ML20079J811
| ML20079J811 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/16/1983 |
| From: | Westafer G FLORIDA POWER CORP. |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20079J789 | List: |
| References | |
| 3F-0983-13, 3F-983-13, NUDOCS 8401240425 | |
| Download: ML20079J811 (5) | |
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=y, y a usmo u y y}q i u n U, g%kN5!2 NiWF C3 SEP 20 A 9 : 0 8 Florida Power C O n P O p a T e O se September 16,1983 3F-0933-13 Mr. 3. P. O'Reilly Regional Administrator, Region II U. S. Nuclear Regulatory Commission Office of Inspection & Enforcement 101 Marietta Street, Suite 2900 Atlanta, GA 30303
SUBJECT:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 IE Inspection Report No. 83-17
Dear Sir:
Enclosed is Florida Power Corporation's response to Inspection Report No. 83-17, dated August 5,1983.
Although Florida Power Corporation (FPC) has agreed with the two enclosed violations, we do not agree that our actions warrant two violations. Based on the similarity of the violations and the Nuclear Regulatory Commission actions oa past violations, we consider the two events to be two examples of one violation.
The two violations discussed within the Report involve similar events, related causes, and identical corrective actions. Violation A is the failure to test containment isolation valves during Refuel IV in the direction of post-accident flow. Violation B is the failure to report a procedural inadequacy which allowed testing containment isolation valves during Refuel III in the incorrect direction.
Both of these violations address the adequacy of FPC's containment isolation valve testing procedure. In addition to being similar events, the violations involve related causes. Violation A was caused by the procedural inadequacy identified in Violation B. Violation B, failure to report an inadequate procedure, was caused by personnel error. Personnel considered the Local Leak Rate Test Report, submitted to the NRC, to satisfy the reporting requirements. That report included a brief description of FPC's intended corrective action.
Due to the similarity of the violation's causes, the corrective actions to prevent recurrence are identical. These actions are:
1)
Revise the piocedure and modify the plant, as necessary, to test the valves correctly; and 2)
Circulate this response among responsihte pirsonnel to inform them of the significance of these events.
8401240425 840106 PDR ADOCK 05000302 G
PDR General Office 3201 Thirty-fourth street soutn. P o. Box 14o42. st. Petersburg, Flonda 33733 813-866-5151
C a.
3F-0983-13 Page Agreement with the position that these events are two examples of one violation would be consistent with the position taken by the Commission in Inspection Reports 82-32,83-10 and 83-14. Inspection Report 82-32 cited two examples of a welder exceeding his qualifications.
One example was caused by a code misinterpretation and the other example by a failure to document testing results. In this instance, the events were similar and the causes were diflerent. Inspection Report 83-10 cited a violation of Action b and d of Specification 3.6.3.1.
Coth of these violations w3re caused by a misinterpretation of the Technical Specification.
Inspection Report 83-14 cited two examples of non-compliance with IWB/lWC-2520 with regard to base metal coverage during a Radiographic Test. The first example was a failure to have an adequate procedure. The second example was a failure to perform a test adequately.
In this case, the second example was caused by the first example.
Due to the similarity of the two events and NRC actions on other violations concerning similar events, FPC considers the two events to be two examples of one violation This violation would be:
" Failure to test containment isolation valves in the direction of post-accident flow during Refuel Ill and IV." or
" Failure of SP-179 to require testing in direction of p/or ASME XI ost accident flow in accordance with 10 CFR 50, Appendix 3, and Section IWV-3420."
Sincerely, i
G. R. Westafer Manager Nuclear Operations Licensing & Fuel Management PGH/ mig Attachments cc:
Document Control Desk U. S. Nuclear Regulatory Commission -
Washington, D. C. 20555
~
FLORIDA POWER CORPORATION RESPONSE INSPECTION REPORT 83-17 September 16,1983 A.
VIOLATION 10CFR50, Appendix 3, Subparagraph Ill.C.I. requires Type C test of containment isolation valves be performed by local pressurization applied in the same direction that the valve would be subjected to pressurization during accident conditions unless it is determined that testing in the opposite direction is equal to or more conservative than testing in the accident direction.
Contrary to the above, during the period of June 6-7, 1983, five containment isolation valves were tested by pressurization in a direction opposite to the accident pressurization direction and such testing was not equivalent nor demonstrated to be more conservative than testing in the accident pressurization direction.
This is a Severity Level IV Violation (Supplement I).
A.
RESPONSE
(1)
FLORIDA POWER CORPORATION'S POSITION:
Florida Power Corporation agrees that the requirements of 10CFR50, Appendix 3, as interpreted by the Nuclear Regulatory Commissicn, Region II, were not met.
The leakage tests performed on June 6 and 7,1983, on the five containment isolation valves were "As-Found" leakage tests. An "As-Found" leakage determination is not explicity required by 10CFR50, Appendix 3, however, the Staff has taken the position that an "As-Found" determination is implicitly required by Appendix 3.
Additionally, Florida Power Corporation, as discussed in Inspection Report 82-26, has agreed to perform such tests. Because these tests are intended to deraonstrate containment integrity prior to maintenance, such tests should be performed in the direction of post-accident flow.
(2)
DESIGNATION DF APPARENT CAUSE:
This violation was caused by a procedural inadequacy and a design oversight.
When testing WSV-3. 4, 5 and 6, personnel failed to recognize that these valves could be tested in the correct direction and, therefore, modify the procedure. Testing WDV-3 in the correct direction was not possible without modifications to the plant due to the piping configuration. _
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'(3)-
IMMEDIATE CORRECTIVE ACTIONS:
The Containment Leak Test was revised to test WSV-3, 4, 5, and 6 in the direction of post-accident flow. A plant modification to the piping upstream of WDV-3 was completed to allow testing in the direction of post-accident flow.
The "As-Left" leakage determination was performed in the correct direction prior to startup and all valves had leakage with8n the acceptance criteria.
(4)
LONG TERM CORRECTIVE ACTIONS:
This Inspection Report response will be circulated to responsible personnel to inform them of the significance of this event.
(5)
DATE OF FULL COMPLIANCE:
Florida Power Corporation was in full compliance by November 1,1983.
B.
VIOLATION Technical Specification 6.9.1.8.f requires notification of the NRC Regional Office within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> with a followup report within 14 days whenever it is determined that a procedural inadequacy could prevent a plant safety system from functioning.
Contrary to the above, as of June 1,1983, a local leakrate testing report dated January 25, 1982, which indicated a possible degradation of containment isolation valves due to an inadequate test procedure was not reported.
This is a Severity Level V Violation (Supplement I).
B.
RESPONSE
(1)
FLORIDA POWER CORPORATION'S POSITION Florida Power Corporation agrees that we failed to report, as required by Technical Specification 6.9.1.8.f, a possible degradation of a containment isolation valve due to an inadequate test procedure.
The report referenced in the subject Inspection Report was submitted to Florida Power Corporation by a consultant.
Florida Power Corporation's position with respect to the local leak rate testing performed during the 1981 refueling outage and documented in the referenced report is described in the Reactor Containment Building Local Leak Rate Test Report submitted to the NRC on February 25, 1982.
In that report, Florida Power noted that fifteen valves were tested in the direction opposite the direction of post-accident flow. Of the 1
a fifteen valves, only WDV-94 was identified by the report as providing
- less conservative results when tested in the direction opposite post-accident flow. This identification should have been promptly reported to the Commission as required by Technical Specification 6.9.1.8.f.
Following the issuance of this Inspection Report, a review of the valves tested in the reverse direction based on valve type was performed. This revuw indicated that a total of six valves (including WDV-94) were of a valve type that could yield leakage that is less conservative when tested in the direction opposite of post-accident flow. These valves are: WDV-3,60,94 and 406; and WSV-5 and 6.
(2)
DESIGNATION OF APPARENT CAUSE:
This violation was caused by personnel error. Responsible personnel considered the February 25,1982 report to have satisfied any reporting requirements.
The procedural inadequacy was caused by personnel error and a design oversight.
WDV-3 and 60 required a plant modification to be tested correctly and apparently had not been designed to be tested in the post-accident direction. At the time of the test, personnel did not consider WDV-94 and 406 to be testable in the direction of post-accident flow with a procedure revision because such testing required use of inadequately reliable valves (check valves). When testing WSV-5 and 6, personnel failed to recognize that these valves could be tested in the correct direction modifying the procedure.
(3)
SHORT TERM CORRECTIVE ACTIONS:
Modifications to the plant were performed to allow testing in the post-accident flow direction for WDV-3 and 60. As stated in the response to Violation A, the procedure has been revised to test WDV-94 and 406 in the post-accident flow direction. The procedure was also revised to test WSV-5 and 6 in the post-accident flow direction.
Prior to startup for Refuel IV, these valves were tested correctly and satisfactorily.
(4)
LONG TERM CORRECTIVE ACTION:
Responsible personnel will be informed of this event to emphasize the l
importance of reporting applicable events to the Commission as required in the Technical Specifications.
(5)
DATE OF FULL COMPLIANCE:
Florida Power Corporation was in full compliance by November 1,1983.