ML20155A918
| ML20155A918 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/13/1988 |
| From: | Holmesray P, Petrosino J, Tedrow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20155A895 | List: |
| References | |
| 50-302-88-24, NUDOCS 8810060116 | |
| Download: ML20155A918 (15) | |
See also: IR 05000302/1988024
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION ll
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101 MARIETTA ST., N.W.
ATLANTA GEORGIA 30323
,,,,
Report No:
50-302/88-24
Licensee:
Florida Power Corporation
3201 34th Street, South
St. Petersburg, FL 33733
Docket No:
50-302
License No.:
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Facility Name:
Crystal River 3
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Inspection Conducted: July 16 - August !?, 1988
Inspectors:
W} b 3.[ em
b
4h/82
f' Holmes-Ray, b a
9hht
Seni r Resi
nt Inspector
Dats Signed
WS
w
J. Tedrow, Resident in pect{
Date S1'gned
~
G). S .,
w La
sl m e
J. Petrosi
NRR, Division (gfReactorInspection
batd S(gned
and Sa g rds
[
N
[
Approved by:
e
R. rg g ak, Sectifn Chief "
~0(te S~igned
Division of Reactor Projects
SUMMARY
Scope:
This routine inspection was conducted by two resident inspectors and
an accompanying NRR inspector in the areas of plant operations,
security,
radiological
controls.
Licensee Event
Reports
and
Nonconforming Operations Reports, facility modifications, control of
incoming vendor related technical information, and licensee action on
previous inspection items.
Numerous facility tours were conducted
,
and facility operations observed.
Some of these tours and obser-
t
vations were conducted on backshifts,
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Results: One violation was identified: Inadequate evaluation and procedures to
control incoming vendor technical issues, paragraph 8.d.
,
Two unresolved items * were identified: To determin? the significance
of the findings from the licensee's review of the disposition of
vendor identified technical issues, paragraph 8; and to determine the
significance of the findings from the licensee's review of the
procedural control of sendor identified technical issues, paragraph
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9.
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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.
8810060116 880919
ADOCK 05000302
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REPORT DETAILS
1.
Persons Contacted
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Licensee Employees
T. Austin, Principal Nucleer Mechanical Engineer
K. Baker, Manager, Nuclear Engineering Assurance
- W. Bandhauer, Assistant Nuclear Plant Operations Manager
- G. Becker, Manager, Site Nuclear Engineering Services
- J. Brandely, Manager, Nuclear Integrated Planning
- G. Castleberry, Nuclear Engineering Supervisor
- M. Collins, Nuclear Safety and Reliability Superintendent
J. Fiijouf, Nuclear Regulatory Specialist
H. Gelston, Supervisor, Site Nuclear Engineering Services
D. Green, Nuclear Licensing Specialist
- V. Hernandez, Supervisor, Nuclear Quality Assurance Surveillance
- B. Hickle, Manager, Nuclear Plant Opera +' .ns
- R. Jones, Nuclear Modifications Specialist
K. Lancaster, Manager, Site Nuclear Quality Assurance
S. Loflin, Senior Nuclear Quality Assurance Specialist
- G. Longhauser, Nuclear Security Superintendent
- M. Martin, Supervisor, Nuclear Electrical / Instrument and Control
- P. McKee, Director, Nuclear Plant Operations
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- R. Murgatroyd, Nuclear Maintenance Superintendent
G. Oberndorfer, Manager, Procurement and Miterial Quality Assurance
- S. Robinson, Nuclear Chemistry and Radiation Protection Superintendent
"V. Roppel, Manager, Nuclear Operations Maintenance and Outages
- W. Rossfeld, Manager, Nuclear Compliance
S. Stearns, Nuclear Site Engineering
P. Tanquay, Manager, Nuclear Operations Engineering
J. Vattamattam, Senior Nuclear Structural Engineer
H. Walker, Supervisor, Nuclear Electrical / Instrument and Control
"R. Widell, Director, Nuclear Operations Site Support
- M. Williams, Nuclear Regulatory Specialist
Other
licensee
employees
contacted
included office,
operations,
engineering, maintenance, chemistry / radiation and corporate personnel.
