IR 05000302/1977021

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IE Insp Rept 50-302/77-21 on 771108-10.Noncompliance Noted: Failure to Follow Maint Administrative Procedures
ML19308D514
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 12/01/1977
From: Dance H, Verdery E, Wessman R
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19308D510 List:
References
50-302-77-21, NUDOCS 8002280829
Download: ML19308D514 (8)


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Report No.: 50-302/77-21 Docket No.: 50-302 License No.: DPR-72 Licensee: Florida Power Corporation 3201 34th Street, South P. O. Box 14042 St. Petersburg, Florida 33733 Facility Name: Crystal River 3 Inspection at: Crystal River site, Crystal River, Florida Inspection conducted: November 8-10, 1977

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Inspectors:

R. H. Wessman E. H. Verdery Reviewed by:

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i H.'C. D.ince,' Chief Date Reactor Projects Section No. 1 Reactor Operations and Nuclear Support Branch Inspection Summary Inspection on November 8-10, 1977:, (Report No. 50-302/77-21)

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Areas Inspected: Routine, unannounced inspection of maintenance activities; followup on outstanding items, unresolved items, and licensee corrective

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actions for previous non-compliances; and facility tour. The inspection involved 44 inspector-hours on site by two NRC personnel.

Results: Of the three areas inspected one item of noncompliance was identified in one area (Infraction:

Failure to follow maintenance

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administrative procedures (77-21-01).)

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RII Rpt. No. 50-302/77-21 I-1

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DETAILS I Prepared by:

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J R. _ li. Wessman, Reac of Inspector Date Reactor Projects Section No. 1 Reactor Operations and Nuclear Support Branch Dates of Inspection: November 8-10, 1977

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/L H. C. Dance, Chief Ifate Reactor Projects Section No. 1 Reactor Operations and Nuclear Support Branch 1.

Persons Contacted

Florida Power Corporation (FPC)

  • G. P. Beatty, Jr., Nuclear Plant Manager pg
  • W. R. Nichols, Operations Supervisor V)
  • P. F. McKee, Assistant Nuclear Plant Manager
  • D. W. Pedrick, IV, Compliance Engineer
  • J. Cooper, Compliance Auditor
  • L. C. Kelly, Compliance Auditor
  • G. M. Williams, Compliance Auditor
  • Denotes those present at the exit interview.

2.

_ Licensee Action on Previoup_ Inspection Findings The inspector reviewed various items from previous Inspection and Enforcement inspections to resolve unresolved items and to confirm licensee corrective actions taken in response to noncompliance items. The results of this review are detailed in paragraphs 5 through 15 of these Details.

3.

Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations. One Unresolved Item, relating to

. accounting for strip charts, was disclosed and is identified as Unresolved Item 77-21-02.

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RII Rpt. No. 50-302/77-21 I-2

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While inspecting Unresolved Item 77-6/3 concerning the retrieval of strip charts, the inspector determined that the licensee has not established a program for receipt accounting of strip charts. It did not appear possible to determine if all charts for a given recorder had been received by the records custodian in that no chronology or file of transmittals for individuil recorder charts were maintained.

4.

Exit In_terview A meeting was held by R. H. Wessman and E. H. Verdery with G. P. Beatty, Jr.

and members of his staff on November 10, 1977. Items discussed included the noncompliance (Details II, paragraph 5) and other areas inspected.

5.

Un

_ resolved Item 77-3/1, offsite Organization

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This unresolved item, identified in IE Report No. 50-302/77-3 pertained to a discrepancy in the If censee's of fsite organization and that depicted in Figure 6.2-1 of the Technical Specifications.

Amendment 5, dated July 5, 1977, revised Figure 6.2-1.

The inspector

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compared this revised organization chart with Figure 1-1, Quality

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Program Responsibilities, in the FPC Quality Manual and with the Personnel Manual Organizational Structure dated 9/27/77. The positions entitled " Purchasing Manager" and " Manager, Projects and Planning" shown in the Technical Specifications Figure 6.2-1 could not be identified in either of these other documents. This unresolved item remains open.

6.

Changes to Test Program

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During IE Inspection 50-302/77-5 an infraction was identified involving the failure to conduct a safety evaluation when making a change to the test program as described in the FSAR.

FPC's responses, dated April 25, and lay 31, 1977, were reviewed.

