ML20197J860

Insp Rept 50-302/86-12 on 860308-0411.Violation Noted: Procedure MP-149 Re Check Valve Cap Removal & Reinstallation Not Implemented.Deviation Noted:Fire Watch Secured W/ Incomplete Seawater Pump Mod

ML20197J860
Person / Time
Site:	Crystal River
Issue date:	05/07/1986
From:	Elrod S, Stetka T, Tedrow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20197J820	List: ML20197J817 ML20197J824 ML20197J840 ML20197J860
References
50-302-86-12, NUDOCS 8605200190
Download: ML20197J860 (12)

See also: IR 05000302/1986012

Text

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UNITED STATES

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Report No.. 50-302/86-12

Licensee: Florida Power Corporation

3201 34th Street, South

St. Petersburg, FL 33733

Docket No.. 50-302 License No.: DPR-72

Facility Name: Crystal River 3

Inspection Conducted: March 8 - April 11, 1986

Inspectors: -

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T. Stetka S i Resident Inspector Datb Signed

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J. E. Tedrow, Residant Inspector Date Signed

Approved by: -

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S. A. Elrod, Section Chief, -

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Datu Signed

Division of Reactor Projects

SUMMARY

Scope: This routine inspection involved 154 inspector-hours on site by two

resident inspectors in the areas of plant operations, security, radiological

controls, Licensee Event Reports (LERs) and Nonconforming Dperations Reports,

facility modifications, 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: Three violations and one deviation were identified (Failure to adhere

to facility procedures, paragraphs 5.b(1), 5.b(9)(a), 5.b(9)(b); Failure to have

an adequate procedure for making changes to facility procedures, paragraph

5.b(9)(c); Failure to report an event via an LER, paragraph 5.b(7)(a); Deviation

from a commitment to provide roving fire watches, paragraph 5.b(7)(b)).

B605200190 860515

PDR ADOCK 05000302

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REPORT DETAILS

1. Persons Contacted '

Licensee Employees

• P. Breedlove, Nuclear Records / Management Supervisor

• C. Brown, Assistant Nuclear Outage & Modifications Manager

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• M. Collins, Nuclear Safety & Reliability Superintendent

C. Dutcher, Nuclear Contracts Supervisor

• P. Ezzell, Nuclear Chemistry Technician

• J. Frijouf, Compliance Specialist

• V. Her.1andez, Senior Nuclear Quality Assurance Specialist

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• J. Lander, Nuclear Outage & Modifications Manager

• P. McKee, Nuclear Plant Manager

• W. Neuman III, Nuclear Reliability Supervisor

, *R. Pinney, Senior Nuclear Quality Assurance Engineer

• S. Powell, Senior Nuclear' Licensing Engineer '

• V. Roppel, Nuclear Plant Engineering & Technical Services Manager

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• W. Rossfe'd, Nuclear Compliance Manager '

Y- *P. 'Skramstad, Nuclear Che'm/ Rad Prctection Superintendent

• D. Smith, Nuclear Maintenance Superintendent

R. Thompson, Nuclear Mechanical / Structural Engineering Supervisor

• E. Welch, Nuclear Plant Engineering Superintendent

,_ K. Wilson, Manager,. Site Nuclear Licensing

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• R. Wittman, Nuclear Operations Superintendent  :.

Other personnel contacted included office, operations, engineering,

l maintenance, chem / rad and corporate personnel.

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• Attended exit interview

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2. Exit Interview

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

.the conclusion of the inspection on April 11, 1986. During. 'this meeting,

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the inspector summarized the scope and findings of the insp~ection as they

are detailed in this report with particular emphasis on the Violations,

Deviation, and Inspector. Followup Items (IFIs)'.

The licensee r.epresentatives 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.

3. Licensee Action on Previous Inspection Items

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(0 pen) IFI 302/85-05-03: The inspector observed the calibration of radia-

tion me..itors RMA-1 and RMA-2. The mid range calibration of these monitors

- was. satisfactorily completed. The high range calibrations were also

compie~ted, however, due to problems with the laboratory calibration

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procedure provided by the vendor, some data may be unacceptable. The

licensee has issued Supplement 2 to Special Report 85-03 which changes the

activity completion date to May 30, 1986. The inspectors will review the

licensee's activities to resolve the data / procedure problems.

