IR 05000302/1989003

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Insp Rept 50-302/89-03 on 890128-0224.No Violations or Deviations Noted.Major Areas Inspected:Plant Operations, Security,Radiological Controls,Lers & Nonconforming Operations Rept,Facility Mods & Licensee Actions on Insp
ML20248G356
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 03/24/1989
From: Crlenjak R, Holmesray P, Tedrow J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20248G351 List:
References
50-302-89-03, 50-302-89-3, NUDOCS 8904130401
Download: ML20248G356 (12)


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f M0g UNITED STATES

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NUCLEAR REGULATORY COMMISSION o

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j 101 MARIETTA STREET,N.W.

's ATLANTA, G EoRGI A 30323

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Report No: 50-302/89-0'3 Licensee:

Florida Power Corporation 3201 34th Street, South s

St.' Petersburg, FL 33733

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Docket No:

50-302 License N'o.: DPR-72

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Facility Name: Crystal River 3

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Inspection Conducted: January 28 - February 24, 1989 Inspectors:

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F. Ho. s-R g en.i g. Resident Inspector Difte Signed M

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J.gdr ResVdgIT1spector Date Signed N

Approved by:

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R./Crienjanvi SectionATiief D6te S/gned Division of Reactor Projects

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SUMMARY Scope:

This routine inspection was conducted by two resident inspe'ctors in the areas of plant operations, security, radiological controls, Licensee Event Reports and Nonconforming Operations Reports, facility modification's,..and licensee action on previo0s inspection items,

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Numero0s ' facility tours were conducted and facility operations observed.

Some of these tours and observations were conducted on backshifts.

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Results: Specific ' strengths and weaknesses were identified in the licensee's control of system drawings, paragraph 5.

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REPORT DETAILS L

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Persons Contacted Licensee Employees s

  • G. Becker, Manager, Site Nuclear Engineering Services
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  • P. Breedlove,' Nuclear Records Management Supervisor
  • R. Clarke, Nuclear Regulatory Specialist
  • B. Hickle, Manager, Nuclear Plant Op'erations

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  • W. - Marshall, Superintendent,. Nuclear Operations P. McKee, Director, Nuclear Plant Operations

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  • T. Neaman, Nuclear-Security Officer
  • J. Roberts, Assistant Superintendent, Nuclear Chemistry and Radiation Protection
  • W. Rossfeld, Manager, Nuclear Compliance.
  • K. Wilson, Maniger, Nuclear Licensing Other lice'nsee employees contacted included office, operations, engineer-ing, maintenance, chemistry / radiation and corporate personnel.
  • Attended exit interview Acronyms and initialisms used throughout this report are listed in the last paragraph.

2.

Review of Plant Operations (71707)

The ' plant continued in power operation (Mode 1) for the duration of this inspection period.

However, power level was limited due to three loop operations caus'ed'by the failure of the "A" Reactor' Coolant Pump (RCP)

discussed in"lnipection Report 50-302/89-01.

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Shift Logs and Facility Records (71707)

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The inspe'ct6r reviewed records and discussed various entries with operations personnel to verify compliance with the Technical i

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Specifications (TS) and the licensee's administrative procedures.

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The.fo'110 wing _ records were revie'wed:

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Shift Supervi'sor.'.s. Log;. Reactor perator's ' Log; Equipment Out-0f-Servicb. Log;'.Shif t Relief Checklist; Auxiliary Building Operator's Log; Active Clearance Log; Daily Operating Surveillance Log; Work Request Log; Short Term Instructions (STI); and Selected. Chemistry /

Radiation Protection Logs.

In addition to these record reviews, the inspector independently verified clearance order tagouts.

No violations or deviations were ident.* ed,

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Facility Tours and Observations (71707)

Throughout the inspection period, facility tours were conducted to observe operations and maintenance activities in progress.

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 activities.

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The facility tours and observations encompassed the following areas:

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security perimeter fence; con.r i room; eme'rgency diesel generator

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s room; auxiliary building; intermediate building; battery rooms; and electrical switchgear rooms.

