ML20215F299
| ML20215F299 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 12/16/1986 |
| From: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | Wilgus W FLORIDA POWER CORP. |
| References | |
| NUDOCS 8612230345 | |
| Download: ML20215F299 (6) | |
See also: IR 05000302/1986014
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NEC 1 s 1986
Florid Power Corporation
ATTN: Mr. W. S. Wilgus
Vice President Nuclear Operations
P. O. Box 14042, M.A.C. C-2-M
St. Petersburg, FL 33733
Gentlemen:
SUBJECT:
REPORT NO. 50-302/86-14
Thank you for your response of August 21, 1986, to our Notice of Violation issued
on July 25, 1986, concerning activities conducted at your Crystal River facility.
After careful consideration of the basis for your denial of Violations A and B,
we have concluded for the reasons given in Enclosure 1 to this letter, that the
violations occurred as stated in the Notice of Violation. The corrective actions
in your response are acceptable and they meet the requirements of 10 CFR 2.201.
We will examine the implementation of your corrective actions during future
inspections.
We appreciate your cooperation in this matter.
Sincerely,
b\\ %.t.h
J. Nelson Grace
Regional Administrator
Enclosure:
Staff Assessment of Licensee Response
w/ encl:
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F. McKee, Director, Nuclear Plant Operations
v . C. Widell, Manager, Nuclear Operations
Licensing and Fuel Management
c w/ encl:
RC Resident Inspector
Document Control Desk
State of Florida
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DEC 16.1086
ENCLOSURE
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STAFF ASSESSMENT OF: LICENSEE RESPONSE
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' Restatement of Violation A
10 CFR Part 50, Appendix B, Criterion V, as implemented by the approved Florida
-Power Corporation Operational Quality Program, paragraph - 1.7.1.8 (1.7.1.5),
' requires adherence to procedures that are writteri to accomplish the 18 criteria
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of Appendix B.
Compliance procedure CP-125, Corrective Action Procedure, that was written to
accomplish Criterion XVI, requires that a Corrective Action Assignment (CAA) form
be. completed to document'and track corrective actions.
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Contrary to the 'above, as of June' 4,1986, a deficiency in a safety related motor
' operated val.ve (DHV-39), which was identified by the licensee on May 2, 1986, did
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not have a CAA completed -as required by procedure CP-125.
As a result, the
deficiency in DHV-39 was not corrected.
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Summary of Licensee's Response
' Florida Power Corporation agrees the torque switch setting for motor operated
valve DHV-39 was not adjusted to the proper value as reported in Licensee Even't
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Report 86-03, Supplement 1.
We do not agree this discrepancy constitutes a
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violation of Compliance Procedure CP-125, Corrective Action Procedure; however,
the violation does identify a concern that needs to be resolved.
On February 2,
1986, Crystal River Unit 3 experienced a loss of decay heat
removal flow due to failure of the pump shaft of
"B" decay heat removal pump
(DHP-18) and subsequent failure of the suction valve to the "A"
decay heat
removal train (decay heat removal valve DHV-39) to open.
This event was
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documented in accordance with Compliance Procedure CP-111, Documenting,
Reporting, and Reviewing Nonconforming Operations Reports, via issue of
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Nonconforming Operations Report (NCOR) 86-22. During the investigation performed
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pertaining to NCOR 86-22, it was noted a contributor to the failure of DHV-39 to
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open was a low torque switch setting on that valve's motor operator.
Further, it
was reported to the Nuclear Operations Technical Advisor (NOTA) assigned the NCOR
the torque switch had been reset to the proper value. CP-111 states "all actions
taken to correct conditions Adverse to Quality of CR-3 Operation. ..shall be
promptly identified and performed.
For those corrective actions that are not
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complete, the assignment, completion, tracking, and documentation of corrective
action 'shall be accomplished in accordance with CP-125, Corrective Action
Procedure." Because corrective action for the DHV-39 torque switch problem was
reported to be completed, a Corrective Action Assignment per CP-125 was not
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required and was not issued.
'During investigation of an NCOR, proper documentation of all corrective actions
is assembled and verified.
This was complete on June 24, 1986, with closure of
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- Enclosure
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DEC 10 193B
NCOR 86-22.
However, prior to completion of this action, Supplement 1 to
LER 86-03 was due to NRC (May 15, 1986) and in an attempt to provide as much
supplemental information as possible, the statement regarding resetting the
DHV-39 torque switch was included prior to complete verification.
