IR 05000302/1986017

Insp Rept 50-302/86-17 on 860519-23.No Violations or Deviations Noted.Major Areas Inspected:Licensee Actions on Previous Enforcement Matters & Insp Findings & QA Effectiveness

ML20203C076
Person / Time
Site:	Crystal River
Issue date:	06/24/1986
From:	Belisle G, Runyan M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20203C064	List: IR 05000302/1986017 ML20203C056
References
50-302-86-17, NUDOCS 8607180350
Download: ML20203C076 (9)

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p Kr4 UNITED s. ATES

'o NUCLEAR REGULATORY COMMISSION

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g n REGION 11

,j 101 MARIETTA STREET, *I e ATLANTA. GEORGI A 30323

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Report No.: 50-302/86-17 Licensee: Florida Power Corporation 3201 34th Street, South St. Petersburg, FL 33733 Docket No.: 50-302 License No.: DPR-72 Facility Name: Crystal River 3 Inspection Conducted: May 19-23, 1986 Inspector: ), / rtmy 0 M. F. Runyan i Date Signed Accompanying Personnel: G. A. Belisle, RII Approved by: %v (f A 6 G. A. Belislet Acting Section Chief ~ Date Signed Division of Reactor Safety

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SUMMARY Scope: This routine, announced inspection was conducted on site in the areas of licensee actions on previous enforcement matters, to assess quality assurance effectiveness,iand licensee action on previously identified inspection findings.

Results: No violations or deviations were identifie ,

h 8607180350 860708 PDR

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G ADOCK 05000302 PDR

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REPORT DETAILS Persons Contacted Licensee Employees

• P. Alberdi, Manager, Nuclear Site Support T. Austin, Nuclear Mechanical Engineer C. Barbour, Senior Quality Auditor D. Betts, Manager Quality Audits P. Breedlove, Nuclear Records Management Supervisor R. Brown, Nuclear Electrical / Instrumentation and Control (I&C) Supervisor

• J. Bufe, Nuclear Compliance Specialist M. Casada, Nuclear Technical Support Analyst T. Catlett, Operations Planning Supervisor H. Eck, Nuclear Maintenance Specialist

• J. Frijouf, Compliance Specialist A. Gelston, Nuclear Electrical /I&C Engineering Supervisor V. Hernandez, Senior Nuclear Quality Assurance (QA) Specialist J. Holton, Nuclear Plant Engineer II R. Hudnet, Nuclear Chief Electrician

• T. Kamann, Nucler.r Operations Records Manager M. Kirk, Operations Technical Advisor

• D. Kurtz, Supervisor, Quality Audits

• K. Lancaster, Manager, Site Nuclear QA H. Liles, Nuclear Results Specialist M. Lord, Nuclear I&C Engineer R. Love, Nuclear Master Mechanic

• M. Mann, Nuclear Compliance Specialist W. Marshall, Nuclear Shift Supervisor P. McKee, Director, Nuclear Plant Operations

• L. Moffatt, Nuclear Safety Supervisor R. Murgatroyd, Assistant Nuclear Maintenance Superintendent W. Neuman, Inservice Inspection (ISI) Supervisor

• R. Pinney, Manager, Quality Systems D. Salute, Nuclear Compliance Specialist L. Santilli, Nuclear Calibration Laboratory Supervisor P. Small, Maintenance Department Coordinator R. Thomoson, Nuclear Mechanical and Structural Engineering Supervisor M. Unger, Senior Nuclear QA Engineer

• G. Westafer, Director, Quality Programs Other licensee employees contacted included office personne NRC Resident Inspector

