IR 05000302/1989018

Insp Rept 50-302/89-18 on 890710-14.Violations Noted.Major Areas Inspected:Inservice Testing & Followup on Previous Insp Findings

ML20246N766
Person / Time
Site:	Crystal River
Issue date:	08/16/1989
From:	Belisle G, Tingen S NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20246N755	List: IR 05000302/1989018 ML20246N750 ML20246N757
References
50-302-89-18, GL-89-04, GL-89-10, GL-89-4, IEB-85-003, IEB-85-3, IEIN-88-072, IEIN-88-72, NUDOCS 8909080259
Download: ML20246N766 (16)

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UNITED STATES

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REGION 11

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Report No.: 50-302/89-18

.c Licensees Florida Power Corporation 3201 34th Street, South St. Petersburg, FL 33733

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

Inspection Conducted: July 10-14, 1989

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Insp ctor: , 6-16-80 4-S. Tinge { Date Signed

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Team Members: S. Sparks $

A._Szczepaniec H. Whitener *

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j' ) / 4 Approved by: j$ Qxd'y G. Belisle, Chief

/lb[rY Date' Signed Test Programs Section Engineering Branch Division,of Reactor Safety SUMMARY

. Scope:

This routine, announced inspection was conducted in the' areas of inservice testing and follow-up on precious inspection finding Results:

The licensee's containment spray system inservice test (IST) program appeared to, be adequate to ensure that the system's components are maintained in an operational readiness state, paragraph 2. Containment Spray System (CSS) IST prograncatic weakness were identified in the areas of check valve full and backflow testing, paragraph 2.a; and verification of remote indication on the remote shutdown panel, paragraph Isolated IST weaknesses were identified in the area of check' valves BSV-150 and BSV-151 full flow testing, paragraph 2.a; and documentation of vacuum relief valve BSV-19 test data, I paragraph 2.c. Failure to verify remote shutdown panel indication, full flow testing for valves BSV-150 and 151,. and document valve BSV-19 test data was 8909080209 890821 FDR O ADOCK 05000302  !

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.. . identified as a violation, paragraph Strengths in the CSS IST program were identified .that involved documentation and trending of pump test data, paragraph 2.b; and an aggressive mo sr operated valve inservice test program, paragraph A violation was identified that involved containment leak rate testing electrical penetrations, paragraph 3.a. A strength was identified that involved clear and accurate instructions contained in motor operated valve maintenance procedures, paragraph The licensee committed to provide to the NRC, in writing, how the issue oT verifying the spray additive system flow rate would be resolved, paragraph 2.a.

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REPORi' DETAILS Persons Contacted Licensee Employees

• B. Black, Nuclear Results Specialist

• Boldt, Vice President, Nuclear Production

• Collins, Superintendent, Nuclear Safety and Reliability

• J. Coopar, Superintendent, Nuclear Technical Support

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• G. Cowles, Senior Nuclear Results Engineer

• J. Holton, Senior Nuclear Results Engineer

• P. 'McKee,, Director, Nuclear Plant Operations

• Williams, Nuclear Regulatory Specialist

• K. Willson, Manager, Nuclear Licensing

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Other licensee employees contacted during this inspection included craftsmen, engineers, operatcrs, mechanics, technicians, and administra-tive personne NRC Resident Inspector

• J. Tedrow

• Attended exit interview f

' Containment Spray System Inservice Test Program Ir.spection The purpose of this IST progrem inspection wcs to assess how the licensee implements the program as it applies to the Crystal River CSS, also referred to as the Building Spray System. Specific pumps, relief valves, motor-operated valves (MOVs), check valves and manu&l valves in this system were pre-selected for evaluation. Evaluation for the diffei ent components included, but was not limited to, the following:

