IR 05000302/2013003
| ML13240A155 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 08/28/2013 |
| From: | Gregory Kolcum NRC/RGN-II/DRP/RPB3 |
| To: | Hobbs T Florida Power Corp |
| References | |
| EA-13-121 IR-13-003 | |
| Download: ML13240A155 (18) | |
Text
UNITED STATES August 28, 2013
SUBJECT:
CRYSTAL RIVER NUCLEAR GENERATING PLANT - NRC INTEGRATED INSPECTION REPORT 05000302/2013003
Dear Mr. Hobbs:
On July 31, 2013, the U.S. Nuclear Regulatory Commission (NRC) completed an inspection at Crystal River Nuclear Generating Plant Unit 3. The enclosed integrated inspection report documents the inspection findings which were discussed on August 12, 2013, with Mr.
Wunderly and other members of your staff.
The inspection examined activities conducted under your license as they relate to safety and compliance with the Commissions rules and regulations and with the conditions of your license.
The inspectors reviewed selected procedures and records, observed activities, and interviewed personnel.
One self-revealing finding of very low safety significance (Green) was identified during this inspection. Although oversight at Crystal River Unit 3 is conducted under the NRCs program for power reactors undergoing decommissioning as described in Inspection Manual Chapter 2561, the finding occurred prior to the plants entry into decommissioning, and was assessed using the reactor oversight process for operating reactors.
This finding was determined to involve a violation of NRC requirements. The NRC is treating this violation as a non-cited violation (NCV) consistent with Section 2.3.2 of the Enforcement Policy.
If you contest the violation or significance of the NCV, you should provide a response within 30 days of the date of this inspection report, with the basis for your denial, to the Nuclear Regulatory Commission, ATTN: Document Control Desk, Washington DC 20555-0001; with copies to the Regional Administrator, Region II and the Director, Office of Enforcement, United States Nuclear Regulatory Commission, Washington, DC 20555-0001. In accordance with 10 CFR 2.390 of the NRCs Rules of Practice, a copy of this letter, its enclosure, and your response (if any) will be available electronically for public inspection in the NRC Public Document Room or from the Publicly Available Records (PARS) component of NRC's Agencywide Document Access and Management System (ADAMS). ADAMS is accessible from the NRC Web site at http://www.nrc.gov/reading-rm/adams.html (the Public Electronic Reading Room).
Sincerely,
/RA/
Gregory J. Kolcum, Acting Chief Reactor Projects Branch 3 Division of Reactor Projects Docket No.: 50-302 License No.: DPR-72
Enclosure:
Inspection Report 05000302/2013003 w/Attachment: Supplemental Information
REGION II==
Docket No.: 50-302 License No.: DPR-72 Report No.: 05000302/2013003 Licensee: Florida Power Corporation Facility: Crystal River Unit 3 Location: Crystal River, FL Dates: April 1, 2013 - July 31, 2013 Inspectors: T. Morrissey, St. Lucie Senior Resident Inspector (1R01)
S. Sandal, Senior Project Engineer (1R05, 4OA2)
D. Lanyi, Operations Engineer (1R11)
W. Pursley, Health Physicist (2RS3)
M. Riches, Project Engineer (4OA3)
J. Montgomery, Reactor Inspector (4OA5)
Approved by: Gregory J. Kolcum, Acting Branch Chief, Reactor Projects Branch 3 Division of Reactor Projects Enclosure
SUMMARY OF FINDINGS
IR 05000302/2013003; 04/01/2013-07/31/2013; Crystal River Unit 3; In-Plant Airborne
Radioactivity Control and Mitigation.
The report covered a four month period of inspection by Region II inspectors. One Green non-cited violation was identified. Although oversight at Crystal River Unit 3 is conducted under the NRCs program for power reactors undergoing decommissioning as described in Inspection Manual Chapter (IMC) 2561, Decommissioning Power Reactor Inspection Program, dated April 14, 2003, the finding occurred prior to the plants entry into decommissioning and was assessed using the reactor oversight process for operating reactors as described in NUREG-1649, Reactor Oversight Process, Revision 4. The significance of the inspection finding was identified by its color (Green, White, Yellow, or Red) and determined using IMC 0609,
Significance Determination Process, (SDP) dated June 2, 2011. All violations are dispositioned in accordance with the NRCs Enforcement Policy dated January 28, 2013.