Corrective action was verified by review of the Plant Review Commit tee Minutes for the meeting numbered 77-25 held on June 2, 1977. This infraction is closed.

7.

RCS Hot Leakage Testing During IE Inspection 50-302/77-5 a Deviation was identified in that RCS Hot Leakage Testing at the 15% power plateau was not adequately performed in accordance with FSTA commitments.

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FPC's response, dated April 25, 1977, was reviewed and subsequent l

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RCS hot Icakage measurements were confirmed. This deviation is l

closed.

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RII Rpt. No. 50-302/77-21 I-3

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Unresolved Item 7; -5/1, RCS Leakage Surveillance This unresolved item, identified in IE Report No. 50-302/77-5, pertained to errors in Surveillance Procedure No. 317 (RC System Water Inventory Balance) data sheets. Followup of this unresolved item-(IE Report No. 50-302/77-9) indicated that errors in the execution of SP 317 data sheets still existed.

The inspector reviewed Revision 6 to SP-317, dated August 18, 1977.

He also reviewed executed data sheets for RCS inventory measurements made in September and October 1977 and found no errors.

This unresolved item is closed.

9.

Testing of Tunnel Sump Pumps During IE Inspection 50-302/77-6 an infraction was identified in that on January 31, 1977, tunnel sump pumps were not tested in accordance with the Technical Specification 3.8.1.1 Action statement.

FPC's response, dated June 10, 1977, was reviewed by the inspector.

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AI-1300, Crystal River Units 1 & 2 Interface With Crystal River

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Unit 3, has been written (as committed by FPC) and was reviewed by the inspector. The inspector had no further questions.

This infraction is closed.

10.

Unresolved Item 77-6/3, Retrieval of Strip Charts i

This unresolvcd item, identified in IE Report No. 50-302/77-6, pertained to difficulties in retrieval of strip charts due to the method of storage. The licensee has organized the storage facility for strip charts to facilitate their retrieval, closing this item.

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In the course of the.eview of strip chart receipt and storage the inspector identified Unresolved Item 77-21-01, relating to strip i

cl. art accounting (see paragraph 3 of these Details).

11.

Epegeney Feedwater Pump Steam Supply nc During IE Inspection 50-302/77-9 an infraction was identified in that the turbine driven emergency feedwater pump was aligned to the auxiliary steam header, rather than the main steam header.

FPC's response dated July 6,1977, was reviewed by the inspector.

Corrective action had been taken at the time of Inspection 77-9 and the definition of " operable steam header" has been clarified. The inspector reviewed OP-606, Auxiliary Steam System, and auxiliary (

steem system drawings without comment. This infraction ic atosed.

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V RII Rpt. No. 50-302/77-21 I-4

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Unresolved Item IIE_Repo_rt No. 50-302/77-9) Emergency Feedwater Automatic Actuation This unresolved item, identified in IE Report No. 50-302/77-9, pertained to an apparent variance between the Technical Specification 4.7.1.2 surveillance requirement for emergency feedwater pump tetting and the plant design (and SP 416, EFW Automatic Actuation).

The Itcensee has submitted Technical Specification Change Request No. 5 on July 15, 1977, which would eliminate this variance.

This unresolved item remains open pending issue of the Technical Specification amendment.

13. Manual Valves in Fire Suppressant Systems During the conduct of inspection 77-13 the licensee committed to evaluate the means of positive control for manual valves in fire suppressant systems (See Details I, paragraph 5.e of IE Report 50-302/77-13). These valves receive a red or white " seal" as required for fire insurance. Also they have been included in a surve111ance

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procedure for periodic verification. The inspector has no further (

questions regarding this item.

14.

Hose Station Adjacent to Cable Spreading Room During the conduct of inspection 77-13 the licensee agreed to post instructions adjacent to the pull box activating FSV-240 (See Details I, paragraph 5.f of IE Report 50-302/77-13). The inspector

verified the posting of these instructions and has no further questions regarding this item.

15.

Modification to Reactor Building Purge Monitor (RM-A1)_

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The inspector reviewed the executed copies of MAR 77-9-24 and Work l

Request T-2177, which documented the completion of a modification to the purge monitor (RM-A1). This modification trips the reactor building purge valves in the event of a RM-Al failure, thus preventing an unmonitored gas release. This completes the licensee's commitment made during inspection 77-18 (See Details I, paragraph 12 of IE Report 50-302/77-18). The inspector has no further questions.