Verification that the l'ST program is current with relief requests, Safety Evaluation Report (SERs), the American Society of Mechanical Engineer (ASME) code Section XI requirements, and Final S #ety Analysis Report -(FSAR) commitment Verification that test procedures accomplish pro; ram requirement Review and ver1'ication of test results and corrective actions, including adherence to, and affect on testin i Review of modifications and their affect on testin Verification of proper accuracy and calibration of piant instruments- :

tion and test equipment,

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The licensee's first 10-year program was based in the 1974 ASME code. The basis for their second 10-year program was changed to the 1983 code with the Summer 1983 Addenda to the Code. The new program became effective January 10, 1988. Numerous relief requests have been submitted to and approved by the Nuclear Regulatory Commission (NRC). Applicable relief-requests are discussed in the appropriate section of the repor In general, in each area evaluated, a review was made of the old and.new ASME Section XI requirements, the old and new IST program, maintenance history over the past two years, test results over the past two years, relief requests, SERs, and other NRC correspondenc The following procedures performed IST progrtm testing for the selected components, as wel! as for other components not evaluated during this inspectio SP-340A A Train Emergency Core Cooling System (ECCS) Pump and Valve Quarterly Operability Test SP-3408 B Train ECCS Pump and Valve Quarterly Operability Test SP-620 Mechanical Exercising of BSV-25 and BSV 27 SP-184A Sodium Hydroxide Flow Verification A Train SP-1848 Sodium Hydroxide Flow Verification 3 Train SP-602 ASME Section XI Relief Valve Testing The inspection results have been divided into the following areas:

Check Valve Full and Back Flow Testing Motor Operated and Manual Valves Testing Relief Valve Testing Panp Testing Leak Rate Testing

) Check Valve Full and Back Flow Testing i Inservice testing of check valves 05V-150, BSV-151, BSV-1, B3Y-8, RSV-26, BSV-27, DHV-33, and CHV-36 was reviewed Sy the inspector Other than routine disassembly for inspection purposes, no maintenance or modifications were performed on the check valves during the previcus two year period, Inservice test data was obt?ined from calibrated instruments.

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Check valves DHV-33, DHV-36, BSV-1, and BSV-8 were full flow tested quarterly. Review of check valves DHV-33, DHV-36, BSV-1, and BSV-8

~ test results obtained per SP-340A and SP-340B during the previous two year period indicated that all inservice test frequencies were adhered tc, no failures had occurred, check valves were not back flow !

tested, and valves DHV-33 and DHV-36 were being full flow tested at flow rates less than full accident flow rat Check valves DHV-33 e and DHV46 are located in the suction lines common to the respective Trains A and B' Containment Spray and Low Pressure Injection Pump In order to obtain full accident flow through the check valves, both the Containment Spray and Low Pressure Injection pumps, in the respective _ train, would be required to run. Past licensee's practice had been to only run a low Pressure Injection pump in each train to verify that DHV-33 and DHV-36' fully opens. Since the issues of full flow testing ' at accident flow rates and back flow testing are specifically addressed in Generic Letter 89-04, Guidance on Developing Acceptable Inservice Test Programs, violations in these areas were not issued. During the inspectiovi it was evident that the licensee was taking action in these areas to comply with Generic Letter 89-0 SP-340B was recently changed to recognize check valve DHV-36 full accident flow rate and a study was in process to determine check valve back flow function Check valves BSV-26 and BSV-27 were disassembled and inspected daring the previous refueling outage per SP-620. The licensee submitted a Section X: relief request which was granted by the NRC to recognize this test method for the first inservice ten-year period and Generic Letter 89-04 allows this ' method for all future inservice test programs, Check valves BSV-150 and BSV-151 were not tested in accordance with inservice test requirement During the first ten-year inservice test interval the licensee submitted a relief request to allow full stroking of check valves BSV-150 and BSV-151 at five year intervals in lieu of quarterly or during cold shutdown In a letter dated May 29, 1987, from the NRC tn the licensee, the relief request was denied because the five year interval was excessive. In the May 29, 1987, letter the NRC provided an acceptable alternate method te test check valves BSV-150 and BSV-151 which involved disassembly and inspection. After denial of the BSV-150 and BSV-151 relief request, the licensee did not modify their inservice test program to comply with the Section XI inservice test requirements or the NRC guidance provided in the May 29, 1987, lette From September 1987 to January 1988 Crystal River 3 was shutdown for refueling outage 6, 3nd was therefore able to disassemble and inspect check valves BSV-150 and BSV-15 As a result, these check valves have not been full stroke tested since June 1983 and, per the current schedule, will not

