IR 05000302/1988027

Insp Rept 50-302/88-27 on 880829-0902.Violations Noted. Major Areas Inspected:Previously Identified Environ Qualification Deficiencies Documented on Justification for Continue Operation.Licensee Commitment Identified

ML20205A013
Person / Time
Site:	Crystal River
Issue date:	10/07/1988
From:	Conlon T, Merriweather N, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20204K133	List: IR 05000302/1988027 ML20204K131 ML20205A009
References
50-302-88-27, NUDOCS 8810250357
Download: ML20205A013 (9)

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puo4g p' *1 UNITED STATES g ,j e

NUCLEAR REGULATORY COMMISSION REGION ll

. o, g e..., 101 MARIETTA ST., ATt ANTA, GEORGIA 30323 Report No.: 50-302/88-27 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: August 29 - Sept er 2, 1988 Inspectors: , W-- M ~ 7' [5 N M riweather / Date Signed C. Smith fk O V '

/D - 7- W Date Signed Approved by: /0[/Jh 8 T. E. Conlon, Chief Da'te Signed Engineering Branch Division of Reactor Safety SUMMARY Scope: This routine, unannounced inspection was in the area of previously :

identified Environmental Qualification (EQ) defic.iencies that had '

been documented on Justification for Continued Operation (JCOs). ;

Results: In the areas inspected, two violations and a licensee comitment were i identified as discussed in paragraphs 2.b. , 2.d. , and 2.e. , !

respectivel ,

FPC had a significant breakdown in the implementation of their EQ j Program over the last three years. This breakdown involved 1) EQ !

components being taken out of the EQ Program based on preliminary l design information without an adequate safety review;

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2) Modifications made to the plant without dequate EQ  !

considerations; 3) inadequate control of the Safety-List and the EQ Master List as design basis documents 4) EQ Program did not consider ;

loop accuracies in establishing qualification for EQ equipment and ;

5) Marginal, if not totally inadequate, training for technical staff I involved in EQ. The licensee is currently taking steps to correct the problems identified above; however, the inspectors do not consider that the licensee has done enough in addressing our concerns regarding the marginal training for Engineers on EQ. Considering that design-engineering was a major contributor to the program 8810250357 881013 DR ADOCK G % 302

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deficiencies it is considered that any corrective action taken by the licensee should consider additional improvements in the training programs for Engineers involved with EQ. One additional weakness was observed in the way the licensee develops JCOs for EQ equipment. The licensee needs to consider developing a configuration control program i

to ensure that JCOs on plant equipment do not conflict with existing JCOs, TS, maintenance or surveillance outages on equipment, procedures, and the design basis for the plan i

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REPORT DETAILS  :

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! Persons Contacted  ;

Licensee Employees D. Adler, EQ Specialist l J. Alberdi, Manager, Nuclear Plant Technical Support  !

X. Baker, Mansger, Nuclear Engineering Assurance l G. Becker, Manager Site Nuclear Engineering Services  ;

A. Friend, Principle Nuclear Lice' sing Engineer i E. Froats, Supervisor, Nuclear Liwnsing P. Geradin, Senior Quality Auditor V. Hernandez, Supervisor, Nuclear Quality Assurance i B. Hickle, Manager, Nuclear Plant Operations G. Longhouser Security Superintendent W. Rossfeld, Manager, Nuclear Compliance B. Serrano, Nuclear Procurement Engineering Services .

L. Tiscione, Manager, Nuclear Procurement Engineering Services  !

E. Ural, Senior Quality Auditor l R. Widell, Director, Nuclear Operations Site Support ,

K. Wilson, Manager, Nuclear Licensing f

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Mr. Williams, Nuclear Regulatory Specialist B. Wunderly, Licensing Engineer ,

NRC Resident Inspectors  :

• P. Holmes-Ray, Senior Resident Inspector J. Tedrow, Resident Inspector I

• Attended exit interview

! Followup On Licensee Identified EQ Problems  ;

i Two Region based inspectors conducted a followup inspection at the Crystal River Site to review licensee's actions on previously identified inspection findings and to examine the circumstances relating to the ,

recently identified EQ deficiencies involving unqualified States Tenninal  :