Cornerstone: Occupational Radiation Safety
- Green.
A self-revealing non-cited violation (NCV) of 10 CFR 20.1701 was identified for the licensees failure to implement process or other engineering controls, to the extent practical, to control the concentration of radioactive materials in air. Specifically, engineering controls described in the as low as reasonably achievable (ALARA) work plan (AWP) #09-026 to control airborne radiation were not used during once through steam generator (OTSG)mirror insulation installation activities on January 26, 2010, and, as a result, two workers became contaminated. The licensee took immediate corrective action to decontaminate the workers and took additional steps to restrict the access of one of the individuals to the Radiological Controlled Area (RCA). The licensee entered the issue into their corrective action program as action request (AR) 378114.
The performance deficiency was more than minor because it was associated with the occupational radiation safety attribute of Program and Process and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. The failure to implement the planned engineering controls in accordance with the AWP resulted in two workers receiving internal intakes and becoming externally contaminated. Using IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the finding was determined to be of very low safety significance (Green) because it did not involve: 1) as low as is reasonably achievable (ALARA)occupational collective exposure planning and controls, 2) an overexposure, 3) a substantial potential for overexposure, or 4) an impaired ability to assess dose. The inspectors determined that the finding was not indicative of current licensee performance and therefore, no cross cutting aspect was associated with this finding. (Section 2RS3)
REPORT DETAILS
Summary of Plant Status:
Crystal River Unit 3 began the inspection period in no mode with the core off-loaded to the spent fuel pool. The unit remained in this condition for the remainder of the inspection period.
On February 20, 2013, Florida Power Corporation, the licensee, certified the cessation of power operations and the permanent removal of fuel from the reactor vessel (Agencywide Documents Access and Management System (ADAMS) Accession No. ML13056A005). The NRC acknowledged the licensees certification of permanent fuel removal by a letter dated March 13, 2013 (ML13058A380). This report documents the results of inspections performed by Region II through July 31, 2013 (ML13135A492). On August 1, 2013, NRC Region I assumed responsibility for implementation of the decommissioning power reactor inspection program at Crystal River Unit 3 (ML13217A088).
REACTOR SAFETY
Cornerstones: Initiating Events, Mitigating Systems, Barrier Integrity
1R01 Adverse Weather Protection
.1 Hurricane Season Preparation
a. Inspection Scope
The inspectors reviewed the licensees hurricane season preparations using the licensees emergency management procedure EM-220, Violent Weather. The inspectors checked that the licensee maintained the ability to protect vital systems and components from high winds and flooding associated with hurricanes. Additionally, the inspectors toured the four plant areas listed below to check for any vulnerabilities, such as inadequate sealing of water tight penetrations, or degraded barriers that could affect the associated systems. The inspectors verified that the licensees violent weather committee had been established and that an initial preparatory walkdown had been completed. Condition reports (CRs) were reviewed to verify that the licensee was identifying and correcting adverse weather protection issues. Documents reviewed are listed in the Attachment.
- auxiliary building sea water room
- control complex, auxiliary, intermediate and turbine buildings flood walls and doors
- engineered safeguards (ES) emergency diesel generator rooms
- 230KV high voltage switchyard
b. Findings
No findings were identified.
.2 External Flooding
a. Inspection Scope
The inspectors performed an inspection of the external flood protection features for Crystal River, Unit 3. The inspectors reviewed the Final Safety Analysis Report (FSAR)
Chapter 2.4.2.4, Facilities Required for Flood Protection, which depicts the design flood levels and protection areas containing safety-related equipment, to identify areas that may be affected by external flooding. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
.3 Offsite and Alternate AC Power System Readiness
a. Inspection Scope
The inspectors evaluated the summer readiness of both the offsite and onsite alternate AC power systems. The inspectors walked down the safety-related emergency diesel generators (EGDG-1A, 1B) and non-safety-related emergency diesel generator (EGDG-1C) to assess their availability during a loss of offsite power event. The inspectors performed a walkdown of the switchyard with plant personnel to verify the material condition of the offsite power sources was adequate. Open work orders (WOs) for the offsite and onsite alternate AC power systems were reviewed to ensure degraded conditions were properly addressed. The inspectors verified that licensee and transmission system operator procedures contained communication protocols addressing the exchange of appropriate information when issues arise that could impact the offsite power system. The inspectors verified that no equipment or operating procedure changes have occurred since the last performance of this inspection that would potentially affect operation or reliability of the offsite or onsite AC power systems.
Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
1R05 Fire Protection
Fire Area Walkdowns
a. Inspection Scope
The inspectors walked down accessible portions of the plant to assess the licensees implementation of the fire protection program. The inspectors checked that the areas were free of transient combustible material and other ignition sources. Also, fire detection and suppression capabilities, fire barriers, and compensatory measures for fire protection problems were verified. The inspectors checked fire suppression and detection equipment to determine whether conditions or deficiencies existed which could impair the function of the equipment. The inspectors selected the areas based on the equipment necessary to support spent fuel pool cooling. The inspectors also reviewed the licensees fire protection program to verify the requirements of Final Safety Analysis Report (FSAR) Section 9.8, Plant Fire Protection Program, were met. Documents reviewed are listed in the Attachment. The inspectors toured the following two areas important to safety:
- train A emergency diesel generator room
- spent fuel pool floor
b. Findings
No findings were identified.
1R11 Licensed Operator Requalification and Performance
Biennial Requalification Activities
a. Inspection Scope
The inspectors reviewed the facility operating history and associated documents in preparation for this inspection. During the week of April 8-9, 2013, the inspectors reviewed documentation and interviewed licensee personnel onsite associated with the licensees operator requalification program. The licensee modified their licensed operator requalification program to reflect a change in its operational status to a plant transitioning into decommissioning. The written examination consisted of 25 questions limited to non-operational activities, such as shutdown cooling, fuel handling, support systems, and associated activities. No operating exam was given. In the conduct of this inspection, the inspectors referenced applicable portions of Inspection Procedure 71111.11, Licensed Operator Requalification Program, as appropriate, considering the non-operational status of the facility. The inspectors assessed the effectiveness of the facility licensee in implementing requalification requirements identified in 10 CFR Part 55, Operators Licenses. The inspectors evaluated the program to determine whether the licensee effectively implemented operator requalification guidelines established in NUREG-1021, Operator Licensing Examination Standards for Power Reactors.
Documentation reviewed included the current written examination, and 2012 Job Performance Measures (JPMs), and simulator scenarios. Additionally, licensee procedures, on-shift records, operator feedback records, licensed operator qualification records, remediation plans, watchstanding records, and medical records were reviewed.
Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
RADIATION SAFETY
Cornerstones: Occupational Radiation Safety and Public Radiation Safety
2RS3 In-Plant Airborne Radioactivity Control and Mitigation
a. Inspection Scope
The NRC staff reviewed the results of the NRC Office of Investigation (OI) case 2-2012-016 which was initiated on March 9, 2012, and completed on May 9, 2013. The NRC reviewed licensee procedures, records, and sworn testimony associated with the case.
The NRC also reviewed the results of the internal dose investigations that were associated with this event. Although Crystal River Unit 3 transitioned out of the Reactor Oversight Process (ROP) in February 2013 as a result of the licensees decision to decommission the facility, the NRC staffs review of the OI case resulted in a finding that occurred while Crystal River was still being assessed under the ROP. That finding is documented below.
b. Findings
Introduction:
A Green self-revealing non-cited violation (NCV) of 10 CFR 20.1701 was identified for the licensees failure to implement process or other engineering controls, to the extent practical, to control the concentration of radioactive materials in air.
Specifically, engineering controls described in the as low as reasonably achievable (ALARA) work plan (AWP) #09-026 to control airborne radiation were not used during once through steam generator (OTSG) mirror insulation installation activities and two workers became contaminated.
Description:
One of the job tasks associated with the Crystal River 3 OTSG replacement project was to install mirror insulation on the new OTSGs. The new insulation was not contaminated; however some older contaminated pieces of insulation were used to complete the work. AWP #09-026, SGR Remove - Install Insulation, required engineering controls, radiation protection coverage, and air sampling requirements to be evaluated and established prior to handling contaminated insulation. The AWP also included provisions to ensure the most highly contaminated insulation was bagged and a temporary enclosure with high efficiency particulate air (HEPA) engineering controls was established in containment for working with contaminated insulation. Mirror insulation has inaccessible surfaces that cannot be readily surveyed yet can contribute to unexpected airborne radioactivity if not handled properly. For this reason, the AWP also required daily job briefings to ensure that the Health Physics (HP) department understood the scope of the work to be performed and to maintain a high level of worker awareness when handling contaminated insulation.