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be full flow tested in the the 1990 refueling outage. Failure to comply with Section XI Subsection IWV-3520 inservice test require-ments to full stroke check valves BSV-130 and BSV-151 quarterly or

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u 4 l-dUring cold shutdowns after NRC denial of a relief request to perform alternate testing is identified Tas Part A to violation -

~50-302/89-16-0 Check valves BSV-150 and BSV-151 ware not back flow

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tested. As; previously discussed.: this area is being evaluated in'

response to Generic Letter 89-0 .

Technica1T Specification Surveillance Requirement 4.6.2.2.d requires the spray additive system be . demonstrated operable at least once per-five' years 'by. verifying the flow rate in the spray additive syste Since the-licensee had planned to use this surveillance requirement

to verify check- valves BSV-150 and BSV-151 to: full troke, the

. inspectors reviewed the past ' performance of this testing. In June 1983 testing was performed to flow check. piping from the-Sodium Hydroxide Tank to the: suction of Containment Spray pumps 3A and 3 This testing involved. installing temporary jumpers down stream of each containment spray pump that discharged to a temporary collection facilit During this test,: flow rates up. to 1200 gpm were obtained fromi3A Containment Spray pump and flow rates up to 850 gpm ware obtained from :3B Containment Spray pum In April'1989 testing was again performed to flow test piping from the Sodium Hydroxide Tank to the: suction . of. the Containment Spray pump This testing was performed per SP184A and SP184B which differed significantly from the testing performed 1983. The 1989 testing involved installing temporary jumpers between the suction of each Containment Spray pump and the suction of the ' Sodium Hydroxide Tank recirculation pump. The contents of the Sodium Hydroxide Tank' were recirculated via the suction of each Containment Spray pump through the Sodium Hydroxide Tank -Recirculation pump back to the tank. Flow rates of 30 gpm were obtained: during this testing. The tests were signed off as satisfactorily. completed and ' determined to have satisfied the requirements of technical specification (TS) surveillance requirement 4.6.2.2.d for verifying spray additive flow rate ~ for the five year i nterval . The inspector questioned the basis for the acceptance

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criteria contained in SP-184A and SP-1848. The basis was that the capacity of the Sodium Hydroxide Tank Recirculation pump was 30 gp Per Appendix 14A of the Final Safety Analysis Report, flow rates in the range of 150 gpm would be required to the suction of each containment spray pump during certain accident conditions. The inspector questioned how the 30 gpm obtained per SP-184A and SP-184B verified that 150 gpm could pass through the same line. In a letter dated May 12, 1989, from corporate - to Crystal River 3 Station personnely corporate. personnel also questioned how the flow rates i obtained from procedures SP-184A and SP-184B proved that a full open -,

flow path existe During the inspection, there appeared to be no plans to resolve this issue in the near future. The inspector

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L considered that until the licensee can illustrate thet 30 gpm

. provides a full of open flow path from the Sodium Hydroxide Tank to

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the suction of each containment spray pump surveillance, . TS requirement 4.6.2.2.d has not been satisfactorily accomplished. The licensee committed to provide to the NRC in writing how the issue of verifying the spray additive system flow rate would be resolved prior to the expiration of surveillance requirement 4.6.2.2.d on October 1, 198 Motor Operated Valves and Manual Valves Testing The inspectors reviewed the licensee's IST for the following motor

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operated valves (MOVs) and manual valves from the reactor building spray system, decay heat removal system, and nitrogen system:

MOVs Manual Valves BSV-11 BSV-12 BSV-5 BSV-6 BSV-3 BSV-4 NGV-260 NGV-261 BSV-16 BSV-17 NGV-226 NBV-218 DHV-34 DHV-35 NGV-179 DHV-42 DHV-43 BSV-18 The requirements for the above valves are cor.tained in the licensee's IST Program for Pumps and Valve The. inspectors interviewed licensee personnel regarding the general nethods used during MOV stroke time testing, and reviewed Surveillance Procedures SP-340A, SP-340B which are the-implementing procedures for inservice testing of the above valves. Requirements for stroke timing MOVs are contained in Subsection IWV-3413 of the Cod Review of stroke time results dating back to 1986 indicated that frequencies for the above valves were in accordar.ce with Section XI requirements. In addition, none of the above MOVs had exceeded their alert range or their limiting stroke time value during the time span reviewe The inspectors also reviewed maintenance records and non-conforming operating reports (NCORs) for the above valves dating back to 1986.

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Subsection IWV-3200 of the Code provides the requirements for post-maintenance testing to demonstrate that the performance parameters which could be affected by replacement, repair, or maintenance are within acceptable limits. The inspectors confirmed that adequate post-maintenance testing had been performed.

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Subsection . IWV-1100 of the ASME Code provides < the escope . for requirements.of IST of certain Classes 11,-.2, and 3 valves whichLare required to perform a^ specific function:in shutting down a reactor to cold: shutdown or in mitigating the consequences of an accident. - As such,. the licensee's, IST Program did not include. all of the abov M0Vs and manual. valves. The inspectors discussed with the licensee

' the basis for not including all of the. above MOVs and manual valves in their IST Progra Specifically, the following valves were

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MOVs BSV-16 an'd BSV-1 These valves are de-energized in the open position - and the licensee considered them Category E valves under.. the 1974 Code requirements (prior to January 10, 1988). -They- are now considered Category B, passive valves', in that a' change of' position is not required to perform a specific function'in shutting down the reactor. . Passive valves have no exercising requirement : Manual valvc BSV-1 This valve is provided. for. manual isolation of nitrogen supply to the sodium hydroxide Na0H tank, and is locked closed.~ A nitrogen blanket is provided to the Na0H tank' to reduce tank corrosion and microbial ' growt Verification of the Na0H chemical composition is required by TS .

at six-month intervals. The' licensee identified this valve to-be a passive valve,.in that no change in position is required to perfonn a specific function in shutting down the reactor.

L , - Manual valves NGV-179, 218, 226, 260, and 261. The licensee

' ' identified these valves -as . Class 4 valves, which are not within the scope of Section XI, Subsection IWV testing. requirement The inspectors concurred ' with the licensee's rationale for not including the above valves in the IST Progra The inspectors also reviewed the licensee's testing methods for verifying remote position indication for valves in the IST Progra Subsection IWV-3300 of the ASME Code states that valves with remote position indicators shall be observed at least once every 2 years to verify that valve operation is accurately indicated. The licensee procedures for IST verify accurate valve position indication at a i

remote location, specifically the main control room. However, remote h position indicators are also located on the remote shutdown pane The remote shutdown panel provides the capability of bringing the plant to a safe cold shutdown. Control indication for components needed for safe shutdown are provided on the shutdown panel, and include status lights for valve position. Specifically, the shutdown-p panel contains valve position indicators for the following IST L Program valves:

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r (-y 7-i DHV;- 3, 4, 5,16, 11. 34, 35, 41, 91, 110 x EFV - 14, 32, 57, 58 e

MSV:- 25, 26-

~ MUV - 3,~- 9, 23, 24, 25, 26, 40,' 41, 53, 58, 62,- 69, 73, 257, 505 RCV - 10, 11

SWV -: 35, 37, 39, 41,' 43, 45, 47, 48, 49, 50, 79-86,109,110,

.151, 152, 353, 354 This list is not all-inclusiv Surveillance Procedure SP-338, ' Remote Shutdown .and Post Accident Monitorf ng Channel ' Check, performs a channel: check of shutdown panel

