IR 05000302/1993027

Insp Rept 50-302/93-27 on 931108-12.Violations Noted.Major Areas Inspected:Reactor Bldg Tendon Surveillance Program

ML20059C084
Person / Time
Site:	Crystal River
Issue date:	11/29/1993
From:	Blake J, Lenahan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20059C073	List: IR 05000302/1993027 ML20059C071 ML20059C079
References
50-302-93-27, NUDOCS 9401040360
Download: ML20059C084 (7)

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Report No.: 50-302/93-27 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 Cenducted: November 8 -12, 1993 Inspector:

J. J.Lenaha ff ' [- ///U >

Dite Signed Approved by: -

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J. la (Chief Uate Signed Mater al and Processes Section Eng' ee ing Branch Division of Reactor Safety SUMMARY Scope:

This rout'ine, announced inspection was conducted in the area of the reactor

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building tendon surveillance progra Results:

Two violations were identified - Paragraph One violation concerned seven examples of failure to implement the tendon surveillance inspection program. The other concerned failure to implement the fifth tendon surveillance inspection within the surveillance interval required by the Technical Specification Weaknesses were identified regarding failure of the licensee to oversee the contractor performing the tendon surveillance inspection activities, inadequate training of the Quality Control inspector, and an inadequate tendon surveillance procedure - Paragraph o1040360 931210-PDR ADOCK 05000302 G PDRL

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REPORT DETAILS Persons Contacted Licensee Employees

• B. Crane, Principal Mechanical Engineer

• R. Davis, Acting Director, Nuclear Plant Operations E. Froats, Manager, Nuclear Compliance

• J. Gibson, Nuclear Technical Specification Coordinator

• C. Long, Supervisor, Nuclear Quality Control

• P. McKee, Director, Quality Programs R. McLaughlin, Nuclear Regulatory Specialist

• L. Moffatt, Manager, Technical Support

• G. Swaney, Nuclear Project Specialist

• K. Wilson, Manager, Nuclear Licensing Other licensee employees contacted during this inspection included engineers, technicians, and quality control inspection personne Other Organizations

• D. McCoy, Project Manager, VSL Corporation NRC Resident Inspectors

• R. Butcher, Senior Resident Inspector

• P. Holmes-Ray, Senior Resident Inspector

• T. Cooper, Resident Inspector

• Attended exit interview Containment Building Tendon Surveillance (61701)

The inspector examined procedures, work activities, and quality records pertaining to the fifth tendon surveillance inspection which was currently being performed. Acceptance criteria utilized by the inspector appear in Technical Specification (TS) 4.6.1.6 and FSAR Sections 5.2.2.3 and 5.2. .1 Review of Tendon Surveillance Procedure The inspector examined FPC Surveillance Procedure SP-182, Revision 10, Reactor Building Structural Integrity Tendon Surveillance Program, and Temporary Procedure Change Review Record, Document Control number 93-10-01, to SP-182. The procedure specifies the requirements for inspection, testing, and data analysis for the containment building post-tensioning system. The temporary procedure change lists the particular tendons to be inspected / tested during the fifth tendon surveillanc Review of the procedure disclosed that the sections of SP-182 covering re-installation of the tendon end caps and tendon regreasing were not clear. Discussions with licensee engineers and the Quality Control (QC)

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inspector indicated that they were uncertain as to meaning of the inspection " Hold Points" regarding this work. In addition, there was no 3 requirement in the procedure regarding application of the corrosion -

protection material (grease) to the anchorage system components prior to reinstallation of the end caps. This is an industry standard practice and in described in Section 5.2.2.5.1 of the FSA ,'

The inspector identified some additional problems to the licensee with SP-182 which required correction. These included references to procedure QAP-19 in paragraph 2.2.2 and 3.5.6. This procedure had been canceled by the licensee more than five months prior to start of the tendon surveillance and replaced with a new procedure (CP-146). The inspector also noted that the reference to the standard test method for >

determining moisture content in the bulk filler grease had been omitted from Enclosure 33 of SP-182 and the test method for sulfides may be outdated. The licensee revised the procedure (SP-182) to clarify the requirement for tendon regreasing and made additional corrections. The procedure was re-issued subsequent to the inspection as Revision 1 ,

2.2 Observation of Tendon Surveillance Work Activities

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( The inspector witnessed stressing operations for the determination of lift off forces in vertical tendon 61V14 (shop end) and the shop end of tendon D215. The inspector noted that the lift off values were determined by inserting one feeler gage, 0.030 inches thick, between the shims and anchor head or bearing plate. Paragraph 3.2.7.a of SP-182 ,

specifies the use of two thin feeler gages (.010 inches thick) located ;

about 180 degrees apart between the bearing plates and shims. This was cited as an example of failure to properly implement surveillance procedure SP-182, discussed in paragraph 2.4, below. The inspector also examined the anchorage assemblies on the shop ends of tendons 61V14 and D215 and verified, that the assemblies were in good condition and had i not been damaged by corrosion. The inspector witnessed reinstallation !

of the end caps on tendon 61V14. The inspector noted that the QC l inspector was not present when the end cap was installed on tendon D21 This was accomplished after the QC inspector departed from the work area. The inspector also noted that the work required by paragraphs !

4.1.7.5. and 4.2.7.5 of SP-182 had not been performed, although this step contains an inspection " Hold Point". These problems were cited as additional examples of failure to implement procedure SP-182, as discussed in paragraph 2.4, belo .3 Review of Quality Records l

The inspector examined the following records relating to tendon surveillance activities:

(1) Stress ram calibration records for ram numbers 6529 and 12- i (2) Calibration records for pressure gages and thermometer .

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(3) Material certification records for bulk filler grease, Visconorust 2090P-4, batch numbers 2-20064 and 2-2069 (4) Partially completed data sheets recording results of tendon surveillance inspections completed as of the inspection dat Review of Enclosure 20, Data Sheet 7, for the shop end of Tendon D215 disclosed that the QC inspector incorrectly recorded the lift-off force measurements for this tendo However, this data sheet had not bee reviewed by the contractor or by the licensee. After questioning by the inspector, the QC inspector reviewed his field notes and determined that he had incorrectly transferred the lift-off data to the final data sheet. The inspector also identified other errors on data sheets which were identified to the licensee as additional examples of failure to implement the tendon surveillance procedur These are discussed in paragraph 2.4 belo .4 Inspection Findings ,

Observation of tendon surveillance activities, and review of records documenting the tendon surveillance inspections disclosed seven examples of failure to implement the requirements of the tendon surveillance procedure, SP-182, Revision 10. Failure to implement the requirements of SP-182 is contrary to Technical Specification 6.8.1.C. The examples of failure to implement SP-182 are summarized below. Paragraph numbers listed reference procedure SP-182. The examples were as follows:

(1) Using one 0.030 inch thick feeler gage instead of two 0.010 inch thick feeler gages to determine tendon lift-off force, as discussed in paragraph 2.1, abov (2) Paragraph 3.7.2.9, under initial conditions, requires verification that references listed in Section 2.0 of the procedure are available for use prior to starting tendon surveillance activities. No verification had been performed to verify that reference number 2.2.2, Procedure QAP-19 was available for us This procedure had been cancelled by the licensee prior to start of the tendon surveillance (see paragraph 2.1, above).

(3) Paragraph 3.7.2.13.1, under initial conditions, requires listing recording equipment and measurement devices, identification -

numbers, and calibration due dates on Enclosure 32 of SP-182 prior to start of the tendon surveillance inspection. During review of Enclosure 32, the inspector noted that this information was not recorded on Enclosure 32 as required. The contractor recorded the necessary data on Enclosure 32 after the inspector identified the proble (4) Paragraphs 4.1.4.1 and 4.2.4.1 of SP-182 require visual inspection of the bulk filler grease used for tendon corrosion protection, per Enclosure 4 of SP-182. Paragraphs 4.1.4.2 and 4.2.4.2 require completion of Data Sheet 3 to document inspection of the tendon L

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4 i corrosion protection system (bulk filler grease). The required grease inspections had not performed or documented for tendon i'

numbers D215, 46H29, and 61V1 ,

(5) Paragraph 4.1.7.4, which contains an inspection " Hold Point", l requires the QC inspector to witness installation of new 0-rings :

in the end cap flanges. The " Hold Point" inspection is documented !

by signing off step 4.1.7.4 on Enclosure 38. The QC inspector did not witness installation of the new 0-ring in the end cap for the !

