ML20210J690
| ML20210J690 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/19/1986 |
| From: | Widell R FLORIDA POWER CORP. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 3F0E86-21, 3FE86-21, NUDOCS 8610010217 | |
| Download: ML20210J690 (6) | |
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@ SEP 23 P 3 : 3 Florida Power CORPORATION September 19, 1986 3F0986-21 Dr. J. Nelson Grace Regional Administrator, Region II Office of Inspection and Enforcement U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, GA 30323
Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 IE Inspection Report No. 86-22
Dear Sir:
Florida Power Corporation provides the attached as our response to the subject inspection report.
As discussed in the Enforcement Conference held on July 9, 1986, FPC is including a Supplemental Information section at the end of this response.
We hope this infonnation will prove beneficial in resolving this concern.
Sincerely, T
Rol f 'E. Widell Manager, Nuclear Operations Licensing and Fuel Management AEF/fe5 Attachment 8610010217 860719 ADOCK OD00 g,=.
PDR I
LEO l GENERAL OFFICE: 3201 Thirty fourth Street South
FLORIDA POWER CORPORATION
RESPONSE
INSPECTION REPORT 86-22 VIOLATION 86-22-01 Technical Specification (TS) 3.7.13.5 requires the oxygen concentration in any waste gas decay tank (WGDT) to be less than 2% by volume whenever the concentration of hydrogen in the WGDT is greater than or equal to 4% by volume.
Action statement b for the TS requires whenever both the concentration of hydrogen and oxygen are each greater than or equal to 4% by volume in a WGDT, that waste gas additions to this tank be suspended and that without delay the oxygen concentration be reduced to within its limit.
Contrary to the above:
During the period of 11:37 p.m. on June 17, 1986 through 6:28 a.m. on June 18,
- 1986, the "B"
WGDT had hydrogen and oxygen concentration that were greater than 4% by volume and waste gas additions to this tank were not suspended; and, During the period of 6:28 a.m. on June 18, 1986 through 7:00 a.m. on June 19, 1986, the "B"
and "C"
WGDT's exceeded the 4% hydrogen and oxygen limits and there was considerable delay before attempts were made to reduce the oxygen concentration to within it's limit.
This is a Severity Level IV Violation (Supplement I).
This is similar to a previous violation sent to you by our letter dated January 31, 1985.
RESPONSE
Florida Power Corporation's Position Florida Power Corporation agrees that a violation of Technical Specification 3.7.13.5 did occur.
The addition of waste gas to the "B" waste gas decay tank (WGDT) was not suspended immediately when the action levels of Technical Specification 3.7.13.5 were reached.
Addi tionally, there was a delay in beginning to reduce the concentration of oxygen in the B and C WGDT's while awaiting chemical analyses.
Apparent Cause of Violation Waste gas addition to the "B" WGDT was not suspended immediately upon reaching the action levels of Technical Specification 3.7.13.5 because this condition was not recognized.
The range selector swi tch on the oxygen channel of explosive gas monitoring ins trumentation was incorrectly left in the high range posi tion which prevented it from alarming at the required concentration. Failure to recognize that the range selector switch was in the incorrect posi tion and that the oxygen concentration was in excess of Technical Specification limits were the result of an inadequate procedure.
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At the time this event occurred, the Operating Daily Surveillance Log, SP-300, required checking the monitor alarm status and power availability.
- However, the procedure did not require,erification of the position of the range selector switches or provide information regarding expected vs. abnormal values of hydrogen and oxygen concentrations in the WGDT's.
The delay in beginning to reduce the concentration of the explosive gas mixture (while awaiting analytical results) was inappropriate when considered in retrospect. However, at the time of the event, the monitor appeared to be malfunctioning and confirmatory analyses were ordered.
Increases in oxygen concentration in the WGDT's usually occur over a period of time, and a trend can be recognized before the monitor 'goes into alarm.
In this case, the monitor suddenly went into alarm when the oxygen channel range selector switch was returned to the correct position. The Shif t Supervisor on duty was not aware that the alarm function of the monitor was dependent upon meter deflection.
He did not associate repositioning the range selector switch with receipt of the alann and assumed the monitor was malfunctioning and ordered the confirmatory analyses.
Corrective Actions Following confi nnation that the explosive gas mixture in the "B"
and "C"
WGDT's was in excess of specified limits, actions were taken to begin reducing the hydrogen and oxygen concentrations.
Date of Full Compliance The concentrations of hydrogen and oxygen in the "B"
and "C"
WGDT's were within specified limits at 0700 on June 19, 1986.
Action Taken to Prevent Recurrence The Operating Daily Surveillance Log has been revised.
It now includes requirements for checking the position of range selector switches on the explosive gas monitor each shift.
It also provides values for expected l
concentrations of hydrogen and oxygen in the WGDT's.
Concentration values which are not wi thin the expected range are noted and reviewed by the responsible supervisor to determine whether further action is required.
The Shutdown Daily Surveillance Log, SP-301, will also be revised in a similar fashion since Technical Specification 3.7.13.5 is applicable at all times.
Addi tional ly, the range selector switches are being replaced with switches that have a spring return to the proper position.
This will eliminate leaving the selector switch on the improper range and affecting the monitor alarm function.
VIOLATION 86-22-02 10 CFR Part Appendix B,
Criterion 16 requires corrective action measures that assure that nonconformances are promptly identified and corrected and that such measures will prevent repeti tion of these noncon formances.
Section 1.7.1.16 of Florida Power Corporation's (FPC)
Quali ty Program requires nonconformances to be promptly identified and corrected and that the corrective action taken be sufficient to prevent recurrence of the nonconfonnance.
