ML20127J635

Insp Rept 50-302/85-20 on 850408-12.Violation Noted: Inadequate QA Records Documenting Visual Insp of safety- Related Snubbers

ML20127J635
Person / Time
Site:	Crystal River
Issue date:	05/01/1985
From:	Jape F, Lenahan J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127J613	List: ML20127J609 ML20127J618 ML20127J635
References
REF-GTECI-A-36, REF-GTECI-SF, RTR-NUREG-0612, RTR-NUREG-612, TASK-A-36, TASK-OR 50-302-85-20, NUDOCS 8505210533
Download: ML20127J635 (7)

See also: IR 05000302/1985020

Text

1. F tr UNITED STATES

l

fY o NUCLEAR REGULATORY COMMISSION

REGloN il

[ 101 MARIETTA STREET,N.W.

y j

• e ATLANTA, GEORGI A 30323

\,...../

Report' No.: 50-302/85-20

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: April 8 - 12, 1985

.

Inspector:

J. J. Lenahan'

//C u t bd

y/ Date Signed

Accompanying Personnel: T. F. McElhinney

Approved by: // OW # [8]

F. Jape, S4ction Chief g/ Date Signed

Engineering. Branch

Division of Reactor Safety

SUMMARY

Scope: This routine, unannounced inspection entailed 68 inspector-hours on site

in the areas of the snubber surveillance program, control of heavy load, emer-

gency. diesel generator surveillance / maintenance procedures, licensee identified

items' (LER), and previously identified inspector followup items.

Results: One violation was identified - Inadequate -Quality Assurance Records

Documenting Visual Inspection of Safety-Related Snubbers paragraph 6.c.

8505210533 850502

PDR ADOCK 05000302

G PDR

m .

-

'O

<

REPORT DETAILS

1. Persons Contacted

Licensee Employees

• G. Boldt, Nuclear Plant Operations Manager

• J. Bufe, Nuclear Compliance Specialist

• M. Collins, Nuclear Safety and Reliability Superintendent

• D. A. Fields, Nuclear Reliability Supervisor

• W. Johnson, Nuclear Plant Engineering Superintendent

J. R. Museda, Nuclear Project Engineer (telephohe conversation)

• P. McKee, Nuclear Plant Manager

• W. G. K?uman, Senior Nuclear In-Service Inspection (ISI) Specialist

• W. Rossield, Nuclear Compliance Manager

• D.-Smith, Nuclear Maintenance Superintendent

Other licensee employees contacted included four mechanics. *

NRC Resident Inspectors

J. Tedrow

• T. Stetka

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on April L?,1985, with

those persons indicated in paragraph 1 above. The inspector described the

areas inspected and discussed in detail the inspection findings. No dis-

senting comments were received from the licensee. The following new items-

were identified during the inspection.

Unresolved Item 302/85-20-01, Snubber Surveillance / Maintenance Procedures,

paragraph 6.a.

Violation Item 302/85-20-02, Inadequate QA Records Documenting Visual

Inspection of Safety-Related Snubbers, paragraph 6.c.

The licensee did not identify as proprietary any of the material provided to

or reviewed by the inspector during this inspection.

3. Licensee Action on Previous Enforcement Matters

This subject was not addressed in the inspection.

.

_

~ ~

E l

. . -

a i

2-

14. ' Unresolved Items

Unresolved items .are matters about which more information is required to

determine whether they are acceptable or may involve violations or devia-

tions. :New unresolved items identified during this inspection are discussed

in paragraph 6.

5. Independent Inspection-Effort (92706)

a. [The inspector. walked down portions ;of the reactor building and exam-

-

ined bolted connections on the_ reactor butiding internal structural

steel supports and platforms.

b. The . inspector reviewed emergency diesel generator maintenance and

surveillance procedures and verified that they met the acceptance

criteriaf specified in Technical Specifications 4.8.1.1 and 4.8.1.2.