(Closed) IFI 302/84-30-02: The licensee has revised procedures SP-177 and

SP-179 to clarify the intent of these procedures to ensure that test lineup

variations are only performed by properly qualified personnel.

(Closed) IFI 302/85-44-04: The licensee has revised procedure SP-201 to

provide a check for the loose jam nuts. In addition, the licensee is

conducting a 100 percent visual inspection of snubbers during the current

outage. Portions of this inspection have been observed by the inspector and

the results are being reviewed on an ongoing basis.

(Closed) IFI 302/85-21-05: The licensee has revised procedure OP-605,

Feeuwater System, to establish a vent path for the pump through a valve

upstream of the pump discharge isolation valve (EFV-8). The inspector has

reviewed the procedure change and considers it adequate to properly vent the

pump.

4. Unresolved Items

Unresolved items were not identified during this inspection.

5. Review of Plant Operations

The plant remained in cold shutdown (Mode 5) for the duration of this

inspection period.

a. Shift Logs and Facility Records

The inspector reviewed records and discussed various entries with

operations personnel to verify compliance with the Technical Specifica-

tions (TSs) and the licensee's administrative procedures.

The following records were reviewed:

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

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

Active Clearance Log; Daily Operating Surveillance Log; Short Term

Instructions (STIs); and Selected Chemistry / Radiation Protection Logs.

In addition to these record reviews, the inspector independently

verified clearance order tagouts.

During a review of the Nuclear Shift Supervisor's Log on April 5, the

inspector noted that during the weekly run of the "B" Nuclear Services

Closed Cycle Coolant Pump (SWP-1B) that one of the two pumps (both

powered from one electric motor) failed to pump and heated up,

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apparently due to cavitation. The reason for the pump failure could

not be determined. An additional run performed about two hours later,

after the pump cooled down, indicated normal pump operation. The

licensee is investigating the pump failure and presently believes that

slight differences in the two pumps' head curves (the pumps are in

parallel) in addition to the reduced flow status (due to the plant

shutdown condition) of the Nuclear Services Closed Cycle Cooling system

could be a factor.

Inspector Followup Item (302/86-12-01): Review the licensee's investi-

gation into the pumping failure of SWP-1B.

b. Facility Tours and Observations

Throughout the inspection period, facility tours were conducted to

observe operations and maintenance activities in progress. Some of

these observations were conducted during backshifts. Also, during this

inspection period, licensee meetings were attended by the inspector to

observe planning and management activities.

The facility tours and observations encompassed the following areas:

security perimeter fence; control room; emergency diesel generator

room; auxiliary building; intermediata building; battery rooms;

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electrical switchgear roons; and reactor building.

During these tours, the following observations were made:

(1) Monitoring Instrumentation - The following instrumentation was

observed to verify that indicated parameters were in accordance

with the TS for the current operational mode:

Equipment operating status; area atmospheric and liquid radiation

monitors; electrical system lineup; reactor operating parameters;

and auxiliary equipment operating parameters.

On March 17, at approximately 11:00 a.m., the inspector noted that

two reactor building (RB) purge exhaust fans and one RB purge

supply fan were running; this is the normal fan lineup with the

equipment hatch installed. Shortly thereafter, however, the

inspector noted that the equipment hatch was not installed. The

inspector then verified that the RB personnel hatches were also

open and notified the control room of these observations. Upon

notification, control room personnel secured the RB purge supply

fan at approximately 11:45 a.m.

The Offsite Dose Calculation Manual (0DCM), in Representative

Sample Method No. 3.1-5 requires the RB purge supply (makeup) fans

to be secured whenever both the personnel and equipment hatches

are open. Failure to adhere to the requirements of the ODCM is

considered to be a violation of TS 6.8.1.

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Violation (302/86-12-02): Failure to adhere to facility proce-

dures as required by TS 6.8.1.

(2) Safety Systems Walkdown - The inspector conducted walkdowns of the

Domestic Water (00) and Nuclear Services Closed Cycle Cooling (SW)

systems to verify that the lineups were in accordance with license

requirements for system operability and that the system drawings

and procedures correctly reflect "as-built" plant conditions.

During a review of the procedures and drawings the inspector noted

that the D0 system was not listed in procedure CP-115, In-Plant

Equipment Clearance and Switching Orders, as being a system that

required an independent lineup verification when returned to

service from a maintenance condition. Discussions with licensee

representatives indicated that this system was only recently

identified as a vital system that could affect the operation of

the Nuclear Services and Decay Heat Seawater Pumps (RWPs). This

system will be added to the appropriate section of CP-115.