- Attended exit interview
Acronyms and initialisms used throughout this report are listed in the
last paragraph.
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2.
Review of Plant Operations (71707)
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.
The following records were reviewed:
Shift Supervisor's Log; Reactor Operator's Log; Equipment Out-Of-
Service Log; Shif t Relief Checklist; Auxiliary Build'ng 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 conducted to
observe operations and maintenance activities in progress.
Some
operations and maintenance activity observations were conducted
during backshif ts.
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; auxiliary building; intermediate building; battery rooms; and
electrical switchgear rooms.
During these tours, the following observations were made:
(1) Monitoring Instrumentation
The following irstrumentation
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and/or indications were 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 .nonitors; electrical system lineup; reactor operating
parameters; and auxiliary equipment operating paraaeters.
No violations or deviations were identified.
(2) Safety Systems Walkdown (71710) - The inspector conducted a
walkdown of the Nuclear Services Closed Cycle Cooling (SW)
system 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 ;onditions.
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No violations or deviations were identified.
(3) Shif t Staffing (71707) - 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
professional manner.
In addition, the inspector observed shif t
turnovers on various occasions to verify the continuity of plant
status, operational
problems,
and other pertinent plant
information during these turnovers.
No violations or deviations were identified.
(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.
During a plant tour, it was noticed that the housekeeping in the
SW room of the Auxiliary Building was less than desired.
The
condition was conveyed to FPC management who took immediate
action to have the SW room cleaned up. Clean up of the SW room
was prompt and thorough.
No violations or deviations were identified.
(5) Radiological Protection Program (71709) - Radiation protection
control activities were observed to verify that these activities
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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;
Radiation Control Area (RCA) exiting practices; and
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Proper
wearing
of
personnel
monitoring
equipment,
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protective clothing, and respiratory equipment.
Area postings were independently verified for accuracy by the
inspector. The inspector also reviewed selected Radiation Work
Permits (RWPs) to verify that the RWP was current and that the
controls were adequate.
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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(6) Security Control (71881)
In the course of the monthly
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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
guards were available and that security activities were
conducted with proper supervision.
The performance of various
shifts of the security force was observed in the conduct of
daily activities to include: protected and 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 Cicsed Circuit Television monitors, the
Intrusion Detection system in the central and secondary alarm
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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,
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actuating
controls,
fire
fighting
equipment,
emergency
,
equipment, and fire barriers were operable.
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On August 8 a fire drill was observed and the post drill
critique was attended.
Several problems were noted:
The fire team was slow to respond. All members (5) were
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not on the scene until about 20 minutes after the drill
started.
One team member had a SCBA, but no face mask and had to
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leave his position on the fire hose to get his mask.
When backup fire fighters arrived, not enough SCBAs were
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readily available.
The PA system was weak in some areas.
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These and other minor problems prompted FPC to declare the drill
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unsatisf actory and to schedule another drill.
The rescheduled
drill was conducted on August 9 satisfactorily.
No violations or deviations were identified.
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Surveillance tests were observed to
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(8) Surveillance (61726)
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verify that approved procedures were being used; qualified
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personnel were conducting the tests; tests were adequate to
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verify equipment operability; calibrated equipment was utilized;
and TS requirements were followed,
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The following tests were observed anJ/or data reviewed:
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- SP-317, Reactor Coolant System Water Inventory Balanc6;
- SP-715, Containment Building Spray Semiannual Surveillance
Program; and
- PT-213, Seating Test for FWV-43.
No violations or deviations were identified.
(9) Maintenance Activities (62703)
The
inspector observed
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maintenance activities to verify that correct equipment
clearances were in effect; work requests and fire prevention
work permits, as required, were issued and being followed;
quality control
personnel were a/ailable for inspection
activities as required; and TS requirements were being followed.
Maintenance was observed and work packages were reviewed for the
following maintenance activities:
Shoot and clean 5WHE-1A in accordance with PM-112, Heat
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Exchanger Maintenance
Inspection / Cleaning / Shooting
and
Plugging.
PT-213, Seating Test for feedwater valve FWV-43.
This
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test was performed to attempt to seat check valve FWV-43 as
a follow-up to the leak from the bonnet of EFV-18.
