IR 05000302/1988018

Insp Rept 50-302/88-18 on 880609-0715.Violations Noted. Major Areas Inspected:Plant Operations,Radiological Controls,Security,Lers,Nonconforming Operations Repts, Review of Bulletins & Actions on Insp Items

ML20151X006
Person / Time
Site:	Crystal River
Issue date:	08/05/1988
From:	Crlenjak R, Holmesray P, Tedrow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20151X000	List: ML20151W996 ML20151X002 ML20151X006
References
50-302-88-18, IEB-88-003, IEB-88-3, NUDOCS 8808250195
Download: ML20151X006 (12)

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UNITED STATES l

1. pm M4g% NUCLEAR REGULATORY COMMISSION  !

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101 MARIETTA STREET, #

2 ATLANTA, G EORGI A 30323

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Report No: 50-302/88-18 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: June 9 - July 15, 1988 Inspectors: N.O- '

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P. Holmes-Ray, Senior Residenf Inspector kJ/98 Date' Signed 140. g,A3do-% ),, s/s-/ es J. Tedro , esi ent Inspector F Oatd Signed Approved by: /. -

~M R. jfflehjak, Secfion ChiefV _

6 Jf8 BageSigned

Division of Reactor Projects

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SUMMARY f Scope: This routine inspection was conducted by two resident inspectors in the areas of plant operations, radiological controls, security, Licensee Event Reports and Nonconforming Operations Reports, facility modifications, annual emergency drill, review of special reports, review of NRC bulletins, and licensee action on previous inspection item Numerous facility tours were conducted and facility operations observe Some of these tours and observations were conducted on backshift Results: Two violations were identified: Failure to properly evaluate and report excessive temperatures in emergency feedwater piping, paragraph 3.b(1);

Failure to provide adequate corrective actions to prevent exceeding the design '

temperature of emergency feedwater piping, paragraph 3.b(1).

The licensee's decision to operate the plant since January 1988 with a bonnet leak from check valve EFV-18 is considered by the inspectors to be a nonconservative operational decision, particularly since a plant shutdown in j February 1988 provided an opportunity to repair this leak. This matter is discussed in more detail in paragraph 3.b(1).

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REPORT DETAILS

, Persons Contacted

. Licensee Employees

• J. Alberdi, Manager, Nuclear Plant Technical Support T. Austin, Principal Nuclear Mechanical Engineer G. Becker, Manager, Site Nuclear Engineering Services

• P. Breedlove, Nuclear Records Management Supervisor D. Brown, Nuclear Electrical / Instrumentation and Control Supervisor

• Clary, Principal Nuclear Mechanical Engineer

• Collins, Superintendert, Nuclear Safety and Reliability

• J. Cooper, Superintendent, Technical Support

• P. Ezzell, Radiochemistry and Environmental Specialist

• J. Frijouf, Nuclear Regulatory Specialist

• R. Fuller, Senior Nuclear Licensing Engineer

• B. Hickle, Manager, Nuclear Plant Operations

• H. Koon, Assistant Superintendent, Nuclear Maintenance

• G. Longhouser, Superintendent, Nucleer Security

• W. Marshall, Superintendent, Nuclear Operations P. McKee, Director, Nuclear Plant Operations

• J. Roberts, Superintendent, Nuclear Chemistry / Radiation

• V. Roppel, Manager, Nuclear Operations Maintenance and Outages

• Rossfeld, Manager, Nuclear Compliance

• J. Smith, Nuclear Regulatory Specialist W. Squires, Nuclear Modification Specialist

• R. Stevens, Senior Nuclear Quality Assurance Specialist

• E. Welch, Manager, Nuclear Electrical / Instrumentation ar.d Control Ergineering Services K. Wilson, Manager, Nuclear Licensing

• R. Wittman, Superintendent, Nuclear Operations

• D. Worley, Manager, Nuclear Chemistry

. Other licensee employees contacted included office, operations, engineering, maintenance, chemistry / radiation and corporate personne !

* Attended exit interview

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Acronyms and initialisms used throughout this report are listed in paragraph 1 . Review of Plant Operations (71707)

l The plant continued in power operation (Mode 1) for the duration of this

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inspection period.

