considered to be closed. Two issues identified in this LER, investigation of the decay heat pump shaft breakage and the failure of valve DHV-39 to open, are being tracked by IFI's 302/86-09-03 and 302/86-07-03, respectively.
b.
The inspector reviewed Nonconforming Operations Reports (NCOR) to verify the following:
compliance with the TS, corrective actions as identified in the reports or during subsequent reviews have been accomplished 'or are being pursued for completion, generic items are identified and reported as required by 10 CFR Part 21, and items are reported as required by TS.
All NCORs were reviewed in accordance with the current NRC Enforcement Policy.
- N, violations or deviations were identified.
7.
Design, Design Changes and Modifications The installation of modification (MAR) 82-10-19-31, RW Pump Flush Water, was reviewed to verify that the change was reviewed and approved in accordance with 10 CFR 50.59, that the change was performed in accordance with technically adequate and approved procedures, that subsequent testing met
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acceptance criteria and deviations were resolved in an acceptable manner, and that appropriate drawings and facility procedures were being revised as necessary.
This review included selected observations of activities in progress.
Following completion of this modification, the inspector noted that to maintain sufficient bearing flush water pressure either Nuclear Services Seawater Pump (RWP) 2A or 2B (safety system pumps) must be run continuously instead of the normal non-safety pump, RWP-1.
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operation could cause degradation of the safety system pumps.
This observation was discussed with licensee representatives who concurred with the inspector. The licensee is presently pursuing additional design changes that will-return the normal system running status to RWP-1.
Inspector Followup Item (302/86-12-08): Review the design change that will return normal RW system operation to RWP-1.
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