ML20127L298

Insp Rept 50-302/85-08 on 850201-28.Violations Noted:Failure to Properly Approve Temporary Procedure Changes Prior to Implementation & to Have Two Independent Decay Heat Seawater Sys Loops Operational

ML20127L298
Person / Time
Site:	Crystal River
Issue date:	04/09/1985
From:	Panciera V, Stetka T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127L279	List: ML20127L273 ML20127L285 ML20127L298
References
50-302-85-08, 50-302-85-8, NUDOCS 8505220313
Download: ML20127L298 (11)

See also: IR 05000302/1985008

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NUCLEAR REIULATORY COMMISSION

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APR 111985

1

Report No.:

50-302/85-08

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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: - February 1-28, 1985

Inspection at Crystal River site near Crvstal

iver, Florida

Inspector: [

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T.F.Stetka,SeniorResidentpspector

Date Signed

Accompanying Perso nel:

J. E

edrow, Res' dent' Inspector-

Approved by:

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V. W. Pandera, Chief, Project Section 28,

Dht'e Signed

Division of Reactor Projects

SUMMARY

Scope:

This routine inspection involved 160 inspector-hours on site by two

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

controls, Licensee Event Reports and Nonconforming Operations Reports, new fuel

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receipt, and licensee action -on previous inspection items.

Numerous facility

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tour's were conducted .and . facility operations observed.

Some of these tours and

observations were conducted on backshifts.

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'Results: -Three violations were identified:

(failure to properly approve

' temporary changes to procedures prior to implementation, paragraph 8; failure to

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properly approve procedure changes and to conduct periodic procedure reviews,

paragraph 5.a.1; . and failure to have two independent Decay Heat Seawater System

loops operational, paragraph 5.a.2).

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APR 111985

REPORT DETAILS

1.

Persons Contacted

Licensee Employees-

• J. Alberdi, Manager, Site Nuclear Operations Technical Services

~*G. Boldt, Nuclear Plant Operations Manager

• R. Brown, Nuclear Electrical /I&C Supervisor

• R. Carbiener, Nuclear Compliance Specialist

M. Culver,-Senior Nuclear Reactor Specialist

• J. Frijouf,-Nuclear Compliance Specialist (Acting)

• G. Hebb,- Nuclear Shift Supervisor

• B. 'Hickle, Nuclear Chemistry and Radiation Protection Superintendent

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'E. Howard, Director, Site Nuclear Operations

• W. Johnson, Nuclear Plant Engineering Superintendent

• R.-M. Jones, Engineering Aide

• J. Lyon, Chief Nuclear Technical Support Technician

• P.~ McKee, Nuclear Plant Manager

• W. Morgan, Nuclear Electrician

• D. Nash, Nuclear Master Mechanic

• W. Nielsen, Nuclear Electrical /I&C Supervisor

'V. Roppel, Nuclear Plant Engineering and Technical Services Manager-

• P. Skramstad, Nuclear Chemistry and Radiation Protection Superintendent

• D.' Smith, Nuclear Maintenance Superintendent

• R. Tyrie, Assistant Nuclear Operator

• K. Wilson, Supervisor, Site Nuclear Licensing

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

-tenance,-chem / rad 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 February 28, 1985.

During this meeting,

the inspector summarized the scope and findings of the inspection as they -

are detailed in this report with particular emphasis placed on the viola-

- tions, unresolved item, and inspector followup items (IFIs). The licensee

acknowledged the inspection findings and did not identify as proprietary any

a

of the materials provided to or reviewed by the inspectors during this

inspection.

3.

Licensee Action on Previous Inspection Items

(Closed) Unresolved Item (302/84-09-09):

The licensee revised procedure

SP-354.(A&B), Emergency Diesel Fuel Oil Quality and Diesel Generator 3A(B)

Monthly Test, on June 28 to add a new step to assure that operators are

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APR 11 1985

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reminded.to perform the additional; surveillances when a diesel is removed

from service.

Thir, addition appears to'be effective to prevent recurrence

of this event.

