3F0896-14, Responds to NRC Re Violations Noted in Insp Rept 50-302/96-05.C/As:operability Concern Resolution Initiated on 960515 & Problem Rept Initiated on 960526 to Document Failure to Use Corrective Action Process

Responds to NRC Re Violations Noted in Insp Rept 50-302/96-05.C/As:operability Concern Resolution Initiated on 960515 & Problem Rept Initiated on 960526 to Document Failure to Use Corrective Action Process

ML20116M081
Person / Time
Site:	Crystal River
Issue date:	08/12/1996
From:	Beard P FLORIDA POWER CORP.
To:	NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
References
3F0896-14, 3F896-14, NUDOCS 9608190298
Download: ML20116M081 (9)

Text

__ _

Florida Power CORPORATION EE August 12, 1996 3F0896-14 U. S. Nuclear Regulatory Commission Attention: Document Control Desk Washington, D. C. 20555-0001

Subject:

Notice of Violation (NRC Inspection Report No.50-302/96-05)

NRC to FPC letter, 3N0796-09, dated July 12, 1996

Dear Sir:

In the subject Inspection Report, Florida Power Corporation (FPC) received a Notification of Violation concerning main steam line hangers, temporary changes to the Design Basis Document, Once lhrough Steam Generator (OTSG) Eddy Current Testing (ECT), Battery Chargers receipt inspections and Amendments to Purchase Requisitions.

The attached provides'our response to the subject violations with the exception of violation (VIO) 96-05-04, Once Through Steam Generator (OTSG) Eddy Current Testing (ECT). The issues involved in VIO 96-05-04 are essentially the same as those which will need to be addressed for FPC to respond to NRC correspondence dated June 7,1996, titled Concerns Relating to Licensing Amendment for Alternate Repair Criteria for Steam Generator Tubing (TAC No. M92 548). To get a thorough understanding by FPC and the NRC of the issues related to the subject of the June 7th correspondence, a meeting was scheduled and noticed for August 21st at One White Flint North. To allow for the August 21st discussions to occur, approval was requested and granted to delay the response to the June 7th letter. The same reasons exist to delay the response to.VIO 96-05-04. Consequently a request was made and granted by Mr. George A. Belisle to delay the response to VIO 96-05-04 until August 29, 1996.

Sin erely, P.M. ard, Jr. b Senior Vice President Nuclear Operations 4y cc: Regional Administrator, Region II NRR Project Manager Senior Resident Inspector \

l CRYSTAL FUVER ENERGY COMPLEX: 15760 W Power Une St Crystal River, Flodde 344286706 . (352) 7954486

• aPmgmss Company

~

l 9608190298 960812 l POR ADOCK 05000302 l 0 PDR l

O. S. Nuclear Regulatory Commission Page 2 of 9

. 3F0896-14 j F h

FLORIDA POWER CORPORATION NRC INSPECTION REPORT NO. 50-302/96-05 REPLY TO A NOTICE OF VIOLATION VIOLATION 50-302/96-05-01 Technical Specification (TS) 5.6.1.1 requires written procedures be established, implemented, and maintained covering the applicable procedures recommended in Regulatory Guide (RG) 1.33, Revision (Rev.) 2, Appendix A, February 1978. RG 1.33, Appendix A requires administrative procedures regarding procedure adherence. Al-500, Conduct of Operations, paragraph 4.2, Nuclear Safety Standards and Procedures, Note, states that written procedures shall be adhered to at all times except as described by AI-400E. AI-400E, Performance and Transmittal of Procedures, paragraph 1.1, Policy, sta.tes that verbatim compliance of procedures is required, but procedures must nec be blindly followed.

Compliance procedure CP-150, Identifying and Processing Operability Concerns, dated May 7,1996, paragraph 4.1.3 states in part that the discovery of degraded conditions of components, where performance is called into question, requires operability determinations. CP-150, paragraph 4.2, Phase 2: Evaluation, states in part that the Shift Supervisor On Duty (5500) evaluates the degraded condition for immediate disposition. If the component is important to safety the SS00 makes an immediate disposition of either Operable, Inoperable, or Complex Requiring Further Review. If the component requires further review, the SSOD is to initiate an Operability Concern Resolution (OCR). The OCR is, among other requirements, to contain the applicable Problem Report number and an immediate disposition.