Procedures examined were as follows:

.(1) Procedure Number MP-117, Emergency Diesel Generators Governor and

Servo-Booster Maintenance.

-(2)' Procedure Number PM-123, Periodic Electrical Checks of Emergency

Diesel Generators.

(3) Procedure Number SP-354-A, Emergency Diesel Fuel Oil Quality and

-Diesel Generator 3A Monthly Test.

(4) Procedure Number SP-354-B, Emergency Diesel Fuel Oil Quality and

Diesel Generator 3B Monthly Test.

_(5) Procedure Number SP-417, Refueling Internal Integrated Plant.

Response to Engineered Safeguards Actuation.

(6) Procedure. Number SP-605, Emergency Diesel Generator Engine

Inspection / Maintenance

(7) Procedure Number SP-901, 4.160Ky ES Bus 'lB" Undervoltage Trip Test

_

Within the areas inspected, no violations or deviations were identified.

6. Snubber Surveillance Program (61729)

.The inspector examined procedures and quality records related to the snubber

surveillance program and inspected selected snubbers on . safety-related

piping systems. . There are no safety-related mechanical snubbers at this

- site, all snubbers are hydraulic. Acceptance criteria utilized by - the

-

inspector are specified in Technical Specification 3/4.7.9.1.

!

'

.

a

, . . - - . - . - . - - - - . - - . . - - -

t

t .

,

,

-

t

3

, a. Review of Snubber Suaveillance/ Maintenance Procedure

i

t

The inspector' examined the following procedures which control snubber

surveillance / maintenance activities. ,

(1) Surveillance Procedure Number SP-200, Hydraulic Snubber Function-

,

al Testing.

(2) Surveillance Procedure Number SP-201, Accessible / Inaccessible

. Hydraulic Snubbers Visual Inspection.

(3) Maintenance Procedure Number MP-174, Pipe Snubber Rebuild and Test

Procedure.

.

(4) Maintenance Procedure Number MP-175, Pipe Snubber Removal and

Installation.

(5) Maintenance Procedure Number MP-177, Power Piping Snubbers

,

In-Situ" Maintenance.

, Review of the above procedures and discussions with licensee personnel

disclosed the following problems. Section 2.1.1 of the procedure ~

i

~

. requires that a functional test be performed to demonstrate that a

snubber is operable when visual inspection discloses a " low ' fluid

-

level". The term low fluid level is not defined in the procedure.

Section 2.-1 implies that the fluid level in a snubber is low when no

1- . fluid is visible in .the sight glass, while Section 6.2.-l.1 of ,

, Procedure SP-201 implies that the fluid level-is not considered low if

there is sufficient fluid in the ' reservoir, as measured by dipstick to .

. supply fluid . to ~ the snubber. However, Section 6.2.1.1 requires

evaluation of each_ individual discrepancy (i.e., fluid level below sight .

, glass).on a case by case basis considering measured fluid level, reservoir

'

orientation, height of outlet part, and. bore and stroke of the snubber.

. Licensee personnel were vague in their discussions with the inspector

regarding the definition of " low . fluid level" and ~when a . functional

test was required. The inspector could not determine if cases when the

fluid level was below the sight glass were being evaluated as required.

'

The functional test should be conducted prior to the performance

of any corrective action; otherwise the snubber must be considered as

~

failed. However, maintenance. procedure MP-175 requires that snubbers

be rfilled -with. fluid prior to their removal and transporting for

. functional testing.

In addition, as a result of design changes and modifications, eight

snubbers manufactured by Grinnell have been added to safety-related

piping systems in the plant. These snubbers have not been included in

-

'

!

the listing of safety-related snubbers requiring inspection under

! procedure SP-20'. and there was no instruction in the maintenance

l. _ procedure regarcing requirements for maintenance or rebuilding of.the

r

l

m

h7 -W e-aq- 4 y--e-w--w--'vnve* y --.qw w ,,.- ,.,,qu,w- - -

e v -ye--*-- gw" -

9 -%- wee-P' "g vm)

~

p s,

3e

i

~

.., 'wq- ,4

4 *

, ,

4

.. w

,

Gr_innel snubbers. However, based on the records reviewed, as discussed

.in paragraph 6.c below, the inspector determined that the licensee had '

made visual inspection of the Grinnel snubbers.

