ML20235F792
| ML20235F792 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/24/1987 |
| From: | Stetka T, Tedrow J, Wilson B NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20235F718 | List: |
| References | |
| 50-302-87-28, NUDOCS 8709290320 | |
| Download: ML20235F792 (13) | |
See also: IR 05000302/1987028
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARIETTA STREET,N.W.
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ATLANTA, GEORGI A 30323
Report No:
50-302/87-28
Licensee:
Florida Power Corporation
3201 34th Street, South
St. Petersburg, FL 33733
Docket No:
50-302
Licensee No.:
Facility Name:
Crystal River 3
Inspection Dates:
August 8 - September 11, 1987
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Inspectors:
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T. E Stetka, Senior Resident Inspector
D' ate Signed
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J. Et Tedrow, Resident Intpettor
Date Signed
Approved by:3Auu k.
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B. 4. Wilson, Section Chief
Date Signed
Division of Reactor Projects
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SUMMARY
Scope:
This routine inspection was conducted by two resident inspectors in the
areas of plant operations, security, radiological controls, Licensee Event
Reports and Nonconforming Operations Reports, facility modifications, qualified
reviewer training, and licensee action on previous inspection item-
Numerous
facility tours were conducted and facility operations observed.
Some of these
tours and observations were conducted on backshifts.
Results:
Three Violations were identified:
Failure of a member on the Offsite
Review Committee to have the proper qualifications, paragraph 3;
Failure to
perform a reactor coolant system cooldown surveillance, paragraph 5.b.(8)(b);
Failure to periodically recertify a qualified reviewer, paragraph 8.
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
- J. Alberdi, Assistant to the Director, Nuclear Plant Operations
- G. Becker, Manager, Site' Nuclear Engineering Services
- J. Brandely, Nuclear Security & Special Projects Superintendent
- P. Breedlove, Nuclear Records Management Supervisor
W. Brewer, Nuclear Engineer II
- M.' Collins, Nuclear Safety & Reliability Superintendent
- B. Hickle, Manager, Nuclear Plant Operations
L. Kelly, Manager, Nuclear Operations Training
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M. Kirk, Nuclear Operations Engineer
M. Kleinman, Vice-Chairman, Nuclear General Review Committee
- J. Lander, Manager, Nuclear Operations Maintenance & Outage
- G. Longhouser, Nuclear Security Superintendent
G. Moore, Chairman, Nuclear General Review Committee
- M. Mann, Nuclear Compliance Specialist
- P. McKee, Director, Nuclear Plant Operations
- W. Rossfeld, Nuclear Compliance Manager
- E. Welch, Manager, Nuclear Electrical /I&C Engineering Services
- K. Wilson, Manager, Site Nuclear Licensing
- R. Wittman, Nuclear Operations Superintendent
Other personnel contacted included office, operations, engineering,
maintenance, chemistry / radiation and corporate personnel.
- Attended exit interview
2.
Exit Interview
The inspector met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on September 11, 1987.
During this
meeting, the inspector summarized the scope and findings of the inspection
as they are detailed in this report with particular emphasis on the
Violations, Unresolved Items and Inspector Followup Items (IFI).
The licensee representatives acknowledged the inspector's comments and did
not identify as proprietary any of the materials provided to or reviewed
by the inspectors during this inspection.
3.
Licensee Action on Previous Inspection Items
(0 pen) IFI 302/86-38-13:
The licensee has performed the following long
term corrective action associated with the addition of the sulfur dioxide
tank at fossil Units 1 and 2:
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A three foot high concrete wall has been constructed around the
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storage tank to permanently protect the tank and limit the available
surface area for any potential spills; and,
A control room habitability report has been ' prepared to determine
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whether any additinnal corrective actions were required.
This report identified the following modifications which still need to be
made to the control complex:
Reduction of inleakage into the control room envelope by installing
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improved door and damper seals; and,
Installation of control logic that will reposition the control
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complex HVAC system dampers to the recirculation mode in the event
toxic gas is detected at the storage tank's local monitors.
These modifications are being accomplished in accordance with
MAR-85-03-10-01 which will be completed during the next refueling outage
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which is scheduled to start on September 19, 1987. This item will remain
open pending completion of these modifications.
(Closed) Unresolved Item 302/87-19-05:
The inspector reviewed the
additional
information provided by the licensee regardin
the
qualifications of the Nuclear General Review Committee (NGRC) gmembers. As
the result of this review it appears that the member assigned to the NGRC
to provide the expertise in the environmental area did not meet the
membership qualification requirements of TS 6.5.2.3.b.
This TS requires
t5at a member have a Bachelor of Science in engineering or related field
and five years related experience including at least three years
involvement with the operation and/or design of a nuclear power plant.
While this member met the educational and experience qualifications for
the related field, the member does not appear to have had any nuclear
plant experience.
This individual was a member of the NGRC from 1977
through 1982 and is presently serving on the NGRC as an alternate member.
Failure to adhere to the requirements of TS 6.5.2.3.b is considered to be a
violation.
Violation (302/87-28-01):
Failure to meet the NGRC membership
qualification requirements of TS 6.5.2.3.b.
For record purposes this unresolved item is closed and all further
activity on this item will be tracked by Violation (302/87-28-01).
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4.
Unresolved items
Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve violations or
deviations.
New unresolved items are identified in paragraph 6.b of this
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report.
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5.
Review of Plant Operations
The plant began this inspection period in power operation (Mode 1).
On
August 21 the plant was shutdown and cooled down to the cold shutdown
condition (Mode 5) to repair a mechanical seal on the "C" Reactor Coolant
Pump (RCP-1C).
Following replacement of the mechanical seal package, a
plant heatup and startup were commenced.
On September 1, the reactor
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achieved criticality at approximately 8:58 AM followed by the resumption
of power operation at 10:18 AM.
The plant remained in Mode 1 for the
remainder 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
Specifications (TS) and the licensee's administrative procedures.
The following records were reviewed:
Shift Supervisor's Log; Reactor Operator's Log; Equipment
Out-0f-Service Log; Shift Relief Checklist; Auxiliary Building
Operator's Log; Active Clearance Log; Daily Operating
Surveillance Log; Work Request Log; Short Term Instructions
(STI); and Selected Chemistry / Radiation Protection Logs.
In addition to these record reviews, the inspector independently
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verified clearance order tagouts.
No violations or deviations were identified.
b.
Facility Tours and Observations
Throughout the inspection period, facility tours were conducted to
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observe operations and maintenance activities in progress.
Some
operations and maintenance activity observations were conducted
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during backshifts.
Also, during this inspection period, licensee
meetings were attended by the inspector to observe planning and
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management activities.
The facility tours and observations encompassed the following areas:
security perimeter fence; control room; emergency diesel generator
room; auxiliary building; intermediate building; reactor building;
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battery rooms; and electrical switchgear rooms.
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During these tours, the following observations were made:
(1) Monitoring Instrumentation - The following instrumentation
and/or indications were observed to verify that indicated
parameters were in accordance with the TS for the current
operational mode:
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Equipment operating status; _ area atmospheric and liquid
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radiation monitors; electrical system lineup; reactor operating
parameters; and auxiliary equipment operating parameters.
No violations or deviations were. identified.
(2) . Safety Systems Walkdown - The inspector ' conducted a walkdown of .
the high pressure safety injection system (MU) to verify that
the lineup. was in accordance withclicense requirements for
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system operability and that the system drawing and procedure
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correctly reflect "as-built" plant conditions.
No violations or deviations were identified.
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(3) Shift Staffing. - The inspector verified that operating shift
staffing was in accordance with TS requirements and that' control-
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room operations; were being conducted in an orderly and
professional. manner.
In addition, the inspector observed shift
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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 - Storage of. material and
components and cleanliness conditiuns of various areas
throughout the' facility were observed to determine whether
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safety and/or fire hazards existed.
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No violations or deviations were identified.
(5) Radiological Protection Program - Radiation protection control
activities were observed to verify that these activities were in
conformance with the facility policies and procedures and in
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compliance with regulatory requirements.
These observations
included:
Selected licensee conducted surveys;
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Entry and exit from contaminated areas including step-off
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pad conditions and disposal of contaminated clothing;
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Area postings and controls;
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Work activity within radiation, high radiation, and
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contaminated areas;
Radiation Control Area (RCA) exiting practices; ar,d,
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Proper wearing of personnel monitoring equipment,
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protective clothing, and respiratory equipment.
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Area. postings were independently ' verified' for accuracy.by the
inspectors. . 1The inspectors also reviewed selected Radiation
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WorkLPermits:(RWPs) to verify that the RWP was current and that
- the controls were adequate,
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The implementation of ! theJ licensee's'. As ; Low As Reasonably-
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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 - In'the course of.the monthly activities, the
Resident Inspectors 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
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security force were observed in. the' conduct of daily activities;
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to include; protected and vital area access controls,' searching
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' of personnel, ! packages, and . vehicles, badge issuance and-
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retrieval, escorting lof L visitors, patrols, and , compensatory
posts.
In' addition, the ' Resident 1 Inspectors observed - the
operational status of Closed Circuit Television (CCTV) monitors,
the Intrusion Detection system in the central and secondary
alarm stations, protected. area lighting, protected and vital-
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area barrier integrity, and the. security organization interface
with operations and maintenance.
. Paragraph 9 of this . report addresses the results of a regional
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meeting'regarding improvements in .the plant security.
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No violaticiis or deviations were identified.
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(7)
Fire Protection - Fire protection activities, staffing and
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equipment were observed to verify that fire brigade staffing was
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appropriate and that fire alarms, extinguishing equipment,
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actuating controls, fire fighting equipment, emergency
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equipment, and fire barriers were operable,
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No violations or ve iations were identified.
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(8) Surveillance - Surveillance tests were observed to verify that
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approved procedures were being used; oualified. personnel were
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conducting the tests; tests were adequate to verify equipment
operability; calibrated equipment was utilized; and TS
requirements were followed.
The following tests were observed and/or data reviewed:
- SP-177
Local Leak Rate Test of AHV-1A thru ID;
- SP-310
Loose Parts Monitoring Subsystem Daily and Weekly
Channel Assessment;
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-'SP-317J
- RC. System Water Inventory Balance;
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- SP-333
. Control Rod' Exercises;
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- SP-338
Remote Sfiutdown Panel Operability Verification;
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Emergency feedwater_ Pump
(EFP-2)- Monthly
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Operability Demonstration;
- SP-390'
Startup Surveillam.e Log;
- SP-421
' Reactivity Balance' Calculations;
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- SP-422'
'RC System Heatup and Cooldown' Surveillance;
- SP-702
Reactor Coolant and Decay. Heat Daily Surveillance
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Program; and,
- SP-722
Secondary Coolant Thrice Weekly Surveillance
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' Program.
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As the ' resulti of thtee reviews, the following items were
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identified:
(a) During a review of the completed data'for procedure SP-3498
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that' was completed on August. 31, 'the inspector noted that-
the-- sign-off on Data ' Sheet I for the operability
verification of. check valve EFV-34 was filled in-as "Not
Applicable" indicating that. the valve was not checked for
operability.
Subsequent discussions with licensee
representatives verified that valve operability'was' not
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' checked.
A review of section 4.4 of this procedure, which
lists the acceptance criteria, recuires that this valve be
checked for proper operation.
Additionally, the inspector
noted.that subsecuent licensee supervisory reviews of the
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completed data d:d not identify the -failure. to meet the
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procedure acceptance criteria.
The licensee has received recurrent violations in the last
two inspection reports (see NRC Reports 50-302/87-17 and
50-302/87-19) and 'is presently involved in an attempt ' to
prevent recurrence of these type of violations. When this
violation was identified to licensee representatives, the
following immediate actions were taken:
Procedure SP-3498 was reperformed on September 1 and
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check valve EFV-34 was properly checked for
operability;
The person performing the supervisory review was
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removed from data review duties;
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A working group will be established that will have as
its primary duty the responsibility to review
completed data to assure procedures are properly
completed.
This group will be established when the
present five shift rotation is increased to six
shifts;
In the interim before this working group is
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established, the licensee will station an individual
in the Control Room whose specific job will be to
rcoiew completed procedures for proper completion;
and,
The licensee will conduct special training for
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supervisory personnel
to clarify their duties
regarding document data reviews.
As a result of these activities, this finding will not be
cited pending a review of the effectiveness of these
immediate actions and other corrective actions being
proposed by the licensee.
(b) During the review of procedure SP-422 performed during the
Reactor Coolant System (RCS) cooldown conducted from
August 21 through August 23, the inspector noticed that
this surveillance was stopped at 2:17 PM on August 23 upon
reaching a RCS temperature of 140 F.
A review of the
reactor operatcrs log for this time period, however,
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revealed that the cooldown of the RCS was continued past
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2:17 PM and that at approximately 4:00 PM the RCS
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temperature was 125 F.
The inspector discussed this matter
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with operations personnel and determined that no rate of
RCS cooldown had been calculated for the cooldown from
140 F to 125 F.
Technical Specification (TS) 4.4.9.1.1 requires that during
a RCS cooldown below 170 degrees, the change in RCS
temperature shall be determined to be less than or equal to
10 degrees per hour at least once every 30 minutes.
During
the time interval during which the cooldown rate was not
calculated (approximately one hour and 43 minutes) the RCS
was cooled 15 degrees.
Although the RCS cooldown rate
limit of 10 degrees per hour does not appear to have been
exceeded, failure to determine this cooldown rate at least
once every 30 minutes is contrary to TS 4.4.9.1.1 and is
considered to be a violation.
Violation (302/87-28-02):
Failure to determine the RCS
cooldown rate at least once every 30 minutes as required by
TS 4.4.9.1.1.
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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:
Troubleshooting, repair and retest of Zone 8 of the
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Intrusion Detection System (IDS) in accordance with
procedure SP-808, Intrusion System Performance Test;
Disassembly and removal of the "C" reactor coolant pump
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mechanical seal in accordance with procedure MP-165, RC
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Pump Seal Cartridge Removal and Replacement; and,
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Replacement of the channel head on the "C" nuclear services
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heat exchanger in accordance with procedures PM-112,
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Inspection / Cleaning / Shooting
and' Plugging of Heat
Exchangers, and MP-132, Erection of Piping.
No violations or deviations were identified.
(10) Radioactive Waste Controls - Solid waste. compacting and selected
liquid and gaseous releases were observed to verify that
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approved procedures were utilized, that appropriate release
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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
observed to insure that fluid levels were adequate and no
leakage was evident, that restraint settings were appropriate,
and that anchoring points 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 actions
appeared appropriate.
Events, which were reported immediately, were
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reviewed as they occurred to determine if the TS were satisfied.
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LERs 87-11, 87-12, 87-13, 87-14, 87-15, 87-16, and 87-17 were
reviewed in accordance with the current NRC Enforcement policy.
LERs
87-12, 87-13, 87-15 and 87-16 are closed.
LER 87-11, 87-14 and 87-17 remain open for the following reasons:
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(0 pen) LER 87-11:
This LER reported a reactor trip.that was caused
.by thef failure of a relay in the reactor' coolant pump power' monitor
(RCPPh; system. During a review of this LER the inspector noted that
the failed lock-out relay that prevented the automatic turbine trip
a refueling. outage and that the
was ~ only being checked during(AP) 580, Reactor Protection System-
applicable Abnorma1 ' Procedure
Actuation, did not require. the depressing of the turbine trip button
following a reactor trip.
These . findings were discussed with licensee representatives.
The
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. licensee is reviewing the inspector's findings and based upon this
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review' will determine whether appropriate procedure and/or
surveillance program. changes are necessary.
This LER remains open
pending completion of the licensee's review and determination of
appropriate corrective actions.
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(0 pen) LER 87-14: .This LER reported that personne1' error caused
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surveillance procedure SP-312, Heat Balance Calculations, to not be
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performed within' the allowable time - interval.
The licensee's
corrective; action for this event included counseling of the
individual involved and a review of this LER by the rest of the
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nuclear shift supervisors.
This LER will remain open pending the
licensee's. documentation of the completed corrective action.
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(0 pen)'LER 87-17:
This LER reported the TS required forced entry
into
the . hot
shutdown
mode
(Mode 4) < due
to
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'inoperability of the steam driven emergency feedwater pump.
The
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licensee's corrective action associated with this event will include
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an analysis to determine the emergency feedwater pump capabilities at
. low reactor coolant system temperatures and low , steam system
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pressures.
This LER will remain open pending corroletion of the
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licensee's analysis and subsequent NRC review.
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b..
The inspector reviewed Nonconforming Operations Reports (NCORs) to
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verify the following:
compliance with the TS, corrective actions as
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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 ii. accordance with the current NRC
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As a result of these reviews the following items were identified:
(1) NCOR 87-131 reported that the TS required testing for the
emergency diesel generators exceeded the diesel design loading
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limits established by the manufacturer.
TS 4.8.1.1.2.d.4
requires testing the diesels at a load of greater than or equal
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to 3000 kilowatts (KW) for greater than 60 minutes.
Although
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the licensee has been testing the diesels in this manner, the
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manufacturer recommendations limit diesel operation to no more
than 30 minutes for loads greater than 3000 KW.
The licensee has further determined that the heaviest engineered
safeguards loading sequence (determined from manufacturer
nameplate ratings) which the "A" emergency diesel generator
might be subjected, could be grcater than the 3180 KW described
in the Final Safety Analysis Report (FSAR), Table 8-1, and that
diesel testing to date has only been to a maximum of 3100 KW.
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The licensee is presently reviewing this issue with the diesel
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manufacturer to determine what effect the increased loads would
have on the emergency diesel operation.
This matter is
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considered unresolved pending completion of this determination.
Unresolved Item (3C2/87-28-03):
Determine the effect that
increased emergency diesel generator loading has on diesel
generator operation.
(2) NCOR 87-133 reported that during plant operation, the Nuclear
Services Seawater (RW) system inlet temperature from the
ultimate heat sink (the Gulf of Mexico) has frequently exceeded
the design seawater temperature of 85 F which was used in the
accident analysis.
Previous seawater temperature data indicates
that the ultimate heat sink has reached temperatures equal to or
in excess of 90 degrees on several occasions.
An increase in RW
system inlet temperature could reduce the ability of the RW
system to adequately cool the Nuclear Services Closed Cycle
Cooling (SW) system which, in turn, supplies cooling water to
various safety related pumps and motors.
The licensee is
presently evaluating the effect of this possible temperature
increase and the capability of the SW system to provide adequate
cooling to this system's design heat loads during a design basis
accident.
This matter is considered unresolved pending
completion of the licensee's evaluation.
Unresolved Item (302/87-28-04):
Evaluate the effect that an
increase in RW system operating temperature might have on the
capability of the SW system to provide adequate cooling.
These unresolved items were discussed in a meeting between the
NRC and licensee representatives held on September 4.
During
this meeting licensee representatives stated that they would
resolve these issues prior to the plant startup from the next
refueling outage which is' scheduled to begin September 19, 1987.
(3) NCOR 87-134 reported personnel non-compliance with procedure
CP-113, Handling and Controlling Work Requests and Work
Packages.
During work on a safety related nuclear services heat
exchanger the licensee's mainter.ance personnel noticed that
non-safety related tape material had been used to help seal a
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threaded connection for the installation of the cathodic
protection probes. These probes are not directly safety related
but do form part of the system's safety related pressure
boundary.
Procedure CP-113, step 4.6.8, requires that only
safety related materials are to be installed in safety related
systems.
The licensee has initiated a work request to replace
this tape with safety related material and will conduct an
investigation to determine the root cause for this event.
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This matter is considered to be a licensee identified violation
in which appropriate corrective action was taken to prevent
recurrence.
7.
Design, Design Changes and Modifications
Installation of new or modified systems were reviewed to verify that the
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changes were reviewed and approved in accordance with 10 CFR 50.59, that
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the changes were performed in accordance with technically adequate and
approved procedures, that subsequent testing and test results met
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acceptance criteria or deviations were resolved in an acceptable manner,
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and that appropriate drawings and facility procedures were revised as
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necessary.
This review included selected observations of modifications
and/or testing in progress.
The inspector reviewed modification (MAR) 85-10-01-01, Relay replacement
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for the
"A" Emergency Diesel Generator (EDG-1A) and observed associated
testing conducted in accordance with test procedure TP-1C.
No violations or deviations were identified.
8.
Review of Qualified Reviewer Training and Qualifications
The inspector reviewed the training and qualification status of procedures
Qualified Reviewers to verify compliance with TS requirements.
To
accomplish this review the inspector reviewed a listing that identified
the Qualified Reviewers and their certification expiration dates and
training procedure ST-09, Qualified Reviewer Training.
As the result of this record review, the inspector identified one
Qualifier Reviewer whose certification expired on June 30, 1987.
Subsequent discussions with this individual indicated that this person
continued to be active as a Qualified Reviewer and review of facility
records confirmed at least six instances during the period of July 13-21,
1987, where this individual performed as a Qualified Reviewer.
TS 6.8.2.c requires the training, qualification, and certification of
Qualified Reviewers to be governed by Administrative Procedures.
These
TS requirements are implemented by procedure AI-401, Origination of
and Revisions to P0QAM Procedures.
This procedure requires the training,
qualification, and decertification of the Qualified Reviewers be conducted
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every two years' . Failure to recertify the Qualif ted Reviewer within the
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two year interval .is' contrary to the requirements' of TS 6.8.2.c and is.
- considered to be a violation.
Violation (302/87-28'05):
Failure to recertify the Qualified Reviewers on
-
a periodic. basis as required by TS 6.8.2.c.
9.. -
Systemmatic Asseksment of Licensee Performance (SALP) Improvement
Program
' On September ' 14'. .1987,- the licensee presented to' NRC Region II' staff.
'
members its most recent. SALP improvement program.
The. licensee has
increased its security force, emphasized . drills and practical
demonstrations,. hired _ a new Security Superintendent, devitalized certain
_
non-safety ' related areas, improved equipment, -and, is tracking and
trending its own' internal audit' findings. The licensee also spoke of its
long range security computer upgrade efforts.
.
The licensee agreed that sensitizing of non-security personnel to' their
security' responsibilities should be an on-going effort.
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