ML20151X006
| ML20151X006 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 08/05/1988 |
| From: | Crlenjak R, Holmesray P, Tedrow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20151X000 | List: |
| References | |
| 50-302-88-18, IEB-88-003, IEB-88-3, NUDOCS 8808250195 | |
| Download: ML20151X006 (12) | |
See also: IR 05000302/1988018
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION il
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101 MARIETTA STREET,N.W.
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ATLANTA, G EORGI A 30323
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Report No:
50-302/88-18
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: June 9 - July 15, 1988
Inspectors: N.O-
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P. Holmes-Ray, Senior Residenf Inspector
Date' Signed
140. g,A3do-%
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s/s-/ es
J. Tedro ,
esi ent Inspector F
Oatd Signed
Approved by:
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R. jfflehjak, Secfion ChiefV _
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BageSigned
Division of Reactor Projects
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SUMMARY
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Scope: This routine inspection was conducted by two resident inspectors in the
areas of plant operations, radiological controls, security, Licensee Event
Reports and Nonconforming Operations Reports, facility modifications, annual
emergency drill, review of special reports, review of NRC bulletins,
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:
Two violations were identified:
Failure to properly evaluate and
report excessive temperatures in emergency feedwater piping, paragraph 3.b(1);
Failure to provide adequate corrective actions to prevent exceeding the design
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temperature of emergency feedwater piping, paragraph 3.b(1).
The licensee's decision to operate the plant since January 1988 with a bonnet
leak from check valve EFV-18 is considered by the inspectors to be a
nonconservative operational decision, particularly since a plant shutdown in
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February 1988 provided an opportunity to repair this leak.
This matter is
discussed in more detail in paragraph 3.b(1).
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8808250195 000011
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REPORT DETAILS
1.
Persons Contacted
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Licensee Employees
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- J. Alberdi, Manager, Nuclear Plant Technical Support
T. Austin, Principal Nuclear Mechanical Engineer
G. Becker, Manager, Site Nuclear Engineering Services
- P. Breedlove, Nuclear Records Management Supervisor
D. Brown, Nuclear Electrical / Instrumentation and Control Supervisor
- M. Clary, Principal Nuclear Mechanical Engineer
- M. Collins, Superintendert, Nuclear Safety and Reliability
- J. Cooper, Superintendent, Technical Support
- P. Ezzell, Radiochemistry and Environmental Specialist
- J. Frijouf, Nuclear Regulatory Specialist
- R. Fuller, Senior Nuclear Licensing Engineer
- B. Hickle, Manager, Nuclear Plant Operations
- H. Koon, Assistant Superintendent, Nuclear Maintenance
- G. Longhouser, Superintendent, Nucleer Security
- W. Marshall, Superintendent, Nuclear Operations
P. McKee, Director, Nuclear Plant Operations
- J. Roberts, Superintendent, Nuclear Chemistry / Radiation
- V. Roppel, Manager, Nuclear Operations Maintenance and Outages
- W. Rossfeld, Manager, Nuclear Compliance
- J. Smith, Nuclear Regulatory Specialist
W. Squires, Nuclear Modification Specialist
- R. Stevens, Senior Nuclear Quality Assurance Specialist
- E. Welch, Manager, Nuclear Electrical / Instrumentation ar.d Control
Ergineering Services
K. Wilson, Manager, Nuclear Licensing
- R. Wittman, Superintendent, Nuclear Operations
- D. Worley, Manager, Nuclear Chemistry
Other
licensee employees
contacted
included office,
operations,
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engineering, maintenance, chemistry / radiation and corporate personnel.
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- Attended exit interview
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Acronyms and initialisms used throughout this report are listed in
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paragraph 10.
2.
Review of Plant Operations (71707)
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The plant continued in power operation (Mode 1) for the duration of this
inspection period.
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a.
Shift. Logs and Facility Records'(71707)
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:
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Shift
Supervisor's
Log;
Reactor Operator's
Log;
Equipment
Out-0f-Service Log; Shift Relief Checklist; Auxiliary Building
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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 identified.
b.
