IR 05000302/1987026

Insp Rept 50-302/87-26 on 870817-21.Violations Noted as Addl Examples of Findings Identified in Insp Rept 50-302/87-17 Dtd 870805.Major Areas Inspected:Review of Inservice Insp Procedures & Completed Records

ML20239A232
Person / Time
Site:	Crystal River
Issue date:	09/04/1987
From:	Blake J, Coley J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20239A223	List: IR 05000302/1987026 ML20239A221
References
50-302-87-26, NUDOCS 8709170193
Download: ML20239A232 (11)

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NUCLEAR REGULATORY COMMISSION y '~ .-

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n REGION ll j 101 MARIETTA STREET, *'- r ATLANTA, CEoRGI A 30323

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Report No.: 50-302/87-26 Licensee: Florida Power Corporation 3201 34th Street, South St. Petersburg, FL 33733 I

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Docket No.: 50-302 License No.: DPR-72 l Facility Name: Crystal River 3 l

Inspectio o puc e . gust 17-21, 1987 i Inspect  : 3- d // 7 J L e Dtte 31 ned Approv d b : _

9 f B7 4 J/ Alake, Section Chief Da'te Signed gfneeringBranch ifision of Reactor Safety SUMMARY Scope: This routine, unannounced inspection was in the area of Inservice Inspection (ISI): Review of ISI procedures and review of completed ISI record Results: The inspection findings indicated that certain activities violated NRC requirements which should be considered as additional examples of findings identified in NRC Inspection Report 302/87-17 dated August 5, 198 PDR ADOCK 05000302 O PDR

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REPORT DETAILS Persons Contacted Licensee Employees 4, ,

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• P. F. McKee, Director, Plant Operations

• W.L.Bandhauer, Assistant,NuclearPlantOperat-).onsMausger

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• E. C. Simpson, Director, Nuclear Site Support -

• J. G. Brandely, Superintendent, Security and Special Projects #

• P. J. Skramstad., Superintendent, Nuclear Technical Support

• K, R. Wilson, Manager, Nuclear Licensing- ,~

• L. Rossfeld, Manager,-Nuclear Compliance >

• Hander, Manager, Nuclear Maintenance and Outage s

• S. Mann, Nuclear Compliance Specialist

• P. c. Haines, Nuclear Licensing W. Heuman, Supervisor, Inservice Inspection (ISI)'

D. Gulling, Nuclear Inservice ~ Inspection Specialist Other- licensee employees contacted included construction craftsmen, engineers, technicians, operators, mechanics, security force ~ members, and office personne t s-

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Other Organizations ,

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• S. J. Rainwater, Techvice, In NRC Resident Inspectors

• J. E. Tedrow -.

• Attended exit interview Exit Interview The inspection scope and findings were summarized on August 21, 1987, with those persons indicated in paragraph 1 abov The inspector described the areas inspected and discussed ~1n detail the inspection findings- . No dissenting comments were received from the license The inspection findings indicated that certain activitf er, violated NRC -

requirements. However, these findings are similar to the findings already identified as violation 302/87-17-06 " Failure to Rev.ew and Approve the

ISI Program and changes to this Program as Required by TS 6.8.2.b.", and violation 302/87-17-07, " Failure to Retain ISI Records as Required by TS 6.10.2.h". Therefore, findings identifiec "in this inspection report should be considered as additional examples oi , findings already reported A

in the above violations, and the licensee's reply to the items of violation identified in NRC Inspection Report 302/87-17 dated August 5, 1987, should also address the findings identified berei _ _ _ - _ _ _ _ _ _ _ _ _ _ _ - _ _ _ .