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During these tours, the following observations were made:

(1) Monitoring. Instrumentation

. The following instrumentation and/or indications were observed to veri fy that indicated parameters were in accordance with the TS for the current

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Equipment operating status; area atmospheric and liquid radia-tion monitors; electrical system lineup; reactor operating parameters'; and auxiliary equipment operating parameters.

No violations or deviations were identified.

(2) Safety iy' stems Walkdown (71710) - The inspector conducted a walkdown of the Emergency Diesel Generators to verify that the lineup was in accordance with license requirements for system operability and that the appropriate drawings and procedures correctly. reflect "as-built" plant conditi6ns.

No violations or deviations were identified.

(3) Shif t/ Staffing (71707) - 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 manner.

In addition, the inspector observed shift turnovers on various occasions to verify the continuity of plant

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status,. operational problems, and other pertinent plant inforWatibn during these turrtovers.

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%. viola.t-io'os or deviations were identified.

(4) Plant Housekeeping Conditions (71707) - 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.

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'(5) Radiological Protection Program (71707)'- Radiation protection control activities were observed to verify that these~ activities were in conformance with the facility policies and procedures, r

and in compliance with regulatory requirements.

These observa-tions included:

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Entry 'to and exit from contaminated. areas, including step-off pad conditions and disposal of corttamina. tea clothing;

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~ Area postings and coritrols;

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Work activity within radiation, high radiation, and

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contaminated areas; Radiation Control Area (RCA) exiting practices; and

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Proper wearing of personnel monitoring equipment,

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protective clothing, and respiratory equipment.

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Area postings were independently verified for accuracy by the inspector. The inspector also reviewed selected Radiation Work Permits (RWPs) to verify that the RWP was current and that the controls.were adequate.

N6' violations or deviations were identified.

(6) Security i ontrol (71707)

In the course of the monthly l

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activities, the inspector included a review of the licenwe's.

physical security program. The performance of various shifts of the security force was observed in the conduct of daily activ'itfes to include: protected and vital' area access controls; sehEching of personnel, packages, and vehicles; badge issuance and retrieval; escorting'of-visitors; patrols; and compensatory posts.

In addition, the inspectoc observed the operational status' of Closed Circuit Television (CCTV) monitors, the IntrusTon Detection system in the central and secondary alarm

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stations, protected area lighting, protected and vital area-barrier integrity, and the security organization interface with operations and maintenance.

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No vToititions or deviations w.ere.identifie~d.

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Fire Pr6tec' Lion (71707) - Fire protection activities, staffing I

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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 operable.

j No violations or deviations were identified.

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(8) Surveillance (61726) - Survei.11ance 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 followed.

The following tests were observed and/or data reviewed:

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SP-317, RC System Water Inventory Salance.

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SP-334A, Spent Fuel Pool Pump (SFP-1A) Operability Test.

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SP-349A, Emergency Feedwater Pump (EFP-1). Monthly l

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Operability Demonstration.

l SP-521, Quarterly Battery Check.

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No violations or deviations were identified.

(9) maintenance Activities (62703) - 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 followed.

Maintenan.ce was observed and work packages were reviewed for the

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following maintenance activities:

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Reduce electrolyte levels in station batteries and Unit 1 &

2 batteries in accordance with procedure SP-521, Quarterly

, Battery Check.

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Troubleshoot / replace sensor for toxic gas monitor.AH-653-CE in accordance with procedures MP-531, Troubleshooting Plant Equipment and SP-3728, Toxic Gas Detection System Calibra-

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'tton (Train B).

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Reopen EFV-33 after closure in accordance with procedure MP-212, Emergency Feedwater Valve Reset (from. A EFIC'

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Overfill Condition) for EFV-11,14,.32, 33, 55, 56, 57, &

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steam.' gene rato r.

These valves will automatically reopen on decreasing steam generator level.

This protective action has occurred several times in the past. and the inspectors requested the licensee to return the system to a normal lineup with the valves open.

The licensee developed procedure MP-212 to accomplish this action.

