ML20127K964

Insp Rept 50-302/85-19 on 850329-0425.Violations Noted: Failure to Have Adequate Corrective Action Sys & Failure to Follow Refueling Procedures

ML20127K964
Person / Time
Site:	Crystal River
Issue date:	05/14/1985
From:	Panciera V, Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127K951	List: IR 05000329/2004025 ML20127K947 ML20127K964
References
50-302-85-19, NUDOCS 8506270680
Download: ML20127K964 (11)

See also: IR 05000302/1985019

Text

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p2 Kro UNITED STATES

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NUCLEAR REGULATORY COMMISSION

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k I )h f., 101 MARIETTA STREET, N.W.

• i e ATLANTA, GEORGI A 30323

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Report No.: 50-302/85-19

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 Date: March 29 - April 25, 1985

Inspector: # $ Mj 8Eate /Y

Signed

N

T. F. Stetka, SeniomWent Ingctof ~

Accompanying Personnel: J. E. Tedrow, Resident Inspector

Approved by: - [ 98[

V.W.Panciera, Chief,poj(ctSection28, Q(teSigned

Division of Reactor Projects

SUMMARY

Scope: This routine inspection involved 108 inspector-hours on site by two

resident inspectors in the areas of plant operations, security, radiological

controls, Licensee Event Reports and Nonconforming Operations Reports, refueling

activities, and licensee action on previous inspection items. Numerous facility

tours were conducted and facility operations observed. Some of these tours and

observations were conducted on backshifts.

Results: Two violations were identified (failure to have an adequate correc-

tive action system, paragraph 3; and failure to follow refueling procedures,

paragraph 7).

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8506270680 850517

PDR ADOCK 05000302

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• J. Alberdi, Manager, Site Nuclear Technical Services

• J. Andrews, Nuclear Plant Engineer I

• G. Boldt, Nuclear Plant Operations Manager

• E. Bosworth, Nuclear Electrical /I&C Supervisor

• J. Bufe, Nuclear Compliance Specialist

• M. Collins, Nuclear Safety & Reliability Superintendent

• J. Cooper, Jr., Manager, Site Nuclear Quality Control

• D. Green, Nuclear Licensing Specialist

• K. Hakken, Chief Nuclear Technical Sunport Technician

• V. Hernandez, Senior Nuclear Quality Assurance Specialist

E. Howard, Director, Site Nuclear Operations

• W. Johnson, Nuclear Plant Engineering Superintendent

• H. Koon, Senior Nuclear I&C/ Electrical Supervisor

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• P. McKee, Nuclear Plant Manager

• D. Nash, Nuclear Master Mechanic

• V. Roppel, Nuclear Plant Engineering and Technical Services Manager

• W. Rossfeld, Nuclear Compliance Manager

• P. Skranstad, Nuclear Chemistry & Radiation Protection Superintendent

• J. Smith, Nuclear Shift Supervisor

• W. Stephenson, Nuclear Operations Engineer

• R. Thompson, Nuclear Mechanical / Structural Engineering Superintendent

• R. Widell, Manager, Nuclear Operations Engineering

• K. Wilson, Supervisor, Site Nuclear Licensing

>

Other personnel contacted included office, operations, engineering, main-

tenance, chem / rad and corporate personnel.

• Attended exit interview

2. Exit Interview

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

the conclur'on of the inspection on April 25, 1985. During this meeting,

the inspectocc summarized the scope and findings of the inspection as they

are detailed in this report with particular emphasis on the violations,

unresolved item, and inspector followup items.

The licensee did not identify as proprietary any of the materials provided

to or reviewed by the inspectors during this inspection.

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3. Licensee Action on Previous Inspection Items

(Closed) Unresolved Item (302/83-11-03): Procedure SP-179 was revised on

April 3 to prohibit a change in the test method by the test engineer. As

presently written, the only way a test method change can be made is by a

procedure revision in accordance with the procedure revision process.

(Closed) Inspector Fol10wup Item (302/85-04-01): The licensee has revised

procedure SP-110, Reactor Protection System Functional Testing, to require

that a separate verification be made to ensure that the isolation valve for

the main feedwater turbine control oil pressure switches is fully opened.

In addition, the licensee has added additional verification requirements to

ensure that similar switches that monitor the main turbine control oil

pressure are properly returned to service.