Four
attempts to seat FWV-43 were made without success.
The
temperature of penetration 109 was monitored and held below
110 degrees F.
A similar test was performed earlier on
emergency f eedwater check valve EFV-44; and EFV-44 was
successfully seated.
June 19 - Open and inspect decay heat exchanger (DCHE)-B
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in accordarce with PM-112, Heat Exchanger Maintenance
Inspection / Cleaning / Shooting and Plugging.
During the
beginning of the job, tools were selected by trial and
error.
To determine which wrench was needed to remove the
closure nuts, several were tried for size prior to finding
the correct size. The procedure was not on the job site at
this time. The inspector obtained a copy of the procedure
(PM-112). Review of PM-112 revealed that the procedure was
not adequate to be performed on a DCHE as written.
The
procedure wts written for a service water heat exchanger
(SWHE) and could not be followed for a DCHE, since the
applicable enclosure for DCHE is not referred to in the
procedure. When maintenance management was questioned about
PM-112, they agreed that the procedure was inadequate. The
procedure was last revised on June 18, 1983. A temporary
revision was processed to allow completion of DCHE-B work.
Maintenance management informed the inspector that the shop
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also realized that the procedure was inadequate and had
initiated ac. ion to get it changed.
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There are two weaknesses illustrated by this event:
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1)
The review cycle which allowed the procedure to be
issued in its inadequate form was 'ess than effective.
2)
Review of the procedure prior to job commencement was
inadequate in that the plant entered a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br />, LC0
for removal of the DCHE from service when the
procedure was inadequate to perform the work,
No citation is issued for this event since the
licensee (concurrently with the inspector) identified
the inadequate procedure and corrected the~ procedure
prior to its use.
No violations or deviations were identified.
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(10) 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
r.o leakage was evident, restraint settings were appropriate, and
anchoring points were not binding.
No violations or deviations were identified.
3.
Review of Licensee Event Reports (9N00) and Nonconforming Operations
Reports (71707)
a.
Licensee Event Reports (LERs) were reviewed for potential generic
impact, to detect trends, and to determine whether corrective actions
appeared appropriate.
Events that were reported immediately were
reviewed as they occurred to determine if the TS were satisfied.
LERs 86-18 and 88-14 were reviewed in accordance with the current NRC
LER 86-18 is closed.
(1) (Closed) LER 86-18:
This LER reported that contaminated
material was found outside of the radiation control area, This
matter is already being tracked by an unresolved item
(Unresolved Item 302/86-35-05).
(2) (0 pen) ' ER 88-14:
This LER reported excessive temperatures
in Eme, uncy Feedwater (EN) system piping.
This event is
discussed in more detail in NRC Inspection Report 50-302/88-18.
The licensee's short term corrective actions as stated in the
LER have been completed, however the following corrective
actions remain to be done:
Disassembly and repair of leaking valves in the EFV system
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(EFV-18, EFV-33, and FW-43);
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Analysis to upgrade the EPW system piping to operate at
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higher temperatures;
Development of leakage criteria and test procedures for EFW
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system check valves; and,
Evaluation of the possibility of "water hammer" effects by
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formation of steam voids in these lines.
This LER will remain open pending completion of these corrective
actions.
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 subseouent 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 acco/ dance with the current NRC
No violations or deviations were identified.
4.
Bulletin (BU) Followup (92703)
BU 88-05:
Nonconforming Materials Supplied by Piping Supplies
Inc. at
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Folsom, New Jersey and West Jersey Manufacturing Comp &ny at Williamstown,
On July 14, 1988, in accordance with Supplement I to NRC Bulletin 88-05,
the licensee made a report to NRC Operations Center of nonconforming
material (17 flanges in the Nuclear Services and Decay Heat Seawater
system (RW)). Licenses analysis of the strength of the flanges shows that
the strength of tae material exceeds the required safety factor, even
though tensile strength and hardness are less than specification.
The
licensee concludes that the above mentioned material is suitable for use
in the RW system.
The licensee continues to take action as required by BU 88-05.
5.