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Disassemble,' inspect, replace valve SWV-501 in accordance

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with procedure MP-118, Bolted and Screwed Valve Bonnet Maintenance.

Preventive maintenance on the. : motor operator for valve

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DHV-8 in accordance with procedure MP-402B, Maintenance of Limitorque Valve Operators Type SMB-00.

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Replace motor operator for valve DHV-76 in accordance with

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procedure MP-402A, Maintenance of Limitorque Valve Operators Type SMB-00'0.

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-(10). Radioactive Waste Controls (71707) - Selected 1.iquid and gaseous 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.

3.

Review of Licensee Event Reports (92700) and Nonconforming Operations

Reports (71707)

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Licensee. Event Reports (LERs) were reviewed for potential generic impact,.to detect' trends, and to determine whether corrective actions appeared appropriate.

Events that were reported immediately were reviewed as they occurred to determine if the TS were satisfied.

LERs were reviewed in accordance with the current NRC Enforcement Policy.

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(1) (0 pen) LER 89-01: This LER reported that solenoid air valve:,

for four containment isolation valves were undersized with resp,ect[tomaximumoperatingpressureandm'aypreventthevalves i

from performing their safety function.

This matter was the subject of a violation (302/89-01-01) and is discussed in detail

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in NRC Inspection Report 50-302/89-01.

The licensee plans to is, sue,.a supplement to this report in March 1989. The LER will remain"bpen pending review of the supplemental report.

(2) (0 pen) LER 89-02:

This LER reported the failure to update the Inse.rvice Inspection Pump and Valve Program for recently

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instaHed safety related check valves' - This LER has been

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i refe'r' red 1!o the NRC Region.II.0ffice for, follow-up by specialist inspectors /..The LER.wi.11' remain -open pending further NRC r4 view

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(3) (Closed) LER 89-03: This LER reported the inadvertent actuation of the emergency feedwater system.

This matter was discussed previously in NRC Inspection Report 50-302/89-01 and was the subject of a violation (302/89-01-03).

The LER will be closed and further action tracked by the violation.

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The inspector reviewed Nonconforming -Operations Reports (NCORs) to verify the following: TS are complied with, 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 NBC.Enfpree-ment Policy.

(1) NCOR ' 89-15 reported that ' TS 3.4.4.c does n'ot require a suf-ficient number of pressurizer heaters needed to maintain a steam bubble in the pressurizer foilowing a loss of off site power.

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The current TS requires at least 126kw of heater load be-available from the emergency power - source 'o maintain the pressurizer bubble. The licensee discovered during correspon-

.dence with. Babcock and Wilcox in response to the Technical

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Specification Improvement Program (TSIF) that convection losses from the pressurizer are greater than 126 KW (approximately 132 KW).- The licensee has performed surveillance tests to ensure that greater than 132 KW of heaters can be supplied from the o

emergency power source and plans to submit a Technical Specifi-cation Change Request (TSCR) to upgrade the existing TS.

IFI (302/89-03-01):

Follow the licensee's activities to change TS 3.4.4.c to require an adequate number of pressurizer heaters.

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Installation and Testing of Modifications (37828)

Installation of new or modified systems were reviewed to verify that the

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changes were reviewed and. approved in accordance with 10 CFR 50.59, that the changes. welre ' performed in accordan'ce with technically adequate and approved pr66eduVes, that subsequent testing and test results met acceptance criteria or deviations were resolved-in an acceptable manner, and that appropriate facility procedures were revised as necessary.

This review inc.luded/se.lected observations of modifications and/or testing in progress.

Modification MAR 88-05-11-01, Modify Main Steam Isolation Valve Limit Switches an,d Test Circuit, and associated testing in accordance with Test Proced'ure #1A,-was reviewed.

