ML20197J860
| 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: |
| References | |
| 50-302-86-12, NUDOCS 8605200190 | |
| Download: ML20197J860 (12) | |
See also: IR 05000302/1986012
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
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ATLANTA, GEORGI A 30323
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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.:
Facility Name:
Crystal River 3
Inspection Conducted: March 8 - April 11, 1986
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Inspectors:
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Stetka S i
Resident Inspector
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J. E. Tedrow, Residant Inspector
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Approved by:
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S. A. Elrod, Section Chief,
Datu Signed
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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
ADOCK 05000302
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REPORT DETAILS
1.
Persons Contacted
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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
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- V. Her.1andez, Senior Nuclear Quality Assurance Specialist
- J. Lander, Nuclear Outage & Modifications Manager
- P. McKee, Nuclear Plant Manager
- W. Neuman III, Nuclear Reliability Supervisor
- R. Pinney, Senior Nuclear Quality Assurance Engineer
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- S. Powell, Senior Nuclear' Licensing Engineer
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- V. Roppel, Nuclear Plant Engineering & Technical Services Manager
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- W. Rossfe'd, Nuclear Compliance Manager '
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- 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
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Other personnel
contacted included office, operations,
engineering,
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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
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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;
electrical switchgear roons; and reactor building.
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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
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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.
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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
conducting the tests; tests were adequate to verify equipment
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operability; calibrated equipment, as required, were utilized; and
TS requirements were followed.
The following tests were observed and/or data reviewed:
SP-179, Containment Leakage Test-Types "B"
& "C"
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(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
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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
Bearing replacement on the turbine driver for EFP-2 in
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accordance with procedure MP-162;
Test run of EFP-2 in accordance with Work Request (W/R)
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- 075920 and work instructions;
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- 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
broken or loose hold down clips in accordance with W/R
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- 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;
Troubleshooting of the anti-jamming - circuit on radiation
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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.
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(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
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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
5/29/85
changed the curve for Reactor Building Radia-
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tion Monitor RM-A1.
The curve book was subsequently restructured into several
procedures, OP 103 A, B, C etc. with additional HKCs as
follows:
1/1986
changed the curve in OP-103G for Reactor
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Building Radiation Monitor RM-A1;
2/3/86
changed the curve in OP-103G for the Auxiliary
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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
(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
instead of the normal non-safety pump, RWP-1.
This change in system
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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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