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2 Shift. Logs and Facility Records'(71707)

The inspector reviewed records and discussed various entries with

. operations personnel to verify compliance with the Technical Specifications (TS) and the licensee's administrative procedure '

The following records were reviewed:

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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 Log In addition to these record reviews, the inspector independently verified clearance order tagout No violations or deviations were identifie Facility Tours and Observations (71707)

Throughout the inspection period, facility tours were :.:onducted to observe operations and maintenance activities in progres Some operations and maintenance activity observations were conducted during backshifts. Also, during this inspection period, licensee.

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meetings were attended by the inspector to observe planning and management activitie The facility tours and observations encompassed the following areas:

security perimeter fence; control room; emergency diesel generator room; auxiliary building; intermediate building; battery rooms; and electrical switchgear room During these tours, the following observations were made:

(1) Monitoring Instrumentation -

The following instrumentation and/or indications were o'o served 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 parameter No violations or deviations were identifie (2) Safety Systems Walkdowr (71710) - The inspector conducted a walkcown of the High Pressure Injection System to verify that the lineup was in accordance with license requirements for system operability and that the system drawing and procedure correctly reflected "as-built" plant condition _ _ - -

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No violations or deviations were identifie . (3) Shift Staffing (71707) - The inspector verified that operating shif t staffing was in accordance with TS requirements and th '

. control room operations were being conducted in an orderly and

-. professional manner. In addition, the inspector observed shif t turnovers en various occasions to verify the continuity of plant status, operational problams, and other pertinent plaat information during these turnover .

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No violations or deviations were identifie (4) Plant Housekeeping Conditions (71707) - Storage of material and components, and cleanliness conditions of various areas

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throughout the facility were observed to determine whether safety and/or fire hazards existe No violations or deviations were identifie (5) Radiological Protection Program (71709) - Radiation protection control activities were observed to verify that these activities were in conformance with the facility policies and procedures, and in compliance with regulatory requirement These observations included:

- Selected licensee conducted surveys;

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Entry to and exit from contaminated areas, including step-off pad conditions and disposal of contaminated clothing;

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Area postings and controls; i

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Work activity within radiation, high radiation, and l-contaminated areas;

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Radiatien Control Area (RCA) exiting practices; ond

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Proper wearing of personnel monitoring equipment, protective clothing, and respiratory equipment.

I Area postings were independently verified for accuracy by the

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- inspector. The inspector also reviewed selected Radiation Work t

i Permits (RWPs) to verify that the RWP was current and that the

, controls were adequat The implementation of the licensee's As Low As Reasonably Achievable (ALARA) program was reviewed to determine personnel involvement in the objectives and goals of the progra .' No violations or deviations were identifie (6) Security Control (71881) -

In the course of the Tcnthly ,

activities, the inspector included a review of the licensee's physical security progra The composition of the security organization was checked to insure that the minimum number of

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guards were available and that security activities were canducted with proper supervision. The cerformance of various shifts of the security force was observed in the conduct of daily activities to include: protected ar.d vital area access controls; searching of personnel, packages, and vehicles; badge issuance and retrieval; escorting of visitors; patrols; and compensatory post In addition, the inspector 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 area barrier integrity, and the security organization interface with operations and maintenanc No violations or deviations were identifie (7) Fire Protection (71707) - Fire protection activities, staffing and equipment were observed to verify that fire brigade staffing was appropriate and that fire alarms, extinguishing equipment, actuating controls, fire fighting equipment, emergency equipment, and fire barriers were operabl No violations or deviations were identifie (8) Surveillance (61726) -

Surveillance tests were observed to verify that approved procedures were being used; qualified personnel were conducting the tests; tests were adequate to verify equipment operability; calibrated equipment was utilized; and TS requirements were followe The following tests were observed and/or data reviewed:

- SP-141, Operability and Functional Check of Valve Moni+.oring System;

- SP-?17, RC Water Inventory Balance;

- SP-3408, "B" Train ECCS Pump and Valve Operability; and

- SP-343, Main Steam Isolation Valves Part-Stroke Exercisin No violations or deviations were identifie (9) Maintenance Activities (62703) - The inspector observed maintenance activities to verify that correct equipment clearances were in effect; work requests and fire prevention work permits, as required, were issuad and being followed; quality control personnel were available for inspection activities as required; and TS requirements were being followe Maintenance was observed and work packages were reviewed for the following maintenance activities: . l

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Repair of emergency feedwater pipe support EFH-126 in accordance with procedure MP-804, Installation of Concrete Anchor Bolts and Integrity Verification, and modification PAR 88-06-12-01;