Facility Tours and Observations (71707)
Throughout the inspection period, facility tours were :.:onducted 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
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management activities.
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
The following instrumentation
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and/or indications were
o' served to verify that indicated
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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 Walkdowr (71710) - The inspector conducted a
walkcown of the High Pressure Injection System to verify that
the lineup was in accordance with license requirements for
system operability and that the system drawing and procedure
correctly reflected "as-built" plant conditions.
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No violations or deviations were identified.
(3) Shift Staffing (71707) - The inspector verified that operating
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shif t staffing was in accordance with TS requirements and thr.t
. control room operations were being conducted in an orderly and
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professional manner.
In addition, the inspector observed shif t
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turnovers en various occasions to verify the continuity of plant
status,
operational
problams,
and other pertinent plaat
information during these turnovers.
No violations or deviations were identified.
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(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.
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No violations or deviations were identified.
(5) Radiological Protection Program (71709) - Radiation protection
control activities were observed to verify that these activities
were in conformance with the facility policies and procedures,
and in compliance with
regulatory
requirements.
These
observations included:
Selected licensee conducted surveys;
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Entry to and exit from contaminated areas, including
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step-off pad conditions and disposal of contaminated
clothing;
Area postings and controls;
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Work activity within radiation, high radiation, and
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-contaminated areas;
Radiatien Control Area (RCA) exiting practices; ond
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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
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Permits (RWPs) to verify that the RWP was current and that the
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controls were adequate.
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The implementation of the licensee's As Low As Reasonably
Achievable (ALARA) program was reviewed to determine personnel
involvement in the objectives and goals of the program.
No violations or deviations were identified.
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In the course of the Tcnthly
(6) Security Control (71881)
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activities, the inspector included a review of the licensee's
physical security program.
The composition of the security
organization was checked to insure that the minimum number of
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guards were available and that security activities were
canducted with proper supervision. The cerformance of various
shifts of the security force was observed in the conduct of
daily activities to include: protected ar.d vital area access
controls; searching of personnel, packages, and vehicles; badge
issuance and retrieval; escorting of visitors; patrols; and
compensatory posts.
In addition, the inspector observed the
operational status of Closed Circuit Television (CCTV) monitors,
the Intrusion Detection system' in the central and secondary
alarm stations, protected area lighting, protected and vital
area barrier integrity, and the security organization interface
with operations and maintenance.
No violations or deviations were identified.
(7)
Fire Protection (71707) - 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.
(8)
Surveillance (61726)
Surveillance tests were observed to
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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:
- SP-141, Operability and Functional Check of Valve Moni+.oring
System;
- SP-?17, RC Water Inventory Balance;
- SP-3408, "B" Train ECCS Pump and Valve Operability; and
- SP-343, Main Steam Isolation Valves Part-Stroke Exercising.
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 issuad 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:
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Repair of emergency feedwater pipe support EFH-126 in
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accordance with procedure MP-804, Installation of Concrete
Anchor Bolts and Integrity Verification, and modification
PAR 88-06-12-01;
Leak repair on emergency feedwater check valve EFV-18 in
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accordance with procedure SNP-242, Leak Repair of EFV-18,
and modification MAR 88-06-13-01; and
Troubleshooting and calibration of the sodium hydroxide
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tank level transmitter (BS-3-LT) in accordance with
procedure MP-531, Troubleshooting Plant Equipment.
No violations or deviations were identified.
(10) Radioactive Waste Controls (71707) - Selected liquid and gaseous
releases were observed / reviewed 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 (71707) - Several pipe
hangers and seismic restraints (snubbers) on safety-related
systems were observed to assure fluid levels were adequate and
no leakage was evident, restraint settings were appropriate, and
anchoring points were not binding.
Ne violations or deviations were identified.
3.
Review of Licensee Event Reports (92700) and Nonconforming Operations
Reports (71707)
a.
Licensee Event Reports (LERs) were rev'ewed for potential generic
impact, to detect trends, and to determine whether corrective actions
appeared appropriate.
Events that were reported immediately were
reviewed as they occu-red to determine if the TS were satisfied.