(0 pen) Unresolved Item (302/84-22-06): The inspector reviewed the

licensee's activities with respect to the annunciator response procedures to

determine if the procedures were revised. This review identified that the

following discrepancies still existed:

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AP-305, ESA Annunciator Response, the cause and operator response

procedures for annunciator E-1-5 "RB TEMP TROUBLE" are blank;

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AP-603, TGF0 Annunciator Response, the operator response procedure for

annunciator 0-1-10 " GEN BRG OIL DRAIN TK PRESS HI" is blank;

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AP-701, SSFP Annunciator Response, the cause and operator response

procedures for annunciator P-3-10 "230 KV GRID DEGRADING" are blank;

and,

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AP-703, SSFR Annunciator Response, page 4 has a list of annunciators

with their respective causes and actions. The annunciator panel,

mounted on the main control panel, has these applicable annunciator

windows blank. Therefore, it is not clear whether the annunciator

procedure is incorrect (i.e., the annunciators do not exist) or the

annunciator panel has not been properly updated.

When this item was identified in August 1984, it was considered to be a

licensee identified violation because the licensee had already identified

the problem and had in progress a program to correct the deficiencies. At

that time the licensee committed to have these deficiencies corrected by

December 31, 1984, and the inspector was informed subsequent to this date

that the deficiencies had been corrected.

The recent findings are indicative that the licensee's corrective action

program is ineffective. Failure to have an adequate corrective action

system is contrary to the requirements of 10 CFR 50, Appendix B,

Criterion XVI and is considered to be a violation.

Violation (302/85-19-01): Failure to have an adequate corrective action

system.

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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 devia-

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tions. A new unresolved item identified during this inspection is discussed

i in paragraph 5.b of this report.

5. Review of Plant Operations

The plant remained in the Refueling Mode (Mode 6) for the duration of this

inspection period. On April 7, 1985, the reactor was defueled for a 10 year

inservice inspection of the reactor vessel and a reactor core barrel bolt

inspection.

a. Shift Logs and Facility Records

The inspector reviewed records and discussed various entries with

operations personnel to verify compliance with the Technical Specifica-

tions (TS) and the licensee's administrative procedures.

The following records were reviewed:

Shift Supervisor's Log; Reactor Operator's Log; Equipment Out-of-

Service Log; Shift Relief Checklist; Auxiliary Building Operator's Log;

Active Clearance Log; Daily Operating Surveillance Log; Work Request

Log; Short Term Instructions (STIs); selected Chemistry / Radiation

Protection Logs; outage Shift Manager's Log and Refueling Logbook.

In addition to these record reviews, the inspector independently

verified clearance order tagouts.

No violations or deviations were identified.

b. Facility Tours and Observations

Throur.hout the inspection period, facility tours were conducted to

observe operations and maintenance activities in progress. Some

operations and maintenance activity observations were conducted during

backshifts. Also, during this inspection period, licensee meetings

were attended by the inspector to observe planning and management

activities.

The facility tours and observations encompassed the following areas:

Security Perimeter Fence; Control Room; Emergency Diesel Generator

Room; Auxiliary Building; Intermediate Building; Battery Rooms;

Electrical Switchgear Rooms; and Reactor Building.

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During these tours, the following observations were made:

(1) Monitoring Instrumentation - The following instrumentation was

observed to verify that indicated parameters were in accordance ,

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with the TS for the current operational mode: '

Equipment operating status; Area, atmospheric and liquid radiation

monitors; Electrical system lineup; Reactor operating parameters;

j and Auxiliary equipment operating parameters.

During a plant tour on March 29, 1985, the inspector observed that the  :

l air start system reservoir for the "A" Emergency Diesel Generator

(EDG-3A) was approximately 200 psig instead of the normal pressure of

i about 250 psig. The inspector also noted that the AC air compressor, r

which normally controls air start . reservoir pressure, was not

, operating. Further investigation revealed that the control switch for

the AC air compressor was in the "off" position rather than the normal

. " auto" position. The inspector discussed these findings with licensee

representatives who took immediate action to restore the air start

reservoir pressure to 250 psig. Licensee representatives stated that

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the air start reservoir pressure was being maintained by manual opera-  ;

tion of the AC air compressor due to a bad pressure switch on the '

compressor. The inspector reviewed procedure SP-301 (Shutdown Daily

Surveillance Log) to determine previous air reservoir pressure. The

, inspector found that the previously logged value for the air start

i system was greater than 215 psig as required by the procedure. On

review of the Final Safety Analysis Report (FSAR), the inspector noted

that chapter 8 states that the emergency diesel generator air start

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system will provide 225-250 psi starting air and that sufficient air is

stored in the air reservoirs for 6 successive start atempts. To

determine if other variations in air start system required pressure

existed, the inspector reviewed additional procedures and the emergency

diesel generator technical manual. On review of procedures SP-300

(Operating Daily Surveillance Log) and SP-354A/8 (Emergency Diesel

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Generator Monthly Test) the inspector found that these procedures also

require an air start system pressure of 215 psig or greater. Although

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the technical manual for the emergency diesel generator states that air

start system pressure must be at least 150-250 psi to ensure a positive

start, it is not clear if an air start system pressure of 200 psig can

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meet the design basis capacity of the air start reservoirs as stated in .