Blocks in the circuitry for Post Accident Sampling System (PASS) Isolation j valves and Reactor Coolant System (RCS) High Point vent valves and j unqualified motor operated valves (FWV-33 and FWV-36) in the Feedwater l System. The primary emphasis for this inspection was to thoroughly review <

the circumstances which lead up to the recent discovery of these problems I and the root cause for the deficiencie In addition, the inspectors reviewed all existing JCOs documented by the licensee, including the above deficiencies, and one other deficiency related to the Ganna-Metrics Excore Neutron Flux Monitoring system. The results of the audit are discussed in the paragraphs that follow:

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! Terminal Blocks Outside Design Basir. Due to Lack of Electrical Equipment Environmental Qualification The lice 6 tee recently discovered that unqualified States (Type ZWM)

Terminal Blocks were installed in safety-related EQ circuits both inside and outside containment subject to LOCA/HELB environment The teminal blocks (installed in terminal boxes CA-16, CA-17, CA-18, CA-19. RC-69. RC-70, and RC-11) provide control power and position indication to containment isolation valves associated with the PASS and RCS high point vent valves system. Ter.ninal boxes CA-18 and CA-19 are located in the intermediate building in a HELB environment and the remaining boxes are located in the Reactor Building in a LOCA/HELB environmen The licensee documented this problem on Nonconforming Operations Report (NCOR) No. 88-98, dated August 19, 1988, and reported the problem to NRC under 10 CFR 50.72. The event description, cause, event analysis and corrective action will be identified in LER 88-016 which had not been reviewed at the writing of this repor The imediate corrective action taken by the licensee was to develop [

a JC0 using the guidance of GL 88-07. The bcsis for continued !

operation is that all of the RC3 High Point Vent Yalves are presently ;

closed and de-energized with their supply breakers locked open and controlled by procedure. Likewise, the PASS isolation valves are normally closed and de-energized, and administrative controls are being implemented to assure these valves remain closed and de-energized. -

The function of the RCS vent valves is to enhMee cure cooling for events beyond present design basis and the function of the PASS isolation valves is to provide containment isolation. The licensee indicated that final corrective action would be to qualify the r teminal blocks or replace them with qualified Raychem splices during ,

the October 1988 mini-outag l The inspectors review of this problem identified some aspects of this problem which had not been vigorously pursued by the licensee in ;

detemining when the terminal blocks were first identified as E !

This lead to a finding that the licensee had revised the Safety-List l by Temporary Changes 286 and 289 dated April 2,1987, which added ;

Terminal Boxes CA-16 thru 19 and RC-69 thru 71 as "QQ" without !

having supporting EQ documentation in their files for states Type '

ZWM teminal blocks. In addition, the inspector determined that the modifications that implemented the RCS High Point Vent Valves and the PASS specified the use of unqualified States Terminal Blocks, although l these systers were intended to have EQ qualified electriul circuit l Considering the above, the inspector :oncluded that the licensee knew, as carly as April 2,1987, that terminal blocks were used in EQ '

circuits in harsh environments (other than radiation only environments) and should have detemined from a review of their cualification files that these States Terminal Blocks were not qualifie The licensee had a breakdown in the implementation of l l

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their Design-Engineering Program which allowed 1) modifications to be installed with unqualified EQ components, and 2) the Safety-List to be revised by adding new items as being EQ (i.e., teminal boxes CA-16 thru 19 and RC-69 thru 71) without supporting qualification documentation included in the EQ fil This violation, although it should have been identified earlier in 1987, is considered to be licensee identified meeting the intent of Part 2, Appendix C, for Discretionary Enforcement; therefore, no viclation is being cited for this ite No further action on this item is pianned by NR JC0 on Feedwater Valve Nos. FWV-33 and 36 Not Qualified for HELB Environment (LER 88-15)