• J. Tedrow

• Attended exit interview k

2. Exit Interview The inspection scope and findings were summarized on May 23, 1986, with those persons indicated in the paragraph above. The inspector described the areas inspected and discussed in detail the inspection result No dissenting comments were received from the license The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio . Licensee Action on Previous Enforcement Matters (Closed) Severity Level IV Violation (302/85-13-02): Failure to Evaluate Out-of-Tolerance Measuring and Test Equipment (M&TE) in a Timely Manne The licensee's response dated May 17, 1985, was considered a':ceptable by Region II. Procedure NCL-01 was revised (Revision 8) to require a FPC supervisor to be immediately responsible for the use of calibrated equipment by non-FPC employee The FPC supervisor is responsible for the out-of-tolerance evaluation and all regular time limits apply. All out-of-tolerance evaluations referenced in the violation have been closed out. No further problems of a similar nature have occurre The inspector concluded that the licensee had corrected the previous problem and developed corrective action to preclude recurrence of similar problems. Corrective actions stated in the licensee response have been implemente (Closed) Severity Level IV Violation (302/85-15-01): Failure to Assure that Conditions Adverse to Quality Were Promptly Correcte Licensee responses dated June 14, and September 17, 1985, denied this violation. The licensee response dated September 17, 1985, did state, however, that several program enhancements for elevating unresolved QA Audit Findings had been instituted. These included a memorandum issued from the Vice President, Nuclear Operations, and a revision to QAP-8, Quality Program Audits. The Vice President's letter was issued on August 1, 1985. QAP-8 was revised on September 30, 1985, and issued on October 9, 198 The inspector reviewed QAP-8, Revision 11, and identified that clarifications have been made relative to resolving outstanding audit findings promptly. The inspector also reviewed Nonconformance Reports (NCR) 02836, 02839, and 02842. These NCRs were identified due to delayed corrective actions relative to findings identified in QA Audits QP-273, QP-254, and QP-26 The inspector also reviewed NCR 0283 Corrective actions for these NCRs appeared satisfactory. The inspector i concluded that the licensee had corrected the previous problem and '

developed corrective action to preclude recurrence of similar problems.

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Corrective actions stated in the licensee response have been imple- l l mente l

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3 (Closed) Severity Level IV Violation (302/85-15-02): Failure to Escalate an Audit Finding to an NC The licensee's response dated June 14, 1985, was found to be acceptable uy Region I The inspector discussed this item with the Manager,

'uality Audits, and was informed that corrective actions had been completed and verified by Quality Programs personnel. The inspector concluded that the licensee had corrected the previous problem and developed corrective action to preclude recurrence of similar problem Corrective actions stated in the licensee response have been imple-mente (Closed) Unresolved Item (302/85-15-03): Failure to Perform Technical Specification (TS) Audits and Criterion II Reviews Within Required Interval In correspondence from the NRC to FPC dated August 28, 1985, the imposition of this violation was withheld pending further revie This correspondence also stated that this item would be considered unresolve In subsequent discussions with NRC personnel, it was determined that the licensee's method for scheduling audits appears acceptabl . Unresolved Items Unresolved items were not identified during the inspectio . General Background In correspondence dated April 4,1986, NRC Region II requested that the licensee forward the following information for Region II review:

Copies of all audits and audit findings conducted by Quality Programs audit personnel started or completed from January 1, 1985, to February 1,1986. Audit checklists and those audits that identified findings that did not require a written reply need not be include Copies of all surveillances and surveillance findings by site QA personnel started or completed from January 1,1985, to February 1, 198 Based on this request, the licensee forwarded the following audits and surveillances:

Audits Surveillances QP-263 84-CHL-28 QP-264 84-CHL-29 QP-265 84-RJC-30 x

(con't) Audits Surveillances QP-266 85-CHL-01 QP-267 85-CHL-02 QP-268 85-CHL-03 QP-269 85-EAF-04 QP-271 85-EAF-05 QP-272 85-RCF-06 QP-273 85-GIL-07 QP-274 85-VAH-08 QP-275 85-EAF-09 QP-276 85-RFC-10 QP-277 85-CGB-11 QP-278 85-RFC-12 QP-279 85-EAF-13 QP-280 85-EAF-14 QP-281 85-RFC-15 QP-282 85-PGP-16 QP-283 85-EAF-17 QP-284 85-LAS-18 85-VAH-19 85-LAS-20 85-LAS-21 85-EAF-22 85-TLO-23 86-VAH-01 The inspectors performed an in-office review of the following NRC Inspection Reports:

Reports 50-302/85-05 50-302/85-27 50-302/85-07 50-302/85-29 50-302/85-08 50-302/85-33 50-302/85-11 50-302/85-34 50-302/85-12 50-302/85-35 50-302/85-13 50-302/85-41 50-302/85-15 50-302/85-42 50-302/85-16 50-302/86-01 50-302/85-17 50-302/86-02 50-302/85-18 50-302/86-04 50-302/85-19 50-302/86-06 50-302/85-20 50-302/86-07 50-302/85-21 50-302/86-10 50-302/85-23 50-302/86-11 50-302/85-26 These licensee audits and surveillances were reviewed to determine if the licensee was identifying and correcting problem areas.

