View source for 3F0387-05, Revises Response to Violations Noted in Insp Rept 50-302/86-39.Temporary Mod T86-06-20-01 Re Temp Hot Channel C Removed.Util Confirmed That Procedure Used to Develop MAR Adequately Addressed Need to Document Refs

{{Adams
| number = ML20207R605
| issue date = 03/12/1987
| title = Revises Response to Violations Noted in Insp Rept 50-302/86-39.Temporary Mod T86-06-20-01 Re Temp Hot Channel C Removed.Util Confirmed That Procedure Used to Develop MAR Adequately Addressed Need to Document Refs
| author name = Widell R
| author affiliation = FLORIDA POWER CORP.
| addressee name = 
| addressee affiliation = NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
| docket = 05000302
| license number = 
| contact person = 
| document report number = 3F0387-05, 3F387-5, NUDOCS 8703170437
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 4
}}

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           %O Florida Power C O R PO R ATIO N March 12, 1987 3F0387-05 Document Control Desk U.S. Nuclear Regulatory Commission Washington, DC 20555

==Subject:==
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 NRC Inspection Report No. 86-39

==Dear Sir:==

Florida Power Corporation provides the attached as our response to the subject inspection report.
Sincerely, t
Rol    C. Widell Manager, Nuclear Operations Licensing and Fuel Management AEF/feb Attachment xc: Dr. J. Nelson Grace Regional Administrator, Region II Mr. T. F. Stetka Senior Resident Inspector 1703170437 870312                                                                                                   f PDR       ADOCK 05000302                                                                                               /
G                     PDR                                                                                            II I GENERAL OFFICE: 3201 Thl.;/ fourth Street South
* P.O. Box 14042
* St. Petersburg, Florida 33733 *
(813) 866-5151 A Florida Progress Company

(3F0387-05)
FLORIDA POWER CORPORATION REVISED RESPONSE INSPECTION REPORT 86-39 VIOLATION 86-39-01 10 CFR 50.59 states that the holder of a license may make changes in the facility, as described in the safety analysis report, without prior Commission approval unless the change involves an unreviewed safety question. Also, the licensee's accepted quality assurance (QA) program (FSAR Section 1.7 Table 1.3) commits to Regulatory Guide 1.33, Quality Assurance Program Requirements (Operations), which endorses ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants. Section 5.2.19.3 of this standard requires that testing shall be performed following plant modifications to confirm that the modification produces expected resul ts .
: a. Contrary to the above, the licensee modified the "C"      temperature hot channel of the reactor protection system by removing a manufacturer's installed ground.       The modification was performed under T-MAR T86-06-20-01 and work request 80209. The manufacturer's ground had to be reinstalled during system surveillance testing to determine the proper trip setting for the reactor trip temperature bistable.         The removal of this ground was not adequately evaluated to ensure this method of system operation does not involve an unreviewed safety question.
: b. Contrary to the above, af ter the temporary modification, T86-06-20-01, was installed, the "C" temperature hot channel was not tested in that surveillance procedure SP-110 was not completed af ter troubleshooting and then modifying the channel.
This is a Severity Level IV violation (Supplement I).

===RESPONSE===
Florida Power Corporation's Position
: a. Florida Power Corporation agrees Temporary MAR T86-06-20-01 involved a violation of 10 CFR 50.59.           The violation did not result from an inadequate safety evaluation as stated in the subject report.         Rather the violation resul ted from a failure to document in the MAR package all references used in the development of the modification.         The information needed to perfonn the safety evaluation was available and was used by the design engineer who prepared the MAR.      However, the individuals contacted by the inspector were unaware of the location of this information.
: b. FPC agrees' that SP-110 was not completed af ter troubleshooting and then modifying the channel . SP-110 would not have verified operability of the "C"    temperature hot channel, however, FPC agrees no other testing was documented immediately af ter installation to verify operability.

(3F0387-05)
While troubleshooting under work request 80547, it was determined a                                               '
circuit ground existed on one of the resistance temperature device (RTD) wires at the RTD's termination enclosure on the RCS piping.                                               SP-112, Calibration of the Reactor Protection System, was performed for the verification                         of                    RPS   temperature   reliability.       This    checked satisfactorily.                                         It was also determined lifting the ground wire at the output of the linear bridge would temporarily alleviate the effects of the 1          inadvertent ground at the RTD enclosure.                                        Resistance values used in SP-112 were loaded into the circuit to prove the lifted ground wire would not affect the normal operation of the T-Hot circuits; but would change the operation of the temperature test circuit due to its dependence upon a circuit ground for certain operations while in the test mode.
Due to the fact the circuitry was proven to function properly under work request 805*7 and the performance of sections of SP-112 demonstrated the ground has no affect under normal circuit operation, further testing of the circuitry was not documented when T-MAR 86-06-20-01 was installed.
However, the technician verified the operability by channel comparison and l          operability was also confi rmed each shift thereafter through routine operations channel checks.
Apparent Cause of the Violation
: a. The cause of this violation is personnel error.                                         The engineer performing the design modification failed to document all references used in the evaluation,
: b. The cause appears to be lack of a reference to a specific post maintenance test that should have been performed af ter the installation.
Corrective Actions
: a. The temporary modification has been removed.                                             It was confirmed the procedure used to develop the MAR adequately addressed the need to document references.
: b. A memo was issued to all maintenance planners and supervisors to remind them to include in work packages specific steps or sections within procedures, or identify any other criteria that should be met, in order to clearly specify what post maintenance testing is required.
Date of Full Compliance
: a. Full compliance was achieved on December 1, 1986, when the temporary modification was removed,
: b. Full   compliance was achieved upon                                         issuance of the above mentioned memorandum, December 2, 1986, 2

r (3F0387-05)
Action Taken To Prevent Recurrence
: a. A memo was issued to all Nuclear Engineering personnel reminding them of the need to properly document all references used in the development of a modification.
: b. A program is being developed to improve post maintenance testing.         This program should be implemented by October 1987.
DEVIATION 86-39-02 The Crystal River Unit 3 FSAR Section 11.4.1 radiation monitoring design basis, states that the radiation monitoring system measures radioactivity at selected plant locations in order to verify compliance with 10 CFR 20.
The spent fuel cooling water monitor RM-L4 is provided to detect any radioactivity released in the spent fuel storage area.
Contrary to the above FSAR commitment, temporary modification, T-MAR 79-08-78, removed RM-L4 from service on September 5, 1979, and is still out of service. The T-MAR also states that until RM-L4 is relocated, it is inoperative.

===RESPONSE===
Corrective Actions T-MAR 79-08-78 will be made a permanent modification.        This will provide for an adequate 50.59 review and in turn indicate the need to change the FSAR.
The FSAR will be revised to delete RM-L4.
Date of Full Compliance Full compliance will be achieved on or before July 1,1967 when the 1987 CR-3 FSAR update is submitted.
Corrective Action to Prevent Recurrence In addition to the deletion of the high radiation annunciator alarm point, the ratemeter module detector, preamplifier, and recorder channel will also be removed, thus rendering the RM-L4 channel non-existent. FSAR will also be revised to reflect this change.       The current 50.59 review process includes steps that identify the need for FSAR changes.
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