ML20132F792

Insp Rept 50-302/84-33 on 841110-1220.Violation Noted: Failure to Isolate Waste Gas Decay Tanks A,B & C While Reducing Oxygen Concentration

ML20132F792
Person / Time
Site:	Crystal River
Issue date:	01/28/1985
From:	Panciera V, Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20132F777	List: ML20132F774 ML20132F786 ML20132F792
References
50-302-84-33, NUDOCS 8507190042
Download: ML20132F792 (10)

See also: IR 05000302/1984033

Text

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UNITED STATES

[ACrov o NUCLEAR REGULATORY COMMISSION

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Report No.: 50-302/84-33

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 Dates: November 10, 1984 - December 20, 1984

Inspection at Crystal River site near Crystal River, Florida

-Inspector: / W -

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T.F.SteTka,SeniorRe[engnspector Date Signed

Accompanying Personne . J. E. Tedrow, Resident Inspector

Approved by: [ n ..,, n rA

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V. W. Pancitra, Sectibn CTiief 7 Date' Signed

. Division of Reactor Projects

SUMMARY

Scope: This routine inspection involved 63 inspector-hours on site by one

resident. inspector in the areas of plant operations, security, radiological

controls, _ Licensee Event Reports and Nonconforming Operations Reports, . 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 isolate waste gas decay tank .

while reducing oxygen concentration, paragraph 5.a.(1)).

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8507190042 850131

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• C. Bennett, Nuclear Operations Planning Supervisor

• G. Boldt, Nuclear Plant Operations Manager

• R. Carbiener, Nuclear Compliance Specialist

• R. Clarke, Radiation Protection Manager

• W. Clemons, Nuclear Compliance Specialist

• M. Culver, Senior Nuclear Reactor Specialist

• C. Davis, Health Physics Technician

• D. Fields, Nuclear Reliability Supervisor

• R. Fuller, Manager Site Nuclear Services

• D. Green, Nuclear Licensing Specialist

• E. Howard, Director, Site Nuclear Operations

• A. Kazemfar, ALARA Specialist

• J. Kralker, Nuclear Operations Specialist

• W. Lagger, Contract Health Physics Technician

D. McCollough, Nuclear Chemistry Supervisor

P. McKee, Nuclear Plant Manager

• V.~Roppel, Nuclear Plant Engineering and Technical Services Manager

• W. Rossfeld, Nuclear Compliance Manager

• P. Skramstad, Nuclear Chemistry and Radiation Protection Superintendent

• D. Smith, Nuclear Maintenance Superintendent

• W. Thomas, Chief Nuclear Chemistry Technician

• R. Tyrie, Assistant Nuclear Operator

• J. Wright, Nuclear Support Specialist Chem / Rad Protection Services

Other personnel contacted included office, operations, engineering, main-

tenance, chem / rad and corporate personnel.

" Attended exit interview

2. Exit Interview

The inspector met with licensee representatives (denoted in paragraph 1) at

the conclusion of the inspection on December 20, 1984. During this meeting,

the inspector summarized the scope and findings of the inspection as they

are detailed in this report with particular emphasis placed on the viola-

tion, unresolved item, and inspector followup items. Also during this

meeting the following items were discussed:

a. During a review of completed 'ata for surveillance procedure SP-317 (RC

System Water Inventory Balance) performed on November 11, December 10,

December 14, and December 17, the inspector identified mathematical

errors in the calculation of the leak rate determination. While these

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errors were insignificant and did not result in any limit being

exceeded, the possibility of larger errors exist. These findings

indicate that careful supervisory review of data results are necessary,

b. During the walkdown of the Emergency Diesel Generator systems, the

inspector determined that the drawing of the diesel water jacket

cooling system (drawing number 302-283) was missing identification

tags.

The licensee representatives acknowledged the inspector's comments and

stated that they would review these issues for appropriate corrective

actions.

3. Licensee Action on Previous Inspection Items

Not inspected.

4. Unresolved Items

An unresolved item is a matter about which more information is required to

determine whether it is acceptable or may involve a violation or deviation.

A new unresolved item identified during this inspection is discussed in

paragraph 5.a.(2)(a) of this report.

5. Review of Plant Operations

At the beginning of this inspection period the plant was in hot standby

(Mode 3) preparing to return to power operation (Mode 1). The plant entered

the startup mode (Mode 2) at 10:35 a.m. , and returned to power operation at

12:00 noon on November 10. The plant continued in power operation for the

remainder of this inspection period.

a. Shift Logs and Facility Records

The inspector reviewed records and discussed various entries with

operations personnel to verify compliance with the Technical

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

The following records were reviewed:

Shift Supervisor's Log; Reactor Operator's Log; Equipment Out-of-

Service Log; Shift Relief Checklist; Auxiliary Building Operator's

Log; Active Clearance Log; Daily Operating Surveillance Log; Work

Request Log; Short Term Instructions (STIs); and selected Chemistry /

, Radiation Protection Logs.

In addition to these record reviews, the inspector independently

! verified clearance order tagouts.