As reported in LER 88-15, dated September 2, 1988, for Crystal River Unit 3, the licensee became aware on August 5,1988, that the unqualified components associated with the Main feedwater Startup Block Valves (Tag Nos. FWV-33 and 36) constituted a enndition outside the plant design basis. The specific components of concern were the limitorque motor operators, motor starters, valve control stations, and terminal boxes. All of this equipment is subject to a harsh environment. The function of the above block valves is to close on a High Energy Steam line break or feedwater line break to isolate the steam generator affected by the failur The corrective action taken by the licensee was to document a JC0 using partial test data and analysis to support continued operatio The licensee states in the JC0 that in case of failure of the start up ble w valve associated with the affected SG, due to the harsh enviroteant, feedwater isolation could be accomplished by closing the MFWP Suction valve and tripping the MFW However, if the associated MFWP suction valve failed to close, the Feedwater Booster Pump could continue to feed the break or affected steam generator (below or at 250 psig) which could worsen the consequences of a HELB environment in the intermediate buildin Subsequent operator action can be taken to trip the Feedwater Booster Pump and teminate feeding of the affected steam generator before significant addition of feedwater occur The licansee indicated; that a schedule for repla;ement of the unqualified components would be submitted to NRC in a supplementary report by January 31, 1989. The licensee indicated during the inspection that feedwater Valves FWV-33 and 36 were on their initial list of environmentally qualified equipment required to be qualified in accordance with IE Bulletin 79-01B and were removed based on preliminary design infomation received by Gilbert on March 8,198 In the NRR SER/TER the subject valves were categorized as not qualified because of certaia qualification deficiencie Ho.1ever, in the licensee's response "Submittal for 10 CFR 50.49 TER Response and Provision of Current Justification for Continued Operatica." dated

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1983, the licensee alluded to the fact that the Feedwater May Valves20,(Tag Nos. FWV-33 and 36) would no lenger require qualification

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because these valves will not be required to operate for the Emergency ,

Feedwater System upon installation of the EFIC syste In their LER (No. 88-15), the licensee indicates that there has been several reviews of their EQ Master List by consultants, AE and FPC engineers since 1985. During this inspection the inspectors determined that a temporary change to the safety-list was also approved on April 2,1987, which reclassified the subject motor operated valves, motor starter, teminal box and control station as EQ. However, the '

licensee still at this time did not recognize that they had an environmental qualification concer The inspectors concluded that the licensee has had several opportunities ,

, to identify and correct this concern prior to them documenting the :

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JC0 in August 198 Therefore, this concern is considered to be a violation of 10 CFR 50.49(d), (f) and (j) for failing to identify these components on their master list of EQ components required to be qualified, and failing to have test data in a file in an auditable form to permit verification that the equipment was qualified. This item will be identified as Violation 50-302/88-27-01. LER 88-15 is now considered close '

c. JC0 On Gama-Metrics Excore Neutron Flux Monitor

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The licensee reported to NRC that the cable assemblies furnished with

] the Gama-Metrics Neutron Monitor may leak and cause the monitors to fail under design basis accident condition This problem was

identified by the vendor and reported in a Part 21 report to the NRC q in a letter dated May 10, 1988. The licensee subsequently docurented

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a JC0 on May 19, 1988 and submitted a voluntary report to the NRC in 1 a letter dated June 0, 198 In this response the licensee indicates ;

that the neutron flux monitors were installed to meet the requirements of R.G.-l.97. The function of the flur monitors is to i provide means for verifying that reactivity contrpi systems have '

functioned as expccted. The licensee goes on to say that alternate means are available to oetermine whether suberitical conditions have

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been reached. The licensee states that both Control Rod Position and RCS soluble boron concentration are variables to indicate whether reactivity control functions are being accomplished. However, under a design basis accident these systems may be inoperable since they too are not environmentally qualified. To take samples of the RCS, ;

soluble boron concentration, the licensee would need to use the PAS ,

As discussed in Paragraph (a) above the isolation valves in this ,

system are also questionable due to unqualified States Teminal Blocks ,

in the control circuits. As a result of this concern, the inspectors !

questioned the adequacy of this JC0 considering the ott.er existing i JC0 on the PAS At the time of the inspection, the licensee's !

position was that the isolation valves previously discussed as being unqualified in the PASS system JC0 would also be required to function i for RCS soluble boron concentration samples. Subsequent to the l inspection, the licensee provided infomation that contradicted their ,

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initial response in that there are three additional valves in

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i parallel with the isolation valves inside containment that would be operable for RCS solutie boron concentration sampling. The licensee comitted to document these valves in a revision to the JC0 on the Gama-Metrics Neutron Flux Monitors and provide it to NRC for revie In a subsequent letter to the NRC dated September 9,1988, the licensee submitted Revision 1 to their report on the Gama-Metrics Neutron Flux Monitor. In this report the licensee now indicates that .