Contrary to the above, on May 15, 1996, following the identification of two damaged main steam line hangers, the Shift Supervisor failed to initiate a Problem Report and an OCR as required by CP-150 until prompted by the NRC Project Manager.

ADNISSION OR DENIAL OF THE ALLEGED VIOLATION ,

Florida Power Corporation (FPC) accepts the violation with the following clarification.

REASON FOR THE VIOLATION FPC agrees a violation occurred due to personnel error in that a Problem Report should have been initiated to document the root cause investigation of the potential causes of the bent hanger rods. However, FPC does not agree that CP-150 was violated. CP-150 classifies a component as Operable But Degraded if it l' 1s not fully qualified but still capable of performing its specified safety function with additional compensatory measures or explanation. The term

" Operable But Degraded" should only be used for dispositioning OCRs. In this case, it was improperly applied when the hangers were actually fully operable.

On May 13, 1996, the Shift Supervisor logged the hangers as having been examined and dispositioned by engineering as operable in their present condition, and that a work request should be generated to repair these hangers when time permits.

i He then improperly logged the condition of the hangers as Operable but Degraded.

l

\ ..

• U. S. Nuclear R:gulatory Commission Page 3 of 9 ,

3F0896-14  !

Based on the engineering evaluation, the log entry should have stated there was no effect on operability. In using the term " Operable but Degraded" the Shift

! Supervisor was in conflict with CP-150. If in fact a degradation from full qualification existed as the term implies, then a formal operability evaluation report was required. Since the hangers were deemed fully qualified from a technical _ basis by the engineering personnel, no written operability evaluation was required. However, a Problem Report should have been initiated per CP-111, Initiation and Processing of Precursor Cards and Problem Reports, to document the root cause evaluation and any potential generic implications. Although there was

no indication of water hammer, further investigation for a root cause was not initially completed.

CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED r

l

! An OCR was initiated on May 15, 1996, which substantiated the original operability decision that the hangers were operable for all plant modes. The OCR was reviewed and approved by the Plant Review Committee on June 20, 1996.

A Problem Report was initiated on May 29, 1996, to document failure to use the corrective action process and repair the identified hangers.

l CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS i l l As a result of the IPAP inspection, a Problem Report was initiated to examine the  !

broader issue of failure to implement the corrective action process for emergent l issues. A discussion was held with the personnel involved with this issue to ,

ensure they were clear on the expectation for implementing CP-111. A revision to i the screening practices of Precursor Cards has been implemented. such that a i detailed screening by the Nuclear Shift Manager is completed each day.  ;

An Operations Night Order was issued effective May 17, 1996, which discusses the 1 proper use of the term " Operable But Degraded" and limits the use of the term to OCR determinations. The Shift Supervisor reviewed the usage of the terms with the procedure Interpretation Contact to ensure lessons learned were clearly understood.

0 ATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved with the issuance of the Problem Report on May 29, l 1996, i

VIOLATION 50-302/96-05-05  ;

10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings, of a type appropriate to the circumstances and shall be accomplished in accordance with these instructions, procedures, or drawings.

Paragraph V.A.3 of Licensee Procedure NEP-216, Rev. 6, Plant Design Basis Documents, requires revision to plant Design Basis Documents if a modification changes a component / system function, functional requirement, or design requirement as delineated in the existing design basis document.

l U. S. Nuclear Regulatory Commission Page 4 of 9

. ~3F0896-14 Paragraph V.E.1 of Procedure NEP-216 requires that: (1) the Supervisor, Nuclear Configuration Management, determine the need for a revision to plant Design Basis Documents every 12 months and that the review be documented and forwarded to records, and (2) that Design Basis Documents be formally revised every two years,

'as a minimum, if any outstanding Temporary Changes exist from the previous two years.

Contrary to the above, activities were not accomplished in accordance with procedures in that:

1. In August of 1993, a Temporary Change to the Makeup System Design Basis Document was not issued when a plant modification changed the Hydrogen Addition Pressure Regulator setting from 10 psig to 19.5 psig.

