ML20127J590
| ML20127J590 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 04/22/1985 |
| From: | Panciera V, Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20127J582 | List: |
| References | |
| 50-302-85-11, NUDOCS 8505210522 | |
| Download: ML20127J590 (11) | |
See also: IR 05000302/1985011
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' UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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101 MARIETTA STREET.N.W.
ATLANTA, CEORGI A 30323
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APR 2 31985
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Report N'o.:
50-302/85-11
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.1-29, 1985
Inspection at Crystal River site near C'r stal River, Florida
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Inspector:
Na
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T. F. StetRa,--Suhior Rep 5ent Jfriipector
Date' Signed
Accompanying P rsonne h:
E. Tedrow, Resident Inspector
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Approved by:
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V. W. PanEier'a, Ch'lel,~P~roject Section 28,
D&te Sighed
Division of_ Reactor Projects
SUMMARY
Scope:
This routine inspection -involved 130 -inspector-hours on site by two
resident inspectors in the areas of plant operations, security, radiological
controls, Licensee Event Reports and Nonconforming Operations Reports, refueling-
preparations, 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: One violation was identified:
(Failure to have an adequate adminis-
trative procedure for procedure review and approval, paragraph 5.b).
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ADOCK 05000302
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REPORT DETAILS
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Persons ~ Contacted
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Licensee Employees-
- D.-Bates, Quality Engineer
- *D.~ Betts, Supervisor, Quality Audits
LG.. Boldt,-Nuclear Plant Operations Manager
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- R. Bright,tManager,' Nuclear Licensing
C. Brown, As'sistant Nuclear Outage.and Modifications Manager
- J. Buckner,~ Nuclear Security-and Special Projects
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- J. Bufe, Nuclear. Compliance Specialist
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- W. Clemons, Nuclear Compliance Specialist
- J. Colby, Manager, Site Nuclear. 0perations Engineering
L*J. Cooper Jr., Manager, Site Nuclear Quality Control
- R._Dorrie, Quality Engineer
1*J.. Frijouf; Acting Nuclsar Compliance Specialist
- R. Fuller, Supervisor Radiological-Support Services
- D. Green, Nuclear Licensing Specialist
'M. Harmon,-Nuclear Operations-Administrative Manager-
- G.;Hebb, Nuclear Shift Supervisor-
E. Howard, Director,. Site Nuclear Operations _
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- W. Johnson, Nuclear-Plant Engineering Superintendent
- B.:Komara, Nuclear Quality Control. Supervisor
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- D. Kurtz, Sr., Nuclear Quality Assurance' Specialist
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- K. Lancaster, Manager, Site Nuclear Quality Assurance
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- J.1 Lander,' Nuclear Outage and Modiciations Manager
- M.-Mann, Nuclear Compliance Specialist
P. McKee,' Nuclear Plant Manager.
- P. Patel,-Supervisor, Nuclear Quality Engineering-(GOC)
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- E.~ Renfro,-Director, Nuclear Operations Materials and Controls
- V.-Roppel, Nuclear Plant Engineering Technical Services, Manager
- P.'Skramstad, Nuclear Chemistry and Radiation: Protection Superintendent
(*R. Smith, Nuclear Principal Mechanical / Structural' Engineer
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- J.1Telford, Director, Quality. Programs
- D..Visser, Material Technology
- K. Wilson,, Supervisor, Site Nuclear Licensing
- J. Wright, Nuclear' Support Specialist Chem / Rad. Prot. Services
Oth'er _ licensee employees contacted included office, operations, engineering,'
maintenance, chem / rad and corporate personnel.
- Attended exit interview
2. . ' Exit' Interview
.The inspectors met with licensee representatives (denoted in paragraph 1) at.
the conclusion of the inspection on March 29, 1985. During this meeting,
the inspectors summarized the scope and findings of the inspection as they
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are detailed in this report with - particular emphasis placed on the.