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The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspectio . -Licensee 7.etion on' Previous Enforcement Matters This subject was not addressed in the inspectio .* Unresolved Items Unresolved items were not identified during this inspectio . Inservice Inspection - Review of First Interval Program (73051, 73052 and

, 73755)

This inspection was conducted as a - follow-up inspection . to an audit performed by the' NRC resident inspectors and reported in Region II Inspection - Report 87-17, dated August 5, 1987. Two violations were identified by the resident: (1) 302/87-17-06, Failure to review and approve the ISI program and changes to this program as required by TS , 6.8.2.b; and.(2) 302/87-17-07, Failure to retain ISI records as required by TS 6.10.2.h., which necessitated a _further review by Region II of the Florida Power. Corporation first interval TSI program for adequacy an completenes Findings identified as such in this report should ' be '

considered as additional examples of the above two violations and the licensee's reply to the violations in Region II Inspection Report 87-17 i should also address the additional findings of this repor ;

Comments identified . in this report as concerns are areas where the i inspector and Florida Power Corporation ISI supervision had discussed program improvements and do not represent violations of Regulatory .

requirements or licensee commitment l The FlorMa' Power Corporation ISI program is conducted in accordance with-the requirements of TS 4.0.5.b. and includes inspection of components and systems over a ten year time interval. The ten year time interval for .

Crystal River 3, began March 13, 1977, and ended on March 13, 198 During- this ten year interval, the licensee has been performing partial system inspections. The intent of this partial inspection program is to spread out the required inspections over the interval with all systems being completed at the end of the interva These inspections include 1 both Non-Destructive Examinations (NDE) of welds using visual inspections

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(VT) Ultrasonic Testing (UT), Magnetic Particle Testing (MT), Radiographic Testing (RT), and hydrostatic testing (Hydro) of system Since Section XI of the ASME Boiler and Pressure Vessel Code allows extension of this interval of up -to one year so that the interval can be made to correspond to a plant's outage schedule, the licensee is planning to complete the first ten year interval during their refueling outage j scheduled to begin in September 198 ,

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The licensee's program is conducted in accordance with " Technical Manuals" that were developed by a contractor. These Technical Manuals delineate the program and provide a proposed schedule that specifies wnen, during the ten year interval, systems or portions of systems will be tested. The results or extent of the testing completed after each outage are reported in an ISI Report. By utilizing the Technical Manvals and the ISI Reports, the licensee performs and tracks the status of the progra The applicable code for the examination activities is the ASME Code,Section XI 1974 edition with addenda through summer 1975. For hydrostatic testing, the applicable codes are ASME Section XI (74S75) for the 1980 and 1983 outages, and ASME Section XI 1980 edition with the winter 1980 addenda for the 1985 and 1987 outage To verify compliance with the TS, the inspector reviewed the following documents and records:

1) Review of Program for the Examination of Components

- Technical Manual for Crystal River 1978 Outage

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Inservice Inspection Report for Crystal River 1978 Outage

- Technical Manual for Crystal River 1979 Outages

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Inservice Inspection Report for Crystal River 1979 Outage 2) Review of Program for Compliance with Hydrostatic Testing Requirements

- Technical Manual for Crystal River 1983 Outage

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Inservice Inspection Hydrostatic test Documentation for 1983 Outage

- Technical Manual for Crystal River 1985 Outage

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Inservice Inspection Hydrostatic Test Documentation for 1985 Outage To determine the completion of the program as delineated in these Technical Manuals and Reports, the inspector reviewed the following procedures:

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AI-701, Administrative Instruction for Conduct of Inservice Inspection

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Florida Power Corporation Nuclear Quality Assurance Plan

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Florida Power Corporation Inservice Inspection Manual

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SP-210 Surveillance Procedure for ASME Class 2 and 3 Pressure Testing

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SP-204, Surveillance Procedure for Class 1 System, System Leakage Test for Inservice Inspection-

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-. MP-137, Maintenance Procedure for System Hydrostatic Pressure Testing

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ISI-61, B&W Administrative Procedure for Control of Manuals and Reports-

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ISI-62, Babcock & Wilcox Administrative Procedure for . Control of-Documents

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ISI-63, 'B&W Administrative Procedure for Approval of Manuals an Reports for Baseline & Inservice Inspection Programs

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ISI-64, B&W Administrative Procedure for Handling Non-destructive Examination Data for Pre-operational, or Inservice Examinations-

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ISI-120, B&W: Ultrasonic Examination Procedure for Class 1 and 2-

~ Piping Welds Joining Similar and Dissimilar Materials-

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I51-103, B&W Ultrasonic Examination Procedure for Vessel-Welds

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ISI-350,_ B&W Visual Examination Procedure of Welds (also covers hydrostatic) and Surface Conditions