NRC Evaluation
The licensee tracks corrective action for identified deficiencies in accordance
with procedure CP-125, Corrective Action Procedure.
This procedure requires in
step 5.1 that a CAA form be initiated for required corrective action. This form
ensures that documentation ' exists that would verify the completion of the
required action and provides a tracking means to ensure that this action will be
completed in a timely manner.
The licensee states in their response that "Because corrective action for the
DHV-39 torque switch problem was reported to be complete, a Corrective Action
Assignment was not required and was not issued." Procedure -CP-111, Documenting,
Reporting, and Reviewing Nonconforming Operations Reports, step 5.5.3.5 requires
in part that for those corrective actions identified that are not complete, the
assignment, completion, tracking, and documentation of corrective action shall-be
accomplished in accordance with procedure CP-125.
Our review of - the facts
indicates that at the time this corrective. action was reviewed by a NOTA (by way
of an interoffice speed letter), the completed action only consisted of revising
procedure MP-402.
There was no evidence that the torque switch had been reset.
Therefore-, a CAA form was required to be issued per the requirements of procedure
Based upon this review, the staff concludes that a violation did occur.
.The licensee's response adequately explains why this violation occurred and the
corrective action taken should be sufficient to focus on the root cause of the
problem and to prevent similar recurrences.
Based upon this corrective action,
no additional response for this violation is required.
Restatement of Violation B
Technical Specification 6.8.1.a
requires that procedures established as
recommended in Regulatory Guide 1.33, November 1972, be adequate for the cause.
Regulatory Guide 1.33, Section 1.3, recommends the establishment of procedures
for the repair or replacement of equipment.
Maintenance Procedures MP-405, Installing, Repair, ard Terminating Cor. trol and
Instrumentation Cables, was written to meet the requirements of Regulatory
Guide 1.32 and requires, in step 7.6.11.5 (2), that control and instrument
cables be tested for insulation resistance using a 1000 volt DC insulation
tester.
Contrary to the above, on June 3,
1986, procedure MP-405 was found to be
inadequate, in that nuclear instrumentation cable that was replaced and tested
with this procedure has a normal operating voltage of approximately 2000 volts
,DC, therefore making a 1000 volt DC test inadequate to verify proper insulation
resistance.
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Enclosure
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DEC 10 1998
Summary of Lice'nsee's Response
FPC does not agree with the alleged violation.
MP-405 was referenced on Work Request #76154 in order to implement the cable
pulling requirements (NIR-1 is an instrument cable between the out-of-core'
detector and the pre-amp for NI-I-NI). The action in question, megger testing of
the cable, was not_a requirement.
Step 7.6.11.5 says, in part, the " Instrument
cable may be megger tested." The technicians performed megger testing in order
to rule out or identify obvious cable problems prior to post maintenance testing.
Megger testing could not prove that NIR-1 was good, although it could have shown
that the cable was bad.
The post maintenance testing requirements for work performed under WR #76154 are
contained in and implemented by SP-110, Reactor Protective System Functional
Testing, and MP-201, Out-of-Core Detector Removal and Replacement.
Although FPC takes exception to the violation, it has been recognized'that MP-405
does need revision to identify the testing methods and acceptance criteria for
instrument cable, should MP-405 be used to test such cable.
MP-405 will be
revised by January 1, 1987.
NRC Evaluation
A review was conducted of the Codes and Standards, Technical Specifications, the
licensee's quality program (Final Safety Analysis Report (FSAR) Section 1.7) and
procedures associated with Work Request #76154. Additionally, an in-depth review
of the work request was conducted:
FSAR Table 1-3,
presents the Regulatory Guides and ANSI Standards
endorsed by FPC as part of its Quality Program.
The quality program
endorses *NSI N45.2.4-1972 with clarification.
ANSI N45.2.4-1972/IEEE Std 336-1971, Section 5.2.1, Electrical tests,
states in part that the following electrical tests shall be performed:
(1) Tests to ascertain circuit continuity,...(2) Tests to ascertain
proper f unctioning of systems, . . .(3) Voltage breakdown tests -on liquid
insulation, (4) Overpotential tests as specified, and (5) Insulation
resistance measurements as specified.
The clarification with regard to Section 5.2 of ANSI N45.2.4-1971
titled Tests: The requirements of Section 5.2, including subsections
5.2.1 through 5.2.3,
shall be implemented as set forth in Sections
1.7.1.3 and 11 of the Quality Program Description.
The test program
shall consider the elements outlined in this Section, where applicable,
when developing test requirements for inclusion in maintenance and
modification procedures.