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No violations-on devia,tions were.. identified;

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Review of Drawing Control (RAI 88-01) (37700, 37701, 37702, 39702)

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Drawings at CR-3 are numbered by discipline as follows:

OXX-XXX Layout l

IXX-XXX Architectural

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2XX4X'XX Electrical 3XX-5(XX Mechanical 4XX-XXX Structural, Concrete

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5XX-XXX Structural, Steel 6XX-XXX Unused 7XX-XXX Civil

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Within a discipline group, drawings are divided into series, cusing,,,the second and third digits, such as:

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206-XXX Electrical, One Line Diagrams

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314-XXX Electrical, Cable Tray and Supports In the Control Room the 302 series, Mechanical Flow Diagrams, and the 201-061 thru 071 series, Distribution Panel Arrangements, are maintained.

These are maintained as up to date, as built blue line drawings.

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In the Techt ical Support Center (TSC) a complete set of aperture cards and selected blue line drawings (302 series) are maintained.

A review of a sample of drawings in the Control Room and in the TSC revealed that the drawings were readable and of the latest revision. The potential exists for the Control Room to have a later revision than the TSC since. the TSC. drawings are of lower priority than the control room

. drawings.

If this were to occur then the TSC would have an interim drawing showing the change.

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For temporary modif'ications (T-Mar), no reference is made on the drawing.

An interim drawing is produced and a. copy placed with the drawing in.the control room.

Since the base drawing does not reference the T-MAR the potential exists for loss of the interim drawing without the operator l

being aware.of!the. loss.. This was discussed with licensee personnel and they are eva10af.ing further actions.

For Control Room drawings there is no specific number of changes that triggers a drawing revision. since the drawing must be revised prior to turnover of the system to operations followingtt)emo;d1fication.

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In the event that a drawing discrepancy is noted, a Field Problem Report i

(FPR) would be written to the engineering department.

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evaluation,of;the Crystal River - 3 drawing system initiated in July.of 1986 and reported in March of 1987, the comment was made that using the FPR was burderisotne! to the preparer and.dispositroner.

This report recommended.that,a " Drawing Discrepancy Report" might be a better vehicle.

i than the FPL.. To.*dat6 the FPR is still used.

i There is no specified turnaround time for drawing discrepancy FPR's.

No periodic audit of the accuracy of control room or TSC drawings was apparent.

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Strengths of the system:

Control Room. drawings appear to be up-to-date

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As-built drawings must be in the control room prior to system /

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component turnover to operations.

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No ' nuclear draftsmen - All CR-3 drawings are drafted by FPC fossil

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drafting and therefore not under the management of FPC Nuclear

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Too.many.- documents involved with ' drawing control and no procedure

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with a combining overview of the system or its goals TSC could lag the control room in drawing updates.

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Procedures Reviewed:

AI-405, Control of Drawings.

DC/RM-310, Control of Drawings.

DC/RM-345, Processing Drawing Change Notices (DCNs).

MPP-107, Turnover of Modifications (Completed / Partial) to Nuclear.0perations.

NEP-211, Modification Approval Records (MAR).

NEP-133, Control.and Approval of Drawings.

NEP-251, Preparat.i.on, Review and Approval of Field Change Notices ( FCNs): -

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NEP-253, Preparation and Control of DCNs.

NEP-271, As-Building and Closure of MARS.

MP-2, Modification Procedure, i

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Docu' ment. Control. Prog ram.

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NEP-131, Db uh4nt Approval and Control.

Guidelines for Use of CR-3 Drawings (Manual).

Drawings us,ed for csystem walkdown. (See paragraph 2.b(2) for walkdown results)

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FD-302-285, Emergency Diesel Lube 011.

FD-302-283, Emergency Diesel Jacket Coolant.

FD-302'284,' Emergency Diesel Air Cool'er Coolant.

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FD-300-281, Emergen#y Diesel Fuel 011.,

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FD-302-282,. Emengency.Di.esel Start.ing Air.

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No violations or deviations were identified.

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Review of Surveillance Procedures and Records (61700)

i The inspector reviewed surveillance procedures and records to verify that (

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the surveillance of systems and components required by the technical

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specifications, and Inservice Testing Program were being properly i

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conducted.

