3F0986-07, Revises Response to Violations Noted in Insp Rept 50-302/85-26.Corrective Actions:Procedural Requirements Emphasized Re Maintaining Copy of Current Clearance Order W/Appropriate Work Request at Job Site
| ML20206S517 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/05/1986 |
| From: | Widell R FLORIDA POWER CORP. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 3F0986-07, 3F986-7, NUDOCS 8609220251 | |
| Download: ML20206S517 (6) | |
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Florida Power CORPORATION September 5, 1986 3F0986-07 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 No. 85-26 Revised Response
Dear Sir:
Florida Power Corporation provides the attached as our revised response to the subject inspection report.
Sincerely, Rolf)C. Widell Manzier, Nuclear Operations Licensing and Fuel Management AEF/feb Attachment 8609220251 860905 PDR ADOCK 05000302 G
PDR GENERAL OFFICE: 3201 Thirty-fourth Street Gouth St. Petersburg, Florida 33733 * (813) 866-5151 P.O. Box 14042
- A Florida Progress Company
FLORIDA POWER CORPORATION
RESPONSE
INSPECTION REPORT 85-26 VIOLATION 85-26-01 Technical Specification 6.8.1 requires adherence to the Administrative and Surveillance procedures.
Administrative - Instruction ( AI) 600, Conduct of Maintenance, specifies that equipment clearances be obtained in accordance with Compliance Procedure (CP) 115, In-Plant Equipment Clearance and Switching Orders, and that Work Requests (WRs) be issued in accordance with CP-113, Procedure for Handling and Control-ling Work Requests and Work Packages.
CP-113, paragraph 5.3 requires the W/R be signed by the Nuclear Shift Supervisor (NSS) before work is begun.
CP-115, paragraph 5.8.2 requires a copy of the accepted clearance to be at the job site.
Surveillance Procedure (SP) 210, ASME Cl ass 2 and 3 Hydrostatic testing ~
requires the following:
No valves shall be installed in any lines going to temporarily installed relief valves and pressure gauges (paragraph 4.2) and, Hydrostatic test boundary valves shall be established as listed on data sheet Enclosure 2 (paragraph 7.4).
Contrary to the above; on June 13, 1985, while performing a hydrostatic test of the Nuclear Services Seawater (RW) System, the following items were identi-fied:
The WR used to authorize the performance of the hydrostatic test was signed by the NSS on June 12, 1985, even though work was begun on the system on June 11, 1985.
The equipment clearance under order #6-10 was amended and a copy of the amended order was not at the job site.
The test was conducted wi th isolation valves installed in the lines leading to each pressure gauge and the relief valve.
Hydrostatic test boundary valve RWV-14, that was listed on Enclosure 2 as a boundary for the test volume, was not the actual boundary valve since upstream valve RWV-6 was left shut.
This is a Severity Level IV Violation (Supplement I).
RESPONSE
1)
FLORIDA POWER CORPORATION'S POSITION Florida Power Corporation agrees with the stated violation in that:
A.
Written objective evidence of approval to begin work on June 11, 1985, could not be found; B.
A copy of the amended clearance order was not at the job site; C.
The test was conducted with isolation valves installed in the lines leading to each pressure gauge and the relief valve; and D.
RWV-6 was not in the open position.
2)
APPARENT CAUSE OF VIOLATION A.
On June 11, 1985, work was begun under a properly completed and approved work request.
During the day, the pipefitter foreman reported the work request was lost.
B&C The cause of these occurrences was failure to follow procedure.
D.
The mispositioning of RWV-6 was due to miscommunication between the test supervisors and workers in the field.
3)
CORRECTIVE ACTIONS A.
Upon report of the work request being missing, work was stopped. A search of all likely locations for the work request was conducted with negative results.
A copy of the lost work request, a copy without the approval signatures, and the requisite approvals were obtained. These approvals were signed on June 12, 1985.
A letter has been sent to quality files to append the file for Work Request-59483, to state that the original had been lost, but was approved on June 11, 1985.
B.
A letter was sent to all Si te Nuclear Operations personnel emphasizing the procedural requirements to maintain a copy of the current clearance order with the appropriate work request at the job site.
C.
The test supervisor and assistant test supervisor were counseled regarding the need to follow procedures.
