ML20235F792

Insp Rept 50-302/87-28 on 870808-0911.Violations Noted.Major Areas Inspected:Plant Operations,Security,Radiological Controls,Lers,Nonconforming Operations Repts,Facility Mods, Qualified Reviewer Training & Action on Previous Insp Items

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: ML20235F715 ML20235F772 ML20235F792
References
50-302-87-28, NUDOCS 8709290320
Download: ML20235F792 (13)

See also: IR 05000302/1987028

Text

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UNITED STATES

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REGION 11

101 MARIETTA STREET,N.W.

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E' ATLANTA, GEORGI A 30323

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Report No: 50-302/87-28

Licensee: Florida Power Corporation

3201 34th Street, South

St. Petersburg, FL 33733

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

Facility Name: Crystal River 3

Inspection Dates: August 8 - September 11, 1987

b Inspectors: m k bb _ fe, k:2N[27

T. E Stetka, Senior Resident Inspector D' ate Signed

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J. Et Tedrow, Resident Intpettor

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Date Signed

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Approved by:3Auu k. i[:L4 /9-)

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.

h9290320870924

G ADOCK 05000302

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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 i

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

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

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

improved door and damper seals; and,

- Installation of control logic that will reposition the control

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) members. g 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).

! 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 ,

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

i 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

l 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;

j_ 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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c 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

l system operability and that the system drawing and procedure

l. correctly reflect "as-built" plant conditions.

No violations or deviations were identified.

l', (3) Shift Staffing. - The inspector verified that operating shift

staffing was in accordance with TS requirements and that' control-

l. room operations; were being conducted in an orderly and

professional. manner. In addition, the inspector observed shift

l 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

i safety and/or fire hazards existed.

L 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  !

compliance with regulatory requirements. These observations

included:

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Selected licensee conducted surveys; 3

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Entry and exit from contaminated areas including step-off j

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

contaminated areas;

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Radiation Control Area (RCA) exiting practices; ar,d,

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Proper wearing of personnel monitoring equipment,

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  :)

WorkLPermits:(RWPs) to verify that the RWP was current and that

the controls were adequate,

i The implementation of ! theJ licensee's'. As ; Low As Reasonably- 1

Achievable (ALARA) program was reviewed:to determine personnel

involvement .in the objectives and goals of the program.

No violations or deviations were identified.

(6) Security Control - In'the course of.the monthly activities, the 1

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 O

security force were observed in. the' conduct of daily activities; .,

to include; protected and vital area access controls,' searching l

' of personnel, ! packages, and . vehicles, badge issuance and- 1

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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- 1

area barrier integrity, and the. security organization interface

with operations and maintenance.

. Paragraph 9 of this . report addresses the results of a regional j

meeting'regarding improvements in .the plant security. <

No violaticiis or deviations were identified. l

(7) Fire Protection - Fire protection activities, staffing and

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equipment were observed to verify that fire brigade staffing was j

appropriate and that fire alarms, extinguishing equipment, }

actuating controls, fire fighting equipment, emergency i

equipment, and fire barriers were operable, q

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No violations or ve iations were identified. l

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

approved procedures were being used; oualified. personnel were

conducting the tests; tests were adequate to verify equipment 1

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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ls - SP-338 Remote Sfiutdown Panel Operability Verification;

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.SP-3498

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Emergency feedwater_ Pump (EFP-2)- Monthly

Operability Demonstration;

- SP-390' Startup Surveillam.e Log;

1. - 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

~1 Program; and,

- SP-722

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Secondary Coolant Thrice Weekly Surveillance

' Program.

r Asi the ' resulti of thtee reviews, the following items were

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 -

' 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 ,

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:

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Procedure SP-3498 was reperformed on September 1 and

check valve EFV-34 was properly checked for

operability;

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The person performing the supervisory review was

removed from data review duties; j

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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;

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In the interim before this working group is

established, the licensee will station an individual

in the Control Room whose specific job will be to

rcoiew completed procedures for proper completion;

and,

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The licensee will conduct special training for

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

l reactor operatcrs log for this time period, however,

l revealed that the cooldown of the RCS was continued past

l 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

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:

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Troubleshooting, repair and retest of Zone 8 of the

Intrusion Detection System (IDS) in accordance with

procedure SP-808, Intrusion System Performance Test;

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Disassembly and removal of the "C" reactor coolant pump

mechanical seal in accordance with procedure MP-165, RC ,

Pump Seal Cartridge Removal and Replacement; and, t

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Replacement of the channel head on the "C" nuclear services

heat exchanger in accordance with procedures PM-112,  !

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

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liquid and gaseous releases were observed to verify that

approved procedures were utilized, that appropriate release

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l 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. l

LERs 87-11, 87-12, 87-13, 87-14, 87-15, 87-16, and 87-17 were

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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

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applicable Abnorma1 ' Procedure being checked during(AP) 580, Reactor Protection System-

Actuation, did not require. the depressing of the turbine trip button

following a reactor trip.

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These . findings were discussed with licensee representatives. The ,

. licensee is reviewing the inspector's findings and based upon this '

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.

c (0 pen) LER 87-14: .This LER reported that personne1' error caused

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

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 the- i

'inoperability of the steam driven emergency feedwater pump. The  !

licensee's corrective action associated with this event will include  !

an analysis to determine the emergency feedwater pump capabilities at

. low reactor coolant system temperatures and low , steam system 1

pressures. This LER will remain open pending corroletion of the I

licensee's analysis and subsequent NRC review. l

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b.. The inspector reviewed Nonconforming Operations Reports (NCORs) to l

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

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

Enforcement Policy. ]

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 l

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 ,

to 3000 kilowatts (KW) for greater than 60 minutes. Although i'

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.

' The licensee is presently reviewing this issue with the diesel

manufacturer to determine what effect the increased loads would

have on the emergency diesel operation. This matter is

! 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

l the changes were performed in accordance with technically adequate and

approved procedures, that subsequent testing and test results met

l acceptance criteria or deviations were resolved in an acceptable manner,

l' 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.

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The inspector reviewed modification (MAR) 85-10-01-01, Relay replacement

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

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a periodic. basis as required by TS 6.8.2.c.

9.. - Systemmatic Asseksment of Licensee Performance (SALP) Improvement

Program

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' 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

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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.

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The licensee agreed that sensitizing of non-security personnel to' their

security' responsibilities should be an on-going effort.

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