ML20215F299

Ack Receipt of Informing NRC of Steps Taken to Correct Violations Noted in Insp Rept 50-302/86-14. Violations a & B Occurred as Stated in Notice of Violation. Staff Assessment of Licensee Response to Violation Encl

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

to Notice of Violation

w/ encl:

- 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 y

STAFF ASSESSMENT OF: LICENSEE RESPONSE

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-TO NOTICE OF VIOLATION

' 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),

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' requires adherence to procedures that are writteri to accomplish the 18 criteria

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

1 be. completed to document'and track corrective actions.

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

y 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

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removal train (decay heat removal valve DHV-39) to open. This event was

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

! pertaining to NCOR 86-22, it was noted a contributor to the failure of DHV-39 to

i 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

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

! 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 2

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

CP-125. 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 3

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 4

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 i

performed in accordance with approved written procedures to assure I

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.

f From the review of the above specifications, the instrument cable was

i required to meet minimum standards to be censidered adequate for use in a

j nuclear instrument application.

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The work request for repairing source range instrument (NI-1) required the

following actions:

( a. Investigate reason for NI-1 swings per procedure MP-531,

{ Troubleshooting in Plant Equipment.

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b. Replace cable for circuit NI-1 with equivalent cable (MP-405),

l Enclosure 16.

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Enclosure 5

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 i

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

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connecting the cable to the detector. Additionally, the procedure required

"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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