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

(1) During a review of the plant records, the inspector noted con-

tinuing efforts to reduce the oxygen concentration in the waste

gas ' decay tanks (WGDTs) due to high (greater than 4%) hydrogen

(H2 ) concentrations. TS 3.7.13.5 requires the oxygen (0 2) con--

centration to be maintained -less than or equal to 2% when the H 2

concentration is greater .than or equal to 4%. Action statement

3.7.13.5.a of this fTS requires that _if the 2H concentration is

greater than or equal to 4% and the 0 2 concentration is greater

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than .or equal to 2%, then .the 02concentration must be reduced to

within specification without delay. If these limits are exceeded,

i.e., the 0 2concentration increases such that the concentration

is greater than or equal to 4%, then TS Action Statement

3.7.13.5.b requires that waste gas addition to the affected tank

must be suspended and the 0 2 concentration must be reduced to

'within specification without delay.

The sequence of events (as excerpted from various plant logs) was

as follows:

Date Time Description

12/12 1530 WGDT "B" H2 - 5.6%, 0 2- 3.9%; enter TS 3.7.13.5.a.

12/13 0330 WGDT "B" H2 - 6.4%, 0 2- 4.75%; enter-TS 3.7.13.5.b.

1430 WGDT "B" isolated due to 75 psig pressure, placed

'WGDT "C" in service.

12/14. 0030 WGDT "C" H2 and 0 2out of specification, enter TS 3.7.13.5.a.

0600 WGDTs "C" and "A" H2 and 0 2greater than 4%, enter

TS 3. 7.13. 5. b. (WGDT "C" H - 4.4%, 0 2 -

4.5%;

WGDT "A" H2 - 5.1%, 02 -4.5k).

0735 Placed WGDT "A" in service (WGDT "C" was secured at

this time).

0825 All WGDTs secured from service.

During the period from 1530 on 12/12 until 1430 on 12/13 for WGDT

"B" and from 1430 on 12/13 until 0735 on 12/14 for WGDT "C" the

licensee .was attempting to reduce the 20 concentration in these

tanks by adding nitrogen (N 2). The N2 was being added via the

waste gas header. As long as the tanks are connected (via open

valves) to the waste gas header, both N2 and waste gas additions

were being made - to the tanks. The WGDT "B" was secured from the

waste gas header when its pressure limit (75 psig) was reached.

At 0735 on 12/14.when WGDT "A" was placed in service, the tank was

still out of specification. The licensee was hoping to be able to

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reduce this tank to within specification via the waste gas header

because this tank had the lowest waste gas amount. The licensee

failed to take any action to develop an alternate means of adding

N2 to the tanks while they were secured from the waste gas header.

After several discussions with the NRC inspector, the licensee

developed a method to reduce the 02 concentration while the tanks

were isolated from the waste gas header. This method was imple-

mented at 2255 on 12/14 and both the "A" and "C" tank were

released, the residual gas in the tank was brought into specifi-

cation at 2100 on 12/16.

Failure to secure the addition of waste gas into the WGDTs and to

provide a timely reduction of the 0 2concentrations is contrary to

the requirement of TS 3.7.13.5.b and is considered to be a

violation.

Violation (302/84-33-01): Failire to secure waste gas addition

and provide a timely reduction of oxygen concentration to the

WGDTs as required by TS 3.7.13.5.b.

(2) STI 84-98 directed operators to ensure that boron additions to the

reactor coolant system be conducted near the requirements of plant

curve 3.20, Boron for Shutdown Margin Versus Cycle Lifetime,

(i.e. , do not add more boron than is necessary) since fuel deple-

tion was greater than predicted and curve 3.20 was excessively

conservative.

Review of this issue identified the following items:

(a) The reactivity worth vs. effective full power days (EFPD)

cuave has the actual fuel depletion rate deviating from the

predicted fuel depletion rate by an amount greater than

expected. This curve is utilized to determine the overall

core reactivity balance.

TS 4.1.1.1.1.2 requires the overall core reactivity balance

be determined every 31 EFPD by comparing actual values to

predicted values and allows the values to be adjusted

(normalized) to actual core conditions prior to exceeding 60

EFPD.

Discussions with the licensee indicate that no such adjust-

ments were made prior to 60 EFPD, but that some adjustments

may have been made subsequent to 60 EFPD. Adjustments

subsequent to 60 EFPD are not permitted by the TS. The

licensee will review records to determine if any overall

reactivity balance adjustments were made for this cycle or

any previous cycles subsequent to 60 EFPD for the operating

cycle.

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Unresolved Item (302/84-33-02): Review overall reactivity

balance adjustments to determine if any adjustments were made

subsequent to 60 EFPD for this cycle or any previous cycle.

(b) The licensee's nuclear engineering department is re-analyzing

the boron concentrations based on , current fuel worths in an

effort to revise curve 3.20 and remove the approximate 140

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ppm' error presently in the curve. This re-analysis may or

may not be completed prior to the end of cycle which is

presently scheduled for March 9.

Inspector Followup Item (302/84-33-03): Review the results of the

i. boron concentration re-analysis being performed to revise curve

3.20.

b. Facility Tours and Observations

Throughout the inspection period, facility tours were conducted to

observe operations and maintenance activities in progress. .Some

operations and maintencnce activity observations were conducted during

backshifts. Also, during this inspection period, licensee meetings

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were ~ attended by the inspector to observe planning and' management

Lactivities.

