3F0597-27, Responds to NRC Re Violations Noted in Insp Rept 50-302/96-09.Corrective Actions:Receipt Insp Process Changed to Require Receipt Inspector to Compare Equipment Nameplate Data to Purchase Order Requirements & to Document Results

Responds to NRC Re Violations Noted in Insp Rept 50-302/96-09.Corrective Actions:Receipt Insp Process Changed to Require Receipt Inspector to Compare Equipment Nameplate Data to Purchase Order Requirements & to Document Results

ML20141K688
Person / Time
Site:	Crystal River
Issue date:	05/20/1997
From:	Cowan J FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F0597-27, 3F597-27, 50-302-96-09, 50-302-96-9, NUDOCS 9705290305
Download: ML20141K688 (5)

Text

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Florida Power CORPORATION U Umm' May 20, 1997 3F0597-27 U. S. Nuclear Regulatory Commission Attention:

Document Control Desk Washington, D. C.

20555-0001

Subject:

Notice of Violation (NRC Inspection Report No. 50-302/96-09)

NRC to FPC letter, 3N1196-19, dated November 27, 1996 l

Dear Sir:

In the subject letter, Florida Power Corporation (FPC) received a request for a supplemental response to Violation 96-09-06 that concerned an Inservice l

Inspection (ISI) class boundary problem.

The request was made because the original response to that Violation had stated our belief that the problem was j

an isolated event. Shortly after providing our response and while performing a j

design review for a modification, FPC identified several examples of seismic l

classification break problems.

The NRC requested that we address the seismic l

classification break problems in our corrective actions for the ISI code classification issue identified in the Violation. We agree that broader, more appropriate corrective actions are required. This correspondence provides our revised response to the Violation.

Sincerely,

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John Paul Cowan Vice President, Nuclear Production i

1 JPC/RLM cc:

Regional Administrator, Region II NRR Project Manager Senior Resident Inspector 9705290305 970520

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U.,S. Nuclear-Regulatory Commission Page.2 of 5.

3F0597-27 FLORIDA POWER CORPORATION NRC INSPECTION REPORT N0. 50-302/96-09 REPLY TO A NOTICE OF VIOLATION VIOLATION 50-302/96-09-06 10 CFR 50, Appendix B, Criterion III, requires the licensee to assure that applicable regulatory requirements and the design basis are correctly translated.

into specifications, drawings, procedures, and instructions.

For this to be

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accomplished, the values of parameters (e.g., equipment input amperage) used in design calculations and the design inservice inspection boundaries specified through drawings and the inservice inspection program must be correct.

Contrary to the above, on March 10, 1996, the licensee failed to assure that applicable regulatory requirements and the design basis were correctly translated into specifications, drawings, procedures, and instructions in that:

(1)

The design input current used in calculations for safety related battery charger (MAR 93-05-07-01) and 4160/480 volt transformer (MAR 95-08-22-01) replacements were incorrect. The input current used in the calculations was 56 amperes, whereas the correct value was 62 amperes.

(2)

The inservice inspection class 2/3 makeup system boundary shown on FSAR drawing FD-302-661, sheet 4, was not moved from valve MUV-64 to valve MUV-65 in 1984, when the Engineered Safeguard signal was removed.from MUV-64.

With that change, MUV-64 could no longer be considered a boundary, as it was open and would not automatically close to provide a boundary.

ADNISSION OR DENIAL 0F THE ALLEGED VIOLATION Florida Power Corporation (FPC) accepts the violation.

While performing a design review for a modification, several examples of seismic classification break problems were identified by FPC.

We are also addressing these seismic classification break problems in our response.

REASON FOR THE VIOLATION The reason for the first examnie is that the receipt inspection process did not include steps for verifying nameplate data against the equipment purchase order.

Additionally, there was no requirement for the design engineer to acknowledge T

verification of the vendor test report results, against the design inputs,.priorz to release of the component from material receiving.