D.
The test supervisor and the assistant test supervisor were counseled regarding the need for precise communications.
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ACTION TAKEN TO PREVENT RECURRENCE A.
No further corrective Action.is necessary.
B.
The "swi tching and tagging" training has been amended to emphasize the need to maintain the current clearance order at the job site.
C&D The procedure for ASME Class 2 and 3, hydrostatic testing, has been revised to allow the snubbing or alternate device to be included as part of the test rig.
Further, steps have been included to document troubleshooting activities and all valve change manipulations during troubleshooting.
This documenta-tion will strengthen control of the troubleshooting process and thus reduce the chance for miscommunication.
5)
DATE OF FULL COMPLIANCE Full compliance was achieved on August 18, 1986 when the quality files for Work Request 59483 were appended.
VIOLATION 85-26-05 10 CFR 50, Appendix B, Cri teria V and X,
as implemented by the approved Florida Power Corporation (FPC) Operational Quali ty Program, requires the following:
Paragraph 1.7.1.5 of the FPC Quality Program implements the requirements of Criteria -Y and requires written procedures for_ the perfonnance of work affecting quality and requires adherence to these procedures.
Paragraph 1.7.10 of the FPC Quality Program implements the requirements of Criteria X and requires an adequate inspection of the activities being inspected.
Contrary to the above, on June 20, 1985, plant modification procedure (MAR) 85-03-13-01 was not adhered to in that eight concrete anchor bolts, which were required to be tightened to a torque of 40 to 45 foot-pounds, were only torqued to 25 foot-pounds.
In addition, the inspection of this modification was inadequate since the inspector failed to identify the incorrect torque values.
This is a Severity Level IV violation (Supplement I).
RESPONSE
1)
FLORIDA POWER CORPORATION'S POSITION Florida Power Corporation agrees with the stated violation in that a plant modification procedure was not adhered to.
Eight concrete anchor bolts, which were required to be tightened to a torque of 40 to 44 foot-pounds, were only torqued to 25 foot-pounds. FPC further agrees that the inspection of this modification was inadequate since.
the inspector failed to identify the incorrect torque values.
2)
APPARENT CAUSE OF VIOLATION On June 20, 1985, various inspections were being performed on relay cabinets identified as RR-3A and RR-38.
Specific work activities involved the installation of seismic supports per Work Package
- 67751.
Af ter the torque operation and subsequent inspection, the NRC reviewed the package sign-offs which revealed incorrect torque values applied.
The cause appears to be personnel error.
Torque values used by both craft and the Quality Control Inspector were those applied to Phillip's wedge anchors.
The actual anchor bolts installed were Maxi-Bolts.
The Phillip's wedge anchors are by far the largest percentage of anchors installed with torque values of 25 foot-pounds, while Maxi-Bol t installation is less frequent.
In
- dddition, discussions revealed that the inspection turnover contributed to this event.
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a 3)
CORRECTIVE ACTIONS Immediate corrective action in the field was to re-torque the bolts in question to the correct values and re-inspect.
This was performed subsequent to the error identification and currently meets design requirements imposed in the work package.
A detailed discussion was held with the two inspectors involved.
The resul ts of these discussions indicate a high degree of familiarity with the torque requirements specified in M0P-408.
The inspection sequence normally completed by one inspector would also include inspection of hole drilling and minimum embedment depth that would have prevented this occurrence.
In order to assure familiarity with torque requirements for both Phillip's wedge anchor bolts and Maxi-Bolts, training was. completed for all inspectors in the inspection plan for anchor and bol t requirements, as well as the torque value criteria identified in M0P-408, " Installation of Concrete Anchor Bolts."
Addi tionally, a review of installation records was performed to verify ' application of proper torque.
The results of this review indicate that all safety-related installations of Drillco Maxi-Bolts (approximately 150 bolts) were conducted to specified torque requi rements.
4)
ACTION TAKEN TO PREVENT RECURRENCE In addition to the corrective actions above, the concrete anchor installation record was revised to require tne field engineer to specify the required torque value for each anchor bolt. This record will be added to the procedure for concrete anchor bol t installation.
5)
DATE OF FULL COMPLIANCE Full compliance was achieved on August 9,1985.
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