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. violation, unresolved items, and inspector followup items. Alsolduring this
-meeting, the inspectors expressed concern over an increase in.the number of'
1 Nonconforming Operating Reports (NCORs) relatiri to procedure adherence.
There appears to be an increasing trend of per onnel failing to follow
procedures as . evidenced by the increasing number of NCOR's per month
relating to this issue. -The licensee was reminded of the NRC's position
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regarding licensee identified violations, .specifically relating to the
requirement that adequate corrective actions.- must be taken to prevent
recurrence.
The -inspectors also discussed the use of outdated procedure
indexes. While there is no specific requirement'regarding these indexes, it
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appears that good practice would dictate use of current indexes. It appears
that current _ procedure . indexes are. available and that appropriate coor-
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dination between departments could ensure their distribution and use.
The. licensee representatives acknowledged the inspectors' comments .and
stated they would review these issues for appropriate corrective actions.
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The . licensee did not identify as proprietary any of the materials provided
to or reviewed by the inspectors during this inspection.
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3.
Licensee Action on- Previous Enforcement Matters-
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(Closed) Inspector Followup Item (302/85-08-03):
The licensee -has cali-
bration . checked . the instruments identified in Nonconforming. Operations
Report (NCOR) 85-26 and has evaluated the effect of out of calibration
. instruments upon system operability.
The . inspector has reviewed ,the
completed calibration data . and evaluated the . licensee's operability
determination-and has no further questions on this item.
.(Closed) Violation (302/84-22-01):
On August 1,
1984, .the licensee
. issued a Short Term Instruction that directed operators to' review the
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- calibration date of the digital voltmeter (DVM) prior to the instruments'
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use.
Subseouently, procedure SP-317, the Reactor Coolant . System leakage
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-determination procedure, was revised to require the recording of the DVM.
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calibration due date and the instrument number if the DVM is utilized during
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the surveillance test. Review of these changes and observation of subsequent.
performances of SP-317 by the inspectors indicate that these changes appear
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. to be effective to prevent recurrence of this event.
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(Closed) Violation (302/84-22-02): The license'e revised procedure SP-381,
which ~-is used 'to verify the position and -locking device status on locked
valves, to require that the locking device be verified by " physical grasping
the . lock and attempting to open it by shaki ng" .
It appears that this
revision will be adequate to ensure that locking devices are properly
established.
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-(Closed) Inspector Followup Item (302/82-22-04):
The licensee has
~ determined that the revision to OP-407M, Operation of the Concentrated Waste
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Storage Tanks, was inappropriate to prevent recurrence of this event. The
licensee has instead revised surveillance procedures SP-300 and SP-301,
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which direct shiftly duties of plant operators, to include a check that the
tank loop seals are filled.
In addition, the loop seals were marked to
' assist the operators in determinirg that the loop seal levels are appro-
priate.
(Closed) Inspector Followup Item (302/83-16-01):
Procedure SP-179,
Containment Leakage Test - Types "B" and "C", was revised to include minimum
times and maximum expected flow rates to ensure measurement of a stable leak
rate.
(Closed)_ Inspector Followup Item (302/83-29-02):
Procedure SP-320,
Operability of Boron Injection Sources and Pumps, was revised to include a
note to ensure that heat tracing temperature readings are taken under static
flow conditions.
(Closed) Unresolved Item (302/83-11-04): Procedure SP-179 has been revised
to provide a proper vent path while testing core' flood system valves CFV-26
and CFV-27.
(Closed) Unresolved Item (302/83-11-05): Procedure SP-179 has been revised
to ensure that all valves required to be operated to perform a test are
included in the applicable equipment clearance.
The inspector's sampling
review of _various valve lineups in SP-179 indicates that the procedure
revision accomplishes this task.
(Closed) Unresolved Item (302/83-11-06): Procedure SP-179 has been revised
to require removal of the air charging line to ensure test results' are not
. invalidated by air leakage past the air charging line isolation valve.
