IR 05000302/1986020

Insp Rept 50-302/86-20 on 860607-0703.Violation Noted: Failure to Adhere to Plant Procedures

ML20214M715
Person / Time
Site:	Crystal River
Issue date:	09/02/1986
From:	Elrod S, Stetka T, Tedrow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214M682	List: IR 05000302/1986020 ML20214M677 ML20214M701
References
50-302-86-20, NUDOCS 8609110240
Download: ML20214M715 (12)

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UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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101 MARIETTA STREET, * ATLANTA, GEORGI A 30323

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Report No.: 50-302/86-20 Licensee: Florida Power Corporation l 3201 34th Street, South St. Petersburg, FL 33733 Docket No.: 50-302 License No.: DPR-72 Facility Name: Crystal River 3 Inspection Conducted: June 7 - July 3,1986 Inspectors: T. F. Stetka, Senior Resident In/pector

[A k 86 Date Signed AVD flb.L 3 fx J. E. Tedrow, Resident Inspectfr 8lU-l8C-Date Signed Approved by: h S. A. Elrod, Section Chief f f Nb

'Dat( Signed Division of Reactor Projects SUMMARY Scope: This routine inspection was conducted by two resident inspectors in the areas of plant operations, security, radiological controls, Licensee Event Reports and Nonconforming Operations Reports, facility modifications, licensee action on previous inspection items, and the annual emergency drill. Numerous facility tours were conducted and facility operations observed. Some of these tours and observations were conducted on backshifts. This inspection report also documents meetings with local public officials held by the resident inspector Results: One violation was identified (Failure to adhere to plant procedures, paragraphs 5.a.(1), 5.b.(8).a, and 5.b.(9)).

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REPORT DETAILS Persons Contacted Licensee Employees

• J. Alberdi, Manager, Nuclear Site Support

• Breedlove, Nuclear Records Management Supervisor

• Clarke, Radiation Protection Manager

• Green, Nuclear Licensing Specialist-

• Hickle, Manager, Nuclear Plant Operations

• M. Mann, Nuclear Compliance Specialist

• P. McKee, Director, Nuclear Plant Operations

• R. Murgatroyd, Nuclear Maintenance Superintendent

• Neuman, Inservice Inspection (ISI) Supervisor

• J. Roberts, Nuclear Chemistry Manager

• V. Roppel, Manager, Nuclear Plant Technical Support

• Rossfeld, Nuclear Compliance Manager

• Stephenson, Nuclear Operations Engineer

• E. Welch, Manager, Nuclear Electrical / Instrumentation and Control Engineering Services R. Wittman, Nuclear Operations Superintendent Other personnel contacted included office, operations, engineering, maintenance, chemistry / radiation protection and corporate personne * Attended exit interview City / County Officials Herb Williams, Crystal River City Mayor John Kelly, Crystal River City Manager Helen Spivy, Member, Crystal River City Council John Barnes, Citrus County Commissioner William Broska, Citrus County Commissioner

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Nick Bryant, Citrus County Commissioner

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Jean Grant, Citrus County Commissioner Alex Griffin, Citrus County Commissioner Exit Interview The inspector met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on July 3,1986. During this meeting, the inspector summarized the scope and findings of the inspection as they are detailed in this report with particular emphasis on the Violation, Unresolved Items (UNR), and Inspector Followup Items (IFI).

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The licensee representatives acknowledged the inspector's comments and did

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not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio . Licensee Action on Previous Inspection Items (Closed) IFI 302/83-27-07: The licensee has completed their investigation into the weld failure of vent valve MUV-283. The failure of the socket weld on this valve was due to high cycle fatigue. The licensee has replaced these socket welds with butt welds, thus increasing the strength of these welds. The inspector has reviewed this investigation and the corrective action and has no further questions on this ite (Closed) IFI 302/86-09-03: The licensee has determined that the cause for

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the "B" Decay Heat Pump shaft breakage was torsional fatigue induced by