The facility tours and observations encompassed the following areas:

Security Perimeter Fence; Control Room; Emergency Diesel Generator

Room; Auxiliary Building; Intermediate Building; Battery Rooms; and,

Electrical Switchgear Rooms.

During these tours, the following observations were made:

(1) - Monitoring Instrumentation l - 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.

(2) Safety Systems Walkdown - The inspector conducted- a walkdown of

the "A" and "B" Emergency Diesel Generator Systems 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 conditions.

No violations or deviations were identified.

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(3) Shift Staffing - The inspector verified that operating shift

staffing was in accordance with TS requirements and that control

room operations were being conducted in an orderly and profes-

sional manner. In addition, the inspector observed shift turn-

overs on various occasions to verify the continuity of plant

status, operational problers, and other pertinent plant informa-

tion during these turnovers.

No violations or deviations were identified.

(4) ~ Plant Housekeeping Conditions - Storage of material and components

and cleanliness conditions of various areas throughout the facil-

ity were observed to determine whether safety and/or fire hazards

existed.

No violations or deviations were identified.

(5) Radiation Areas - Radiation Control Areas (RCAs) were observed to

verify proper identification and implementation. These observa-

tions included selected licensee conducted surveys, review of

step-off pad conditions, disposal of contaminated clothing, and

area ' posting. Area postings were independently verified for

accuracy through the use of the inspector's own radiation moni-

toring 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.

(6) 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

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 area.

No violations or deviations were identified.

(7) Fire Protection - Fire protection activities, staffing and equip-

ment were observed to verify that fire brigade staffing was

appropriate and that fire alarms, extinguishing equipment, actua-

ting controls, fire fighting equipment, emergency equipment, and

fire barriers were operable.

No violations or deviations were identified.

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(8) Surveillance - Surveillance teccs 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.

The following tests were observed and/or data reviewed:

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SP-140, Incore Neutron Detector System Calibration;

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S0-312, Heat Balance Calculations;

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SP-317, RC System Water Inventory Balance;

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SP-335, Radiation Monitoring Instrumentation Functional

Test;

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SP-433, In-core Neutron Detectors Channel Check; and

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SP-701, Radiation Monitoring. System Surveillance Program

(for calibration of RM-All in accordance with

procedure CH-232 Atmospheric Radiation Monitoring

System Calibration).

As a result of these reviews the following item was identified:

Procedure SP-312 requires a quarterly heat balance cross check

with a backup computer (IBM 5100) to ensure that the plant compu-

ter is providing adequate data. Recent problems with the IBM 5100

prevented the performance of this cross check on two. occasions.

The licensee is developing a hand calculation method to enable the

' cross ' check to be performed if the IBM 5100 is out of service.

This method will be incorporated into a review SP-312 procedure.

Inspector Followup Item (302/84-33-04): Review revision to

procedure SP-312 to add hand calculation method for computer cross

check.

(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 I

required, were issued and being followed; Quality Control person-

nel 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:

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Repair of Waste Disposal Flow Recorder WD-19-FR;

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Repair of Fuel Storage Pool Area Criticality Monitor, RM6-14;

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Maintenance performed on - NI-11-NR, Incore Detector No. 2

Recorder; and

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Troubleshooting Security System Vital Door Failure.

No violations or deviations were identified.

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-(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.

No violations or deviations were identified.

(11) Pipe Hangers and Seismic Restraints - Several pipe hangers and

seismic restraints (snubbers) on safety-related systems were

observed to ensure 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 Licensee Event Reports and Nonconforming Operations Reports

a. Licensee Event Reports (LERs) were reviewed for potential generic

-impact, to detect trends, and to determine whether corrected actions

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appeared appropriate. Events, which were reported immediately, were

reviewed as they occurred to determine if the-TS were satisfied.

LERs 84-19, 84-20 and 84-21 were reviewed in accordance with current

NRC enforcement policy.

No violations or deviations were identified.

b. 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 TS.

All NCORs were reviewed in accordance with the current NRC enforcement

policy.

No violations or deviations were identified.

7. Review of Surveillance Program

During a review of the plant surveillance program, the inspector noted the

licensee's practice of performing preventive maintenance (PM) on equipment

at the time the equipment is due for its routine surveillance test. This

practice has been adopted by the licensee to minimize both out of service

times and testing frequency (due to the requirement to verify operability of

the equipment after a PM has been performed) for plant equipment.

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While there is merit to this method, since it reduces equipment downtime and

minimizes equipment test cycling, the inspector noted that this methodology

could mask the "as found" condition of equipment (e.g., the performance of a

PM could repair a deficient condition that may have prevented the equipment

from operating).

The inspector's observations were discussed with licensee personnel. The

licensee .will review this practice and make changes as necessary to ensure

that surveillance test results are not altered by the PM program.

Inspector Followup Item (302/84-33-05): Review the licensee's progress to

ensure that surveillance test results are not altered by the PM program.

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