(0 pen) Unresolved Item (302/83-11-03):
Procedure SP-179 has been revised
to clarify that valve lineups for a local leak rate test may be changed by a
qualified leak rate examiner and that such changes are documented, however
the change also allows a test method change by the test engineer. When this
was discussed with licensee representatives, the representatives stated that
a test method change by the test engineer was not intended and that the
procedure would- be immediately revised.
This item remains open pending
revision of the procedure.
(0 pen) Deviation (302/84-26-01): The licensee has completed the procedure
changes to procedures SP-112 and SP-113 as stated in their response dated
January 25, 1985. In addition, most of the changes to the tracking system
have been made except for the implementation of the Nuclear Operations
Policy. As stated in the response letter, these changes will be implemented
by May 1,1985. 'This item remains open pending completion of the Nuclear
Operations Policy changes.
(0 pen) Inspector Followup Item (302/83-30-02): The licensee has completed
re-training of qualified reviewers and has reduced the number of the
-reviewers, however a finalized list of qualified reviewers is not complete.
This list will be available by April 30, 1985.
This item , remains open
pending completion of this list.
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4. . . Unresolved Items,
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. Unresolved- items. are matters about which more information is required -to
determine whether.they are acceptable.or may involve violations or deviations.
A:new1 unresolved 11 tem identified during this inspection is discussed in
paragraph-5.c of. this report.
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Review of. Plant Operations
The plant was in power. operation (Mode 1) at the beginning of th'is inspection'
period.' At 0020 on March 9,1985, the plant .was shutdown in support of
an extensive refueling and plant modification outage. The plant entered
cold shutdown' (Mode 5) at 0210 on March 11 and the refueling. mode- (Mode 6)
at 0855'on: March 20 where 'it remained for the duration of this inspection
period-.
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.During review of . procedure OP-209, Plant Cooldown, conducted on
March 9, 1985, the inspector noted .that : step 6.2.15 was not1 accom-
plished. Step 6.2.15 requires Core Flood Valves 5 and 6 (CFV-5, CFV-6)
to _be closed and breakers red tagged in .the " Locked Reset" position
when Reactor Coolant System pressure. decreases to 700 psig or less.
Valves CFV-5 and CFV-6 were left open to allow the Core Flood Tanks-
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. (CFT) to' discharge tocthe reactor vessel to permit maintenance ~ to be
. performed on the CFT's at a later time'.
This change to . procedure
OP-209 was implemented byLthe operator initialling the step and provid -
ing a' footnote at-the bottom of the page which' detailed the reason.for
the change. Making-a procedure change in this manner is contrary to
-the requirements of TS 6.8.3 and is considered to be a_ violation. This
TS allows temporary changes to be made to procedures .but requires the
change to be made by two members of the plant management staff at least
one of whom holds.a senior . reactor operator license.
The -licensee was issued;a similar violation against TS 6.8.3 in NRC
Report 50-302/85-08. Since this report covered inspection activities
for the month of February 1985, there- has been insufficient time for-
licensee. response. Therefore, this' violation will'not be cited in~this
report but is considered to be another example of violation:50-302/85-08-07.
This violation was discussed in-the Exit Meeting conducted on March-29, 1985.
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-The licensee will address their corrective actions to this violation
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concurrently with their response to violation 50-302/85-08-07.
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b.
During: further review of OP-209, the inspectors noted that the
! Qualified Reviewers Check-off Sheet (enclosure (5) to procedure AI-401,
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Origination of and Revisions to P0QAM Procedures) attached ~to a change-
to _0P-209 was only reviewed by operations department personnel. This
change method was in accordance with AI-401, Section 4.3.4.
requires procedure changes. to be reviewed by intradepartmental
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qualified reviewers
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in the same department) and inter-
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departmental qualified reviewers in interfacing departments.
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review cycle assures that procedures and procedure changes receive
interdisciplinary review.