LERs 88-05 and 88-13 were reviewed in accordance with the current NRC
(1) (Closed) LER 88-05: This LER reported the failure to enter the
TS action statement for exceeding the maximum stroke time for a
containment isolation valve.
This event has been reviewed by
all licensed operators.
LER 88-05 was further discussed in
Inspection Report 302/88-11.
(2) (0 pen) LER 88-13: This LER reported that the control room
ventilation (HVAC) control air tubing did not meet seismic
requirements.
The licensee made a one hour verbal report of
this matter to the NRC on June 10, 1988, and in a letter to the
NRC dated June 22, 1988 provided a justification for continued
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power operation of the plant. The inspector verified completion
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of the licensee's short term corrective action as stated in this
LER, however the licensee's long term corrective actions are not
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yet completed. This LER will remain open pending completton of
the long term corrective actions.
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b.
The inspector reviewed Nonconforming Operations Reports (NCORs) to
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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 NRC
(1) NCOR 88-81 was written on June 19, 1988 to identify feedwater
temperatures, which were higher than normal in Emergency
Feedwater Pump (EFP) discharge piping.
The higher temperatures
in this piping occurred when a bonnet leak developed on check
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valve EFV-18.
This leak caused a slight decrease in system
pressure which allowed high temperature feedwater from the Once
Through Steam Generator (OTSG) to backflow through another check
valve (FWV-43) into the normally cool Emergency Feedwater (EF)
line. The licensee measured the piping surface temperature and
the corresponding temperature on the piping's penetration into
the reactor butiding (penetration #109) to be approximately 480
r hrenheit (F) and 272 F,
respectively.
Concrete
degrees
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surfaco temperatures at the penetration reached approximately
195 F.
On June 21. 1988, the licensee determined that the 110 F
design temperature for this piping and penetration had been
exceeded, and reported this situatioa to the NRC.
The licensee has experienced several previous problems with
excessive temperatures in the EF piping. LER's 82-76 and 83-43,
dated December 20, 1982 and October 3,
1983, respectively,
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reported increased temperatures in this piping which rendered
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flow instrumentation inoperable.
In these events, the licensee
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was able to cool the affected piping by running the emergency
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feedwater pump and supplying relatively cold water to the OTSG.
This actica was successful in seating the chock valves, which
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stopped the backflow Jf hot temp'erature feedwater into the EF
line.
However, during these evants the licensee did not
recognize or analy:e the effect that the increased temperatures
had on tnis piping.
Further overtemperature events have
occurred on the following dates:
On March 8, 1988 licensee operations personnel found this piping
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to have a surface temperature of approximately 300-400 F.
An
engineering question was written (EQ#88-1191) to request
assistance to determine if this piping was designed for this
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temperaturs,. Again the licensee was able to cool the EF lines
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by running the EFP,
The raquested engineering evaluation was
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never performed and although the design temperature for this
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piping had been exceeded, no report of this event was made to
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the NRC.
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0n- May 27, 1988 the Shift Operations Technical Advisor
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warmer thatL normal.
This situation was discussed with the
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' Nuclear Shift Supervisor and the EFP was .run to cooldown the
piping.
However, this~ action was-insufficient to prevent the
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backflow from the OTSG and several successive -attempts were
required on June 6, E,10,12, and 19 to cool the piping with
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the EFP. On June 22,1988, the licensee installed a temporary
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modification (MAR T88-06-11-01) to -provide a' small pump to
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inject the water leaking from valve EFV-18 back into the EF.
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line.
This modification prevented the decrease in system
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pressure and thereby stopped the backflow from the OTSG.
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After reviewing NCOR 88-81 on June 20, tha inspector performed'a
quick review (approximately I hour) of Chapter 5 of the Final
Safety Analysis Report and piping specification . R0-2891, and
obtained preliminary information which indicated that this event
was reportable under 10 CFR 50.72.
This preliminary determina-
. tion was communicated to licensee management personnel on June
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20.
The licensee reported this event at 11:15'a.m. on June 21.