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The NRC Reports were reviewed to determine the types of problems being identified by the NRC and to determine if these problems could have been reasonably avoided by more comprehensive licensee identification method i The problems icentified by the licensee and NRC were extremely divers With the exception of similar type document control problems, there were no common problems identified by both organizations. Problems identified by the NRC relating to operator licensing and by an audit conducted by the licensee in the same area were not included in the data base since NRC .

action is pending. Corrective actions for licensee identified operator licensing problems are in the process of being resolved. Quality Assurance Effectiveness For the purposes of this inspection, quality assurance effectiveness is being defined as the ability of the licensee to identify and correct their own problems. Such identification can be by one or more of the following mechanisms:

Audits Surveillances INP0 findings Any other internal or external licensee mechanism Licensee problem identification basically consists of two general mechanisms; Quality Program Department (QPD) and the line organization. The inspectors conducted interviews with QPD and various line organization personnel and were informed of some of the various mechanisms that were currently being used by FPC personnel to identify problems. Some mechanisms are systematic in nature and are not as easily defimble as Licensee Event Reports (LERs), Nonconformance Operations Reports .(NCORs), or NCR The following listings are not intended to be all inclush Interviews with FPC personnel were not conducted at the corporate offices in St. Petersbur QPD utilizes the following mechanisms:

NCR Nonconformance Report AFR Audit Finding Report QPSR Quality Program Surveillance Report QPFR Quality Program Review Form RCA Request for Corrective Action QCIR Quality Control Inspection Report QMPR Quality Material Problem Report NCI Nonconforming Item Tag HOLD Hold Tag CAR Corrective Action Report QPDR Quality Program Deficiency Report The various line or corporate organizations utilize the following '

mechanisms:

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NCOR Nonconformance Operations Report FPR Field Problem Report FUR Followup Report RSIR Radiation Safety Incident Report VIR Unusual Incident Report 50ER Significant Operating Event Report WR Work Request MAR Modification Approval Record REI Request for Engineering Information LER Licensee Event Report SIR Security Incident Report PRR Procedure Review Record PA&TS Procedure Approval and Transmittal Sheet MPR Material Problem Report CAA Corrective Action Assignments MQR Material Qualification Form EQ Engineering Question PM Preventive Maintenance Program Safety Concerns (NL-06)

Nuclear Operations Error / Deficiency Log (SREP 8)

Nuclear Construction Evaluation Material Technology Department (MTAP 13, MTAP 14)

Nuclear Licensing & Fuel Management Department (NLCFMP-03)

Nuclear Outages & Modification Department (MOP 405)

The inspectors determined that there does not exist a system for processing and trending information from the entire spectrum of these reporting mechanism Within disciplines, some trending is accomplished with a specific portion of the data bas For example, the Nuclear Safety and Reliability Staff trends NCORs in an informal progra The QA staff utilizes the computerized Noncompliance Tracking / Trending System (NTTS)

which is currently being upgraded to provide real time trending capability for QA-identified items. In Maintenance, FPRs are tabulated but not trended. With this widespread dispersion of information, it is possible that what appears to be a small problem in several areas is in fact, cumulatively, a larger problem which may go undetected as such. Further inspections would be needed to evaluate the various reporting mechanisms and to determine the effectiveness of systems to process the informatio The assessment of QA effectiveness included a detailed review of two operational issues as they pertained to the theme of this inspection. One dealt with a generic issue concerning potential problems of overspeed trips of turbine-driven auxiliary feedwater (AFW) pumps. The other involved high pressure turbine drain line failure These issues were addressed in such a manner to answer the following questions:

Should the licensee have been expected to circumvent the problem through early detection?