'The above reviews were organized to audit the licensee's program in'thre separate areas: (1) program and records for examination of components in the 1978-and 1979 outage; (2) program and hydrostatic test records for the 1983 outage; and (3) program and hydrostatic test records fca the 1985 outage. Each area will be discussed below:

(1) Program and Records for Examination of Components During the 1978 and 1979 Outages --

The inspector's review of the licensees examination program and records revealed that the vendor, B&W, had provided a well-organized, computerized program; vendor administration and examination procedures were well writte Records were complete and indications, particularly ultrasonic indications, were plotted to determine their origi Component item numbers were verified by the inspector as accomplished from each examination category during the outage that the Technical Manual delineated the examinations to be performe However, the inspector did identify the following finding which was identical to  ;

the resident inspector's finding, 302/87-17-06, reported in Report '

Number 87-1 Finding: The Technical Manual (including ISI non-destructive examination procedures) for the program conducted in the 1978 and 1979 outages did not receive the review and approval required by TS 6.8. _ _ _ _ _ _ _ _ _ _

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5-In addition to the above, the inspector discussed the' followin concern with the ISI supervisor and the Superintendent of Technical

' Suppor Concern: Admini strative - Instruction - AI-701, " Conduct of Inservice Inspection" should be enhanced to better define the ISI program; the . intent and scope of reviews; responsibility of personne1 'and organizations within Florida Power Corporation; interfacing-

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procedures; Level III responsibility for evaluation and disposition of adverse findings; handling of plans, schedules .and ' reports for filing with regulatory authorities. This procedure should interface',

by reference, the ISI program to the established, however, . broader program of the plant. AI-701 is a QA ' approved - procedure . that

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requires a review of any changes; therefore, defining the ISI program and responsibility in this document would ensure program stabilit ~

This document will also require revision after the September. outage because of the required Code updates. for the second interval inspections. The licensee indicated that the inspector concerns and enhancement comments would.be considered at that tim .(2) Program and Hydrostatic Test Records for the 1983 Outage The following tests were performed in the 1983 outage. The inspecto reviewed 100% of the hydrostatic test records for this outag Procedure MP-137 was used to conduct'the hydro test listed below:

1) Building Spray Suction; 3" and 10" suction lines for BSP-1B 2) Building Spray Discharge; 6" and 8" discharge lines for BSP-1B 3) 3" Recirc line on DHP-1B; discharge header 2h" line to makeup prefilters 4) Nuclear Services Closed Cycle Cooling; Service Water to and from letdown coolers and reactor drain tank cooler, penetrations 361, 360, 322, and 321 Instrument Air.to Building Spray; Test line and penetration #11

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6) Industrial Cooling Water to AHHE-14B; penetrations 206 and 207'

7) Reactor Coolant System; 3" Recirc line on DHP-1A discharge *

header and 2h" line to makeup prefilters 8) Makeup and Purification System; 3", 4", and 2h" makeup / seal injection line from MVP-1B to MVV-18F and MVV-27F

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9) Makeup and Purification System; 1" reactor coolant pump bleed off line penetration 377

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10)' Liquid Waste Disposal; Reactor coolant drain tank pump discharge

to miscellaneous waste storage. tank penetration #374 11)- Nitrogen supply to pressurizer and RC drain tank penetration -

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12) Core flooding "B" train {

l 13) Main Steam;. Ils" chemical cleaning line to the "B" steam generator l 14) Main Steam; 3" drain lines from "B" OTSG including ' penetrations '

314 and 428 15) Decay Heat; 14" line between BWST and DHV-35F As a result of the above review, the inspector had the following findings:

(a) Test: Reactor Coolant System; 3" recirc line on DHP-1A, j discharge header and 21" s line to makeup prefilters 4 Finding: Records do not indicate valve DHV-91 was open (Valve position "NA") part of hydro boundary could have been excluded if. this -valve ' was close Adequacy .of hydrostatic test uncertai l