, the FSAR. Licensee representatives could not verify that the reduced  !

air start reservoir pressure can meet the FSAR commitments and have

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contacted the vendor for analysis. This matter is considered

unresolved pending completion of the vendor analysis.

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Unresolved Item 302/85-19-02): Review vendor's analysis on the

! Emergency Diesel Generator Air Start System to determine the pressure

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required to satisfy FSAR commitments.

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(2) Safety Systems Walkdown - The inspector conducted a walkdown of

the Reactor Building Spray (BS) system to verify that the lineups

were in accordance with license requirements for system

operability and that system drawings and procedures correctly

reflect "as-built" plant conditions.

As a result of this walkdown the following items were identified

and were discussed with licensee representatives at completion of

the walkdown and during the exit meeting:

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Building Spray Valve (BSV)-169 and BSV-167 identification

labels in the field do not match the system drawing. It

appears that the labels may be reversed;

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A drain valve physically located between BSV-166 and BSV-63

has no identification label and does not appear on the system

drawing; and,

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Drain valve BSV-170 is incorrectly located on the system

drawing. The valve is actually located between BSV-161 and

BSV-165. I

The inspector noted that these findings appear to be on a recently

completed modification to the system in which the system drawing

was not properly revised. While these findings were considered to

be minor and not indicative of a programmatic breakdown, further

discussions with licensee representatives emphasized the major

modification outages the plant is presently in and that proper

drawing revision is a necessary part of the modification process.

The licensee acknowledged the inspector's comments and stated that

appropriate action will be taken to correct the BS system drawing.

(3) Shift Staffing - The inspector verified that operating shift

staffing was in accordance with TS requirements and that control

room operations were being conducted in an orderly and profes-

sional manner. In addition, the inspector observed shift turn-

overs on various occasions to verify the continuity of plant

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status, operational problems, and other pertinent plant informa-

tion during these turnovers.

No violations or deviations were identified.

(4) Plant Housekeeping Conditions - Storage of material and components

,

and cleanliness conditions of various areas throughout the facil-

ity were observed to determine whether safety and/or fire hazards

existed.

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While conducting a walkdown of the BS system, the inspector

noticed that the Reactor Building Spray Tank (BST-1) Room had

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protective clothing and debris scattered on the floor near

the door. Escorting technicians also noted the debris and

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began cleaning the area. Licensee housekeeping practices in other

areas of the plant have been eff ective; however, due to the

limited access to this room, it appears that housekeeping

practices had degraded in this area. During the exit meeting,

licensee management acknowledged the inspector's remarks on this

issue and will assure that housekeeping in this area is routinely

monitored.

(5) Radiation Areas - Radiation Control Areas (RCAs) were observed to

verify proper identification and implementation. These observa-

tions included selected licensee conducted surveys, review of

step-off pad conditions, disposal of contaminated clothing, and

area posting. Area postings were independently verified for

accuracy through the use of t'ne inspector's own radiation

monitoring instrument. The inspector also reviewed selected

radiation york permits and observed personnel use of protective

clothing respirators, and personnel monitoring devices to assure

that the licensee's radiation monitoring policies were being

folicwed.

No violations or deviations were identified.

(6) Security Control - Security controls were observed to verify that

security barriers are intact, guard forces are on duty, and access

to the Protected Area (PA) is controlled in accordance with the

facility security plan. Personnel within the PA were observed to

ensure proper display of badges and that personnel requiring

escort were properly escorted. Personnel within vital areas were

observed to ensure proper authorization for the area.

No violations or deviations were identified.

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

ment were observed to verify that fire brigade staffing was

appropriate and that fire alarms, extinguishing equipment,

actuating controls, fire fighting equipment, emergency equipment,

and fire barriers were operable.

No violations or deviations were identified.

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

approved procedures were being used; qualified personnel were

conducting the tests; tests were adequate to verify equipment

operability; calibrated equipment, as required, were utilized; and

TS requirements were followed.

The following tests were observed and/or data reviewed:

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SP-200, Hydraulic Snubber Functional Testing;

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SP-220, Source Range Functional Tests During Refueling

Operations;

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SP-523, Station Batteries Service Test; and

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SP-532, Reactor Building Main and Auxiliary (FHCR-1 and

FHCR-2) Fuel Handling Bridges Electrical Interlock

Surveillance.

No violations or deviations were identified.

(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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Rebuild and replace an oil seal on Reactor Building Spray

Pump 1A (BSP-1A) in accordance with modification (MAR)

T80-04-89;

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Replace pump casing flange gasket on Makeup Pump 18 (MVP-1B)

in accordance with maintenance proceudre MP-126;

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Cyclone separator piping modification on BSP-1A and BSP-1B

and hydrostatic test performed in accordance with MAR

84-01-18-03 and MP-137.