2. On January 29,1996, the 12 month review of the Design Basis Documents had not been performed and documented, resulting in six Design Basis Document Temporary Changes not being incorporated into a Design Basis Document revision within the required two year time.

ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Florida Power Corporation (FPC) accepts the violation.

REASON FOR THE VIOLATION In both examples, the reason for the violation was personnel error. For item 1, the responsible design engineer for the calculation that resulted in the modification failed to make the Design Basis Document temporary change.

Compounding the error, the modification design engineer failed to include the Design Basis Document change as an "open item", which would have tracked the change to completion. For item 2, the six temporary changes had been identified .

in September 1995, as requiring incorporation into the Design Basis Document.

However, the individual responsible for the task was placed on temporary assignment and the need for the changes was not communicated to the responsible ,

supervisor, causing the expiration date to pass without the changes being made.

CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED

1. A properly processed temporary change (Number 487) was made to the Design Basis Document on April 9,1996, as a result of another plant modification affecting the hydrogen addition pressure regulator setting.

2. The six temporary changes which were outstanding were incorporated into a Design Basis Document revision made on February 29, 1996.

CORRECTIVE STEPS THAT WILL BE TAKEN TO AVO!D FURTHER VIOLATIONS Subsequent to the occurrence of item 1, NEP-213, Design Analyses / Calculations, was revised to require the identification of plant documents affected by the change. Those document revisions are tracked by the Nuclear Operations Tracking and Expediting System (NOTES) until completion.

The relevant portions of the Problem Report developed for this concern will be reviewed with applicable design Engineers, Verification Engineers, Supervisors

1 U. S. Nuclear Regulatory Commission Page 5 of 9

. 3F0896-14 and Configuration Management personnel. Additionally, NEP-216 will be further evaluated to assure the directives for revising the Design Basis Documents are clear. The procedure will be revised if discrepancies or uncertainties are found. These actions will be completed by October 1,1996.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED l For item 1, full compliance was achieved on April 9,1996, with the posting of the temporary change noted above. For item 2, Full compliance was achieved on February 29, 1996, with the incorporation of the six temporary changes into the Design Basis Document also noted above.

VIOLATION 50-302/96-05-07 ,

l 10 CFR 50, Appendix B, Criterion VII, Control of Purchased Material, Equipment, I and Services, requires that measures shall be established to assure that purchased material, equipment, and services conform to the procurement documents.

These measures shall include objective evidence of quality furnished by the contractor and examination of products upon delivery.

Procedure FPC-016, Receiving Inspection of Equipment and Material, Rev. 0, dated April 24, 1972, step 4.2.2.2 requires that Quality Control Inspection personnel verify that any documentation required is present and that test results conform to the specifications.

Nuclear Procurement and Storage Manual, Section 8.4, Receiving Inspection, Rev.

12, dated June 7,1995, step 8.4.3.2 requires that the Nuclear Materials Quality Control Inspector verify that the documentation, such as Certificate of Conformance, furnished by the vendor meets the requirements of the Florida Power Corporation purchase order. Step 8.4.3.2 also requires that test documents shall describe the type of operation and provide evidence of completion and/or verification.

Contrary to the above:

1. Six safety-related battery chargers were improperly accepted on receiving inspections in July 1972. The vendor had supplied a certificate of compliance with the licensee's purchase order; however, test data from the vendor that had been supplied with the battery chargers indicated that the battery chargers had not been tested to assure they would operate at the lowest alternating current (ac) input voltage specified in the purchase order or required by the design basis. The test data also indicated that one of the battery chargers subsequently installed in the B train failed to meet direct current (dc) output voltage regulation requirements at ac

, input voltages to which it was tested. The licensee's receipt inspection report, dated July 17, 1972, accepted the six battery chargers and the l test data. In April, 1996, one of the two A train battery chargers was tested and similarly failed to meet dc output voltage regulation requirements. The licensee's analysis of past battery charger operability, in Licensee Event Report 96-012-01, concluded that while the battery chargers did not meet purchase specifications or the design basis, they would have been able to perform their safety function from plant licensing in December 1976 through April 1996.