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The following surveillance procedures and completed data were reviewed:

SP-334A, Spent Fuel Pool Pump (SFP-1A) Operability Test, and data i

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completed on October 10, 1988, November 8, 1988 and February 14,

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SP-349A, Emergency Feedwater Pump (EFP-1) Operability Demonstration,

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and data completed on September.13, 1988, October 22,. 19p8, November 9,1988, January 1,1989, and February 13, 1989.

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SP-375A, Chilled Water Pump (IA)-Quarterly Operability Demonstration,

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and data completed on August 5, 1988 and November 8, 1988.

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While reviewing procedure SP-344A to verify implementation of the licensee's IST program, the inspector noticed that spent fuel pump discharge check valves (SFV-26/27) were not being tested in the closed position.

.The testing of emergency feedwater system check valves to

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verify ~ p' roper performance of safety functions in the closed position is

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already the subject of an unresolved item * (302/88-31-01).

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licensee is presently evaluating all safety system check valves to determine safety functions and proper testing, the unresolved item will be

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expanded to include all safety systems.

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Licensee Action on Previously Identified Inspection Findings (92702 &

92701)

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(Closed) Violat on 302/88-14-02:

Failure to implement the require-ments of plant procedures.-

The inspector reviewed and verified implementation of the corrective actions stated in the FPC response letter dated July 11, 1988.

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(0 pen)IFk305[87-1b-09:

Review the licensee's progress to detect and repair leaks in the Post Accident Sampling System (PASS).

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.l i cen see ';s progress was updated in NRC Inspection Report 50-302787-12.

During this reporting period the licensee has experienced additional problems with the PASS system.

Testing of this system has been performed ano cdditional leaks identified. The licensee.is. presently working on the identified leaks.

In response t'o th'e unmonitored release flok path creat'5d by these types of

event.s, 'the liicensee is proposing to enc 1,ost the PASS system

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equipment.in the.. Intermediate Building with air flow barriers.

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VentiTat. ion + ducrwork will be added with a fan for exhausting the

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enclosed area to the Auxiliary Building filters and radiation l

i monitors. This action is being tracked by a request for e.ngineering l

information (REI 87-03-16-00) for development into a modification package.

The licensee plans to implement this action by December, 1989.

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(Closed) IFI 302/88-11-04:

Review the licensee's corrective action -

for preventing main steam isolation valve closure during procedure SP-343,, Main Steam Isolation Valves Part-Stroke Exercising.

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This item was' previously discussed in NRC Inspection. Report 50-302/88-18.

The licensee has completed modification MAR 88-05-11-01 so that the operator can stop valve motion by simply releasing the test pushbutton.

Procedure SP-343 will be; revised by.

April 1989 to reflect the changes due to this modification.,.

  • Unresolved. items are a matter about 'which more'information is required to

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determine whether: they are acceptable or may involve violations or deviations.

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8.

-ExitInterview(30703)

The inspectors met with licensee representatives (denoted in paragraph 1)

at the c'onclusion of the inspection on February 24, 1989. During this meeting, the inspectors summarized the scope and findings of the inspec-tion as they are detailed in this report with particular emphasis on the.

inspector followup items.

The licensee. representatives 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.

Item Number Description and Reference

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50-302/89-03-01 IFI - Follow the licensee's activities to change TS 3.4.4.c to require an adequate number of pressurizer heaters.

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Acronyms and" Abbreviations i

CCTV - Closed Circuit Television

CFR

- Code of; Federal Regulations

DCN

- Drawing Change Notices I

FCN

- Field Change Notices i

FPC

- Florida Power Corporation FPR

- Field Problem Report

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IFI L Ins'pec' tor Followup Item i

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LER

- Licens'e'e'Ev6nt Report

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MAR

- Mod 4 fica. tion? Approval. Record -

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NCOR - Nonconforming'. Operation Report NRC

- Nuclear Regulatory Commission PM

- Preventive Maintenance RCA

- Radiation Control Area RWP

- Radiation Work Permit SP

- Surveillance Procedure STI

- Short Term Instruction T-MAR - Temporary MAR

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TSC

- Technical _ Support Center TSCR - Technical Specification Change Request TS

- Technical Specification TSIP - Technical Specification Improvement Program UNR

- Unresolved item

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