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RII Rpt. No. 50-302/77-21

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V7 DETAILS II Prepared

_. Verdery, Re._ tor Inspector Ifate Nuclear Support Section No. 2 Reactor Operations and Nuclear Support Branch Dates of Ins fon:

vember 8-10, 1977

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Reviewed by:,_

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C.

derson, Acting Chief

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Nuclea Support Section No. 2 Reactor Operations and Nuclear Support Branch 1.

Persons Contacted Florida Power Corporation (FPC)

  • G. P. Beatty, Jr., Nuclear Plant Superintendant

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  • D. W. Pedrick, Compliance Engineer

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  • T. C. Lutkehaus, Maintenance Engineer
  • G. Williams, Compliance Auditor
  • C. Coering, Compliance Auditor
  • F. Plubell, Electrical Maintenance Supervisor
  • Denotes those present at the exit interview.

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2.

Licensee Action on Previous Inspection Findings Not inspected.

3.

Unresolved Items None identified during this inspection.

4.

Exit Interview See Details I, paragraph 4.

5.

Maintenance

'Ihe inspector reviewed maintenance related documentation and a.

procedures to determine conformance to the Technical Specifications, Plant Operations Quality Assurance Manual (P0QAM) controls, FSAR commitments, and ANSI N18.7-1976 requirements. The inspector reviewed approximately thirty safety-related work O

requests, as well as related maintenance reports, equipment clearance orders, procedural check-off sheets, surveillance procedure data sheets, and other supporting data.

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RII Rpt. No. 50-302/77-21 II-2

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Administrative Instruction AI 400, " Plant Operating QAM Control Document," Section 9.5.7 states.in part: "The equipment to be worked on is to be isolated and removed from service using an approved Operating Procedure and an Equipment Clearance Order per CP-115, In-Plant Equipment Clearance and Switching Orders. For those cases where an Operating Procedure will not satisfactorily isolate safety-related equipment, the Equipment clearance Order must be approved as a procedure before the clearance is granted..

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Contrary to the above requirements, Work Raquest No. 0-04066 was completed on September 9, 1977, on Makeup Pump "B" Discharge Drain Valve (MOV 347) without the use of an approved procedure

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or a Plant Review Connittee (PRC) approved Equipment Clearance Order for taking the pump out of service. (08-228)

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This discrepancy is illustrative of a general maintenance practice deficiency in that no work request packsge reviewed contained any documentation of the use of an approved operating procedure to remove or return a safety-related component to service. The licensce's representative stated that, frequently, (

the practice in plant was to rely on the Equipment Clearance

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Order (not previously approved by the PRC) to accomplish the removal of safety-related components from service for maintenance.

Administrative Instruction AI 600, " Conduct of Maintenance," Section c.

4.2 states in part: "All repairs of safety-related equipment shall be performed to written procedures and returned to original configuration or a properly approved and documented configuration."

Contrary to the above requirement Work Roquest No. 0-03752 was completed on August 8, 1977, on a Ifigh Pressure Coolant Injection valve (MOV-24) without documentation of the use of an approved maintenance work procedure.

The above discrepancy is not an isolated case and is further supported by the fo11 ewing work request packages which contained no evidence of the use of approved maintenance procedures:

Work Request No. 0-04006, In Limit Light,

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Rod 3-3, completed September 19, 1977.

Work Request No. 0-04080, Inverter D,

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completed September 19, 1977.

['~')N Work Request No. 0-03620, Makeup Pump B,

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g completed July 28, 1977.

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RII Rpt. No. 50-302/77-21-II-3

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Work Request No.-0-1923, Steam Supply Valve to

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Energency Pecdwater Pump No. 2 (ASV-5), completed January 13, 1977.

The items noted above have been designated as an infraction (77-21-01).

6.

Centralized Review Point for Completed Maintenance Actions The inspector noted that the Plant Compliance Section does not review the entire work request package, with all of its required supporting docunentation, upon completion of the work and the individual reviews made by other members of the plant staff.

In essence there is no final review point to ensure that all required QA documentation is available and complete for each maintenance action on safety-related equipment. The inspector stated that the improper documentation noted in paragraph 5 above, could be attributable,

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in part, to this lack of a coordinated final review process.

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