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Leak repair on emergency feedwater check valve EFV-18 in accordance with procedure SNP-242, Leak Repair of EFV-18, and modification MAR 88-06-13-01; and

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Troubleshooting and calibration of the sodium hydroxide tank level transmitter (BS-3-LT) in accordance with procedure MP-531, Troubleshooting Plant Equipmen No violations or deviations were identifie (10) Radioactive Waste Controls (71707) - Selected liquid and gaseous releases were observed / reviewed to verify that approved procedures were utilized, that appropriate release approvals were obtained, and that required surveys were take No violations or deviations were identifie (11) Pipe Hangers and Seismic Restraints (71707) - Several pipe hangers and seismic restraints (snubbers) on safety-related systems were observed to assure fluid levels were adequate and no leakage was evident, restraint settings were appropriate, and anchoring points were not bindin Ne violations or deviations were identifie . Review of Licensee Event Reports (92700) and Nonconforming Operations Reports (71707) Licensee Event Reports (LERs) were rev'ewed for potential generic impact, to detect trends, and to determine whether corrective actions appeared appropriat Events that were reported immediately were reviewed as they occu-red to determine if the TS were satisfie LERs 88-05 and 88-13 were reviewed in accordance with the current NRC Enforcement Polic (1) (Closed) LER 88-05: This LER reported the failure to enter the TS action statement for exceeding the maximum stroke time for a containment isolation valve. This event has been reviewed by all licensed operator LER 88-05 was further discussed in Inspection Report 302/88-1 (2) (0 pen) LER 88-13: This LER reported that the control room ventilation (HVAC) control air tubing did not meet seismic requirement The licensee made a one hour verbal report of this matter to the NRC on June 10, 1988, and in a letter to the NRC dated June 22, 1988 provided a justification for continued

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power operation of the plant. The inspector verified completion I

of the licensee's short term corrective action as stated in this LER, however the licensee's long term corrective actions are not i

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yet completed. This LER will remain open pending completton of the long term corrective action !

' The inspector reviewed Nonconforming Operations Reports (NCORs) to verify the following: TS are complied with, 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 T All NCORs were reviewed in accordance with the current NRC Enforcement Polic (1) NCOR 88-81 was written on June 19, 1988 to identify feedwater temperatures, which were higher than normal in Emergency Feedwater Pump (EFP) discharge pipin The higher temperatures in this piping occurred when a bonnet leak developed on check i valve EFV-18. This leak caused a slight decrease in system pressure which allowed high temperature feedwater from the Once Through Steam Generator (OTSG) to backflow through another check valve (FWV-43) into the normally cool Emergency Feedwater (EF)

line. The licensee measured the piping surface temperature and the corresponding temperature on the piping's penetration into the reactor butiding (penetration #109) to be approximately 480 degrees ra hrenheit (F) and 272 F, respectively. Concrete .

surfaco temperatures at the penetration reached approximately 195 F. On June 21. 1988, the licensee determined that the 110 F design temperature for this piping and penetration had been exceeded, and reported this situatioa to the NR The licensee has experienced several previous problems with excessive temperatures in the EF piping. LER's 82-76 and 83-43, i

dated December 20, 1982 and October 3, 1983, respectively,

. reported increased temperatures in this piping which rendered ,

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flow instrumentation inoperable. In these events, the licensee was able to cool the affected piping by running the emergency i feedwater pump and supplying relatively cold water to the OTSG.

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This actica was successful in seating the chock valves, which stopped the backflow Jf hot temp'erature feedwater into the EF lin However, during these evants the licensee did not recognize or analy:e the effect that the increased temperatures had on tnis pipin Further overtemperature events have  ;

occurred on the following dates:

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- On March 8, 1988 licensee operations personnel found this piping l to have a surface temperature of approximately 300-400 F. An engineering question was written (EQ#88-1191) to request assistance to determine if this piping was designed for this ,

temperaturs,. Again the licensee was able to cool the EF lines f

by running the EFP, The raquested engineering evaluation was never performed and although the design temperature for this l

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piping had been exceeded, no report of this event was made to

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0n- May 27, 1988 the Shift Operations Technical Advisor  ;

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, warmer thatL normal. This situation was discussed with the

' Nuclear Shift Supervisor and the EFP was .run to cooldown the piping. However, this~ action was-insufficient to prevent the -

backflow from the OTSG and several successive -attempts were !

required on June 6, E,10,12, and 19 to cool the piping with ,

the EFP. On June 22,1988, the licensee installed a temporary i modification (MAR T88-06-11-01) to -provide a' small pump to ,

inject the water leaking from valve EFV-18 back into the E :l

- line. This modification prevented the decrease in system ,

pressure and thereby stopped the backflow from the OTS !

