3F0886-15, Forwards Response to Violations Noted in Insp Rept 50-302/86-14.Corrective Actions:Torque Switch Setting for Motor Operated Valve DHV-39 Adjusted to Proper Value. Disagrees W/Violation 86-14-05 Re Cable Pulling

Forwards Response to Violations Noted in Insp Rept 50-302/86-14.Corrective Actions:Torque Switch Setting for Motor Operated Valve DHV-39 Adjusted to Proper Value. Disagrees W/Violation 86-14-05 Re Cable Pulling

ML20209E675
Person / Time
Site:	Crystal River
Issue date:	08/21/1986
From:	Widell R FLORIDA POWER CORP.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
3F0886-15, 3F886-15, NUDOCS 8609110307
Download: ML20209E675 (4)

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Florida Power CORPORAT4ON August 21, 1986 3F0886-15 Dr. J. Nelson Grace Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, GA 30323

Subject:

Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 IE Inspection Report 86-14

Dear Sir:

Florida Power Corporation provides the attachcd as our response to the subject inspection report.

Sincerely, Rolf)C.Widell Manager, Nuclear Operations Licensing and Fuel Management AEF/feb Attachment fhh ADO k2 O

GENERAL OFFICE: 3201 Thirty-fourth Street South + P.O. Box 14042 + St. Petersburg, Florida 33733 +

(813) 866-5151 A Florida Progress Company fL \\

n FLORIDA POWER CORPORATION

RESPONSE

INSPECTION REPORT 86-14 VIOLATION 86-14-01 10 CFR Part 50, Appendix B, Cri terion V, as implemented by the approved Florida Power Corporation Operational Quali ty Program, paragraph 1.7.1.8, requi res adherence to procedures that are wri tten to accomplish the 18 criteria of Appendix B.

Compliance procedure CP-125, Corrective Action Procedure, that was written to accomplish Criterion XVI, requires that a Corrective Action Assignment (CAA) form be completed to document and track corrective actions.

Contrary to the above, as of June 4,1986, a deficiency in a safety-related motor operated valve (DHV-39), which was identified by the licensee on May 2, 1986, did not have a CAA completed as required by procedure CP-125. As a result the deficiency in DHV-39 was not corrected.

This is a Severity Level IV violation (Supplement I).

RESPONSE

1. Florida Power Corporation's Position Florida Power Corporation agrees the torque switch setting for motor operated valve DHV-39 was not adjusted to the proper value as reported in Licensee Event Report 86-03, Supplement 1. We do not agree this discrepancy constitutes a violation of Compliance Procedure CP-125, Corrective Action Procedure, however, the violation does identi fy a concern that needs to be resolved.

On February 2,1986, Crystal River Unit 3 experienced a loss of decay heat removal flow due to failure of the pump shaft of "B" decay heat removal pump (DHP-1B) and subsequent failure of the suction valve to the "A" decay heat removal train (decay heat removal valve DHV-39) to open. This event was documented in accordance with Compliance Procedure CP-111, Documenting, Reporting, and Reviewing Nonconforming Operations Reports, via issue of Nonconforming Operations Report (NCOR) 86-22. During the investigation performed pertaining to NCOR 86-22, it was noted a contributor to the failure of DHV-39 to open was a low torque switch setting on that valve's motor operator. Further, it was reported to the Nuclear Operations Technical Advisor (NOTA) assigned the NCOR the torque switch had been reset to the proper value. CP-111 states "all actions taken to correct conditions Adverse to Quality of CR-3 Operation...shall be promptly identified and performed. ... For those corrective actions that are not complete, the assignment, completion, tracking, and documentation of corrective action shall be accomplished in accordance with CP-125, Corrective Action Procedure." Because corrective action for the DHV-39 torque switch problem was reported to be complete, a Corrective Action Assignment per CP-125 was not required and was not issued.

, During investigation of an NCOR, propar docum:ntation of all corrective

• • actions is assembled and verified. This was complete on June 24, 1986, with closure of NCOR 86-22. However, prior to completion of this action, Supplement 1 to LER 86-03 was due to NRC (May 15, 1986), and in an attempt to provide as much supplemental information as possible, the statement regarding resetting the DHV-39 torque switch was included prior to complete verification.

2. Apparent Cause of Violation The investigation into the cause of the violation revealed Site Nuclear Engineering Services identified a potential plant discrepancy and notified the responsible department via speed memo. An adequate method for tracking corrective actions was not utilized and conclusive evidence of corrective action completion was not received. This resul ted in a miscommunication that the torque switch had been reset when in fact it had not. This information was given to the NOTA and was included in the LER prior to complete verification.

3. Corrective Actions The torque swi tch setting for motor operated valve DHV-39 has been adjusted to the proper value. This action was completed on June 5,1986, and appropriately documented by completion of a Work Request form.

4. Action Taken To Prevent Recurrence Si te Nuclear Engineering Services will evaluate the effectiveness of existing methods for assuring that technical inadequacies identified by Nuclear Engineering are tracked and resolved. Subsequent actions will be taken to correct any identified weaknesses. This evaluation will be completed by December 30, 1986.

5. Date of Full Compliance Full compliance was achieved on June 5, 1986, when the torque switch setting for DHV-39 was adjusted to the proper value.

VIOLATION 86-14-05 Technical Specification 6.8.1.a requires that procedures established as recommended in Regulatory Guide 1.33, November 1972, be adequate for the cause. Regulatory Guide 1.33, Section 1.3, recommends the establishment of procedures for the repair or replacement of equipment.

Maintenance procedure MP-405, Installing, Repairing, and Terminating Control, Power and Instrumentation Cables, was written to meet the requirements of Regulatory Guide 1.33 and requires, in step 7.6.11.5 (2), that control and instrument cable be tested for insulation resistance using a 1000 volt DC insulation tester.

Contrary to the above, on June 3, 1986, procedure MP-405 was found to be inadequate, in that nuclear instrumentation cable that was replaced and tested with this procedure has a normal operating voltage of approximately 2000 volts DC, therefore making a 1000 volt DC test inadequate to veri fy proper insulation resistance.

This is a Severity Level IV violation (Supplement I).

a

• ' RESPONSE

. Florida Power Corporation's Position FPC does not agree with the alleged violation.

MP-405 was referenced on Work Request #76154 in order to implement - the' cable pulling requirements (NIR-1 is an instrument cable between the , out-of-core detector and the pre-amp for NI-1-NI). The action in question, megger testing of the cable, was not a requi rement. Step 7.6.11.5 says, in part, the " Instrument cable may be megger tested." The technicians performed megger testing in order to rule out or identi fy obvious cable problems prior to post maintenance testing. Megger testing could not prove that NIR-1 was good, although it could have shown that the cable was bad.

The post maintenance testing requirements for work performed under' WR #76154 are contained in and implemented by SP-110, Reactor Protective System Functional Testing, and MP-201, Out-of-Core Detector Removal and Replacement.

Although FPC takes exception to the violation, it has been recognized that MP-405 does need revision to identify the testing methods and acceptance criteria for instrument cable, should MP-405 be used to test such cable.

MP-405 will be revised by January 1,1987.

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