shop end of tendon D215. The QC inspector signed off this step on Enclosure 38, even though he did not witness and inspect the new 0-ring installation for this tendon. Discussions with the QC ;

inspector disclosed he did not understand what work was required by the procedure to complete this step. As stated in Paragraph 2.1, above, the procedure was not clea (6) Paragraph 4.1.7.5 specifies a procedure " Hold Point" which ,

requires checking for voids in the bulk filler in the trumpet Paragraph 3.2.4 defines a procedure " Hold Point" as a step beyond which work is not permitted to proceed until the work is inspected and accepted by the QC inspector. There was disagreement between the licensee's architect-engineer, and the contractor regarding the feasibility of completing the work required by this procedure ,

step. The QC inspector and licensee personnel also were not sure what work was required by this procedure step. Instead of revising the procedure to clarify the work requirements, this step was by passed and work was permitted to proceed beyond the " Hold Point" for tendons 61V14, D215, and 46H29, even though the work required for step 4.1.7.5 had not been performe l (7) Paragraph 4.7.10 specified an inspection " Hold Point" for 'l inspecting the bearing plate gasket bearing surfaces to be sure - ;

they are clear and smooth and free of loose mill scale, rust, dirt etc., prior to installation of the permanent end cap. The " Hold Point" inspection is documented by signing off step 4.1.7.10 on Enclosure 38. The QC inspector did not perform the inspection required in step 4.1.7.10 for tendon D215. The QC inspector l signed off step 4.1.7.10 on Enclosure 38 although he did not perform the required inspection. The procedure also required clarification to define the work required by this ste The above examples of failure to implement the tendon surveillance ,

procedure requirement was identified to the licensee as violation of '

Technical Specification 6.8.1.c, Violation Item 302/93-27-01, Failure to Perform Tendon Surveillance Inspection in Accordance with Procedural Requirement .

The failure to implement the tendon surveillance program was caused by .

an inadequate surveillance procedure, inadequate training of the quality

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control inspector, and inadequate oversight of the tendon surveillance i

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contractor by the licensee. This was identified to the licensee as a weaknes The inspector also identified a second violation. This violation involved failure to perform the current, ongoing fifth tendon surveillance in the time period specified by Technical Specification (TS) 4.6.1.6.1.. TS 4.6.1.6.1 requires that the tendon surveillance be performed at the end of one, three and five years following the initial containment Structural Integrity Test (SIT), and at five year intervals thereafter. The SIT was completed in November, 1976. Therefore the fifth tendon surveillance should have been performed within 15 years following the SIT, or November,1991. Inclusion of the maximum allowable surveillance interval extension of 25 percent, in accordance with TS 4.02, permits extension of the surveillance date to January, 199 The failure to perform the fifth tendon surveillance inspection by January, 1993 was identified to the licensee as Violation Item 302/93-27-02, Failure to Perform Fifth Tendon Surveillance within Time -

Required by Technical Specification l The licensee disagreed with the inspector regarding the requirements of the TSs regarding performance of the fifth tendon surveillance inspection. The licensee stated that since the fourth tendon l surveillance was preformed in November,1987, they could select the surveillance date for the fifth tendon surveillance by adding a 25 percent extension to the five year interval, (15 months to the five year interval), and by adding six years three months to November,1987, determine the time for completion of the fifth tendon surveillanc This would permit the fifth tendon surveillance to be completed by January, 1994. The licensee stated that the fifth tendon surveillance was originally scheduled to be preformed in 1992, but for. convenience

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and economic considerations, they decided to delay it until late 1993.

The inspector did not accept the licensee's position for the following reasons:

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The Bases for TS 4.0.2 clearly states that the provisions of TS 4. are not intended to be used repeatedly as a convenience to extend surveillance intervals. The allowable extensions of surveillance intervals are primarily based on considerations of plant operating .

conditions. The Safety Evaluation Report (SER), upon which the current TS 4.0.2, (Amendment 128), was based, references NRC Generic Letter 89-1 It is noted in the SER that it is not the intent of the allowance for extending surveillance intervals be used repeatly merely as an operational convenience to extend surveillance intervals beyond that specified. Generic Letter 89-14 contains the same language.

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1 3.0 Exit Interview The inspection scope and results were summarized on November 12, 1993, with those persons indicated in paragraph 1. The inspector described the areas inspected and discussed in detail the inspection results ,

listed below. Proprietary information is not contained in this repor ;

Dissenting comments were received from the licensee regarding violation .

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item 302/93-27-02. The licensee stated that they did not agree with the inspector regarding the due date for the fifth tendon surveillance ,

inspectio ! Violation item 302/93-27-01, Failure to Perform Tendon Surveillance Inspection in Accordance with Procedure Requirement (See paragaph2.4, page 4) ' Violation item 302/93-27-02, Failure to Perform Fifth Tendon Surveillance within the Time Required by Technical Specification (See paragraph 2.4, page 5)

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