?' excessive shaft loadin A contributing factor for this failure was determined to be air entrainment in the suction piping to the pump's impeller caused by vortexing from the low reactor coolant levels which existed during pump operation. The licensee evaluated the possible effects that loose pipe hangers could have had on this failure and concluded that no significant contribution occurre The licensee has revised procedure OP-404, Decay Heat System, to provide minimum reactor coolant levels required for decay heat pump operation. The inspector reviewed the failure analysis and procedure revision and has no further questions on this ite (0 pen) UNR 302/85-29-03: A review of this item indicated that the licensee runs one of the two air handling fans (AHF) during Emergency Diesel Generator (EDG) testing but that both fans start and run under an actual EDG demand condition. The inspector questioned this practice since the test as presently run does not simulate actual conditions (i.e., both fans running together). It appears that both fans can be run under the testing conditions and the licensee intends to revise the EDG testing procedures (SP-354A & B) to run both of these fan This item remains open pending revision of these procedures and review of the written evaluation of fan operation by the licensee's engineering department.

I (0 pen) IFI 302/85-42-04: Review of this item indicated that the licensee considers their present procedure, AI-1803, to cover the concern identified (i.e., protection of equipment from damage from ancillary items such as ladders and scaffolding) and that no further action is required. The inspector's review of procedure AI-1803 indicated that this procedure was written to insure personnel safety and was not intended to address protection of equipment from ancillary item The licensee intends to reconsider their actions on this item, therefore, it will remain open pending review of this action.

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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 or deviations. A new unresolved item is identified in paragraph 5.b.(8).b of this repor s

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5. Review of Plant Operations The plant started this inspection period in cold shutdown (Mode 5). A plant heatup was commenced and the plant entered Mode 3 hot standby at 8:35 p.m.,

on June 13, 1986. The reactor was taken critical on June 19, 1986, at 9:45 p.m, resumed power operation (Mode 1) at 10:25 p.m, and remained in Mode 1 for the remainder of the inspection period, Shift Logs and Facility Records The inspector reviewed records and discussed various entries with operations personnel to veri fy compliance with the Technical Specifications (TSs) and the licensee's administrative procedure The following records were reviewed:

Shift Supervisor's Log; Reactor Operator's Log; Equipment Out-0f-Service Log; Shift Relief Checklist; Auxiliary Building Operator's Log; Active Clearance Log; Daily Operating Surveillance Log; Work Request Log; Short Term Instructions (STIs); and Selected Chemistry / Radiation Protection Log In addition to these record reviews, the inspector independently verified clearance order tagout (1) The inspector observed plant heatup activities on June 11, 1986, conducted in accordance with procedure OP-202, Plant Heatu Shortly after the plant entered hot shutdown (Mode 4), the inspector checked safety system valve status on the main control board and noticed that a discharge throttle valve (DHV-111) for the "B" Decay Heat Pump (DHP-18) was in the closed position vice the usual throttled positio This valve regulates flow to the reactor vessel in the event a Low Pressure Safety Injection (LPI)

signal is actuated due to a loss of coolant acciden In Mode 4 the licensee is required to have one operable LPI system. The inspector verified that the "A" LPI system was operable and questioned the Nuclear Operator (NO) if valve DHV-111 was in the proper position. The NO agreed that the valve should have been in the throttled position and checked the valve's controller. The operator found the valve's controller in the manual position vice the normal automatic position. The operator placed the valve's controller in the automatic position and set the controller for the proper throttled positio The inspector reviewed procedure OP-202. Step 6.4.7.15 requires that the Decay Heat Removal (DH) system be aligned for Engineered

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Safeguards (ES) standby operation per procedure OP-404, DH Syste Procedure OP-404, section 11, aligns the DH system for ES standby operation and requires valve DHV-111 to be in the throttled position. Step 6.4.7.15 in procedure OP-202 had been signed off

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as complete even though valve DHV-111 was not in the required throttled positio OP-404 positioning of DHV-111 had been performed about two weeks earlier but the valve had been subse-quently repositioned. The on-shift operators thought the line-up was complet Failure to adhere to the requirements of procedures for plant heatup and operation of the DH system is contrary to Technical Specification (TS) 6.8.1.a. and is considered to be a violatio Violation (302/86-20-01): Failure to adhere to plant procedures as required by TS 6. (2) On June 30, 1986, during a review of the shift supervisor's log and Nonconforming Operations Reports (NCORs), the inspector noted that venting of the primary containment building through valves LRV-71 and LRV-73 was performed to lower containment pressure while the plant was in Mode 1. These valves and associated piping were installed for the post accident hydrogen purge system and are

not automatically closed by a containment isolation signa In August 1984, the NRC agreed to allow this method of venting if the following criteria were met:

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the NRC would be notified and concurrence obtained prior to beginning the evolution;

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TS 3.6.1.1, which requires the maintenance of primary containment integrity, would be voluntarily entered and venting would be limited to the one hour allowed by the Action Statement of this TS;

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the valves to be used would be cycled open and closed before use; and

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a dedicated operator would be stationed at the control panel switches for the applicable valve The licensee concurred with these criteria and committed to meet them if further containment venting was required as ' documented in an inter-office correspondence dated August 7, 198 These commitments were not formally written to the NRC at that tim The venting process was performed from approximately 11:00 p.m. ,

on June 29 to 3:29 a.m., on June 30 (a period of approximately hours). Operations personnel performed the venting in accordance with procedure OP-417, section 1 The procedure does not require completion of any of the criteria that the licensee had verbally committed to meet prior to and during containment venting operation .

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Subsequent to the inspection, the NRC staff determined that failure to meet verbal commitments of August 1984, was not a deviation from a commitment to the NRC, however, this matter is under staff technical consideration (IFI 302/86-20-02).

b. Facility Tours and Observations Throughout the inspection period, facility tours were conducted to observe operations and maintenance activities in progres Some operations and maintenance activity observations were conducted during backshifts. Also, during this inspection period, licensee meetings were attended by the inspector to observe planning and management activitie The facility tours and observations encompassed the following areas:

security perimeter fence; control room; emergency diesel generator room; auxiliary building; intermediate building; battery rooms; electrical switchgear rooms; and reactor buildin 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; electri-cal system lineup; reactor operating parameters; and auxiliary -

equipment operating parameter No violations or deviations were identifie (2) Safety Systems Walkdown - The inspector conducted a walkdown of the High Pressure Injection (HPI) system to verify that the lineup was in accordance with license requirements for system operability and that the system drawing and procedure correctly reflect

"as-built" plant condition ,

No violations or deviations were identifie (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 professional manne In addition, the inspector observed shift turnovers on various occasions to verify the continuity of plant status, operational problems, and other pertinent plant information during these turnover No violations or deviations were identifie . -

(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 existe No violations or deviations were identifie (5) Radiation Areas - Radiation Control Areas (RCAs) were observed to veri fy _ proper identification and implementatio These observations included selected licensee conducted surveys, review of step-off pad conditions, disposal of contaminated clothing, and area postin Area postings were independently verified for accuracy through the use of the inspector's own radiation monitoring instrumen 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 followe No violations or deviations were identifie (6) Security Control - Security controls were observed to verify that security barriers were intact, guard forces were on duty, and access to protected area (PA) was controlled in accordance with the facility security plan. Personnel within the PA were observed to verify proper display of badges and that personnel requiring escort were properly escorted. Personnel within vital areas were observed to ensure proper authorization for the are No violations or deviations were identifie (7) Fire Protection - Fire protection activities, staffing and 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 operabl No violations or deviations were identifie (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 operability; calibrated equipment was utilized; and TS requirements were followe The following tests were observed and/or data reviewed:

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SP-102, Control Rod Drop Time Test;

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SP-179, Containment Leakage Test-Types "B" & "C";

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SP-181, Containment Air Lock Test (Semiannual);

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SP-201, Accessible / Inaccessible Hydraulic Snubbers Visual Inspection;

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SP-224, Reactor Coolant Flow Measurement Determination;

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SP-317, Reactor Coolant System Water Inventory Balance;

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-' SP-403, Decay Heat Removal System Valves Automatic Closure &

Interlock Verification;

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SP-417, Refueling Interval Integrated Plant Response to 9' Engineered Safeguards Actuation; and

• - SP-422, Reactor Coolant System Heatup & Cooldown

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As a res' ult of these reviews, the following items were identified:

(a) Durihg a review of the completed data for procedure SP-201, revision 17, on July 2, the inspector noted that snubber FWV-124 was found on February 27, 1986, to have a sightglass fluid level of 40 percent and that no action was taken to correct the level. Step 6.2.1 of procedure SP-201 requires that if the sightglass fluid level is between 0-50 percent full that the fluid reservoir be " topped off" so that sufficient fluid is available for snubber operatio Upon notification of this finding, the licensee immediately checked the fluid level in FWV-124, found it to be at approximately 45 percent and subsequently refilled the

, reservoir. The snubber did not indicate any evidence of fluid leakag Failure to adhere to the requirements of procedure SP-201 is considered to be contrary to the requirements of TS 6.8. ,

and is considered to be another example of the procedure

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adherence violation identified in paragraph 5.a of this

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repor (b) While reviewing a new revision (number 18) to procedure SP-201, which was implemented on May 5,1986, the inspector c noted that there were no acceptance requirements specified for the reservoir fluid levels. The procedure merely states to check the fluid level but does not specify an acceptable level range nor does it require the "as found" and "as left" fluid level readings to be recorde Previous NRC inspections had identified a similar problem with the licensee's snubber inspection procedure, and "as found" and "as lef t" data points were subsequently added to enable the licensee to track changes in the reservoir levels so that possible leaks in the snubber fluid system could be readily detecte During discussions with the licensee concerning these observations, the licensee agreed to review procedure SP-201 l

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and consider changes to the procedure to include acceptance criteria for the fluid level and a requirement to record "as found" and "as left" fluid level dat Unresolved Item (302/86-20-03): Revise procedure SP-201 to include snubber fluid level acceptance criteria and "as found" and "as left" data point (c) While touring the control room on - June 10, the inspector-noted that one of the Emergency Diesel Generator (EDG) air handling fans (AHF-228) was in the " pull-to-lock" (PTL)

position and, therefore, not available for automatic EDG operation. The licensee had just completed the monthly EDG test in accordance with procedure SP-354A, which required one of these fans to be placed in the PTL positio The inspector reviewed the test data and determined that SP-354A had been completed and was ready for document transmitta The completed data indicated that the signoff for returning the fans to their proper (normal-after-stop) position. had been completed even though AHF-228 was still in PTL. The licensee was informed of this finding and the fan was returned to its proper positio For EDG operability, only one of these fans needs to be operabl Further review of SP-354A indicated that step 9.7.8 only requires either one of the two fans to be returned to its proper position even though the intent of this step is to return the fan placed in the PTL position by step 9.5.1 to be returned to its proper positio The licensee will revise procedure SP-354A and B to insure that both fans are returned to their proper positions following the completion of procedure SP-354 Inspector Followup Item (302/86-20-04): Review the revision to procedures SP-354A & B to insure that both AHFs are returned to norma (9) Maintenance Activities - The inspector observed maintenance 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 followe Maintenance was observed and work packages were reviewed for the following maintenance activities:

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Troubleshooting Emergency Feedwater Initiation and Control System level instrument (CD-100-LT) in accordance with procedure Mp-531;

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Troubleshooting and repair of the steam admission valve ,

(ASV-204) to the steam-driven Emergency Feedwater Pump in accordance with procedures MP-531 and MP-405;

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Troubleshooting a reactor coolant hot leg temperature instrument in accordance with procedure MP-531;

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Testing of control rod absolute and relative ~ position indication relays; i

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Troubleshooting the startup feedwater regulating valve ( FWV-39);

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Periodic electrical checks of Emergency Diesel Generators in accordance with procedure PM-123; and

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Repacking valve IAV-90 in accordance with procedure MP-11 During a review of Work Requests (W/Rs) on June 26 and discussions with maintenance personnel, the inspector determined that corrective maintenance (packing adjustment) on safety-related-valve IAV-90, had been performed by operations personnel on April 8. When operations personnel failed to correct the packing leak, W/R No. 78566 was issued to the Maint? nance Department to repair the valve. Apparently the effort to correct the packing leak by operations personnel had increased the leakag When this finding was discussed with plant management personnel, it was determined that making " minor adjustments" to