On January 26, 2010, a contractor foreman began installation of contaminated insulation on OTSG piping inside containment without notifying HP of his actions. Consequently, HEPA ventilation, temporary enclosures, and appropriate air sampling controls were not implemented. The manner in which the mirror insulation was handled created airborne radioactive material which contaminated the foreman and a worker. Both workers received a small intake which correlated to an internal dose of less than 2 mrem for each individual. The issue was documented in the licensees corrective action program as action request (AR) 378114. Corrective actions included decontaminating the workers and restricting the foremans access to the radiological controlled area (RCA). Due to the difficulty associated with assessing contamination levels within mirror insulation, the inspectors concluded that the low internal dose received by the workers was fortuitous.
Analysis:
The failure to implement engineering controls to mitigate airborne radioactivity as described in the AWP was a performance deficiency. The performance deficiency was more than minor because it was associated with the occupational radiation safety attribute of Program and Process and adversely affected the cornerstone objective to ensure the adequate protection of the worker health and safety from exposure to radiation from radioactive material during routine civilian nuclear reactor operation. The failure to implement the planned engineering controls in accordance with the SWP resulted in two workers receiving internal intakes and becoming externally contaminated.
Using IMC 0609, Appendix C, Occupational Radiation Safety Significance Determination Process, the finding was determined to be of very low safety significance (Green)because it did not involve: 1) as low as is reasonably achievable (ALARA) occupational collective exposure planning and controls; 2) an overexposure; 3) a substantial potential for overexposure; or 4) an impaired ability to assess dose. The inspectors determined that the finding was not indicative of current licensee performance and therefore, no cross cutting aspect was associated with this finding.
Enforcement:
10 CFR 20.1701 requires the use of process or other engineering controls, to the extent practical, to control the concentration of radioactive materials in air. Contrary to this requirement, on January 26, 2010, the licensee did not use, to the extent practical, process or other engineering controls to control the concentration of radioactive materials in air during the installation of insulation on the OTSG. Because the failure to use process or other engineering controls to minimize airborne radioactivity was determined to be of very low safety significance (Green) and was entered into the licensee's corrective action program as AR 378114, this violation is being treated as an non-cited violation consistent with Section 2.3.2 of the Enforcement Policy (NCV 05000302/2013003-01 Failure to Use Process or Engineering Controls to Control Airborne Radioactivity).
OTHER ACTIVITIES
4OA2 Problem Identification and Resolution
Daily Review
a. Inspection Scope
As required by Inspection Procedure 71152, Identification and Resolution of Problems, and in order to help identify equipment failures or specific human performance issues for follow-up, the inspectors performed a screening of items entered into the licensees corrective action program (CAP). This review was accomplished by attending plant status meetings during onsite inspections and reviewing entries in the licensees computerized database. Documents reviewed are listed in the Attachment.
b. Findings
No findings were identified.
4OA3 Event Follow-up
.1 (Closed) Licensee Event Report (LER) 50-302/2013-001-00, Valid Actuation of
Emergency Diesel Generator Due to a Spurious Fault on a Breaker Non-segregated Bus Duct On June 1, 2013, Crystal River Unit 3 was in no mode with fuel permanently removed from the reactor vessel when a spurious fault above breaker 3104 (startup transformer feed to the B unit 6.9 kV non-segregated bus) occurred. Protective relays de-energized the startup transformer and the backup engineered safeguards transformer which resulted in a loss of offsite power to the 3B 4160V safeguards bus. The B emergency diesel generator automatically started and re-energized 3B 4160V bus. The licensee entered the event into the corrective action program as condition report 609671 and initiated a root cause analysis.