< instrumentation. However, this procedure demonstrates that shutdown panel .-instrumentation 'is consistent with that of the main control room and. does not. verify- the open and closed position of the valve ' As 'such, the : licensee currently does not verify. correct . valve position indication at the remote shutdown panel. every two years, which is a ~ violation of Subsection IWV-3300 of the Code. This is identified as Violation 302/89-18-0 ' Relief' Valv'e . Testing Five relief valves; BSV-19, BSV-20, DHV-69 - DHV-70, and NGV-115 were evaluated regarding the'IST program. BSV-19 and BSV-20~ are pressure / -

vacuum relief valves on the Na0H tank and are included ~ in the test

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program. : Valves DHV-69 and DHV-70, Residual Heat Removal System relief valves, and NGV-115,'a Nitrogen System relief valves are not n . in t the program. These three valves are class- 4 valves and are not required by the code to be included in the program. These valves are

not required -to safely shutdown the plant nor mitigate the consequences of .an accident. These valves' do; however, undergo testing 'per. Maintenance Procedure MP-113. Relief. Valva Testin ,

Based on these findings, the exclusion of valves DHV-69. DHV-70 and NGV-115 from the IST program appears acceptabl Relief valves BSV-19 and BSV-20 are tested per procedure SP-620, ASME Section'XI Relief Valve Testin The procedure appears to be in accordance . with the current code requirements, or with relief-

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requests approved by the NRC as stated in Safety Evaluation Report The licensee has established a testing frequency such that approximately one-half of the code relief valves are tested each refueling outage, currently planned to occur approximately every two years. This provides for all valves being tested every two refueling

. cycle Furthermore the schedule was established such that all relief valves in any one system are tested during the same outag All the code relief valves were tested in 1985 according to the licensee. The established schedule meets the minimum sampling criteria and test frequency requirements of the ASME code. Relief e-- _ - - _ - - _ - _ _ - __

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request V-115,' approved by the NRC, allows use of ASML OM-1,1981 for test procedures, leaving the frequency. requirements of the 1983 code in effec The . testing records _ for the_ -1985- tests for- BSV-19 and BSV-20 were alsof reviewe Although test results for .the pressure reliefz ifunction of-thel valves were' presented and found ti be satisfactory,

' test' results for the vacuum function' of the valver could not be found by the licensee. A review of the applicable work requests was made and work request #67183 indicates valve BSV-20 was tested for vacuum relief. ' Work. request _ f67193 for BSV-19 had no such indication. The-

, only. other IST: program test of these valves was in 1983 when. the were installed on the new NaOH. These test results were reviewed and it was- found that BSV-19 had no vacuum relief 7ests results; BSV-20 did have~ vacuum testing result This _ failure to' provide documentation that BSt-19 was satisfactorily tested during' the required time period of at least once every five years indicates that the licensee's IST program failed to ensure all required relief valves were adequately tested as required by .the ASME code. This failure is collectively combined with additional examples and constitutes' violation 89-18-0 . Pump Testing-Containment Spray ' pumps BSP-1A, and BSP-1B, and the Na0H recircula- -

tion' pump,' were selected for review regarding the IST program. The containment spray pumps were found to be 11cluded in the program and were reviewed further. The NdOH pump was found not to be' in the program. The licensee stated this was because _the Na0H pumps is a class 4 pump and, in accordance with the Code, 'not required to be tested. . Furthermore the pump is used primarily for 'NaOH tank ~

recirculation and is not required for tre safe shutdown of the plant nor to mitigate the consequence of.an accident. The inspector found this to be satisfactor Test records for the past two years, plus the current IST procedures for the containment spray pumps were reviewed. Testing is performed per procedures SP-340A and SP-340 These pumps' are single speed centrifugal pumps and data measured during testing include; flow rate, suction and discharge pressure, and vibration. The differen-

-tial pressure is calculated. All items were measured in accordance with the ASME Code requirements, or with submitted relief requests approved by the NRC as stated in Safety Evaluation Reports, whichever was appropriate at the time of testing. Specifically, vibration measurements are currently measured in inches per second, instead of mils, and bearing temperature is no longer required to be measured, as approved for relief request V-113. Oil levels are observed per procedure as required by the Code. Test equipment, instrument accuracy and calibration were found to be satisfactor All test data reviewed were satisfactor .