The apparent reason for failing to update the ISI code class on drawing FD-302-661 Sheet 4 was a lack of adequate interface between the mechanical and.

electrical design engineering disciplines during the modification process.. The1 reason for the seismic classification break problems is not known yet, since our extent of condition evaluation. is still in progress.

Once the. extent of condition evaluation is complete, a final root cause will be' performed on_both the ISI and seismic class issues so that any additional' corrective actions arc 1

identified.

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1 U. S. Nuclear Regulatory Commission Page 3 of 5 3F0597-27 C0.RRECTIVE STEPS THAT HW E BEEN TAKEN afb THE RESULTS ACHIEVED The receipt inspection arocess has been changed to require the receipt inspector to compare the equipment nameplate data to the purchase order requirements and to document the results. The Engineering Software Acceptability Letter (ESAL) has been changed to require the design engineer to verify the vendor test report results against the specification requirements and acknowledge acceptance prior to release of material from the receiving warehouse.

Correspondence NED96-0357 titled " Engineering Design Errors" was issued on June 13, 1996, as a result of the battery charger input error.

The correspondence contains a management expectation to wa1Xdown new hardware for modifications and ensure the nameplate data matches the Purchase Order and specification requirements. The correspondence was tent to all engineering personnel and was placed in the department " Industry Experience / Lessons Learned" manual.

l A procurement self-assessment has been completed which sampled 10 electrical and 10 mechanical procurement packages for deficiencies similar to the nameplate violation above.

As a result, one additional discrepancy was discovered with motor space heater rating (on a spare motor in the warehouse) and therefore the electrical procurement sample was expanded to a total of 30 with no additional discrepancies noted.

Drawing FD-302-661 Sheet 4 has been revised to move the ISI code classification boundary to MUV-65.

The Design Review Board process has been enhanced to improve inter-disciplinary reviews at the conceptual and. final design phase to identify actions required of interfacing design groups or other Nuclear Operations departments.

CORRECLIVE STEPS THAT WILL BE TAKEN TO AV0ID FURTHER VIOLATIONS An extent of condition evaluation is underway to determine the design basis requirements for seismic and ISI classifications of piping systems, especially the interface requirements which govern the transition between classes.

This effort requires that class breaks be identified and evaluated for acceptability such that a cause analysis can subsequently be performed.

Since several examples of seismic classification break problems were found, additional CR-3 piping systems have been reviewed for identification of seismic class break locations.

In the case of ISI code class breaks, only the problem noted in the violation has been found. Therefore, only selected piping systems have been reviewed for identification of ISI code class break locations. Those selected for review are the Level I systems in our System Readiness Review Program, and are as follows:

1) Makeup and Purification (MU)

2) Emergency Feedwater (EF)

3) Decay Heat Removal (DH)

4) Reactor Coolant (RC)

U.' S. Nuclear Regulatory Commission Page 4'of 5 3F0597-27

5) Core Flooding (CF) l

6) Emergency Diesel Generator (DF, EG, DJ, DL) i Each ISI and seismic classification break identified will be evaluated for acceptability, specifically those located at valves where the classificatioa break depends on the normal and required post-accident operating positions of the valve.

For example, a normally open manual valve cannot serve as an adequate classification break in an application where automatic closure of the valve is required for performance of a safety function.

When the foregoing evaluation is complete, cause analysis will be performed based on the overall results, and any additional corrective actions will be developed.

This effort is approximately 50 percent complete, with a projected finish date of August 15, 1997.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED FPC is in full compliance for the first example.

A date for full compliance of piping classification breaks will be established after a determination is made of the full extent of the problem and additional corrective actions, if any, are in place. FPC will provide this information to the NRC within 30 days following completion of the evaluation noted above.

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U. S. Nuclear Regulatory Commission Page 5 of 5

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3F'597-27 0

ATTACMENT 1 The following table contains a listing of commitments contained in this response:

RESPONSE SECTION COMMITMENT DUE DATE Page 4 When the evaluation is August 15, 1997 complete, cause analysis will be performed based on the overall results, and any additional corrective actions will be developed.

Page 4 A date for full September 14, 1997 compliance will be provided to the NRC.

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