Failure of procedure AI-401 to require the interdepartmental review is
contrary to the requirements of TS _6.8.2, represents an inadequate
procedure as required by TS 6.8.1, and is considered to be a violation.
Violation (302/85-11-01):
Failure to have an adequate administrative
procedure for the review and approval of plant procedures.
c.
During a review of the Operations Section Implementation Manual (OSIM)
that is used to direct plant operations, the inspectors noted that
Section VI, paragraph B.1.3 allows a procedure to be changed through
the use of an equipment clearance (system tagout).
This method of
procedure change is contrary to the review and approval requirements
for procedure changes as delineated in - TS 6.8.2 and 6.8.3.
This
finding was discussed with licensee representatives who stated that the
-intent of paragraph B.1.3 was not to circumvent the TS requirements but
was to' allow flexibility during plant evolutions.
The inspector acknowledged the licensee's position of flexibility
during plant evolutions, however the use of the equipment clearance as
stated in B.1.3 of the OSIM could result in changes that are contrary
to the TS. It appears that a clarification of OSIM paragraph B.1.3 is
in order to assure that equipment clearances address the specific
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evolution involved and are not used as a procedure change medium.
The licensee will review this OSIM section and make appropriate
clarification to assure that the TS review process is not circumvented.
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Unresolved Item (302/85-11-02):
Review the licensee's activity to
clarify the use of equipment clearances as delineated in OSIM
section VI, paragraph B.1.3.
(1) Shift Logs and Facility Records
The inspector reviewed records and discussed various entries with
operations personnel to verify compliance with the Technical
Specifications (TS) and the licensee's administrative procedures.
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The following records were reviewed:
Shift Supervisor's Log; Reactor Operator's Log; Equipment
Out-of-Service Log; Shift Relief Checklist; Aux 11ary Building
Operator's Log; Active Clearance Log; Daily Operating
Surveillance Log; Work Request Log; Short Term Instructions
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(STIs); Selected chemistry / Radiation Protection Logs; and
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Outage Shift Manager's Log.
In addition to these record reviews, the inspector independently
verified clearance order tagouts.
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No violations or deviations were identified.
(2) Facility Tours and Observations
Throughout the inspection period,. facility tours were conducted to
observe operations and maintanence activities in progress. - Some
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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.
The facility tours and observations encompassed the following
areas:
security perimeter fence; control room; emergency diesel
generator room; audiliary building; intermediate building; battery
rooms; electrical switchgear rooms; and reactor building.
During these tours, the following observations were made:
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(a) 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.
No violations or deviations were identified.
(b) -Safety Systems Walkdown - The inspector conducted a walkdown
of- the core flood and spent fuel . systems to verify that the
lineups were in accordance with licensee requirements for
system operability and that system drawings and procedures
correctly reflect "as-built" plant conditions.
No' violations or deviations were identified.
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(c) Shift Staffing - The inspector verified that operating shift
staffing was in accordance with TS requirements and that
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control room operations were being conducted in an orderly
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and professional manner. 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 turnovers.
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No violations or deviations were identified.
(d) Plant Housekeeping Conditions
Storage of material and
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components and cleanliness conditions of various areas
throughout the facility were observed to determine whether
safety and/or fire hazards existed.
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No violations or deviations were identified.
(e) Radiation Areas - Radiation Control Areas (RCAs) were
observed to verify proper identification and implementation.
These observations 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 personnel use of protective clothing respirators,
and personnel monitoring devices to assure that the-
licensee's radiation monitoring policies were being followed.
No violations or deviations were identified.
(f) Security Control - Security controls were observed to verify
that security barriers are intact, guard forces are on duty,
and access to the Protected Area (PA) is controlled in
accordance with the facility security plan. Personnel within
the PA were observed to ensure proper display of badges 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.
(g)
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 operable.
No violations or deviations were identified.
(h) 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, as required,
were utilized; and TS requirements were followed.