Regulation 10 CFR 50.72(b)(ii)(B) requires that any event that
results in a nuclear power plant being in a. condition that 'is
outside the design basis of the plant be reported to the NRC
Operations Center within one hour.
The failure'.to properly
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evaluate and report the March 8 EF overtemperature event, and
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the delay in reporting the June 19 event until approximately
11:15 a.m. on June 21, is contrary to the requirements of 10 CFR
50.72, and is considered to be a violation.
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Violation (302/88-18-01):
Failure to properly evaluate and
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report excessive terperatures in the EF piping.
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The repetitive nature of the events reported by LERs 82-76 and
83-43, and subsequent events en March 8, May 27, and June 6
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tnrough 19, 1988 is evident of the licensee's inability to
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erovide adequate corrective actions.
Failure to provide
adequate corrective actions is contrary to the requirements of
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10 CFR 50, Appendix B, Criterion 16 and is considered to be a
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violation.
Violation
(302/88-18-02):
Failure
to
provide
adequate
corrective actions to prevent exceeding the design temperature
of the EF system piping and asscdated penetration.
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In correspondence to the NRC dated June 28, 1988 and July 5,
1988, the licensee stated their justification for continued
power operation with temporary repairs to the. leaking valves and
committed to shut down the plant by October 15, 1988 to effect
permanent repairs. A Confirmatory Action Letter was issued by
the NRC on July 6, 1988 which concluded that continued operation
was acceptable to the NRC and confirmed the licensee's
commitments to effect permanent repairs.
4.
Design, Design Changes and Modifications (37700)
Installation of new or modified systems were reviewed to verify that the
changes were reviewed and approved in accordance with 10 CFR 50.59, that
the changes were performed in accordance with technically adequate and
approved procedures, that subsequent testing and test results
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acceptance criteria or deviations were resolved in an acceptable manner,
and that appropriate drawings and facility procedures were revised as
necessary.
This review included selected observations of modifications
and/or testing in progress.
The following modification approval records (MARS) were reviewed and/or
associated testing observed:
MAR 88-06-13-01, Repair Leak on Valve EFV-18;
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MAR T88-06-11-01, Temporary Installation of Pump Between Valves
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EFV-18 and EFV-65;
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MAR T88-06-03-01, Emergency Operating Gas for Valves CHV-56 through
CHV-59; and
MAR 88-06-12-01, Repair of Pipe Support EFH-126,
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5.
Annual Emergency Drill (82301)
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On June 9, 1988, the annual emergency drill was conducted by the licensee
to verify the effectiveness of the Radiological Emergency Response Plan
and implementing procedures.
In addition to the licensee,
the
participants in the drill included the State of Florida, Citrus and Levy
Counties, and the NRC.
The drill was observed by a number of personnel,
including the NRC. Details of the drill, including the results of the
critiques held on June 10, 1988, are discussed in NRC Inspection 9eport
50-302/88-15.
6.
Review of Special Reports (90713)
The licensee submitted a special report dated July 13, 1988 regarding a
discrepancy between the containment leakage test pressure (Pa-49.6 psig)
specified in the TS and the maximum containment accident pressure possible
(52.6 psig). To assure that the containment leakage test pressure bounds
the possible accident pressure, the licensee plans to revise the TS to
increase Pa to 52.6 psig.
The applicable surveillance procedures will
also be revised to reflect the higher test pressure prior to their next
performance.
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IFI (302/88-18-03):
Review the revisions to TS and applicable
surveillance procedures to reflect a Pa of 52.6 psig.
7.
Review of NRC Bulletins (92703)
In a letter dated June 15, 1988, the licensee responded to the actions
requested in Bulletin 58-03, General Electric HFA Latching Relays.
The
response letter stated that the licensee does not use the latching relays
discussed in the bulletin Action on this item is considered complete and
this bulletin is closed.
8.
Licensee Action on Previously Identified Inspection Findings (92702 &
92701)
a.
(Closed)
Violation
302/88-01-01,
Failure
to
Implement the
Requirements of Plant Procedures.
The inspector reviewed and verified the implementation of the
corrective i.ctions stated in the FPC response letter dated April 7,
1988.
b.