The licensees root cause analysis determined that the electrical fault was due to the lack of a preventive maintenance (PM) task to inspect the internal penetration seals on the bus duct. Post-failure visual inspections revealed that seal material was missing at the seal plate penetrations which allowed moisture to accumulate on the surface of the seal plate around the bus bars. A contributing cause was determined to be the flow of cooling air directed towards the bus duct which increased the likelihood of formation of condensation inside the duct. As part of the root cause investigation, the licensee conducted a review of the vendors service manual and determined that the vendor did not include periodic inspections of the seal plate penetrations as part of their maintenance recommendations. Corrective actions by the licensee included revising the PM procedures to include periodic inspection of the penetration seals on the bus ducts.
The licensee also planned an extent of cause evaluation to determine if deficiencies in seal material at the penetrations on similar bus ducts exist and to make repairs as necessary. The inspectors reviewed the LER and the licensees root cause evaluation to gain a better understanding of the circumstances which led to the electrical fault inside the bus duct. The inspectors evaluated the accuracy of the information submitted in the LER and potential generic implications related to the event. Additionally, the inspectors evaluated the licensees corrective actions to determine if the actions appropriately addressed the causes that were identified in the licensees root cause evaluation. No findings were identified. The LER is closed.
4OA5 Other Activities
.1 Inspector Observations of Security Personnel Activities
a. Inspection Scope
During the inspection period, the inspectors conducted observations of security force personnel and activities to ensure the activities were consistent with licensee security procedures and regulatory requirements relating to nuclear plant security.
These inspector observations of security force personnel and activities did not constitute any additional inspection samples. Rather, they were considered an integral part of the inspectors normal plant status reviews and inspection activities.
b. Finding No findings were identified.
.2 (Closed) Unresolved Item (URI)05000302/2004009-03, Unapproved Local Manual
Operator Actions Instead of Required Physical Protection or Separation of Cables to Preclude Fire Damage
a. Inspection Scope
During an NRC Triennial Fire Protection Inspection (TFPI), as documented in NRC Inspection Report 05000302/2004009 (ADAMS ML050740113), inspectors discovered cables for redundant safe shutdown trains located in the same fire areas that had not been protected from potential fire damage by one of the methods specified in 10 CFR Part 50, Appendix R, Section III.G.2. Inspectors began performing an in-office review of the licensees fire protection program licensing documents, design basis documents, and plant procedures to determine if a performance deficiency existed. Inspectors also began reviewing corrective actions taken by the licensee to determine if they were adequate. Inspectors reviewed this finding against NRC enforcement guidance documents to determine to what extent enforcement discretion was applicable. Prior to the completion of this review, the licensee informed the NRC of their intention to decommission the reactor. Based on discussions with regional management and technical staff at the NRC Office of Nuclear Reactor Regulation (NRR), the NRC determined that the plants change in operating status alleviated the technical concern associated with this URI. This URI is closed.
b. Finding No findings were identified.
4OA6 Exit
Exit Meeting Summary
On August 12, 2013, the inspection results were presented to Mr. Blair Wunderly, Crystal River Unit 3 Plant Manager, and other members of licensees staff. The inspectors confirmed that proprietary information was not provided or examined during the inspection.
ATTACHMENT:
SUPPLEMENTAL INFORMATION
KEY POINTS OF CONTACT
Licensee personnel
- B. Akins, Radiation Protection and Chemistry Manager
- C. Bergstrom, Emergency Preparedness Supervisor
- S. Bowden, Performance Support Supervisor
- J. Connor, Engineering Manager
- P. Dixon, Decommissioning Support Manager
- T. Hobbs, Decommissioning Director
- J. Huegel, Maintenance Manager
- G. McCallum, Operations Manager
- D. Westcott, Licensing Supervisor
- B. Wunderly, Plant Manager
NRC personnel
- D. Rich, Branch Chief, Division of Reactor Projects
LIST OF ITEMS OPENED, CLOSED, AND DISCUSSED
Opened and Closed
- 05000302/2013003-01 NCV Failure to Use Process or Engineering Controls to Control Airborne Radioactivity (Section 2RS3)
Closed
- 05000302/2004009-03 URI Unapproved Local Manual Operator Actions Instead of Required Physical Protection or Separation of Cables to Preclude Fire Damage (Section 4OA5.2)
- 05000302/2013001-00 LER Valid Actuation of Emergency Diesel Generator Due to a Spurious Fault on a Breaker Non-segregated Bus Duct (Section 4OA3.1)
Discussed
None