Review of Multi-Plant Action Item B-03, PWR Moderator Dilution (71707)
The inspector reviewed the licensee's efforts to prevent the inadvertent
injection of sodium hydroxide (NaOH) into the Reactor Coolant System
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(RCS).
In LER's 77-17 and 77-52, the licensee reported that an
unterminated injection of the NaOH tank (BST-2) into the RCS could result
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in inadvertent reactor criticality.
In Februsry 1977, with the plant in
the cold shutdown condition, NaOH was introduced into the Decay Heat
Remaval (OH) system during the performance of a surveillance test to
exercise the isolation valves associated with tank BST-2. The cycling of
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the isolation valves allowed NaOH to drain into the DH system and the NaOH
was then subsequently transmitted into the RCS during routine OH system
operation. Although this event did not result in a sufficient reduction
in RCS boron concentration to create an inadvertent criticality,
subsequent aralyses determined that the possibility existed to do so. In
June 1977, the licensee imposed administrative safeguards to preclude such
an event.
This action was reviewed and approved by the NRC in an
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dmendment to the facility operating license (license amendment #20).
Subsequsnt amendments to the operating license restricted the shutdown
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reactivity margin to 3.0*4 delta k/k.
This shutdown reactivity would
prevent a moderator dilution accident of this type from resulting in an
inadvertent reactor criticality.
In 1983, the licensee emptied and isolated tank BST-2 from the DH system
and provided for NaOH addition from the present NaOH Spray Additive Tank
BST-1.
This tank provides Na0H to the reactor building spray system
instead of the DH system and is isolated from the DH system by check
valves. This modification prevented the introduction of NaOH into the OH
system and RCS. The NRC reviewed and approved of this thodification in
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license amendment #64 (dated August 2,
1983), which also restored the
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shutdown reactivity margin to the previous value.
In reviewing the above information, the intpector noticed that the
moderator dilution accident described in the Final Safety Analysis Report
(FSAR) Section 14.1.2.4.2, Unterminated Oilution Through the Decay Heat
Removal System, still described the old BST-2 tank configuratio i with
associated administrative controls to prevent this type of accident. This
finding was discussed with licensee personnel who stated that Chapter 14
of the FSAR was in the process of being reviewed and revised for the next
annual update in July 1989.
The licensee w'il include revisions to the
moderator dilution accident analysis to-reflect the current method of NaOH
addition as part of this annual FSAR update.
IFI (302/88-24-01):
Reviaw the licensee's revision to the moderator
dilution accident analysis in the FSAR. (TI 2515/94 is closed.)
6.
Inspection of Quality Assurance for Diesel Generator Fuel Oil (71707)
The inspector reviewed the licensee's purchasing requirements plat.ed on
f uel oil ordered for the emergency riiesel generators.
The licensee buys
this product as a "Safety-Related" commercial grade purchase and utilizes
the>:ommodity rethod of procurement specified in the licensee's Nuclear
Procurement and Storage Manual. This method requires a receipt inspection
and test of the new fuel received.
Tne inspector discussed this process with licensee material quality
assurarce personnel and reviewed recent procurement, purchase order, and
receipt inspection documentation for the purchase of this fuel oil
(TI
2515/93 is closed.)
No violations or deviations were identified.
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7.
Licensee Action on Freviously Identified Inspec.; ton Findings (92702 and
92701)
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(Closed) Unresolved Item 302/84-21-05: Change the Plant Review Committee
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(PRC) Charter to Correct the Use of Alternate Members and Change PRC
Meeting Activities
As stated in NRC Inspection Report 50-302/85-21, this item remained open
pending a clarification of job position philosophy and subsequent revision
to the PRC charter. Subsequent verbal ccmmunication between the NRC and
the licensee on May 24, 1988, has clarified this issue.
The temoorary
absence of a full time PRC member can only be filled by a designated
alternate me3.ber.
This reouirement ensures that continuity of con.mittee
activities is maintained.
The licensee has subsequently revised the PRC
charter (revision 26 dated July 15, 1938) to reflect tnis position.
8.
Licensee Disposition Actions in Regard to Vender Related Issues (36100)
The inspect.or reviewed the licensee's hardware problem disposition actions
associated with the followiag issues:
a.