'(b) Test: 6" and '8" Building Spray Discharge Line for BSP-1B Finding: Instrument lines between valves BSV-46 and BSV-47, 1 '

records do not . indicate position of valve Adequacy of hydrostatic test uncertai The above findings are similar to the resident inspector's findings 302/87-17-07, reported in Report No. 87-1 l (3) Program and Hydrostatic Test Records for the 1985 Outage The 1985 outage was a very significant outage for Crystal River 3 nearly 70 different hydrostatic tests were accomplished. A new test procedure was written (SP-210) to upgrade the test program to the 1980 edition of the ASME Code (Relief Request and Approval #100) and test boundaries changed as a result of this update. The inspector started the review of the outage by examining each test and verifying program completenes This soon became impractical due to time limitation The inspector's review at this point, however, had disclosed findings that appeared to be generic to the 1985 testing activities because of wording in the new procedure and techniques used in establishing clearance sheet l

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' As ' a _ result, the inspector reviewed only the test records listed-below 100% for completeness and program adequac However,.100% of'

the 1985 hydrostatic tests were reviewed for findings that appeared to be generic as the result of the partial review and, unless. listed below, were considered satisfactor Test records reviewed for completeness and adequacy:

(1) Service Water System; SW to RCP-18, from SW-71 to SW-75 (2) Service Water Systein; supply and return from AHF-IC (3) Service Water System; AHF-18 supply to return (4) Service Water System; supply to and return from CRDM - excluding portion of piping that extended.over the fuel transfer canal to the reactor head (5) Service Water System; supply to ' return from CRDM (portion excluded from above test)

(6) Service Water System; SW tank 1 to SWV-1

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(7) Service Water System; between boundary valves: SWV-12, 345, 347, 69, 70, 57, 58, 314, 358, 315, 359, 169, and 170

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(8) ASME Class 3 piping to include the complete service water system header: Test to ' include al piping from SW pumps' to component isolation valves and return piping to SW heat exchangers  ;

(9) RCP-1B seal cavity vent piping (ASME Class 2 and 3)

(10) RCP-1A seal cavity vent piping (11) Domestic Water (Class 3) from D0 pump to RW pump seal

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(12) Building Spray Tank #1 (13) DC System B-Train As a result of the above review, the inspector had the foelowing findings:

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Records for the ASME Class 3 piping to include the complete service water system header-test also include all piping from SW pumps to component isolation valves and return piping to SW heat exchanger _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - J

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Finding: Records do not indicate position

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of in-line valve Position of pump, gages, and recorded leaks do not preclude portions of the system from. being isolated to hydro pressute. Adequacy:of test uncertai (Item (7) above) -

Records-for the service water Class 3 piping between boundary valves: SWV-12, 345, 347,.

69, 70, 57, 58, 314,-358, 315, 359, 169, and 17 Finding: Records do not indicate position of in-line valve Position of pump, gages, and recorded leaks do not preclude portions of the system from being isolated to hydro pressure. Adequacy of test encertai (Item (12)-above)- -

Records for the building spray tank # Finding: Position of in-line valves' BSV-99 and BSV-100 were not identifie Adequacy of test cannot be verifie (Item (13) above) -

Records for the DC system B-trai Finding: Position of in-line valves were not identifie Position of pump, gages, and record leaks do not preclude portions of. system from being isolated from tes Adequacy of test uncertai (Item (6) above) -

Records for the service water SW tank #1 to SWV- Finding: Enclosure 2, sheet I to SP-210,

" Data and Approval Sheet" Item 4 ,

entry for hydro pump attachment )

location have been marked through, i signed and dated. However, no new entry was made (records incomplete).

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In a'ddition to the above findings, the inspector discussed $$he following concerns with the ISI supervisor and the test consultan , E2 (1) SP-210, Enclosure 2, sheet 2 should be revised to indicate.'

position of all. valves within .the test and the sheet should;

- have a signoff for verification of the test position.~'(The ,

licensee was revising SP-210 before the end of the inspe'ctop's

i visit. This preceding comment was included.) ,

Lo (2)- Clearance sheets serial' numbers should be entered on khe specific test enclose sheets because1two different organizations are involved with the retention of these records. (The licensee

> also was in the process of making this change at the conclusion of.the inspector's visit.)

The findings identified above are similar to the' resident inspector's finding 302/87-17-07 reported in Report No. 87-1 Within the areas examined, no violations or deviations were identified except those noted' as ' additional findings above to violations addressed in'NRC Inspection Report 87-1 '

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