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Installation of flex hose on makeup pump suction relief

valves MUV-61, MUV-67, and MUV-71, in accordance with MAR

83-11-02-01;

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Change out of the Second Level Undervoltage Relays (SLUR) in

accordance with MAR 84-04-26-01; and,

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Inspection and maintenance on Emergency Diesel Generator IB

(EDG-1B) in accordance with SP-605 and MP-122.

No violations or deviations were iCentified.

(10) Radioactive Waste Controls - Selected liquid releases and trash

compacting were observed to verify that approved procedures were

utilized, that appropriate release approvals were obtained, and

that required surveys were taken.

No violations or deviations were identified.

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(11) Pipe Hangers and Seismic Restraints - Several pipe hangers and

seismic restraints (snubbers) on safety-related systems were

observed to ensure 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 corrected actions

appeared appropriate. Events, which were reported immediately, were

reviewed as they occurred to determine if the TS were satisfied.

LERs85-001, and 85-002 were reviewed in accordance with current NRC

enforcement policy and were closed.

b. The inspector reviewed nonconforming operations reports (NCORs) to

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

identified in the reports or during subsequent reviews have been

accomplished or are being pursued for completion, generic items are

identified and reported as required by 10 CFR Part 21, and items are

reported as required by TS.

All NCORs were reviewed in accordance with the current NRC enforcement

policy.

(1) NCOR 85-62 reported that two motor operated reactor coolant valves

(RCV-11 and RCV-13) had damaged insulation exposing bare

conductors within the motor operator. The condition appears to

have been caused by exposure to prolonged excessive heat, as these

valves are located near the top of the pressurizer inside the

reactor building. The licensee is evaluating this condition to

determine corrective action and possible generic effects.

Inspector Followup Item (302/85-19-01): Review the licensee's repair

to damaged cables in RCV-11 and RCV-13, and subsequent review for

generic effects.

(2) NCOR 85-64 reported the failure of the B Emergency Diesel

Generator (EDG) output breaker to close during a bus undervoltage

condition. The closure failure was determined to be caused by a

contact failure in the breaker manual operating switch, a General

Electric (GE) type SBM.

The licensee will either repair or replace this switch and has

initiated actions to . aview the generic implications of this

failure.

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Inspector Followup Item (302/85-19-04): Review the licensee's

activities to study and resolve the SBM switch failure.

7. Refueling Activities

The inspectors witnessed several shifts of fuel handling operations and

verified that the defueling was being performed in accordance with TS

requirements and approved procedures. Areas inspected included the periodic

testing of refueling related equipment, containment integrity, housekeeping

in the refueling area and shift staffing during defueling.

While observing fuel handling operations in the Spent Fuel Pools being

conducted in accordance with Refueling Procedure (FP-601) (Fuel Handling

Equipment Operations), the inspector notice that FP-601 enclosures 12B

(Verification of Fuel Handling Bridge Startup), -12C (Verfiication of Fuel

Handling Bridge Shutdown), and 13A (Spent Fuel Handling Bridge Log Sheet)

were not being completed. The enclosures are required to be filled out by

FP-601 when the Fuel Handling Bridge is started, shutdown or tested to

ensure that the Fuel Handling equipment is capable of safety moving the

fuel.

Technical Specification (TS) 6.8.1.b requires adherence to refueling

procedures. Failure to adhere to the requirements of a refueling procedure

is contrary to the requirements of TS 6.8.1.b and is considered to be a

violation.

Violation (302/85-19-05): Failure to adhere to the requirements of

refueling procedure FP-601.

8. Potential Exposure From In-Core Neutron Detectors

The inspector reviewed the licensee's control over potential exposure from

the use of in-core neutron detectors in accordance with a memorandum from

Roger D. Walker to Senior Resident inspector dated April 4, 1985. This

review included neutron detector withdrawal procedures, access to the

reactor cavity (sump) area, an evaluation of the hazard, and the training /

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retraining program's identification of hazards associated with very high

radiation areas.

No violations or deviations were identified.

9. Review of IE Bulletins (IEB)

The licensee's response to IEB 84-03, Refuel Cavity Water Seal, was reviewed

to verify that the Bulletin requirements had been accomplished. The

inspector's review identified that the response did not address the

consequences of a seal failure while fuel was in transit on the refueling

bridge. Under these circumstances, the fuel in transit could be uncovered

because the fuel would be raised above the minimum water levels the pools

would reach in the event of a seal failure.

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This issue was discussed with licensee personnel who acknowledged the

inspector's comments. The licensee will submit an additional response to

this Bulletin that will address the fuel-in-transit condition. This

Bulletin remains open pending NRC review of the additional response.

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