verification of reactivity control functions can be accomplished by verification that the reactor trip breakets have opened as a result of a trip signal from the RPS and use of the PASS to take sarrplec tn assure boric acid concentration is maintained. The licensee further states that "this sampling can be performed under all FSAR postulated

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accident conditions." Based on the above, this matter is considered close , Inttrument 8.oop Accuracy Calculations The license revealed to the inspectors a list of recently identifi-EQ deficiencias which involve: 1) failure to establish qualification

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files for certain EQ components identified on the Safety-List as EQ, 2) updating qualification files to include revised calculations for chemical spray effects, and 3) adding accuracy data into qualification files for certain instrument The licensee was i recently made aware of their EQ program deficiency on "Instrument

. Loop Accuracy" when their AE notified them that they had perfomed 1 similar calculations for another nuclear site. The licensee l contracted Gilbert to perfonn these calculations on a schedule to be 4 completed in 1989. The inspectors requested additional information ,

from the licensee to support their conclusion that no safety problemt !

existed with instrument loop accuracies due to insulation resistance :

changes which are attributed to environmental effects. The licensee l'

obtained additional assurance from their AE that their instrument

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configurations are similar to configurations that were analyzed for i Three Mile Island Nuclear Plant. Gilbert /Comor. wealth in their letter FCS-9738 dated September 1,1988, states that based on the result of existing IR analysis for TMI, and its similarity to CR-3, 4 in their judgment safety limits are maintained. 00R Guide', '.nes i require that the evaluation of qualification test plans and results l should include consideration for instrument accuracy requirements !

1 based on the maximum crror assumed in the plant safety analyses. The '

acceptability of the accuracy required for instruments could not be j

> determined from a review of the licensee's qualification files ,

because loop error calculations had not been perfomed to compare the i j demonstrated tested accuracy plus all error contributtoris (i.e., l

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cable, splices, and penetratfons) evaluated against the maximum error j assumad in the safety analysis. This problem was identified by the ;

licensee, however, due to the failure to consider this in their EQ '

, Program, the length of time the violation existed (as far back as j

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November 30, 1985), and the licensee's failure to evaluate this :

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concern for reportabilit This item will be cited as Violation 50-302/88-27-0 EQ Master List Several concerns were identified regarding the licensee's controls i for revising the Safety-List and EQ Master List. Initially the licensee's position was that the Safety-list was also their EQ Master List. However, the Safety-List was not considered acceptable as a 50.49 EQ Master List because it only identified equipment by tag number without a component descriptio In addition, components suca as cable, penetrations, splices, and mechanical seals were not even included on the Safety-List. The licensee subsequently changed their position on the Safety-List and now considers the computerized EQ Maintenance Program Data Base as the official EQ Master List. The

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inspectors considered this was acceptable in resolving their concerns regarding the deficiencies in the Safety-list. However, one concern '_

still remained in that the FQML was not a Quality Assurance Record

.aintained by the Records Management Uni The EQML has been adated

and revised in accordance with the EQ Manual, however, the list was not being maintained as a quality record. To resolve our concerns, i

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the licensee comitted to make the EQML a quality record. This action has been completed by the licensee and was confirmed in a letter to the NRC dated September 9,1988. No further questions exist in this are . Exit Interview

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The inspection scope and results were summarized on September 2,1988, with th;se persons indicated in paragraph 1. The inspectors described the areas inspected and discussed in detail the inspection results listed belo Dissenting coments were not received from the licensee, however, the licensee did make certain commitments which are discussed in ,

Paragraph 2.e. Proprietary infonnation is not contained in this repor !

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The following new items were identified during this inspection,

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item Number Description and Retrence 302/88-27-01 Violation . The licensee failed to environ-mentally qualify Fredwater valves FWY-33 and 36 and associated control circuitry for HELB accidents, para- -

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302/88-27-02 Violation - FPC EQ Program was inadequate in that the specified instrument l

. accuracies did not consider error  !

contributions from all components  !

in the loop (i.e., cable, splices, l and penetrations) during accident l conditions Paragraph L

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, , Acronyms and Initialisms EQ - Environmental Qualification FWV - Feedwater Valve HELB - High Energy Line Break l JC0 - Justification for Continued Operation

LOCA - Loss of Coolant Accident l MFWP - Main Feedwater Pump

PASS - Post Accident Sampling System i RCS - Reactor Coolant System j RPS - Reactor Protection System i TS - Technical Specifications i l

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