(Closed) IFI (302/84-29-04):

The licensee reset the quadrant power tilt

(QPT) alarms on the computer to alarm at 3.0 and 8.0 (steady- state and

transient respectively) to assure that operators are warned of an impending

out of specification QPT condition prior to the limit being exceeded.

In

addition, Short Term Instruction (STI) 85-02 was written on January 4, 1985,

to remind operators of the special QPT. surveillance requirements, thus

assuring that these requirements - are properly applied.

This STI has been

reviewed by the on-shift operators.

-(Closed) IFI (302/84-34-01):

Procedure SP-433, Incore Neutron Detectors

Channel Check, has been reviewed by licensee personnel to determine whether-

the layout of Data Sheet I was adequate for performing the required

surveillance.

From this review, the licensee has determined that the data

sheet is adequate and no changes are necessary.

The resident inspector-has

reviewed the licensee's determination and has observed the use of this data

sheet and has no further questions on this item.

(Closed) Unresolved Item (302/84-34-02):

The licensee has examined the

inspector's concern about lack of annunciation of Meteorological Tower 2

alarms on the main annunciator system and has determined that this function

-is not necessary.

This determination is based on the fact that this system

is surveilled daily in accordance with procedure SP-157, Meteorological

System Surveillance, which is adequate to determine system operability.

The

resident inspector reviewed the licensee's determination and noted that in

addition to SP-157, the licensee has two Meteorological Systems one of which

acts as an installed backup system.

Additionally, since' the Technical

Specifications (TS) allow up to seven days to return a system to operation,

the licensee's position that the daily surveillance requirement is ' adequate

to detect system operability in a timely manner appears to be conservative.

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-

tions.

A new unresolved item identified during this inspection is discussed

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in paragraph 7 of this report.

5.

Review of Plant Operations

The plant continued in power cperation (mode 1) for the duration 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 TS and the

licensee's administrative procedures.

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lThe following-records were reviewed:

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

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

Active Clearance - Log; Daily Operating Surveillance Log; Work Request -

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

~ Protection Logs.

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In - addition to these record reviews, . the -inspector independently

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. verified clearance order tagouts.

As a result of these reviews, the following_ items were identified:

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(1). . On: February 13, while Lreviewing a recent change to the Operations

' Section Implementation Manual:(OSIM), the inspector noted _that a

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. memorandum dated April -17, 1984,-' was ' replaced by an outdated-

-memorandum dated June 18, 1981.-

The inspector also'noted that the

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transmittal cover sheet for-this manual change was signed by a

site secretary in lieu of site management personnel.

Discussion =

with licensee personnel indicated that no c documentation of

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Operations,-Superintendent approval ~of OSIM changes was available. ^

'The licensee's Administrative Instruction (AI)-500, Conduct of-

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Operations [ requires OSIM changes-to be. approved byLthe operations

superintendent . prior to implementation.

This AI implements the

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requirements of TS 6.8.2.b.

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The inspector also reviewed the'0SIM to determine if the periodic,

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two year reviews' required byfAI-500 were being performed.' As'a-

result of this review, it appeared that these reviews were not

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being conducted. ' Subsequent' discussions with licensee personnel

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-indicated that .while some type of review may have been conducted,

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there was no documentation 'available to demonstrate the

performance of these.perlodic reviews.

The, periodic ' reviews of

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AI-500 implement the requirements of TS 6.8.2.d.

Failure to have Operations Superintendent' approval of OSIM changes

prior to implementation' and failure to conduct period reviews of

the OSIM are contrary to the requirements of TS 6.8.2.b and d'and

is considered to be a violation.

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Violation -(85-08-01); Failure to revise procedures and conduct

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periodic reviews as required by TS 6.8.2.b and d.

-(2)' On February 26, while reviewing the STIs the inspector noted that

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STI 85-14, issued on February 22, directed the shutting of a decay

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heat (DH) seawater system isolation valve (RW _40).

To implement

this STI,'the inspector also noted that equipment clearance number

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2-153 was written- to place a blue tag on RW-40 and that this

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clearance was initiated at 1525 on February 22.

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LProcedure . OP-404,- Decay Heat Removal- System, providp in para-

graph-11.0, : the valve. lineup for.the Engineered Safeguards (ES)

normal standby mode . of -the DH _ seawater system.

This lineup

- requires valves RW-40, RW-32' and RW-33 to be open.

Review of

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.the system diagram by the . inspector indicated that to assure

independence of : the seawater system which -is required by

.TS 3.7.3.2, valve RW-40 would have to be open and at least either

-l valve RW-32 or RW-33 would have to be closed.

These findings were discussed'with licensee representatives. _As a-

_ result -of . these discussions, the inspector determined the

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'following:

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'The change made to 0P-404 to close valve RW-40 by the STI

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represented an unapproved change to the . procedure.

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addition the inspector noted 'that. the licensee had made no

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determination of the effect of this change upon the

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operability' of the DH ' seawater system ES normal standby mode

- prior .to closing RW-40. When notified of this finding, the

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licensee representative immediately opened RW-40.

The valve

had been shut-for approximately 94 hours0.00109 days <br />0.0261 hours <br />1.554233e-4 weeks <br />3.5767e-5 months <br />.

The requirement of-proceddre OP-404 to have ' valves .RW-32 and-

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RW-33 open simultaneously represents an inadequate operating,

procedure.

it-appears that this procedure and the applicable.

valve lineup has been'in effect for at least the duration of

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the -last operating cycle which extended from July 1983

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through March 11, 1985.

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Failure to have two independent DH seawater loops is contrary _to <

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the requirements of TS 3.7.4.2 and is considered to be a

violation.

Violation (302/85-08-02):

Failure to have two independent DH

seawater loops operable-as required by TS 3.7.3.2.

b.

Facility Tours and Observations

Throughout 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

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-were f attended by the. inspector to observe planning and management

activities.

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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,

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Electrical'Switchgear Rooms.

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During these tours, the following observations were made:

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(1)' Monitoring . Instrumentation - The following instrumentation was-

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observed'to verify thatLindicated parameters were in accordance

with the:TS for thel current operational mode:

Equipment operating status; Area, atmospheric and liquid radiation

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monitors; Electrical system lineup; Reactor operating parameters;

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and Auxiliary equipment operating parameters.

No: viol $tions or dev_iations were identifled.

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

the Nuclear. Services and Decay Heat Seawater and the Decay Heat

Closed Cycle Cooling Systems to verify that the lineups were in

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accordance with. license ' requirements for system - operability and -

.that the system drawing and procedure correctly reflect "as-built"

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plant conditions.

While reviewing the Nuclear Service and Decay Heat Seawater System

drawing (FD-302-611), the inspector.' identified two vent valves

with the same . identification number, RW-112, but with different

locations in the' system.

The system walkdown revealed that both

these 1 valves exist Lin the field as shown on the drawing.

One of

these ' valves is : included on a valve ' checklist 'in Operating

Procedure OP-404, Decay Heat Removal System, but the other valve.

is not included on any valve checklist.

The inspector- had .

previously identified this matter . to the licensee during a

walkdown of the same system conducted on June' 1,1984.

The

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licensee issued ~ a Field Problem Report, FPR #84-031, on _ June -1,

1984, to correct the system drawing, but this problem still hasn't

been resolved.

The licensee is commencing a new effort to correct

the erroneous ~ drawing and to revise _the valve checklists.

Inspector Followup -Item (302/85-08-03):

Review the. licensee's

- efforts to correct Nuclear Service and Decay Heat Seawater System-

drawing (FD-302-611) and to revise the applicable ' valve ~ checklists

to assure that valve RW-112 is properly identified.

(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

turnovers 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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No violations or deviations were identified.

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

vertfy proper identification and . implementation.

These observa-

tions included selected licensee conducted . surveys, review of

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

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arean posting.

Area ~ postings were -independently verified for-

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accuracy' through the use of - the . inspector's own radiation

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monitoring instrument. ' The inspector also reviewed _ selected

radiation work permits and observed personna) use of protective

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clothing, respirators, and personnel monitoring devices to assure

L that ,the _ licensee'.s radiation monitoring poli _cies were . being

followed.

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No violations orideviations were identified.

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

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

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

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facility ' security plan.'

Personnel within the PA were observed to

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verify 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.requi. red, were utilized; and

TS requirements were followed.

The following tests were observed and/or data reviewed:

SP-130, Engineered Safeguards Monthly Functional Tests

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SP-169, Plant Safety-Related Instrument Calibration

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SP.-317, RC System Water Inventory Balance

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SP-333, Control Rod Exercises

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.SP-344, Nuclear Services Cooling System Operability

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SP-347, ECCSland Boration' Systems Flow Path

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SP-349, Emergency Feedwater System Operability Demonstration

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'SP-354A,oEmergency Diesel Fuel Oil Quality and Diesel

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Generator Monthly Test.

SP-358,-Operations ES' Monthly Automatic Functional Test-

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_SP-718, BWST Weekly Surveillance Program

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~No. violations'or deviations were identified.

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L(9)' Maintenance Activities - The inspector observed : maintenance

Lactivities - to verify that correct equipment clearances were-in

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effect; Work Requests and Fire Prevention Work Permits, as

required,- were ' issued and ; being followed; Quality Control

personnel were available -for inspection activities as l required;

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-and TS' requirements were being followed.

Maintenance was observed and work packages were reviewed for the

following maintenance activities:

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Inspection and cleaning of a Nuclear Services Closed Cycle

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Cooling Heat Exchanger (SWHE-1A) Lin accordance with

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preventive maintenance procedure PM-112;-_

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Troubleshooting and repair of the_ Reactor Building Pressure

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and Borated Water Storage -Tank Level Recorder (BS-65-PR);

and,

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Troubleshooting of the Borated Water Storage Tank Low-Low

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Level Alarm.

No violations or deviations were identified.

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(10) Radioactive Waste Controls - Solid waste compacting operations and

selected ' liquid and gaseous releases were observed to verify.that .

approved procedures were utilized, that appropriate release

approvals were obtained, and that required surveys were taken.

[

On February 11, 1985, during a liquid radioactive release of

Laundry Tank WDT-118, the inspector noted that the operator had

made' an. incorrect assumption about the dilution flowrate.

The

operator assumed that the running pump had a- flow capacity of'

14,000 gpm.whereas actual pump capacity was approximately

9,800 gpm.

The inspectors verified that the actual'flowrate for

this release (which required 10,000 gpm) was adequate by noting

'that two pumps had been running during the release.

The inspector

discussed this observation with licensee representatives and

postulated the possibility that a liquid radioactive release could

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Ioccur without adequate . dilution. flowrate.

To prevent recurrence,

the licensee'_is requiring operators .to obtain actual dilution

flowrate from pump curves to prevent _ incorrect assumptions to be

made and is training operators on -the correct ~ method ; to- obtain

dilution flowrates;

Thist item will be examined during subsequent

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troutine inspection activities.

.'(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.

- On February 6, 1985, the inspector noted that snubber MSH-124

appeared to have an oil leak and that snubber MSH-118 had a low -

' oil Llevel.

This information was brought to .the-attention ~ of

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licensee representatives.

The licensee initiated a quality

control inspection of the. snubbers which revealed that MSH-124 had

slight oil leakage' at -the bottom of the snubber's sightglass 'and

that snubber MSH-118 had a cccked radial bushing (which was

unrelated to the -. low snubber > oil _ level).

The low level for

MSH-118 was caused by normal operation of the snubber piston due

to changes in~ piping temperature.

The licensee has initiated work

requests to repair. the MSH-124 sightglass.~and the MSH-118 cocked '

radial bushing.

The inspector will follow this maintenance during

subsequent routine inspection activities.

6.

Review of Licensee Event Reports and Nonconforming Operations Reports

The inspector reviewed Non-Conforming Operations Reports (NCOR) 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.

As a' result of this review, the following items were identified:

a.

NCOR 85-26 reported finding certain instrumentation to have exceeded

their calibration -intervals.

The licensee is presently calibrating

.these instruments and for those found out of calibration, determining

the effect of system operability.

Inspector. Followup Item (302/85-08-04):

Follow the licensee's activity

to calibrate instruments and verify system operability for those

instruments found out of calibration.

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NCOR 84-244) reported parts missing from chilled water system (CH)

valves CHV-68.and CHV-69 which supply the Control Complex Chillers.

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The -licensee conducted a search for the parts in the Nuclear Services

Closed Cycle Cooling -(SW) system, the system that supplies cooling

- water' to the CH system and no parts could be located.

The. licensee is

- planning to ; modify the chilled water system -in accordance with

MAR 81-03-09-01, which will instal 1:.new Fisher design valves.

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. Inspector Followup Item (302/85-08-05):

Review the licensee's progress

'to replace valves CHV-68 and CHV-69 with new Fisher valves.

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Design, Design Changes and Modifications

The ' inspectors ; monitored . performance of modification MAR 78-12-09-02,

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" Fabricate. and Install Supports for Air Handling Filter .(AHFL-2C) Inlet

Damper", and noted the following:

On February 12, 1985, the inspector

observed -the installation of a blank flange in the ductwork downstream of

the . inlet ! damper for an auxiliary building ventilation filter AHFL-2C, .and

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the' cutting of interfering internal duct -support bars. . On review of

modification package MAR 78-12-04-02, the inspector noted that the modifica-

tion was incomplete in that it did.not address the type of material for the

flange', flange installation, or the ' cutting of the internal support bars.

The inspector also noted that the modification was classified as non-safety-

and that the Safety.. Listing listed the Auxiliary Building Ventilation System

as non-safety related.

The inspector'.s review of the Final . Safety Analysis

Report (FSAR), Section 14.2.2.6 indicates that credit is taken for the

Auxiliary Building Ventilation, System filters and fans to mitigate a letdown

line ' rupture airborne; release to prevent exceeding limits -specified in

10'CFR Part 100.

The' licensee is reviewing the non-safety related classifi-

cation with ' preliminary results indicated that the Auxiliary Building

Ventilation System filters and fans are not needed to mitigate' the letdown

line~ rupture airborne release.

The licensee'has also issued a Field Change

Notice to correct the deficiencies identified by the inspectors in the

modification package.'

This item is considered to be unresolved pending

completion -of' the safety related classification determination by the

licensee.

Unresolved Item (302/85-08-06):

Review the results of the Auxiliary

Building Ventilation System filters and fans safety related classification

' determination.

8.

Receipt and Inspection of New Fuel

The -inspector reviewed procedures prior to receipt of new fuel to verify

that approved procedures were' available and were technically adequate to

cover the receipt, inspection, and storage of new fuel elements.

Fuel

-receipt, inspection and ' storage activities were observed to verify that

these activities were conducted in accordance with the approved procedures

and that any deficiencies were appropriately resolved.

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1While observing the receipt of ~ new fuel on February 8,1985, the inspector

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-noted-that the procedural step in refueling procedure FP-304, Receiving New

Fuel, had been marked "Not Applicable" and signed by the reactor specialist.

This c step' required the fuel handling area fan -(AHF-10) to ' be in service

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'while receiving new fuel. f The: fan was secured _during the fuel receipt.

When licensee. representatives were questioned about .this apparent procedure

deviation, the _-inspector 'was- informed that the fan was not necessary to

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ensure - proper ventilation ' and that the fan; caused excessive lowered

temperatures, E resulting _in ' personnel . discomfort.

The inspectors verified

that proper ventilation - flow was available and noted that the procedure

change execution was incorrect.

Technical- Specification' 6.8.3~ allows' temporary changes to be made to

refueling procedures provided the' intent of the procedure'is not altered and

that the change Lis' approved by two members' of the plant management staff at

least one 'of whom holds a Senior Reactor Operators- (SRO) license.

The

-licensee.-has a. method for implementing a. temporary change, that is called an

Immediate- Temporary. Change (ITC), and delineates this change method _~in

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Administrative Instruction'AI-401.

This change was made without approval of

two members of the plant management staff, at least one of whom holds an SR0

license and is considered to be a violation.

Violation (302/85-08-07):

Failure to _ have 'two members of the plant manage-

ment staff approve a temporary procedure change as required by TS 6.8.3.

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