Inspector Followup Item (302/86-12-03): Review the licensee's

progress to add the D0 system to section 5.7.2 of CP-115.

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

staffing was in accordance with TS requirements and that control

room operations were being conducted in an orderly and profes-

sional manner. In addition, the inspector observed shift

turnovers on various occasions to verify the continuity of plant

status, operational problems, and other pertinent plant informa-

tion during these turnovers.

No violations or deviations were identified.

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

and cleanliness conditions of various areas throughout the

facility were observed to determine whether safety and/or fire

hazards existed.

No violations or deviations were identified.

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

verify proper identification and implementation. These observa-

tions included selected licensee-conducted surveys, review of.

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

area posting. Area postings were independently verified for

accuracy through the use of the inspector's own radiation

monitoring instrument. The inspector also reviewed selected

radiation work permits and observed the use of protective

clothing, respirators, and personnel monitoring devices to assure

that the licensee's radiation monitoring policies were being

followed.

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No violations or deviations were identified.

(6) Security Control - Security controls were observed to verify that

security barriers were intact, guard forces were on duty, and

access to the protected area (PA) was controlled in accordance

with the facility security plan. Personnel within the PA were

observed to verify that badges were properly displayed and that

personnel requiring escort were properly escorted. Personnel

within vital areas were observed to ensure proper authorization

for the area.

No violations or deviations were identified.

(7) F!re Protection -

Fire protection activities, staffing and

equipment were observed to verify that fire brigade staffing was

appropriate and that fire alarms, extinguishing equipment,

actuating controls, fire fighting equipment, emergency equipment,

and fire barriers were operable.

During a review of the licensee's Appendix R Fire Protection

Evaluations submitted to the NRC on December 19, 1985, tFe

inspector noted that the licensee had identified a design error

involving the bearing flush water for the Nuclear Services

Seawater and Decay Heat Seawater pumps (RWPs). Previous evalua-

tions had assumed that bearing flush water was not necessary for

RWP operation, however recent findings suggest that such flush

water is necessary to prevent pump failure.

To remedy this situation the licensee proposed to modify the RW

system (as further discussed in paragraph 7) to provide a backup

flush water flow path. In the interim, the licensee committed in

the December 19 letter to continue the 20 minute roving fire

watches in the affected areas to compensate for the degraded

system condition.

As a result of this review the following items were identified:

(a) While the licensee notified NRC licensing (NRR) in the

December 19 letter of the potential to lose the RW system,

they had failed to issue a Licensee Event Report (LER) as

required by 10 CFR 50.73(a)(2)(V)(B).

This statute requires the issuance of an LER for any condi-

tion that could prevent the functioning of a system that is

needed to remove decay heat. Failure to issue an LER is

contrary to the requirements of 10 CFR 50.73 and is

considered to be a violation.

Violation (302/86-12-04): Failure to issue an LER as

required by 10 CFR 50.73.

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(b) The licensee had originally established the 20 minute roving

fire watch as a compensatory measure pending completion of

wrapping of safe shutdown cables. This cable wrapping was

completed and the licensee terminated the fire watch at

. 2:00 p.m. on March 14.

On Monday, March 17, while on a plant tour, the inspector

noted that no fire watch had been established in the area of

the RW system and subsequently verified that the modification

to the RW system had not been completed. The licensee, when

notified of these observations, established a fire watch in

the affected area and subsequently restored the roving fire

watch.

Failure to maintain the roving fire watch until completion of

the RW system modification is considered to be a deviation

from a commitment made to the NRC.

Deviation (302/86-12-05): Failure to maintain the roving

fire watch in the RW system area as committed to in the

December 19, 1985, Appendix R Fire Protection Evaluation

letter.

(8) Surveillance - Surveillance tests were observed to verify that

approved procedures were being used; qualified personnel were

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conducting the tests; tests were adequate to verify equipment

operability; calibrated equipment, as required, were utilized; and

TS requirements were followed.