In some cases, testing requirements may be
met by post-installation surveillance testing in lieu of a special
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post-installation test.
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En losure
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DEC 10 1986 -
FPC's Quality Program (FSAR Section 1.'7), Section 1.7.1.3,
states,
maintenance
or modifications which may affect
safety-related
structures, systems, or components are performed in a manner that
ensures'o ality requirements, material specifications, and inspection
requirements are met. Maintenance or modifications of safety-related
equipment are planned and performed in accordance with written
procedures, documented instructions, or drawings appropriate to the
circumstances which conform to applicable codes, standards, specifica-
tions, and criteria as clarified in-Table 1-3.
FSAR Section 1.7.1.11, Test Control, states in part, required tests are
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performed in accordance with approved written procedures to assure
compliance with design documents.
Testing activities are conducted
during the operational phase to verify the compliance of components to
design requirements.
FPC's Quality Program contains provisions which require in part that:
1.
The test program covers the required tests, including, where
appropriate, prototype qualification tests, proof tests prior .to
installation, preoperational tests, and operational tests.
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2.
Written test procedures are prepared which incorporate or
reference the requirements and acceptance limits contained in
applicable design and procurement documents.
The instrument cable in question is a triaxial nuclear instrument detector
cable,
manufactured
by
the
Brand-Rex
Company.
FPC's
procurement
specification requirements for insulation resistance, as documented by
certified test report #91298-01-01, is 40,000 Megohms /1000 f t. , and for
insulation resistance between the cable shields is 10,000 Megohms /1000 ft.
Additionally, FPC's Nuclear Plant Library Technical Manual #280, Nuclear
Detector Installation and Handling procedures, contains a data sheet for
source range detector proportional counters (including the cable).
The
specifications for the associated triaxial cable and detector include
minimum resistance, center conductor to inner shield of 10" Ohms; and
minimum resistance, inner shield to outer shield of 102' ohms.
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From the review of the above specifications, the instrument cable was
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required to meet minimum standards to be censidered adequate for use in a
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nuclear instrument application.
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The work request for repairing source range instrument (NI-1) required the
following actions:
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Investigate reason for NI-1 swings per procedure MP-531,
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Troubleshooting in Plant Equipment.
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Replace cable for circuit NI-1 with equivalent cable (MP-405),
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Enclosure 16.
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Enclosure
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c.
Run high voltage plateau in accordance with MP-201, Enclosure 5.
d.
Functional test as per SP-110, applicable sections.
The licensee states in their response that " Step 7.6.11.5 says in part; the
instrument cable may .be megger tested."
A further staff review of the
procedure step revealed that the step additionally states, " instrument cable
should be tested when circuit performance is dependent upon insulation
resistance." Since cables that supply power to and receive signals from
nuclear. instrument detectors are highly dependent upon
insulation
resistance, it appears that this type of testing is needed.
The staff
review also revealed that the procedure guidelines for conducting insulation
resistance checks did not cover the particular cable type being tested. The
procedure also lacked proper precautions and guidance for handling of
triaxial cable.
The following items were not covered adequately, cable
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minimum bend radius, proper methods to clean connectors and proper
instruction on how to terminate triaxial cable.
In general, procedure
MP-405 is inadequate for handling triaxial cable.
A review of procedure MP-201, out-of-core detector removal and replacement,
has triaxial cable precautions, but this section was not used for
connecting the cable to the detector. Additionally, the procedure required
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"after installation," insulation resistance measurements, for all cables
associated with detectors.
It even has a note to measure the resistance
associated with source range detectors from the preamplifier.
The cable
replaced was from the preamplifier to the junction box of the detector.
In addition to the inadequate cable pulling procedure, the following
additional concerns with Work Request #76154 were noted: (1) the preamplifier
and a connector were replaced under a troubleshooting procedure, contrary to
procedure MP-531,
Section
1.0,
Purpose, and Section
7,
Procedure,
(2) connectors were cleaned with ethyl alcohol when the only approved
cleaning agent is freon 11 or 12 per MP-201, step
7.3.9., and (3) the
triaxial cable was terminated per MP-405, when this procedure contains no
termination instructions for triaxial cable.
In general, the entire work request was inadequate, in that it attempted to
marry a number of pieces of procedures together without an adequate review
to determine if this action accomplished the required results while meeting
the precautions and limitations associated with replacing a triaxial source
range detector cable.
NRC Conclusion
For the above reasons, the NRC staff concludes that violations A and B occurred
as stated.
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