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," ' ir f The : licensee also - satisfactorily ' met - the pumpt record keeping-requirements. The re. quired Sunnary Listing of pump testing is-maintained on. computer using the Pump and Valve Trending Progra d This program'was recently obtained and past data are in .the process - 1

of being incorporated. . The program exceeds the Code requirements of only recording the dates for _successfully completed tests. This

. program not on l y record s all the measured data, but also.can trend each component's' perfonnance. . . The required test record are maintained by. keeping copies ' of the test results sheet Deficiencies and corrective ; actions' are documented by Corrective Action Procedure CP-102. Test plans are specified in the actual test procedures and' pump technical records are in the vendor manual ' IST Leak. Rate: Testing Leak rate testing on valves in the Reactor Building Spray System

(RBSS) was reviewed for conformance with Section XI,, Subsection IWV

and the licensee's IST program. The inspector found that valses in the RBSS had been categorized in the IST program as A, B, or C in accordance withl the, requirements of IWV-211 For . the RBSS, - no category A valves were identified- in the licensee's program. The inspectors ' review of. system drawings and valve functions for this system did not identify any valves requiring leak testin Containment isolation valves- BSV-3, BSV-4, BSV-26 and BSV-27 which would normally be category A valves requiring a leek- rate test are exempted from Type C leak rate testing by T . Action on' Previous Inspection Findings (92701) (Closed) Inspector _ Followup Item 302/88-10-02, Review the licensee's

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. evaluation ' as~ to . the need to local leak rate test containment electrical' penetration The inspector reviewed the following documentation supplied by the licensee and discussed the evaluation with licensee personne CFR 50, Appendix J, Paragraph II.G, Technical Specification 3/4.6.1.2, 3.6.3 and Table 3.6-1 (Table 3.6-1 has been removed from the Technical Specification and included in the FSAR by Licensee Amendment No.114).

FSAR, Section 5.6. SER, Section 6. Licensee Internal Memoranda:

W. G. Nueman, III to E. E. Welch dated 8/22/87 G. V. Hilderbrandt to D. A. Shook dated 9/17/87 D. S. Shook to E. E. Welch dated 3/25/88

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p; In the memorandum dated September 17, 1907 6 sito engineeri _ personnel identified- that the Conax electrical paaetration assemblies have potential leak paths through the metal to metal seal betweea the outside of the feed through tube and the assembly header plate, and through the polysulfone sealant between the inside of the feed through tube- and the wire '

In ~ the memorandum dated March 25, 1988, corporate engineering personnel responded to the site. engineering staff vith the pnsition that the metal to metal seal created by a cap and ferrule device is not considered a flexible metal seal assembly and the polysulfone sealant is not a resilient sea Consequently, Appendix Paragraph II.G and II.G.1 do not apply to Crystal Rive Based on this evaluation the licensee docs r.ot leak rate test these electrical penetration The inspecter reviewed certain design characteristics of the Conax electrical penetrations against the licensee's evaluation and the explicit requirements of Appendix J, paragraph II.G and II. Based on this - review the inspector disagrees with the licensee's evaluation. Specifically, the polysulfone material used as a seal between the wires and feed through tube can be classified as a sealant compound. Paragraph II.G.1 reqJires Type B testing of any penetration whose design employs a sealant compound. Also, the metal to metal seal between the feed throdgh tube and the header plate is achieved by assembling twn metal parts, i.e., cap and ferrul Assembly of these metal parts creates the metal seal. Further, the metal is flexible, as 6pposed to rigid or brittle, to allow the metal to deform and create a seal against the opposing rigid metal surfaces.- The inspector determined that the Conax electrical penetrations are fitted with a flexible metal seal assembl Paragraph II.G.I explicitly requires Type B testing on electrical penetrations fitted with flexible metal seal essemblie The inspector reviewed FSAR, Section 5.6.4.2 (Type B Tests),