10 CFR Part 21 report from Brown Boveri Company (BBC) dated May 13
1985, in regard to an incorrectly configured short time delay band
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lever for BBC (also identified as ITE) K-Line circuit breakers.
This issue was previously identified as an inspector tollowup item
(IFI 302/87-19-04) and was also discussed in Information Notice (IN) 85-64.
NRC Inspection Report 302/87-19 stated, in part, that work
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request (WR) 69571, dated 7/11/85 was initiated to verify whether or
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not any of the safety-related or balance of plant (80P) circuit
breakers in the DBC K Line breaker series contained the incorrectly
configured lever.
The vendor identified two circuit breakers as
suspect at Crystal River in its May 13, 1985 letter; however,
subsequent licensee communications with BBC discovered that the
incorrect link may have been installed on K-Line circuit breakers
manufactured earlier than was previously stated, but was limited to
the 480 VAC auxiliary power BOP and safety-related breakers.
Therefore, WR 69571 was written to inspect all of the 480 VAC BBC
devices that may contain the incorrect lever.
The inspector followup on this issue revealed that the WR is not
completed for the B0P circuit breakers; however, the safety-related
circuit breakers have all been inspected and no incorrect band levers
were found.
The licensee has taken satisf actory corrective actions
to determine the applicability of this issue to Crystal River.
Action on this matter is complete and this issue is considered closed
(P21SS-03).
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b.
Two 10 CFR Part 21 reports from Brown Boveri Company in regard to
other BBC K-Line circuit breaker problems were received by Crystal
River as follows: (1) a March 19, 1985, BBC letter discussing the
potential of cut auxiliary switch control wires on its K-Line circuit
breakers,
that can occur during racking operations due to
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interference with a sharp edge on a stationary breaker dust t:over,
and (2) a June 30, 1986 BBC letter discussing the potential of cut
and shorted control wire harness wiring due to oversi7e clearance
holes in the K-Line panel enclosure that allows the harness to come
into contact with the racking gear teetn.
Adequate investigative and corrective actions are being performed by
the licensee, as follows: (1) Work request 69571 discussed above was
also scoped to include work activities to install protective gasket
material over the sharp edge of the dust cover and secure the wires
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to the auxiliary switch, and (2) Work requests 94001-94011, dated
,
September 14, 1987, were written to inspect and repair as necessary
the applicable 480 VAC K-Line breakers,
To date, WRs 94006, 94007,
94008, 94009, 94010 and 94011 have been completed with no problems
found. WR's 94001, 94002, 94003, 94004, and 94005 are still
uncompleted.
The licensee has taken action to determine the applicability of this
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issue to Crystal River. The above WRs are noted as optn but should
be adequately controlled by the licensee maintenance and quality
control organizations. Therefore, action on this matter is complete
and this issue is considered closed (P2185-06 and P2186-02).
c.
A
report
from Limitorque
Corporation dated
December 19, 1980, in regard to potential Limitorque DC motor lead
wire groun;ing/ shorting problems due to the type of lead wire
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insulating material (Nomex-Kapton) used by the motor vendor.
IN 87-08 was subsequently issued and discusses the problem in greater
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detail.
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The licensee performed inspections of all applicable Limitorque
operators and discovered that none had the questionable insulation;
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instead, the DC notor leads have an epoxy impregnated glass braid on
top of Nomex type insulation which is consicered environmentally
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qualified by Limitorque.
These actions are discussed in a Florida
Power Letter, dated February 15, 1988, letter 3F0288-13, to the
Region II Administrator.
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The licensee has taken satisfactory corrective actions to determine
the applicability of this issue to Crystal River. Action en this
matter is complete and this issue is considered closed (P2186-03).
d.
Two 10 CFR Part 21 reports concerning Limitorque Corporation
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actuators were received in 1935 by Crystal River, and do not appear
to have been evaluated for the design basis hardware functionality
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aspect, as follows: (1) A ':ay 8,1985, Babcock and Wilcox letter
discusses Limitorque actuators supplied to the Bellefonte Plant that
have an actual weight that exceeds the valve vendor documents and
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stress analysts bases, which is therefore non-conservative, and (2)
An August 13,19S5 Limitorque letter that discusses potential worm
shaf t gear failures when certain critical speeds are combined with
repetitive actuator clutch nechanism transfer of size-2, type SM3, SB
and $80 actuators.