(Closed)
IFI 302/88-01-05, Review the Licensee's Revision to
Procedure SP-523, Station Battery Service Test, to Reflect the Actual
Battery Load Profile.
The licensee has revised procedure SP-523 (revision 21 dated June 7,
1988) to reflect the correct load profile,
c.
(Closed)
IFI
302/88-01-02,
Review the
Installation of Plant
Modifications to Return the
"C" Inverter (VBIT) to Operable Status.
The inspector reviewed the installation of two modifications, MAR
T86-03-04-07, Inverter VBIT-1C Input Voltage Relay Interlock, and MAR
86-03-04-06, FCN#2, Inverter / Static Switch Adjustable Power Resistor,
and associated testing.
d.
(Closed) IFI 302/87-30-04, Review Retest of Valve CFV-5 Not Fully
Open Alarm in Accordance with Procedure SP-402, Core Flooding System
Isolation Valves Alarms Actuation.
The licensee has installed modification MAR 86-10-14-01A to add
supports to the valve limit switch actuators and has performed
procedure SP-402 on January 4,1938 satisfactorily.
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e.
(0 pen) IFI 302/89-11-04, Review the Licensee's Corrective Action For
Preventing Main Steam Isolation Valve Closure During Procedure
The licensee is developing modification MAR 88-05-11-01 which will
modify the test circuit for these valves so that the operator can
stop the stroking by simply releasing the test pushbutton. This MAR
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will also address any design problems identified with the valve limit
switches.
The MAR is presently scheduled to be installed during
refuel 7 in September 1989.
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(0 pen) IFI 302/88-11-03, Review the Licensee's Activities to Cleanup
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the Borated Water Storage Tank Room and Evaluate the Corrosion
Effects of Sodium Hydroxide.
The licensee has determined that the component materials in the area
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of sodium hydroxide leakage are compatible with sodium hydroxide. An
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inspection of the cleaned surfaces was made by engineering personnel
and no significant damage was discovered. The licensee has written
numerous work requests (WR 102377 through 102386) to repair leaking
fittings / flanges and to recoat exposed surfaces.
This work is
presently scheduled for accomplishment in refuel 7 in Sept 9mber 1989.
In the interim the licensee has established a monthly cleanup /
inspection of this room.
g.
(0 pen) IFI 302/88-06-02, Review the Licensee's Investigation into
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Similar Causes for Failure of Control Rod Drive Breakers to Re-close.
The licensee could not positively determine if a generic cause was
present in the failure of the breakers to re-close.
However the
licensee has decided to replace 4.11 relays in the source interrupt
device / shunt trip circuitry for both breakers to prevent possible
contact sticking (WR 103156).
On June 29, 1988, during the performance of procedure SP-110, Reactor
Protective Functional Testing, a replacement control rod drive
breaker failed to re-close.
This breaker (#AC-1B) was the same
breaker which failed to re-close on March 1, 1988. The licensee has
been unable to find the cause for this condition and has decided to
send the breaker back to the manufacturer for root cause analysis for
the failure.
9.
Exit Interview (30/03)
The inspector met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on July 15, 1998.
During this
meeting, the inspector summarized the scope and findings of the inspection
as they are detailed in this report with particular emphasis on the
violations and IFI.
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.
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10. Acronymt and Initialisms
ALARA - As Low As Reasonably Achievable
Closed Circuit Television
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Code of Federal Regulations
CFR
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EF
Emergency Feedwater
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Emergency Feedwater Pump
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F
Fahrenheit
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Field Change Notice
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Florida Power Corporation
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IFI
Inspector Followup Item
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Inservice Inspection
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LER
Licensee Event Report
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Modification Approval Record
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NCOR
Nonconforming Operation Report
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NRC
Nuclear Regulatory Commi ssion
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0TSG
Once Through Steam Generator
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Preventive Maintenance
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psig
pounds per square inch gage
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Radiation Control Area
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RC
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Radiation Work Permit
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Surveillance Procedure
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Short Term Instruction
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TS
Technical Specification
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Violation
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Work Request
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