After reviewing NCOR 88-81 on June 20, tha inspector performed'a quick review (approximately I hour) of Chapter 5 of the Final Safety Analysis Report and piping specification . R0-2891, and obtained preliminary information which indicated that this event :

was reportable under 10 CFR 50.72. This preliminary determina-

, . tion was communicated to licensee management personnel on June <

2 The licensee reported this event at 11:15'a.m. on June 2 ;

Regulation 10 CFR 50.72(b)(ii)(B) requires that any event that results in a nuclear power plant being in a. condition that 'is outside the design basis of the plant be reported to the NRC Operations Center within one hour. The failure'.to properly -

i evaluate and report the March 8 EF overtemperature event, and

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the delay in reporting the June 19 event until approximately ;

11:15 a.m. on June 21, is contrary to the requirements of 10 CFR ;

50.72, and is considered to be a violatio l Violation (302/88-18-01): Failure to properly evaluate and s

report excessive terperatures in the EF pipin '

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The repetitive nature of the events reported by LERs 82-76 and

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83-43, and subsequent events en March 8, May 27, and June 6 ,

tnrough 19, 1988 is evident of the licensee's inability to !

erovide adequate corrective action Failure to provide ;

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adequate corrective actions is contrary to the requirements of 10 CFR 50, Appendix B, Criterion 16 and is considered to be a '

violation.

Violation (302/88-18-02)

Failure to provide adequate corrective actions to prevent exceeding the design temperature of the EF system piping and asscdated penetratio l t

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In correspondence to the NRC dated June 28, 1988 and July 5, 1988, the licensee stated their justification for continued power operation with temporary repairs to the. leaking valves and committed to shut down the plant by October 15, 1988 to effect permanent repairs. A Confirmatory Action Letter was issued by the NRC on July 6, 1988 which concluded that continued operation was acceptable to the NRC and confirmed the licensee's commitments to effect permanent repair . Design, Design Changes and Modifications (37700)

Installation of new or modified systems were reviewed to verify that the changes were reviewed and approved in accordance with 10 CFR 50.59, that the changes were performed in accordance with technically adequate and approved procedures, that subsequent testing and test results r..e t acceptance criteria or deviations were resolved in an acceptable manner, and that appropriate drawings and facility procedures were revised as necessary. This review included selected observations of modifications and/or testing in progres The following modification approval records (MARS) were reviewed and/or associated testing observed:

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MAR 88-06-13-01, Repair Leak on Valve EFV-18;

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MAR T88-06-11-01, Temporary Installation of Pump Between Valves EFV-18 and EFV-65;

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MAR T88-06-03-01, Emergency Operating Gas for Valves CHV-56 through CHV-59; and

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MAR 88-06-12-01, Repair of Pipe Support EFH-126, 5. Annual Emergency Drill (82301)

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On June 9, 1988, the annual emergency drill was conducted by the licensee to verify the effectiveness of the Radiological Emergency Response Plan and implementing procedure In addition to the licensee, the participants in the drill included the State of Florida, Citrus and Levy Counties, and the NR The drill was observed by a number of personnel, including the NRC. Details of the drill, including the results of the critiques held on June 10, 1988, are discussed in NRC Inspection 9eport 50-302/88-1 . Review of Special Reports (90713)

The licensee submitted a special report dated July 13, 1988 regarding a discrepancy between the containment leakage test pressure (Pa-49.6 psig)

specified in the TS and the maximum containment accident pressure possible (52.6 psig). To assure that the containment leakage test pressure bounds the possible accident pressure, the licensee plans to revise the TS to increase Pa to 52.6 psig. The applicable surveillance procedures will also be revised to reflect the higher test pressure prior to their next performanc _

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IFI (302/88-18-03): Review the revisions to TS and applicable surveillance procedures to reflect a Pa of 52.6 psi . Review of NRC Bulletins (92703)