,Pending further review by NRC of the procedures regarding clarification

.of Jacceptance criteria, discrepancies between procedures - SP-201 and:

'

MS_175 regarding addition of fluid to reservoirs prior to performance

of functional tests,; and clarification' of. inspection and maintenance

requirements for Grinnell snubbers, the apparent deficiencies in the-

procedure were identified to the licensee as Unresolved Item 302/85-20-01,

Snubber Surveillance / Maintenance Procedures.

b. Inspection of Snubbers

% ,.

The inspector performed a visual inspection of the snubbers 11sted

1 -below and verified that the snubbers were not damaged, that attachment

to' the , supporting structure was secure, that the fluid level in the

snubbers'was visible in the reservoir sight glass as defined in proce-

dure SP-201, and that the. fluid was not leaking from the snubber.

Snubbers examined were as follows:

(1) Snubber Numbers FWH-122, 126 and 171* on the feedwater system

(2) Snubber Numbers RCH-63 and.90 on the reactor coolant system

(3) Snubber Numbers MVH 44, 45, 83 and 85 on the makeup and purifica-

tion system.

(4) Snubber Numbers MSH-121*, 122*, 123*,.124*, 149, 160,- 161, 162,

164 165, 227*, 232*, 576L and 576U on the main steam system

L .(5), Snubber Number CHH-24 on the decay heat removal system

) .

• Sn'ubbers located in the Intermediate Building which are accessible for-

inspection during plan * operation. All others listed are in the

'

reactor containment building and are inaccessible during plant opera-

tion (Modes 1-4).

.- c. Review of Quality Records

!

The inspector: reviewed the quality records documenting _the results of

visual. inspections performed on safety-related snubbers. These-inspec-

tions are required by Technical Specification Amendment No. 64 after

i. four ' months, but- within ten months of commencing power operations

r

following the 1983 refueling outage. This review disclosed that the

records documenting the . inspection of 60 safety-related inaccessible

L snubbers were undated. and did not identify the inspector or data

~

L recorder. This is in conflict with the' requirements of Criterion XVII

i -

of 10 CFR 50, Appendix B and was identified to the licensee as

[

Violation' Item 302/85-20-02, Inadequate QA Records Documenting Visual

-

i

l~ ,

.

f

ga

i

s:

e'

a

Inspection of Safety-Related . Snubbers. The inspector- were able to

verify that the inspections had been,made within the required tism frame

since the data were recorded on data -sheets identified as attachments

.to Revision 15 to Procedure SP-20. Revision 15 is dated January 27,

1984 -and the results of these inspections were . discussed with .NRC

Region II personnel in March and April 1984. In~ addition, there was no

-avidence in the records that the performance engineer had evalauted low

fluid >1evels as required by Section 6.2.1.1. of the procedure (this -

requirement is discussed in paragraph 6.a . above), or that : functional

tests had been performed when required by SP-201. These two items.will

be covered under resolution of Unresolved Item 302/85-20-01 discussed-

in~ paragraph 6.a above.

The inspector . examined records documenting visual inspections per-

-

formed in March - April 1984 for the snubbers listed in paragraph 6.b

-

above. During the walkdown inspection discussed in paragraph 6.b, the

inspectors compared the licensee's snubber inspection results with the

actual conditions observed by the inspector during the walkdown. No

discrepancies were noted. .The inspector also reviewed the results of

functional testing conducted on the ten snubbers per the Technical

Specification requirements. All_ snubber tested met the functional test

acceptance criteria. Within the areas inspected, no deviations were

.identi fied.