Were actions taken after the problem was identified indicative of an effective quality assurance process? l

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Inspection and Enforcement (IE) Information Notice 86-14 dated March 10, 1986, identified several generic overspeed failures involving AFW single-stage noncondensing turbines manufactured by the Terry Corporation with Woodward governors. The specific incident which occurred at Crystal River (documented in NCOR 84-247) involved seat leakage of a steam inlet isolation valve which, after the trip valve was closed and then reset during a surveillance test, caused the shaft to idle at approximately 160 revolutions per minute (rpm). When the steam inlet isolation valve was opened to perform the test, the shaft oversped and tripped to a lockout condition because the governor did not have time to respond due to the high initial rp The steam leak could not be repaired in an operating mode. A surveillance test was performed and proved that the pump would auto-start without overspeeding. In lieu of shutting down, the licensee decided to conduct a regular visual inspection of the shaft to ensure that it was not rotating. This was documented on Short-Term Instruction 85-5, dated January 11, 1985, and expiring April 11, 198 The steam leak was repaired during the subsequent outag The licensee's identification of this problem appeared timely (the steam leak probably occurred after the last surveillance test) and safety issues were conscien-tiously addressed. Overall corrective action revealed a sound quality assurance attitud Other overspeed failure modes of the Terry turbines involved steam condensation in the supply lines to the turbine and operator error in assuring that the governor is drained back (reset) prior to manual start The licensee experienced steam condensation problems in 1976, placed steam traps in the lines, and has not experienced further problems. The licensee's surveillance procedure SP-349, Emergency Feedwater Pump Operability, Revision 48, and operator training have apparently assured that turbine governor resetting had been properly performed. The licensee has apparently addressed the entire scope of the problem with adequate assurance of qualit The other issue involved a failure of the drain line for the main turbine high pressure crossover line on August 20, 1985, and a failure of the repaired line on August 21, 1085. Although this is a non-safety-related system, actions surrounding these events shed light on the licensee's attitude toward quality assurance. The ensuing steam leak caused by the first failure was isolated by tripping the turbine generator which resulted in a reactor tri The line failure was determined to be the result of fatigue failure of a socket weld at a fabrication defec The line was rewelded and failed again the next day during startup but a reactor trip did not result due to a lower initial power leve The second failure was determined to be the result of a lack of bonding between the base metal and weld filler metal such that a significant part of the joint was not really welded togethe The repair weld received a visual inspection which could not detect this type of proble However, had a magnetic particle or i penetrant inspection taken place, it is doubtful that the fusion failure I

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would have been detected since most of the outer diameter was fused. The licensee documented (Material Technology Surveillance Report, MTSR-550) five

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possible reasons for the weld repair failure: It was a difficult weld to perform in the overhead position.

! " Arc . blow" due to magnetic effects near the turbine and large 4 piping or "fingernailing" of the weld ro Weld amperage too low.

! Foreign substance on the weld preparation surface.

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Failure to direct the weld arc correctly due to low visibility.

{ The skill of the welder was not considered suspect due to his qualification

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') - The weld was then repaired successfully and other likely failure points were inspected with no damage identified. The licensee believed that the root

cause of the first failure was excessive vibration caused by the recent installation of modified muffler cages around the-turbine governor valves.

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These modified cages were installed to avoid post cracking problems with the-cage After the second weld failure, the original style cages were ,

{ reinstalled and no further pr>blems have occurred. In. terms of assessing i

! quality assurance effectiveness, the above scenario is inconclusive. The

licensee was apparently guilty of hastily and ineffectively repairing the i

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weld to shorten operating down time but the system being non-safety-related !

l could be considered a mitigating factor.

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In general, the two issues described above demonstrate that the licensee's quality assurance program is functional and that the general attitude toward ;

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quality assurance is based on sound principles.

! A final conclusion cannot be made at this time as to the overall effective-1 ness of quality assurance at Crystal Rive Further_ inspection would be ;

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. Licensee Action on Previously Identified Inspection Findings (92701)

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!. _ (Closed) Inspector Followup Item (302/85-15-06): -Health Physics Calibration l Evaluation.

i ( The inspector reviewed HPP-202, Radiological Surveys, Revision This

procedure delineated actions to be taken by personnel if radiological

! measuring and test equipment credibility becomes questionable. The Heal _th i Physics (HP) program calibration centrol program now. addresses HP iraasuring i and test equipment being found out of ' calibration and for performing

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evaluations on equipment found out of calibration.

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