In a letter to the Nuclear Regulatory Commission (NRC) from FPC dated June 6,1985 in response to and providing corrective actions for the violation identified in NRC Inspection Report 50-302/84-33, the licensee stated that the waste gas disposal system procedure, OP-412, would be revised and that temporary nitrogen addition equipment would be utilized to provide a method to reduce the oxygen and hydrogen concentrations in the waste gas decay tanks (WGDT's).
Contrary to the
- above, FPC has failed to take prompt corrective action and, in a letter to the NRC from FPC dated March 14, 1985, in response to a
Deviation identified in NRC Inspection Report 50-302/85-44, FPC denied the Deviation to the above commitment based upon FPC's interpretation that the commitment did not include any specific pieces of the temporary nitrogen equipment, designate any specific location for the equipment, nor specify any actual use of the equipment.
As a resul t of this failure to take prompt corrective action on two separate occasions during the periods of January 5,
1986 and June 17 to 19,
- 1986, the temporary nitrogen addi tion equipment and even the ni trogen itsel f was unavailable to provide for a timely reduction of the oxygen and hydrogen concentrations in the WGDT's.
This is a Severity Level IV Violation (Supplement I).
RESPONSE
Florida Power Corporation's Position Florida Power Corporation agrees that the unavail abili ty of a temporary nitrogen supply to reduce the concentrations of hydrogen and oxygen in the WGDT's resulted from previous inadequate corrective actions.
Apparent Cause of Violation Previous corrective actions taken in response to high hydrogen and oxygen concentrations in the WGDT's focused on establishing a method to add dilution nitro en without using the waste gas header.
The need to develop a means of s
assuring the continued availability of an adequate supply of nitrogen was overlooked.
Corrective Actions Efforts to secure a supply of dilution nitrogen began when it was determined that the "B" and "C" WGDT's hydrogen and oxygen concentrations were outside the Technical Specification limits and the nitrogen supply was low.
The concentrations of hydrogen and oxygen in both WGDT's were returned to Technical Specification limits wi thin 26 hours3.009259e-4 days <br />0.00722 hours <br />4.298942e-5 weeks <br />9.893e-6 months <br /> of being notified of the questionable reading on the explosive gas monitor.
Date of Full Compliance Full compliance with the requirements of Technical Specification 3.7.13.5 were achieved on June 19, 1986, when the hydrogen and oxygen concentrations in the "B"
and "C" WGDT's were reduced to Technical Specification limits.
Action Taken to Prevent Recurrence The Operating Daily Surveillance Log, SP-300, was revised on June 19, 1986, to require checking the availability of nitrogen and necessary equipment for dilution of the WGDT's.
This revision provided assurance that the temporary nitrogen dilution system remained available.
A permanent nitrogen addition system has since been installed.
This system provides a method of adding nitrogen from the plant nitrogen header to the WGDT's without reliance on temporary equipment.
The Waste Gas Disposal System operating procedure has been revised to include instructions on operation of the permanent nitrogen addition system.
Supplemental Information Florida Power Corporation wishes to note some of the difficulties that have been encountered with compliance with the requirements of Technical Specification 3.7.13.5.
The Crystal River Uni t 3 Waste Gas System was designed, installed, and operated for approximately seven years before Technical Specification 3.7.13.5 became effective.
The system was not originally designed to operate within the limits of this specification and has required extensive modification in an attempt to achieve compliance.
The violations which have occurred since the specification became effective are the result of problems encountered while operating the newly modified system under new restrictions.
Each violation has been addressed by appropriate corrective actions (including system and procedural modifications) which have enhanced the safety of Waste Gas System operations and Technical Specification compliance.
Some of the difficulty encountered in compliance with Technical Specification 3.7.13.5 is related to a unique departure from the Standard Radiological Effluent Technical Specification (SRETS) taken at Crystal Riv'er Unit 3.
The SRETS action statement requires that explosive gas concentrations be restored to specified limits within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> when the limits are exceeded. The Crystal River Unit 3 specification requires that actions to reduce the explosive gas concentrations begin wi thout delay, but do not specify a time limit for completion of the task.
This departure was taken during development of the Crystal River Unit 3 RETS because it was unknown whether the concentration reductions could be accomplished within 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> while complying with radiological release rate specifications, isotopic sampling requirements and i
system operational limits.
The Crystal River Unit 3 specification has proved to be overly restrictive and has resulted in the issuance of violations on two occasions when the explosive gas mixture was returned to required limits in less than the 48 hours5.555556e-4 days <br />0.0133 hours <br />7.936508e-5 weeks <br />1.8264e-5 months <br /> allowed by the standard specification.
In an effort to further enhance Technical Specification compliance, several activities have recently been completed, or are in progress.
FPC wishes to point out that while some of these activities are presently in progress or planned for the near future, we reserve the right to terminate or cancel at l
any time, any actions that prove to be inaffective or impractical.
These l
enhancements include:
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o Operator training _ on use and purpose of the explosive gas monitoring instruments; o
Installation of a permanent nitrogen dilution system which does not rely upon the use of temporary equipment or the waste gas header for nitrogen addition to the WGDT's;
-o The on-site nitrogen storage capaci ty has been expanded to assure maintenance of an adequate supply for WGDT dilution; o
Initiation of efforts to identify and eliminate sources of oxygen in-leakage to the Waste Gas System; o
Provision 'of a method to purge the waste gas header prior to placing a new WGDT in service; and, o
Development of a means to sample the contents of a WGDT while it is isolated from the Waste Gas Header.
These efforts are indicative of Florida Power Corporation's attention to this matter and consni tment to comply with the requi rements of Technical Specification 3.7.13.5.
In summary, Florida Power Corporation has been responsive to solving the problems associated with the Crystal River Unit 3 Waste Gas System.
Many of the problems encountered were not foreseen and could only be identified through operational experience.
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