ML20151X006

Insp Rept 50-302/88-18 on 880609-0715.Violations Noted. Major Areas Inspected:Plant Operations,Radiological Controls,Security,Lers,Nonconforming Operations Repts, Review of Bulletins & Actions on Insp Items

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: ML20151W996 ML20151X002 ML20151X006
References
50-302-88-18, IEB-88-003, IEB-88-3, NUDOCS 8808250195
Download: ML20151X006 (12)

See also: IR 05000302/1988018

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UNITED STATES l

1. pm M4g% NUCLEAR REGULATORY COMMISSION  !

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101 MARIETTA STREET,N.W.

2 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

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Date' Signed

140. g,A3do-% ),, 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

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Division of Reactor Projects

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SUMMARY f

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 '

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

j 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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REPORT DETAILS

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1. Persons Contacted

. Licensee Employees

• 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,

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

paragraph 10.

2. Review of Plant Operations (71707)

l The plant continued in power operation (Mode 1) for the duration of this

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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 ,

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.

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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; auxiliary building; intermediate building; battery rooms; and

electrical switchgear rooms.

During these tours, the following observations were made:

(1) Monitoring Instrumentation -

The following instrumentation

and/or indications were o'o served 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 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

shif t staffing was in accordance with TS requirements and thr.t

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. control room operations were being conducted in an orderly and

-. professional manner. In addition, the inspector observed shif t

turnovers en various occasions to verify the continuity of plant

status, operational problams, and other pertinent plaat

information during these turnovers.

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No violations or deviations were identified.

(4) Plant Housekeeping Conditions (71707) - Storage of material and

components, and cleanliness conditions of various areas

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throughout the facility were observed to determine whether

safety and/or fire hazards existed.

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

step-off pad conditions and disposal of contaminated

clothing;

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Area postings and controls;

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Work activity within radiation, high radiation, and

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-contaminated areas;

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Radiatien Control Area (RCA) exiting practices; ond

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Proper wearing of personnel monitoring equipment,

protective clothing, and respiratory equipment.

I Area postings were independently verified for accuracy by the

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Permits (RWPs) to verify that the RWP was current and that the

, 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.

(6) Security Control (71881) -

In the course of the Tcnthly ,

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

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

accordance with procedure MP-804, Installation of Concrete

Anchor Bolts and Integrity Verification, and modification

PAR 88-06-12-01;

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Leak repair on emergency feedwater check valve EFV-18 in

accordance with procedure SNP-242, Leak Repair of EFV-18,

and modification MAR 88-06-13-01; and

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Troubleshooting and calibration of the sodium hydroxide

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

Enforcement Policy.

(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

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

Enforcement Policy.

(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 i

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

degrees ra hrenheit (F) and 272 F, respectively. Concrete .

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,

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dated December 20, 1982 and October 3, 1983, respectively,

. reported increased temperatures in this piping which rendered ,

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flow instrumentation inoperable. In these events, the licensee

was able to cool the affected piping by running the emergency i

feedwater pump and supplying relatively cold water to the OTSG.

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This actica was successful in seating the chock valves, which

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:

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- On March 8, 1988 licensee operations personnel found this piping

l 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 ,

temperaturs,. Again the licensee was able to cool the EF lines

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by running the EFP, The raquested engineering evaluation was

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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0n- May 27, 1988 the Shift Operations Technical Advisor  ;

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- discovered during a routine plant tour that the EF piping was i

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, warmer thatL normal. This situation was discussed with the

' 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 ,

the EFP. On June 22,1988, the licensee installed a temporary i

modification (MAR T88-06-11-01) to -provide a' small pump to ,

inject the water leaking from valve EFV-18 back into the EF. :l

- line. This modification prevented the decrease in system ,

pressure and thereby stopped the backflow from the OTSG.  !

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 <

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 -

i 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. l

Violation (302/88-18-01): Failure to properly evaluate and s

report excessive terperatures in the EF piping. '

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The repetitive nature of the events reported by LERs 82-76 and

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83-43, and subsequent events en March 8, May 27, and June 6 ,

tnrough 19, 1988 is evident of the licensee's inability to  !

erovide adequate corrective actions. Failure to provide  ;

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adequate corrective actions is contrary to the requirements of

10 CFR 50, Appendix B, Criterion 16 and is considered to be a '

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. l

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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 r..e t

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:

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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

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

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MAR 88-06-12-01, Repair of Pipe Support EFH-126,

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

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procedure SP-402 on January 4,1938 satisfactorily.

e. (0 pen) IFI 302/89-11-04, Review the Licensee's Corrective Action For

Preventing Main Steam Isolation Valve Closure During Procedure

SP-343.

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.

j f. (0 pen) IFI 302/88-11-03, Review the Licensee's Activities to Cleanup

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

l 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

CCTV -

Closed Circuit Television

CFR -

Code of Federal Regulations

ECCS -

Emergency Core Cooling System

EF -

Emergency Feedwater

EFP -

Emergency Feedwater Pump

F -

Fahrenheit ,

FCN -

Field Change Notice

FPC -

Florida Power Corporation

IFI -

Inspector Followup Item

ISI -

Inservice Inspection

LER -

Licensee Event Report

MAR -

Modification Approval Record

NCOR -

Nonconforming Operation Report

NRC -

Nuclear Regulatory Commi ssion

0TSG -

Once Through Steam Generator

PM -

Preventive Maintenance

psig -

pounds per square inch gage

RCA -

Radiation Control Area

RC -

Reactor Coolant

RWP -

Radiation Work Permit

SP -

Surveillance Procedure

STI -

Short Term Instruction

TS -

Technical Specification

VIO -

Violation

WR -

Work Request

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