The following tests were observed and/or data reviewed:

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SP-179, Containment Leakage Test-Types "B" & "C"

(For valves CFV-25 and CFV-42);

- SP-344, Nuclear Services Cooling System Operability

(For Nuclear Services Closed Cycle Cooling

Pump "1B");

- SP-3548, Emergency Diesel Fuel Oil Quality & Diesel

Generator Monthly Test;

- SP-523, Station Batteries Service Test; and

- SP-701, Radiation Monitoring System Surveillance Program

(For radiation monitors RMA-1 and RMA-2 Mid and

High Range monitors).

No violations or deviations were identified.

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(9) Maintenance Activities -

The inspector observed maintenance

activities to verify that correct equipment clearances were in

effect; work requests and fire prevention work permits, as

required, were issued and being followed; quality control

personnel were available for inspection activities as required;

and TS requirements were being followed.

Maintenance was observed and work packages were reviewed for the

following maintenance activities:

- Disassembly and bearing replacement on the turbine driven

Emergency Feedwater Pump (EFP-2) in accordance with procedure

MP-124;

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Bearing replacement on the turbine driver for EFP-2 in

accordance with procedure MP-162;

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Test run of EFP-2 in accordance with Work Request (W/R)

. #075920 and work instructions;

- Disassembly and reassembly of check valve RWV-117 in

accordence with procedure MP-149;

- Testing of vital bus inverter 3B in accordance with a W/R and

work instructions;

- Check of various Reactor Protection System (RPS) modules for

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broken or loose hold down clips in accordance with W/R #77114;

- Rebuild and subsequent testing of hydraulic snubber #760135

in accordance with procedures MP-174 and PT-130 respectively;

- Boring of drive pin holes in the impeller of the "D" Reactor

Coolant Pump (RCP) in accordance with W/R #77146 and work

instructions;

- Adjustment of the position indicating limit switches on valve

CFV-42 in accordance with a W/R;

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Troubleshooting of the anti-jamming - circuit on radiation

monitor RMA-2 in accordance with a work request; and

- Troubleshooting of the local valve position indication on

valve EFV-11 in accordance with procedure MP-531.

As a result of these reviews and observations the following items

were identified:

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(a) Step 7.4 of the work instructions of W/R #075920 required

that vibration readings be taken during the 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> test run

of EFP-2. Step 5.2 of these work instructions furthermore

required that if the vibration readings exceeded the " alert"

limits specified, that the test be stopped. On March 10-11,

while observing the test run and reviewing the test data, the

inspector noted that the vibration readings for bearing

position "D" had exceeded the alert limit at least a dozen

times and that the test was not stopped.

Failure to adhere to the requirements of work instructions is

contrary to the procedure adherence requirements of TS 6.8.1

and is considered to be a violation.

This violation is another example of the procedure adherence

violation discussed in paragraph 5.b(1) of this report.

(b) Procedure MP-149, Check Valve Cap Removal and Reinstallation,

Step 7.2.9, requires lubrication of the cap studs prior to

initial torquing. While observing the reassembly of check

valve RWV-117 on March 14, the inspector noted that the valve

cap was initially torqued without lubricating the cap studs.

Failure to adhere to the requirements of procedure MP-149 is

contrary to the procedure adherence requirements of TS 6.8.1

and is considered to be a violation.

This violation is another example of the procedure adherence

, violation discussed in paragraph 5.b(1) of this report.

(c) While observing the rebuilding of hydraulic snubber #760135

on March 20, the inspector noted that his copy of procedure

MP-174, Power Piping Snubber Rebuild Procedure, Revision 7,

was different than the MP-174, Revision 7, that was being

used in the field. Specifically, the inspector's copy had

additional signature blanks added to steps 7.2.19 and 7.2.21

(which were duplicates of existing signatures in the

procedure) and a quality control " HOLD POINT" added to step

7.2.31 (which was a new HOLD POINT). Further investigation

indicated that the change to the inspector's copy of the

procedure was called a " Housekeeping Change" (HKC).

Step 4.1.16 of Administrative Instruction (AI) 401,

Origination of and Revisions to P0QAM Procedures, allows HKCs

to be made as follows:

"Any change in format. Corrections of typographical

errors and/or spelling. Correction of figures, tables,

graphs, (e.g. , updating OP-103, Plant Curve Book) data

sheets, and updating references. Correction of

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obviously incorrect valve lineups, out of order proce-

dure steps, and instrument identification."