Technical Specification Section 3.6.3, Table 3.6-1, and 3ER, Section 6.2.5 to determine if these decumcnts grant an exemption to 10 CFR 50, Appendix J, regarding leak rate testing electrical penetration GAR Section 5.6.4.2 specifically addresses penetrations with resilient seals and only generally addresses electrical penetratier Exclusion of electricai penetrations from the class of penetrations with resilient seals is not considered as an exemption frcm testing electrical penetration Table 3.6-1 identifies containment isolation valves and also includes a heading for Type B tests. Prior to removal of Table 3.6-1 from the Technical Specifications the table was used in conjunction with Technical Specification 3.6.3 which addresses specifically and

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exclusively. 'the operability. of containment isolation valves. The table was not intanded to identify Type B testin Consequently, acceptance .of . Table 3.6-1 in tha Technical Specifications with electrical penetrations omitted does not constitute an exemption from thc' requirements of 10 CFR 50, Apper. dix J. .The Safety Evaluation Report (SER), Sectica 6.2.5 states that the licensee has a program for testing resilient sedls, but also indicates electrical penetrations will be leak rate teste The ir.spector concluded that Type B tests are required for the Conax electrical p2netrations by Appendix J, Paragraph II.G and II. Additionally, TS 4.6.1.2 commits the licensee to leak rate testing in accordance with 10 CFR 50, Appendix J. Item d of this specification requires that Type B tests shall be conducted with gas at Pa, 4 psig, at intervals no greater than 24 month The licensee stated that Type B tests have not been performed on the Conax electrical penetrations. At the exit interview this matter was identified as a violation as follows:

Violation 89-18-02: Contrary to the requirements of Technical 3 specification 4.6.1.2.d Type B tests on Conax electrical penetrations have not been performed at intervals of 24 months or les Based on this review, inspector followup item IFI 302/88-10-02 is close (Cinsed) 50-302/85-BU-03,T2515/73, IE Bulletin 85-03, Motor Operated Valve Corrun Mode Failure' During Plant Transients Due to Improper Switch Settin NRC Inspection Report 50-302/88-20 listed the following item to be completed prior to final NRC acceptance of IE Bulletin 85-03:

Revision of MP-402 and subsequent Ragion II review of the revie NRR review of the final response required by Action Item f. of the Bulletin. On February 17, 1988, the licensee provided this final response and this is presently updergoing review by NR Eight of the 17 Bulletin valve actuators are DC motor drive DC motor failure in Limitorque actuators with continuously eriergized shunt fields may be susceptible to surge voltages induced in the short field winding when energized has been identified as a occurrence at other utilities. The licensee has been notified of this problem and is determining if this if applicabie to Crystal River linit 3.