In a letter dated June 15, 1988, the licensee responded to the actions requested in Bulletin 58-03, General Electric HFA Latching Relays. The response letter stated that the licensee does not use the latching relays discussed in the bulletin Action on this item is considered complete and this bulletin is close . Licensee Action on Previously Identified Inspection Findings (92702 &

92701) (Closed) Violation 302/88-01-01, Failure to Implement the Requirements of Plant Procedure The inspector reviewed and verified the implementation of the corrective i.ctions stated in the FPC response letter dated April 7, 198 (Closed) IFI 302/88-01-05, Review the Licensee's Revision to Procedure SP-523, Station Battery Service Test, to Reflect the Actual Battery Load Profil The licensee has revised procedure SP-523 (revision 21 dated June 7, 1988) to reflect the correct load profile, (Closed) IFI 302/88-01-02, Review the Installation of Plant Modifications to Return the "C" Inverter (VBIT) to Operable Statu The inspector reviewed the installation of two modifications, MAR T86-03-04-07, Inverter VBIT-1C Input Voltage Relay Interlock, and MAR 86-03-04-06, FCN#2, Inverter / Static Switch Adjustable Power Resistor, and associated testin (Closed) IFI 302/87-30-04, Review Retest of Valve CFV-5 Not Fully Open Alarm in Accordance with Procedure SP-402, Core Flooding System Isolation Valves Alarms Actuatio The licensee has installed modification MAR 86-10-14-01A to add supports to the valve limit switch actuators and has performed l

procedure SP-402 on January 4,1938 satisfactoril (0 pen) IFI 302/89-11-04, Review the Licensee's Corrective Action For Preventing Main Steam Isolation Valve Closure During Procedure SP-34 The licensee is developing modification MAR 88-05-11-01 which will modify the test circuit for these valves so that the operator can stop the stroking by simply releasing the test pushbutton. This MAR

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will also address any design problems identified with the valve limit switches. The MAR is presently scheduled to be installed during refuel 7 in September 1989.

j (0 pen) IFI 302/88-11-03, Review the Licensee's Activities to Cleanup the Borated Water Storage Tank Room and Evaluate the Corrosion Effects of Sodium Hydroxid The licensee has determined that the component materials in the area

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of sodium hydroxide leakage are compatible with sodium hydroxide. An l inspection of the cleaned surfaces was made by engineering personnel and no significant damage was discovered. The licensee has written numerous work requests (WR 102377 through 102386) to repair leaking fittings / flanges and to recoat exposed surface This work is presently scheduled for accomplishment in refuel 7 in Sept 9mber 198 In the interim the licensee has established a monthly cleanup /

inspection of this room.

, (0 pen) IFI 302/88-06-02, Review the Licensee's Investigation into l

Similar Causes for Failure of Control Rod Drive Breakers to Re-clos The licensee could not positively determine if a generic cause was

present in the failure of the breakers to re-close. However the licensee has decided to replace 4.11 relays in the source interrupt device / shunt trip circuitry for both breakers to prevent possible contact sticking (WR 103156).

On June 29, 1988, during the performance of procedure SP-110, Reactor Protective Functional Testing, a replacement control rod drive breaker failed to re-clos This breaker (#AC-1B) was the same breaker which failed to re-close on March 1, 1988. The licensee has been unable to find the cause for this condition and has decided to send the breaker back to the manufacturer for root cause analysis for the failur . Exit Interview (30/03)

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

at the conclusion of the inspection on July 15, 199 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 and IF 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 inspectio %.

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10. Acronymt and Initialisms ALARA - As Low As Reasonably Achievable CCTV -

Closed Circuit Television CFR -

Code of Federal Regulations ECCS -

Emergency Core Cooling System EF -

Emergency Feedwater EFP -

Emergency Feedwater Pump F -

Fahrenheit ,

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Field Change Notice FPC -

Florida Power Corporation IFI -

Inspector Followup Item ISI -

Inservice Inspection LER -

Licensee Event Report MAR -

Modification Approval Record NCOR -

Nonconforming Operation Report NRC -

Nuclear Regulatory Commi ssion 0TSG -

Once Through Steam Generator PM -

Preventive Maintenance psig -

pounds per square inch gage RCA -

Radiation Control Area RC -

Reactor Coolant RWP -

Radiation Work Permit SP -

Surveillance Procedure STI -

Short Term Instruction TS -

Technical Specification VIO -

Violation WR -

Work Request l

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