Subsequent discussions with licensee management personnel

indicated that the licensee intended to make changes to

various plant graphs and tables (e.g. , reactivity balance

curves, rod worth curves, etc.) as HKCs. The inspector

stated that making such changes circumvented the procedure

review and approval process as required by TS 6.8.2.b and in

fact had resulted in such an occurrence with the change to

procedure MP-174. There were numerous examples of HKCs which

circumvented TS 6.8.2.b in changing the curve book, OP 103:

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4/16/85 changed curves for radiation monitors (air

samplers) RM-A6, RM-A7, RM-A8; and

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5/29/85 changed the curve for Reactor Building Radia-

tion Monitor RM-A1.

The curve book was subsequently restructured into several

procedures, OP 103 A, B, C etc. with additional HKCs as

follows:

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1/1986 changed the curve in OP-103G for Reactor

Building Radiation Monitor RM-A1;

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2/3/86 changed the curve in OP-103G for the Auxiliary

Building Liquid Release Monitor RM-L2;

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2/20/86 changed the curves in OP-103G for RM-Al and

RM-L2; and

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3/31/86 changed three curves in OP-103B heatup/

cooldown curves.

The requirements of procedure AI-401 are considered to be

contrary to the requirements of TS 6.8.1.a and therefore

inadequate for the cause. This item is considered to be a

violation of TS 6.8.1.a.

Violation (302/86-12-06): Failure to have an adequate

administrative procedure directing changes to facility

procedures.

(d) While observing work on EFP-2 in accordance with procedures

MP-124, Disassembly and Reassembly of Emergency Feedwater

Pumps, and MP-162, Disassembly and Reassembly of Emergency

Feedwater Pump Turbine Bearings, the inspector noted that the

procedures did not contain specifications and tolerances for

aligning the pump to the turbine.

When the inspector queried the maintenance personnel about

these alignment specifications they were produced from a file

in the shop. Licensee representatives informed the inspector

that these specifications would be added to both procedures.

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Inspector Followup Item (302/86-12-07): Verify addition of

alignment specifications to EFP-2 procedures MP-124 and

MP-162.

(10) Radioactive Waste Controls - Solid waste compacting and selected

liquid releases were observed to verify that approved procedures

were utilized, that appropriate release approvals were obtained,

and that required surveys were taken.

No violations or deviations were identified.

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

seismic restraints (snubbers) on safety-related systems were

checked to insure that fluid levels were adequate and no le:kage

was evident, that restraint settings were appropriate, and that

anchoring poirts were not binding.

No violations or deviations were identified.

6. Review of Licensee Event Reports and Nonconforming Operations Reports

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

impact, to detect trends, and to determine whether corrective tctions

appeared appropriate. Events that were reported immediately were

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

LER 86-003 was reviewed in accordance with current NRC enforcement

policy and is considered to be closed. Two issues identified in this

LER, investigation of the decay heat pump shaft breakage and the

failure of valve DHV-39 to open, are being tracked by IFI's

302/86-09-03 and 302/86-07-03, respectively.

b. The inspector reviewed Nonconforming Operations Reports (NCOR) to

verify the following: compliance with the TS, corrective actions as

identified in the reports or during subsequent reviews have been

accomplished 'or are being pursued for completion, generic items are

identified and reported as required by 10 CFR Part 21, and items are

reported as required by TS.

All NCORs were reviewed in accordance with the current NRC Enforcement

Policy.

N, violations or deviations were identified.

7. Design, Design Changes and Modifications

The installation of modification (MAR) 82-10-19-31, RW Pump Flush Water, was

reviewed to verify that the change was reviewed and approved in accordance

with 10 CFR 50.59, that the change was performed in accordance with

technically adequate and approved procedures, that subsequent testing met

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acceptance criteria and deviations were resolved in an acceptable manner,

and that appropriate drawings and facility procedures were being revised as

necessary. This review included selected observations of activities in

progress.

Following completion of this modification, the inspector noted that to

maintain sufficient bearing flush water pressure either Nuclear Services

Seawater Pump (RWP) 2A or 2B (safety system pumps) must be run continuously

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instead of the normal non-safety pump, RWP-1. This change in system

operation could cause degradation of the safety system pumps. This

observation was discussed with licensee representatives who concurred with

the inspector. The licensee is presently pursuing additional design changes

that will-return the normal system running status to RWP-1.

Inspector Followup Item (302/86-12-08): Review the design change that will

return normal RW system operation to RWP-1.

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