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The following tests were observed and/or data reviewed:
SP-163, Waste Gas H/0 Analyzer Channel Functional
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Test and Channel Calibration;
SP-169, Plant Safety-Related Instruments Calibration;
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SP-190, Channel Functional and Circuitry Operability of
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Fire Detection Instrumentation;
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SP-210, ASME Class 3 Hydrostatic Testing;
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SP-301, Shutdown Daily Surveillance Log;
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SP-317, RC System Water Inventory Balance;
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'SP-406, Refueling Operations Daily Data Requirements;
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SP-421, Reactivity Balance Calculations;
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SP-422, RC System Heatup and Cooldown Surveillance; and,
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SP-601, Procedure .for Load Testing Slings and ' Lifting
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Fixtures.
(1) During review of shutdown margin calculations performed
in accordance with procedure SP-421 the inspector was:
unable to calculate Xenon reactivity because the'
licensee failed to retain the computer generated data
sheets. . Xenon reactivity is calculated using a computer
program based on the previous . power history of the
plant. After these calculations are printed. out, _the
data ~is transferred to Worksheet I of SP-421 and the
computer calculations ' are discarded.
After a consi--
- derable . effort by the licensee, the ' inspector was able
to verify the Xenon reactivity -from ,a- licensee
reproduced computer calculation based on the same power
history. The-licenseeLissued a Short Term Instruction
(STI) as a temporary fix to retain the computer data
sheets. As a long term :fix the licensee is revising
procedure SP-421 -to require retention of the computer
calculation data sheets.
Inspector Followup Item (302/85-11-03): Review revision
to SP-421. to retain -Xenon reactivity computer data
sheets.
(2) - On March 7,1985, the inspector observed 'a hydrostatic
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test of the Spent Fuel (SF)-System 'in accordance ~with
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procedure SP-210.
During the test, the inspector
notified a' packing leak on Spent Fuel Valve 20 (SFV-20).
The licensee has issued a work request to repack SFV-20
which requires the SF system to .be drained down after
refueling operations are complete.
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Inspector Followup Item (302/85-11-04):
Review the
licensee's repair to the packing leak on SFV-20.
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(1) Maintenance Activities - The inspector observed maintenance
activities to verify that correct equipment clearances were
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in effect; Work' Requests and Fire Prevention Work Permits, as
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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:
Setting Emergency Diesel Generator 3A (EDG-3A) start
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relays in accordance with modification MAR-2A-82-
04-23-01;
Repair of Exhaust Manifold Leak on EDG-3A; and,
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Troubleshooting and repair of source range nuclear
Instrument #2 (NI-2).
No violations or deviations were identified.
(j) Radioactive Waste Controls - Solid Waste Compacting
operations and selected liquid 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.
(k) 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 binding.
No violations or deviations were identified.
6.
Review of Nonconforming Operations Reports
- 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 onforcement
policy.
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No violations or deviations were identified.
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7.
Preparations for Refueling
The . inspector. reviewed refueling procedures to verify that approved
procedures were available and were technically adequate. to cover fuel
ihandling, fuel transfers, inspection of fuel to be reused, handling and-
' inspection of - core internals and core- verification.
The inspector also
observed the receipt, inspection and storage of_ new fuel elements to verify
that these . activities were conducted in accordance -with the approved
procedures-and that any deficiencies were appropriately resolved.
'The'fo11owing procedures were reviewed:
FP-203, Defueling and Refueling Operations;
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FP-302, New Fuel Assembly Unloading Inspection Storage and Container
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Reclosing;
FP-304, Receiving new fuel;
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FP-501, Reactor Internal Removal and Replacement;
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FP-601, Fuel Handling Equipment, Operations;
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FP-602, Irradiated fuel assembly inspection;
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-FP-801, Failed fuel identification; and,
FP-1001, Spent fuel handling.
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No violations or d'eviations were' identified.
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