3F0887-03, Forwards Revised Response to Violations Noted in Insp Rept 50-302/86-39.Temporary Mod Removed & Procedure Used to Develop MAR Confirmed to Adequately Address Need to Document Refs

Forwards Revised Response to Violations Noted in Insp Rept 50-302/86-39.Temporary Mod Removed & Procedure Used to Develop MAR Confirmed to Adequately Address Need to Document Refs

ML20236N734
Person / Time
Site:	Crystal River
Issue date:	08/07/1987
From:	Eric Simpson FLORIDA POWER CORP.
To:	NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM)
References
3F0887-03, 3F887-3, NUDOCS 8708120082
Download: ML20236N734 (4)

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• Florida Power

' CORPORATION-August 7,1987 3F0887-03 U. S. Nuclear Regulatory Comm'ssioni

,~ Attention: Document Control Desk l- Washington, DC 20555

Subject:

Crystal-River Unit 3 Docket No. 50-302

' Operating License No. DPR-72 1

Inspection Report 86-39 i

Revised Response 86-39-01

Dear Sir:

Florida Power Corporation (FPC) provides the attached as our-  !

revised response to the subject Inspection Report. FPC has-established a task force to develop the improved post maintenance testing program. During their study of other utility maintenance testing programs, it was determined that an October 1987 date is not sufficient time to implement .a comprehensive mainter,ance testing program. Our revised response contains a more realistic completion date.

Sincerely, 9

E. C. Simpson Director, Nuclear Operations Site Support WLR/sjm Attachment cc: Dr. J. Nelson Grace

, Regional Administrator, Region II Mr. T. F. Stetka i Senior Resident Inspector 8708120002 870B07 2 PDR ADOCK 0500

• l g,O A Florida Progress Company gh

FLORIDA POWER CORPORATION REVISED RESPONSE INSPECTION REPORT 86-39 VIOLATION 86-39-01

- 10 CFR 50.59 states that the holder of a license may make changes in the facility, as described in the safety analysis report, without prior Commission approval unless the change involves an unreviewed safety question. Also, the licensee's accepted quality assurance (QA) program (FSAR Section 1.7 Table 1.3) commits to Regulatory Guide 1.33,. Quality Assurance Program Requirements (Operations), which . endorses ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear power Plants. Section 5.2.19.3 of this standard requires that testing shall be performed following plant modifications to confirm that the modification produces expected fresults.

a. Contrary to the above, the licensee modified the "C" temperature hot chan.nel of the reactor protection system by removing a manufacturer's installed ground. The modification was performed under T-MAR T86-06-20-01 and work request 80209. The manufacturer's ground had to be reinstalled during system surveillance testing to determine the-proper trip setting for the reactor trip temperature bistable. .The removal of this ground was not adequately evaluated to. ensure this method of system operation - does not involve an unreviewed safety question,

b. Contrary to the above, after the temporary modification, T86-06-20-01, was installed, the "C" temperature hot channel was not tested in that surveillance procedure Sp-110 was not completed after troubleshooting and then modifying the channel.

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

RESPONSE

Florida Power Corporation's position

'a. Florida Power Corporation agrees Temporary MAR T86-06-20-01 involved a l violation of 10 CFR 50.59. The violation did .not result from an inadequate safety evaluation as stated in the subject report. Rather the violation resulted f rom ' a failure to document in the MAR package all references used in the development of the modification. The information needed to perform the safety evaluation was available and was used by the design engineer who prepared the MAR. However, the individuals contacted by the inspector were unaware of the location of this information.

b. FPC agrees that Sp-110 was not completed af ter troubleshooting and then modifying the channel. Sp-110 would not have verified operability of the "C" temperature hot channel, however, FpC agrees no other testing was documented immediately after installation to verify operability.

L Apparent Cause of the Violation f

l

a. The cause of this violation is personnel error. The engineer performing the design modification failed to document all references used in the evaluation.

b. While troubleshooting under work request 80547, it was determined that a circuit ground existed on one of the resistance temperature device (RTD) 1 wiring at the RTD's termination enclosure on the RCS piping. Sp-112, Calibration of the Reactor protection System, was performed for the verification of RpS temperature reliability. This checked satisfactorily. It was also determined that lifting the ground wire at the output of the linear bridge would temporarily alleviate the effects of the inadvertent ground at the RTD enclosure. Resistance values used in Sp-112 were loaded into the circuit to prove that the lifted ground wire would not affect the normal operation of the T-Hot circuits; but would change the operation of the temperature test circuit due to its dependence upon a circuit ground for certain operations while in the test mode.

Due to the fact that the circuitry was proven to function properly under work request 80547, and by performance of sections of Sp-112, that the ground has no affect under normal circuit operation, further testing of the circuitry was not documented when T-MAR 86-06-20-01 was installed.

However, the technician verified the operability by channel comparison and operability was also confirmed each shift thereafter through routine operations channel checks.

In summary, the cause appears to be lack of a leference to a specific post maintenance test that should have been performed after the installation.

Carrective Actions

a. The temporary modification has been removed. It was confirmed that the procedure used to develop the MAR adequately addressed the need to document references.

b. A memo was issued to all Maintenance planners and Supervisors to include in work packages, specific steps or sections within procedures or identify any other criteria that should be met, in order to clearly specify what post maintenance testing is required.

Date of Full Compliance

a. Full compliance was achieved on December 1, 1986, when the temporary modification was removed.

b. Full compliance was achieved upon issuance of the above mentioned memorandum, December 2, 1986.

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' Action Taken To Prevent Recurrence

a. 'A' memo was issued to all Nuclear Engineering personnel reminding them of the need to properly document all references used in the development of a modification.

b. FpC plans to prepare an interim post maintenance testing (pMT) program for trial use during the Refuel VI outage, beginning in September 1987. Based on practical experience and observation during this outage - additional enhancements to the PMT program will be developed and implemented before the'end of 1988.

DEVIATION 86-39-02 The following deviation was identified during a Nuclear Regulatory Commission (NRC) inspection conducted on November 17-21-and December 1-5, 1986.

.The Crystal River Unit 3 FSAR Section 11.4.1 radiation monitoring design basis, states that the radiation monitoring system measures radioactivity

-at selected plant' locations in order to verify compliance with 10 CFR 20.

The spent fuel cooling water monitor RM-L4 is provided to detect any radioactivity released in the spent fuel storage area.

Contrary to the above FSAR commitment, temporary modification, T-MAR 79-08-78, removed' RM-L4 from service on September 5, 1979, and is still out of service. The T-MAR also states that until RM-L4 is relocated, it is inoperative.

RESPONSE

Corrective Actions T-MAR 79-08-78 will be made a permanent modification upon the expiration of the current temporary modification. This will provide for an adequate 50.59 review and in turn indicate the need to change the FSAR. The FSAR will be revised to delete RM-L4.

Date of Full Compliance l

Full compliance will be achieved during the 1987 FSAR update.

Corrective Action to Prevent Recurrence

.In addition to the deletion of the high radiation annunciator alarm point, the I ratemeter module detector, preamplifier, and recorder channel will also be removed, thus rendering the RM-L4 channel non-existent. FSAR will also be

- revised to reflect this change. The current 50.59 review process includes i steps that Hentify the need for FSAR changes.

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