The inspector and licensee reviews indicate that the two issues have
not been evaluated for their effect on the operation of the plant
systems, nor has all of the eo,uipment or systems been identified.
Failure to provide an adequate evaluation and procedures to control
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incoming vendor technical issues is contrary to 10 CFR Part 21 and
10 CFR Part 50, Appendix B, Criterion XVI, and is considered to be a
violation (Violation 302/88-24-02). This issue is also discussed in
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section 9, below. Action on these issues as 10 CFR Part 21 items ir,
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complete, and will be followed as part of the corrective action for
violation 302/83-24-02.
This issue is therefore considered closed
(P2185-02).
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Violation (302/38-24-02): Inadequate evaluation and procedures to
control incoming vendor technical issues.
,
t
e.
A 10 CFR Part 21 report frem GA Technologies (Sorrento Electronics
Division), dated February 23, 1937 in regard to a Sorrento
Electronics model RD-23 ion chamber detector Rockbestos coaxial cable
i
insulation resistance probloa at high temperatures (LOCA conditions).
The letter identifies Crystal River as having procured the analog
I'
version of ,its post-LOCA high range radiation monitor (HRRM) syrtem
for use in containment.
The inspector reviewed the site nuclear engineering evaluation ef the
.
problem, and the package (Doc. Catl. No. T87-73) indicated that
Crystal River does not use the RD-23 in the identified application.
The package stated, in part, that the Crystal River HRRM devices
"...are
supplied by Gammametrics and not Sorrento Electronics.
!
kockbestos cable is not utili:ed in a safety related function for
!
equipment located in a harsh environment. . .The attached technical
information from Sorrer.to Electronics is not applicable..." However,
i
contrary to the licensee statements the inspector's r eview of the
>
.
Crystal River master instrument list and discussions with licensee
'
staff indicated that Crystal River does have Sorrento Electrontes
RD-23 devices installed in the HRRM application (RM-G29/G30) and has
the Sorrento Electronics RP-23 analog readout module.
Additional
j
verification efforts by the inspector appear to indicate that the
d
Rockbestos cables are installed according to the electrical circuit
I
schedules. The licensee's evaluation of this Part 21 report is
considered incorrect, and is used as an example in violation
,
302/88-24-02 because procedures were inadequate to assure that a
i
l
proper evaluation is conducted.
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_ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ - _ _ - _ - _
_.
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_ _ _ _
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_ _ _ _
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12
Subsequent discussions with the licensee staff revealed a second
licensee evaluation of a Sorrento followup letter.
This evaluation
was handled correctly and resulted in a Gilbert / Commonwealth
engineering heat transfer calculation being performed to determine if
the problem was applicable. The calculation indicates that the cable
is qualified for its application. This issue is therefore considered
closed (P2187-01).
f.
An April 30, 1987 letter from Colt Industries, as required by
Section 21.21 of 10 CFR Part 21, identifies an indicator valve plug
failure (P/N-92-002-SS3) in its Fairbanks-Morse model 38TD8-1/8 EDG
adapter relief and indicator valve.
The lett1r recommends that
Crystal River remove and inspect the brass plug threads for
deterioration and to implement a periodic inspection program at least
once in five years. Work Request 896S8, dated May 5, 1987 was issued
to inspect the plugs on EDG 1A and 18. All plugs were replaced with
new parts, even though no degradation was indicated on the WR.
Crystal River interoffice letter No. SNES83-0486 was issued to
incorporate an
inspection attribute in
the EDG preventative
maintenance program.
The licensee has taken satisfactory corrective actions to determine
the applicability of this issue to Crystal River.
Action on this
(
matter is complete, and this issue is considered closed (P2187-02).
i
j
g.
The inspector reviewed a Crystal River engineering evaluation of a
i
February 10, 1988 letter from Power Conversion, to determined whether
i
or not the licensee evaluated the impact of an electrical circuitry
design change (i.e., to increase an existing 100 ampere fuse to a 225
'
ampere fuse) contained in the Power Conversion letter.