7. _ Control of Heavy Loads (NUREG-0612)

,

= The inspector reviewed records of crane operator training conducted- in

November 1984 and reviewed procedures listed' below which address-

requirements for safe handling of heavy loads stipulated in NUREG-0612.

'

=a. Surveillance Procedure Number SP-530, Demonstration of kuxiliary

Building Overhead Crane (FHCR-5) Interlock Operability

b .- Preventative' Maintenance Procedure Number PM-109 Check and Maintenance

of Miscellaneous Cranes and Hoists

c. Performance Testing Procedure Number PT-118, Spent Fuel Pool Missile

Shield Handling Crane Load Test Procedure '

-

d. _ Performance Testing Procedure Number PT-202, Auxiliary Building Over-

-head Crane Load Test

e. Performance Testing Procedure Number PT-203, Reactor Building Polar

Crane Load Test

f. Performance Testing Procedure Number PT-204, Miscellaneous Crane and

Hoists Load Test

g. Operating Procedure Number OP-421, Operations of CR-3 Overheads Cranes

and Hoists

%

,

e.

6

-Within the areas inspected, no violations or deviations were identified.

8. Licensee Event' Report Followup (92700)

(Closed) LER 302/83-53, Inoperable snubber during a routine visual inspec-

tion : on November 9, 1983. No fluid was observed in the sight glass of

snubber f number MSH-252 on the main steam system. Further investigation

-

-

disclosed that a loose' jam nut on the stationary end of the snubber .had

permitted the snubber to rotate to another position, which resulted in the

- fluid draining out.of . the snsbber. Operability of the snubber was restored

by replacing snubber MSH-252 with a spare snubber. The inspector. reviewed

work request number 40789 which documented replacement of snubber MSH-252

with an operable snubber. The inspector also reviewed the snubber _' instal-

lation procedure which was revised to ensure that. proper snubber orientation

would be maintained after snubber installation.

I~

'9. 'Previously Identified Inspector Followup Items (IFI)

a. (Closed) IFI 302/83-16-02, Perform a 100% Visual Inspection of Safety-

Related Snubbers After Four Months, but Within Ten Months of Commencing

Power Operation. As discussed in paragraph 6.c above, the inspector

reviewed the records documenting the visual inspect' ion of the snubbers

performed after four months, but within ten months of commencing power

operations, following the 1983 refueling outage. IFI 302/83-16-02 is

closed.

b. (Closed) IFI 302/84-26-06, Review Progress With Respect To Snubber End

Bushing Problems Identified In IE Information Notice 84-73. IEN 84-73,

Down Rating of Self-Aligning Ball Bushing Used. in Snubbers, reports a

problem found during testing of large bore snubber from the H. B. Robinson

plant. - After this problem was, identified, Paul Monroe Energy Products,- i

the firm who is the technical repr?sentative for Anker-Holth/McDowell-

Wellman Hydraulic Snubber (type installed at Crystal River), identified

a potential problem with the 32- large bore snubbers installed on the

four reactor coolant snubbers in a letter to the. licensee dated August' 10, .

There are four sizes of large bore snubbers (1000, 1200,

'

1984.

1600 and 2000 kip) installed on .each pump. After further analysis,

Paul Monroe issued a revised letter dated October 18, 1984, to the

licensee stating that a potential problem existed with only the 2000

kip snubbers, and that this did not involve the radial _ bearings

-(bushings), but rather the rod end clevis which contains the bearings.

The licensee's design engineering group performed an analysis in

accordance with AISC guidelines. The results of this analysis

-disclosed that the ' structural integrity of the snubber rod end clevis

would be maintained when loaded to design capacity. The inspector

reviewed Florida Power Interoffice memo number WPN 84-0898, dated

November 13, 1984, which documents the results of this analysis. IFI

'302/84-26-06 is closed.