l

U. S. Nuclear Regulatory Commission

' Page 6 of 9

. 3F0896-14

2. Six safety-related battery chargers were improperly accepted on receiving inspections in November 1995. The vendor had supplied a certificate of compliance with the licensee's purchase order; however, test data from the vendor that had been supplied with the battery chargers indicated that the battery chargers had not been tested to assure they would operate at the lowest ac input voltage specified in the purchase order or required by the design basis. Two of the six battery chargers were installed in the A l

train in March 1996 with the plant shut down in an outage. One of the battery chargers was satisfactorily tested in April 1996 while the plant was still shut down, confirming the battery chargers' compliance with t purchase specifications and the design basis. l ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Florida Power Corporation (FPC) accepts the violation.

REASON FOR THE VIOLATION The primary cause for this violation is a weakness in the receipt inspection process involving actions by the design engineer, procurement engineer, and ,

receipt inspector. For the "new" chargers accepted November 1995, the FPC design l l engineer stated that although the test results did not envelope the input voltage ranges specified by FPC, he took into consideration other documentation including l catalog data, the certificate of conformance (CofC) to the purchase order, and statements from C&D Engineering (the vendor) that similar model battery chargers had been tested to 423 VAC. The engineer failed to obtain evidence of this testing but accepted statements by C&D that the chargers had been type tested to this value. In retrospect, this information was not sufficient as a basis for acceptance considering C&D's April 11, 1996, letter indicating test data was  !

unavailable to substantiate their CofC's. In November 1995, a Quality Material ,

Problem Report (QMPR) was issued to identify the need for an Engineering Software i Acceptability Letter (ESAL) for required vendor submitted documentation (this included the test reports). A procurement engineer dispositioned the QMPP. "use- l as-is" in February 1996, based on being provided an ESAL from the design rngineer which presumably reflected acceptance of all documentation requires by the 7

purchase order. Although the inspection plan delineated ' test reralts" as a '

! specific deliverable requiring engineering acceptance, the receipt inspector i accepted the disposition without test results being listed as a specific item on

! the ESAL. This would have provided an opportunity to request an explanation from ,

the design engineer regarding the basis for acceptance of the test results. '

l For the "old" battery chargers accepted July 1972, FPC utilized its architect l engineer, Gilbert Associates for review of manufacturers' quality program i procedures and technical data. The purchase order for the original chargers was dated February 10, 1971, and required C&D to submit a quality control program (it should be noted that 10CFR50 Appendix B was officially issued June 27, 1970, and the requirements of 10CFR21 were not imposed on the purchase order process until

! after January 6,1978). A review of the " Vendor Evaluation Checklist" completed by Gilbert Associates -in 1971 indicates C&D's Quality Control submittal was reviewed against-the requirements of Military Specification MIL-Q-9858 " Quality Program Requirements". Evidence exists to confirm that C&D procedures were reviewed and tests were witnessed at the manufacturer's facility. C&D provided a CofC dated June 9,1972, certifying the material met FPC's purchase order. i However, C&D did not test to 460 VAC +/- 10 % and did not meet the 1/2 %

I i

l

l

~

U. S. Nuclear Regulatory Commission Page 7 of 9

. 3F0896-14 l in one case. A review of the " Charger Test Card" dated March 9, 1972, for S/N ES71606 reveals the test results at 432 VAC input yielded only 131.2 DC volts at i 200 DC amps (full load) versus the required 131.34 volts. A contributing cause was FPC failure to recognize the differences between the specification requirements associated with the "old" chargers and the manufacturer's nameplate l

data and drawing information.

CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED DPBC-1B and DPBC-10, the "B" Train DC battery chargers, were declared operable but degraded on April 17, 1996, with reduced ES loads in MODE 5 and a decision was made requiring their replacement prior to entering MODE 4 (H0T SHUTDOWN).

Battery Chargers DPBC-1A,1B,10, and ID were replaced during Refuel 10. The l Train "A" chargers were fully operable on April 16, 1996, and the Train "B" l chargers were declared fully operable as of April 23, 1996. Battery Chargers DPBC-1E and IF, the backup " swing" chargers, have also been replaced with "new" chargers.