The inspector concluded that the design change was not addressed in
the evaluation conducted by the licensee's engineering reviewer, and
therefore represents an inadequate evaluation. This is used as an
example in violation 302/88-24-02.
In conclusion four out of nine licensee evaluation packages of incoming
vendor technical issues that were reviewed were found to be incomplete
and/or inadequate.
Two limitorque items, which were in the Nuclear
Operations Engineering Department REI format, were initiated in in85 and
1986 but were found to be incomplete and still open. The other two issues
(Sorrento Electronics and Power Conversion) were found in the Nuclear Site
Engineering evaluation packages.
All four evaluations, as discussed
above, do not adequately determine the individual impact on the design
function of the component or system.
Thus, the results of this inspection bring into question how many other
inappropriate or incomplete technical issues were performed by the
licensee staff.
The licensee has committed to implement immediate
corrective action to determine whether or not this is a problem to the
plant components or systems.
,
_ _ ___________ _ - _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ - - _ - _ _ - _ _ _ _ _ _
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.
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UNR (302/88-24-03): To determine the significance of the findings from
the licensee's review of the disposition of vendor identified technical
issues.
9.
Nuclear Operation Selected Procedure Establishment and Implementation
Review (42700)
Based on the problems identified as Violation 302/88-24-02, the inspector
performed a cursory review of the following procedures:
N00-06,
Technical Information Program, dated 11/14/85;
-
OC/RM-375, Routing and Processing Incoming Technical Information,
-
dated 6/1/85;
AI-404,
Review of Technical Information, dated 7/22/88;
-
Documenting, Reporting, and Reviewing Nonconforming
-
Operations Reports, dated 6/4/88;
N L-06,
Resolution of Safety Concerns, dated 11/8/85;
-
NEP-144,
10 CFR Part 21, dated 6/1/88;
-
NEP-141,
Corrective Action, dated 6/1/88; and,
-
NEP-201,
Preparation and Processing of REIs, SPs, and
-
Engineering Studies, dated 6/1/88.
The review indicated that the procedures were inadequate to assure
compliance with the requirements of 10 CFR Part 21; therefore, violation
202/88-24-02 was identified.
Furthermore, a review of the procedures appears to indicate that the
licensee may not be adequately controlling all of the incoming vendor
technical information to assure that the information is addressed per the
intent of NRC Generic letter 83-28.
Each department appears to be
attempting to establish its own instructions and procedures without
verifying that its controls will not negatively af fect another procedure
or department.
The licensee f.taff is currently reviewing this concern.
UNR (302/88-24-04):
To deternine the significance of the findings from
the licensee's review of the procedural control of vendor identified
technical issues.
10.
Exit Interview (30703)
The inspector met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on August 12, 1988.
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
violation, unresolved items, and inspector followup item.
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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14
1
11. Acronyms and Abbreviations
ALARA - As Low As Reasonably Achievable
BBC
- Brown Bovtri Company
- Balance of Plant
- Dulletin
CFR
- Code of Federal Regulations
- Decay Heat Closed Cycle Cooling
DCHE - Decay Heat Heat Exchanger
DH
- Decay Heat Remeval
- Emergency Feedwater
- Florida Power Corporation
FSAR - Final Safety Analysis Report
HRRM - High Range Radiation Monitor
IFI
- Inspector Followup Item
IN
- NRC Information Notice
LCO
- Limiting Condition for Operation
LER
- Licensee Event Report
LOCA - Loss of Coolant Accident
- Modification Approval Record
NaOH - Sodium Hydroxide
NCOR - Nonconforming Operation Report
NRC
- Nuclear Regulatory Commission
- Nuclear Reactor Regulation
- Freventive Maintenance
- Plant Review Committee
- Radiation Control Area
REI
- Request for Engineering Information
- Nuclear Services and Decay Heat Seawater
- Radiation Work Permit
- Surveillance Procedure
- Short Term Instruction
- Nuclear Services Closed Cycle Cooling
SWHE - SW Heat Exchanger
TS
- Technical Specification
- Unresolved Item
- Violation
- Work Request
.