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?3 (Closed) Inspector Followup Item 50-302/87-31-03. This item involved inservice testing check valve procedures containing too vague acceptance criteria for determining if valves were performing their intended function The inspectors reviewed the procedures referenced in NRC Inspection Report 50-302/87-31 and verified that procedure ' changes have been made to provide specific acceptance criteri In sddition the procedures reviewed that accomplished containment spray system check valve testing contained adequate acceptance criteri (Closed) Inspector Followup Item 50-302/87-31-04. This item involved revision of CP-102, Inservice Inspection Pump and Valve Data Review and Corrective Action, to provide sufficient guidance on handling test results. Procedure re'Jsions addressed timely evaluation of pump test results, notification of the Nuclear ISI Specialist when out of specified conditions were resolved, and revisions to better identify actual requirements of actions to be taken when a pump or valve deta parameter was in . the ALERT or ACTION rang The licensee's actions to address this issue were satisfactor (Closed) Inspector Followup Item 50-302/88-20-01. This item involved a revision to MP-402 to address concerns regarding the effects on setpoint when adjustments were performed on leaking Main Stem Safety Valves. Specifica'lly, the revision to MP-402 included a precaution to determine the setpoint only if the valve is not leaking, and requirements for the valve to be thermally stable prior to adjusting the setpoin The licensee's actions to address this issue were satisfactory, (Closed) Inspector Followup Item 50-302/88-10-01. This item involved revisions to procedure PT-114, Moderator Temperature Coefficient Determination, involving notification of proper personnel if acceptance criteria were not satisfied, independent verification and sign-off of test results, and the re-incorporation of an acceptance criteria to provide addition technical validity of result The licensee's revisions to PT-114 were satisfactor . Exit Interview The inspection scope and results were summarized on July 14, 1989, with those persons indicated in paragraph 1. The inspectors described the areas inspected and discussed in detail the inspection results listed abov Proprietary information is not contained in this repor Dissenting comments were received from the licensee in the areas of verifying valve remote indication on the shutdown panel and containment l leakage testing of electrical penetration in that they considered these l

items did not warrant violations.

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The' inspectors reviewed MP-402 revisions. MP-402 was broken down into edition. a through Each edition accomplished a specific functio The editions reviewed by the inspectors provided clear, and accurate instructions to accomplish motor operated valve maintenance and control switch seeting Generic Letter 89-10, Safety-Related Motor-0perated Valve Testing and Surveillance, has expanded the scope of IE Bulletin 85-03, therefore IE Bulletin 85-03 responses will no longer require NRR review. Information Notice 88-72, Inadequacies in the Design of DC motor operated valves', was issued to alert licensees to potential problems in the design specifications of de motor-operated valves, which has been evaluated by the license (Closed) Licensee Event Report (LER) 89-0 During Refueling Outage 6, completed in January 1988, the flush water systems for the Nuclear Services and Decay Heat Sea Water Pumps were modified to allow each sea water pump to supply flush. water to itself and associated train pumps in the event the normal supply faile Nine new sea water check valves installed by this modification were not intergraded into the Inservice Inspection Pump and Valve Program in a timely fashio As a result, no testing of the valves was

. performed during the first three quarters of 1988. When test requirements (component testing) were determined and testing was attempted, it was discovered that five of the valves could not be tested in the closed direction due to the configuration of the check valves and piping, although the system, as designed, could be demonstrated operabl A modification has been accomplished that allows testing of the five valves in the closed direction. Testing in the closed direction of these five valves is scheduled to occur in August 198 (Closed) Unresolved Item 50-302/88-33-01. This item involved not inservice testing the closed function of emergency feedwater check valves. Testing the closed function of check valves is addressed by Generic Letter 89-04. In complying with Generic Letter 89-04, the licensee will resolve emergency feedwater check valves deficiencie (Closed) Inspector Followup Item 50-302/87-31-02. This item involved not testing check valves in a manner that would determine that the valve can perforrn all of its safety functions. This item was to be resolved during the next NRC inservice test program review. Per Generic Letter 89-04, the Crystal River inservice test program will not receive a NRC full review. Generic Letter 89-04 addresses the check valve testing deficiencies noted in Inspection Report 50-302/87-31, In complying with Generic Letter 89-04, the licensee will reso e these check valve deficiencies.

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It.em Number Description and Reference 302/89-18-01 Violation - Failure to adequately perform Inservice Testing, paragraph 2 302/89-13-02 Violation - Failure to perform containment leak rate testing on electrical penetration, paragraph The licensee committed to provide to the NRC in writir.g how the issue of verifying the spray additive system flow rate would be resolved, paragraph' Licensee management was infnrmed that the five Inspector Followup items, one unresolved item, one-licensee event report and one Bulletin discussed in paragraph 3 were closed during this Inspectio _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ - _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ - _ _ _