View source for 3F0690-18, Responds to Violations Noted in Insp Rept 50-302/90-09. Corrective Action:Temporary Lettering Placed on Index Plates for Consistency W/Previous Markings Immediately Following Discovery of Error

{{Adams
| number = ML20055C815
| issue date = 06/20/1990
| title = Responds to Violations Noted in Insp Rept 50-302/90-09. Corrective Action:Temporary Lettering Placed on Index Plates for Consistency W/Previous Markings Immediately Following Discovery of Error
| author name = Beard P
| 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 = 3F0690-18, 3F690-18, NUDOCS 9006250200
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 3
}}

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C O R POR ATION June 20, 1990 3F0690-18 m.
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         ,                                                                                                                   1 1- [.                     U. S. Nuclear Regulatory Commission l                                Attention: Document Control Desk Washington, D. C. 20555

==Subject:==
-     Crystal' River Unit 3                                                  '
Docket No.-50-302 Operating License No. DPR-72 Inspection Report 90 09                                                      :

==Dear Sir:==

L                                 Florida Power Corporation gFPC) provides the attached as our response l                                 to the subject inspec'. ion report.                                                        1 L.                                        .                                                                                  .
L                                 Should--there be any. questions, please contact this-office.
E Sincerely,                                                                               .;
            .                                                                                                               .i 1
1 N
P. M. Beard n .       [.                                                                   :
Senior Vice' President                                                                     ,
                                . Nuclear Operations fa,                               .
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7                               . Enclosure xc:      Regional: Administrator, Region II
           ~E                             Senior Resident Inspector.
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t 9006250200 900620
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PDR        ADOCK 05000302 Q                       PDC                                                              v
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POST OFFICE BOX 219
* CRYSTAL RIVER, FLORIDA 32629-0219 * (904) 563-2943 i
A Florida Progress Company

               ,                                                                                                 l FLORIDA POWER CORPORATION
                                                  -INSPECTION REPORT 90-09 REPLY TO NOTICE OF VIOLATION
                     . VIOLATION 90-09-02 Technical Specification 6.8.1 requires the implementation of written procedures for those activities. recommended in Appendix "A" of Regulatory Guide 1.33, November 1972.       Regulatory Guide 1.33 includes post modification testing procedures.
Contrary to-the above:
On April 20, 1990, Post Modification procedure TP-1, MAR Functional Test- for Reactor Building Fuel Handling Equipment Upgrade, was deficient in that the bridge and trolley index marks were not adequately tested to determine that the trolley index marks had been changed. This caused the first 2 fuel assemblies t #k removed out of sequence.
Thi    u a Severity Level IV Violation (Supplement 1).
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FLORIDA POWER CORPORATION RESPONSE Florida Power Corporation (FPC) accepts the violation.           FPC also provides clarification to a statement made in reference to the violation- that was contained in-the Inspection Report. Section 7 of the Report makes reference to          ~i MAR (Modification Approval Record) Functional Test Procedure 87-12-10-01, TP-1.
                    .-The Report states: "The bridge and trolley marks were checked in Step 7.3.3.49 of the procedure.. ."; This is misleading because Section 7.3.3 of this procedure p                     was not intended to verify the bridge and trolley index marks. This section was
                     -intended to verify the Fuel Assembly Mode Interlocks. This verification must
                    - be performed over the core to meet the necessary grapple elevation requirements.
3, The core coordinate referenced in Step 7.3.3.49 is used as a convenient location to perform this verification. The Fuel Assembly Mode Interlocks Test is not dependent on the coordinates of. the fuel grapple, only that it is over a fuel assembly in the core region, r
APPARENT CAUSE OF VIOLATI_QH There was no intent for the modification to the fuel handling mechanism to change L
L the indexing. The vendor who made the modification-deviated from the original indexing letters. The FPC engineer did not review the drawings returned from R                     the vendor for this. type of change and, therefore, did not recognize the change.          !
A review of the drawings with the vendor, after the violation.was identified,              I revealed that the change was made on vendor drawings that were submitted for another purpose. Those drawings were submitted to show new video camera mounting R                     details and were reviewed for that purpose. The index plate details were not shown on this drawing except that the beginning and ending indices, A, R,1, and L                     '15 were shown. The old indices were A, 0, 1, and 15. Because this change was t            'not intended or recognized, the MAR made no mention of replacement of the existing core Index Plates. The MAR Functional Test is performed to verify the
                    . equipment operates properly as intended by the modification. Since there was               l no intent- to modify the indexing marks, verification of the indexing was not              j i             included in the MAR Functional Test.                                                      ,
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       .1,        .-                                                                                                                     r CORRECTIVE ACTION Temporary lettering was placed on the index plates to make them consistent with previous markings immediately following the discovery of the error.         The permanent lettering was installed several days later,                                                                  ,
DATE OF FULL COMPLIANCE I
full compliance was achieved on April 20, 1990.
ACTIONS TAKEN TO PREVENT RECURRENCE The engineer involved in the incident was counselled. A memorandum will be tissued to engineering personnel describing the incident and reinforcing the L                 importance of assuring that all paperwork returned from vendors is verified L                 prior to turning over the modification for testing..
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