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safety-related plant equipment by. operations personnel without any procedures or W/Rs was an accepted practic TS 6.8.1.a which endorses Regulatory Guide 1.33, requires maintenance to be performed in accordance with written procedures and the licensee's procedure AI-600, Conduct of Maintenance, ,

requires, in step 4.4.12, that all nonemergency corrective maintenance on plant safety-related equipment be authorized and documented by an approved W/ Failure to adhere to the requirements of procedure AI-600 is contrary to the requirements of TS 6.3.1.a and is considered to be another example of the procedure adherence violation identified in paragraph 5.a of this repor (10) Radioactive Waste Controls - Solid Waste Compacting and selected liquid and gaseous waste releases were observed to verify that approved procedures were utilized, that appropriate release approvals were obtained, and that required surveys were taken.

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On June 18, 1986, the inspector observed high oxygen and hydrogen concentrations in the B and C Waste Gas Decay Tanks. A NRC Region II inspector, who specializes in plant chemistry, was dispatched to the site to assist the resident inspectors in their investigation of these observations. Details of this investi-gation and subsequent findings are discussed in NRC Inspection r Report 50-302/86-2 (11) Pipe Hangers and Seismic Restraints - Several pipe hangers and seismic restraints (snubbers) on safety-related systems were observed to insure that fluid levels were adequate and no leakage was evident, that restraint settings were appropriate, and that anchoring points were not bindin With the exception of the findings concerning snubber FWH-124 discussed in paragraph 5.b.(8)(a), no other violations or deviations were identifie . Review of Licensee Event Reports and Nonconforming Operations Reports Licensee Event Reports (LERs) were reviewed for potential generic impact, to detect trends, and to determine whether corrective actions appeared appropriat Events, which were reported immediately, were reviewed as they occurred to determine if the TS were satisfie LERs 85-32, 86-06, and 86-07 were reviewed in accordance with current NRC policy and are close The inspector reviewed Nonconforming Operations Reports (NCORs) 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 T All NCORs were reviewed in accordance with the current NRC Enforcement Polic NCOR 86-105 reportec. incorrect tubing and fittings installed on safety-related instrumentation. The instrumentation involved is used for indication only, and based on the size of these instrumentation lines (approximately one quarter to one half inch) system operability is not a concer The licensee has attributed the cause for this condition to be the installation of a modification (MAR T80-06-80) that did not specify the correct tubing and fittings to be used. The licensee is presently evaluating this condition and is considering validating the existing piping or replacing i IFI (302/86-20-05): Review the licensee's evaluation and corrective action for incorrect tubing and fittings on safety-related instrumentatio .

7. Nonroutine Event Followup The plant entered an unusual event at 11:30 a.m., on June 11, 1986, due to a tornado siting near the plant. The inspector was in the control room at the time of the event and observed operator actions and the implementation of the licensee's emergency plan. The tornado did not cause any plant damag The unusual event was terminated at 12:32 p.m., on June 1 . Annual Emergency Drill On June 19, 1986, the- annual emergency drill was conducted by the licensee to verify the effectiveness of the Radiological Emergency Response Plan and implementing procedures. In addition to the licensee, the pa-ticipants in the drill included the State of Florida, Citrus and Levy Counties, and the NRC. The drill was observed by a number of personnel, including the NR Details of the drill, including the results of the critiques held on June 20, 1986, are discussed in NRC Inspection Report 50-302/86-1 . Meeting with Local Public Officials On June 30, 1986, the resident inspectors held meetings with members of the city council for the City of Crystal River, and Lembers of the county commission for Citrus Count The objectives of this meeting were to:

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acquaint local officials with the mission of the NRC;

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introduce the resident inspectors stationed at the Crystal River Nuclear Plant;

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discuss the lines of communication between the local officials and the NRC resident inspector and regional offices;

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discuss the operating status of the Crystal River Nuclear Plant; and

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discuss any related community concerns with the plant or its operatio The inspectors were impressed with the interest the community leaders showed in -the Crystal River plan It is felt that all participants benefitted from this meeting and that the meeting objectives were accomplishe ,