ML20210A463

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-302/86-23. Supplemental Response to Violation B Requested.Assessment of Util Responses to Violations B & D Requested

ML20210A463
Person / Time
Site:	Crystal River
Issue date:	01/26/1987
From:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:	Wilgus W FLORIDA POWER CORP.
References
NUDOCS 8702060478
Download: ML20210A463 (5)

See also: IR 05000302/1986023

Text

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FloridaJ. ewer Corporation

ATTN: *Pr. W. S. Wilgus

Vice President Nuclear Operations

P. O. Box 14042, M.A.C. C-2-M

St. Petersburg, FL 33733

Gentlemen:

SUBJECT: NRC REPORT N0. 50-302/86-23

Thank you for your response of October 17, 1986, to our Notices of Violation

and Deviation, issued on September 18, 1986, concerning activities conducted at

your Crystal River facility. We have evaluated your responses and found that

they meet the requirements of 10 CFR 2.201 for Violations A and C, and for

the Deviation. We will examine the implementation of your corrective actions

during future inspections.

With respect to Violation B and D, we have concluded, for the reasons presented

in the enclosure to this letter, that the violation occurred as stated in the

Notice of Violation. Therefore, in accordance with 10 CFR 2.201, please

submit a supplemental response to the Notice of Violation for Violation B. The

corrective actions for Violation 0 appear adequate and a revised response is not

required.  !

The response directed by this letter and the enclosure are not subject to the

clearance procedures of the Office of Management and Budget issued under the

Paper Reduction Act of 1980, PL 96-511.

We appreciate your cooperation in this matter.

Sincerely,

013G5:a E- -

LNELS0:1GM;E

{g206047s870126 J. Nelson Grace

G ADOCK 0500 2 Regional Administrator

Enclosure:

Staff Assessment of Licensee Response

to Inspection Report 50-302/86-23

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VP. F. McKee, Director, Nuclear

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C. Widell, Manager, Nuclear

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RC Resident Inspector

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JAN 2 619R7

ENCLOSURE

STAFF ASSESSMENT OF LICENSEE RESPONSE

TO INSPECTION REPORT 50-302/86-23

Restatement of Violation B (86-23-03)

Technical Specification 6.8.1.a requires adherence to written procedures that

cover those activities recommended in Appendix A of Regulatory Guide 1.33,

November 1972.

Regulatory Guide 1.33, Appendix A, paragraph 1.5 recommands procedures for the

control of maintenance, repair, replacement and modification work.

Procedure CP-114, Procedure for Handling Permanent Modifications, Temporary

Modifications, Modification Revisions, Field Change Notices, and Advance Field

Change Notices, was written to meet the requirements of Regulatory Guide 1.33 and

requires, in step 3.11, the use of a Modification Approval Record (MAR) to

document the safety evaluation, review, and approval for nuclear plant

modifications.

Contrary to the above, on July 21, 1986, a physical alteration was mada on the

lube oil system for the "B" Emergency Diesel Generator (EDG-1B) without the

appropriate safety evaluation, review, and approval required for a nuclear plant

modification.

Summary of Licensee's Response

Florida Power Corporation (FPC) does not concur with the violation as stated.

The replacement of valve DLV-10 did not require a plant modification to

accommodate installation but, in fact, was due only to a manufacturer part

change. In response to a Field Problem Report, this part change and the

initial review for conformance was handled in accordance with the FPC Nuclear

Procurement and Storage Manual " Catalog" method covered under Section 6.3. This

effort revealed that the original part number had been replaced by another part

number as stated in a letter received from the manufacturer.

Procurement Engineering reviewed the new item against the original item to

determine that no design inputs for the original part were affected. This review

was documented accordingly on the " Safety-Related Procurement Requisition

Checklist." The replacement part was adequately reviewed to perform its intended

function, and a "New Part Add" was initiated to input this item into the FPC

inventory system as the replacement for the original part.

A Drawing Change Notice (DCN) has been initiated to reflect the change in part

numbers. This is also in accordance with established FPC procedural

requirements. However, prior to investigating this alleged violation, it had

been recognized that a mechanism to notify Nuclear Engineering of potential

problems, the Field Problem Report (FPR), was not a procedurally controlled

vehicle. This problem is being rectified, and the procedure for the " Preparation

and Issuing of Field Problem Reports" should be finalized by January 30, 1987.

Enclosure 2 JAN 2 6 @

NRC Evaluation

The NRC staff has carefully reviewed the licensee's response and has concluded

that the licensee did not provide any infonnation that was not already considered

in determining the violation.

The licensee stated, "that the replacement of valve DLV-10 did not require a

plant modification to accomodate installation but, in fact, was due only to a

manufacturer part change." The part change involved the replacement of DLV-10, a

three-way valve, with a pressure gauge piping assembly. This assembly included

two separate valves.

Ccmpliance Procedure CP-114, section 3.10, defines a modification as a planned

change in plant design or operation and accomplished in accordance with the

requirements and limitations of applicable codes, standards, specifications,

licenses, and predetermined safety restrictions. Additionally, the licensee's

Quality Assurance Prngram as implemented by FSAR section 1.7 complies with the

requirements of NRC Regulatory Guide 1.64, " Quality Assurance Requirements for

the Design of Nuclear Power Plants."

Regulatory Guide 1.64 endorses ANSI N45.2.11-1974. Sections 8 and 8.1 of the

standard state:

8. DESIGN CHANGE CONTROL

Documented procedures shall be provided for design changes to approved

design documents, including field changes, which assure that the

impact of the change is carefully considered, required actions

documented and information concerning the change is transmitted to all

affected persons and organizations. These changes shall be justified

and subjected tu design control measures conrensurate with those

l applied to the original design.

i 8.1 REASONS FOR CHANGES

!

l Design changes frequently result from such things as the following:

l

'

1. Qualification, preoperational, or operational test results are not

satisfactory.

2. Interference problems discovered during construction.

3. Failures of structures, systems, or components to meet functional

requirements.

4 Disposition of nonconforming items.

5. Changes in regulatory or other requirements.

6. Operational experience.

7. Design improvements.

The replacement of a three-way valve (DLV-10) for two separate valves and piping

assembly, changes the way the system is operated and was a result of a design

improvement (by the manufacturer) and/or failures of structures, systems, or

components (three-way valve) to meet functional requirements. Therefore, the

valve replacement is considered a plant modification.

l

.

Enclosure 3 JS 2 6 'E

The licensee additionally states that the new item was reviewed in accordance

with the " Safety-Related Procurement Requisition Checklist." A material

procurement review is not the same as a plant modification review. A plant

modification review takes into account the impact of the change on other systems

and ensures that other required actions are accomplished. These actions may

include, system drawing updates, procedure changes, and training of personnel on

the changes.

NRC Conclusion

For the above reasons, the violation occurred as stated.

Restatement of Violation D (86-23-02)

10 CFR Part 50, Appendix B, Criterion V as implemented by the approved Florida

Power Corporation Operational Quality Program, paragraph 1.7.1.5, requires that

procedures or drawings include adequate instructions for work affecting quality.

Contrary to the above, as of July 30, 1986, plant modification procedures (MARS

79-11-70-01 and 79-11-70-02) were inadequate in that they caused the Containment

Hydrogen Monitoring System to be installed incorrectly and failed to identify the

incorrect installation during subsequent post-installation testing.

Sumary of Licensee's Response

Florida Power Corporation agrees with the stated violation in that (a) the

Containment Hydrogen Monitoring System was installed incorrectly, and (b)

post-installation testing ' ailed to identify the incerrect installation. FPC

does not agree that plant modifications procedures (MARS 79-11-70-01 and 02) were

inadequate.

(a) Incorrect installation of the FAR appears to be a result of personnel error.

(b) There appears to be two possible reasons for failure o' the PAR Functional

Test TP-70-1 to identify the incorrect installation, neither of which can be

positively determined without bringing the plant to cold shutdown.

,

(1) Improper interpretation of a test instruction by the test engineer,

l

,

(2) Back leakage through a check valve connecting the two incorrectly

'

installed tubing runs.

Item 1 refers to step 8.5.1 of the MAR Test Procedure. The intent of this step

was to direct the valve lineup for either Channel A or Channel B Hydrogen

Analyzers. Sign-offs for each channel were in the back of the procedures. If,

inadvertently, both channel inlet / outlet valves were opened during the performance

of Step 8.5.1, a flow path to each analyzer would have existed considering the

crossed inlet procedure,

i

It should be noted that explicit instructions prohibitino simultaneous work in

i both channels were not defined in the procedure.

l

.

.

Enclosure 4

jgy 2 6 1Q97

Item 2 refers to the drain line between the inlet tubing runs. This drain line

is protected for cross flow by check valves WSV-659 and WSV-660. Backflow

through either o# these check valves would provide an inlet flow path to the

hydrogen analyzers.

Regardless of which item provided a flow path to the inlet of the hydrogen

analyzers, it must be emphasized that a flow path must have existed. Otherwise,

Section 8.6, of the test (Alarm Test) could not have been successfully performed.

(Section 8.6 verified flow through both analyzers to be 3.0 SCFH).

NRC Evaluation

The NRC staff notes that while the licensee agrees with the stated violation,

the licensee does not agree that the plant modification procedures were

inadequate. During review of the section of the licensee's response that

addresses the apparent cause of the violation, the staff notes the following

statement; "It shculd be noted that explicit instructions prohibiting

simultaneous work in both channels were not defined in the procedure...." From

this statement it appears that the licensee has identified the inadequate MAR

Functional Test procedure. If this test had been adequate, the construction

error would have been identified.

NRC Conclusion

For the above reason, the Violation occurred as stated. The corrective actions

stated in your response appear adeouate to prevent recurrence and a revised

response to this item is not required.