A Request for Corrective Action (RCA) was issued by FPC's Procurement Quality group on April 12, 1996, to C&D requesting a response to the identified deficiency regarding failure to test the "new" chargers in accordance with FPC specification criteria. ,

l l CORRECTIVE STEPS THAT W'LL BE TAKEN TO AVOID FURTHER VIOLATIONS A copy of this event repo t (LER 96-12-02) along with management's expectations has been distributed to design and procurement engineers and receipt inspectors as a " lessons learned". Further, a Management Review Panel will be convened on this problem to provide additional management oversight.

l Additional guidance was incorporated into the Nuclear Procurement & Storage Manual (NP&SM) section concerning receipt inspectors' review of engineering l software acceptability letters provided by engineering. This guidance addresses the need to perform a line-by-line review of information contained in the

software acceptability letter versus the applicable technical requirement l

reference.

l i The next revision to the NP&SM will include a requirement to verify that I

nameplate data complies with Purchase Requisition requirements. This will be completed by September 30, 1996.

! DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance was achieved on August 7,1996, with the installation of the final "new" battery charger DPBC-1E.

VIOLATION 50-302/96-05-08 10 CFR 50, Appendix B, Criterion IV, Procurement Document Control, required, in part, that measures be established to assure that requirements which are necessary to assure adequate quality are suitably included in the documents for procurement of equipment.

,. U. S. Nuclear Regulatory Commission Page 8 of 9

. 3F0896-14 Nuclear Procurement and Storage Manual, Section 3.3, Amendments to Procurement Requisitiens for Items, Rev. 6, dated October 31,1991, required that Procurement Requisition Amendments be used for Purchase Order Change Orders to change procurement requirements such as item description.

Nuclear Engineering and Projects procedure 220, Specifications and Minispecifications, Rev. 5, dated November 30, 1994, required that revisions to ,

minispecifications be prepared, verified, approved, and issued in the same manner as the original.

Contrary to the above, a letter dated April 5,1995, from the licensee's Nuclear Engineering Design Department to the vendor, changed procurement requirements for safety-related inverters without using a Procurement Requisition Amendment. The letter directed the vendor to change inverter design specifications, including output voltage, that were in the minispecification that was incorporated into the Purchase Order. Also, the minispecification was not revised and required verification and approvals were not obtained. On about April 10, 1995, the letter was included in a revised Purchase Order without a Procurement Requisition Amendment.

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

REASON FOR THE VIOLATION ,

The reason for the violation was personnel error. The engineer originating the letter to the vendor did not utilize the correct method for implementing technical changes to a purchase order. Other personnel reviewing the letter  !

should also have known a Procurement Requisition Amendment was required in this case. As a contributing factor, the Safety Related Purchase Order Review Checklist used by the Purchasing Department does not include a specific )

checkpoint for proper approval of Procurement Requisition Amendments as it does i for the original Procurement Requisition.

)

CORRECTIVE STEPS THAT HAVE BEEN TAKEN AND THE RESULTS ACHIEVED A Problem Report was generated to determine the root causes of the occurrence and i a Corrective Action Plan has been developed.

CORRECTIVE STEPS THAT WILL BE TAKEN TO AVOID FURTHER VIOLATIONS

1. All Nuclear Engineering Design personnel will be required to read / review both the Problem Report noted above and Nuclear Engineering and Projects (NEP) procedure 220 by September 1, 1996.

2. All Buyers and Buyers Associates will be required to read / review Nuclear Procurement and Storage Manual (NP&SM), Section 3.3 by September 1,1996.

3. The Safety Related Purchase Order Review Checklist will be revised by September 1,1996, to include a checkpoint for Procurement Requisition Amendment approvals.

i

d

- U. S. Nuclear Regulatory Commission Page 9 of 9 i.,. 3F0896-14

4. A Procurement Requisition Amendment will be processed in accordance with j NP&SM Section 3.3 and the associated minispecification will be revised in '

accordance with NEP-220. This will be completed by September 13, 1996.

DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance will be achieved by September 13, 1996, with completion of the Procurement Requisition Amendment and minispecification revision as noted in item  :

4 above.

l l

l l

i l

l l

l

~.

l

. . .