View source for 3F1086-12, Responds to Violations Noted in Insp Rept 50-302/86-23. Corrective Actions:Auxiliary Bldg Ventilation Exhaust Sys HEPA Filters & pre-filters Visually Inspected on 860909 & Determined to Be Satisfactory

{{Adams
| number = ML20215M824
| issue date = 10/17/1986
| title = Responds to Violations Noted in Insp Rept 50-302/86-23. Corrective Actions:Auxiliary Bldg Ventilation Exhaust Sys HEPA Filters & pre-filters Visually Inspected on 860909 & Determined to Be Satisfactory
| author name = Simpson E
| author affiliation = FLORIDA POWER CORP.
| addressee name = Grace J
| addressee affiliation = NRC OFFICE OF INSPECTION &amp; ENFORCEMENT (IE REGION II)
| docket = 05000302
| license number = 
| contact person = 
| document report number = 3F1086-12, NUDOCS 8611030330
| document type = CORRESPONDENCE-LETTERS, INCOMING CORRESPONDENCE, UTILITY TO NRC
| page count = 8
}}

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86 0CT 28 P l : 55                                              7)cp Florida Power C O i1 P O R A T I O N October 17, 1986 3F1086-12 Dr. J. Nelson Grace Regional Administrator, Region II U.S. Nuclear Regulatory Commission 101 Marietta Street N.W., Suite 2900 Atlanta, GA 30323

==Subject:==
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 NRC Inspection Report No. 86-23

==Dear Sir:==

Florida Power Corporation provides the attached as our response to the subject inspection report.
Sincerely, n
E. C. Simpson Director, Nuclear Operations Engineering and Licensing AEF/feb Attachment 8611030330 861017 PDR  ADOCK 05000302 G                 PDR GENERAL OFFICE: 3201 Thirty-fourth Street South + P.O. Box 14042 + St. Petersburg, Florida 33733 * (813) 866-5151 A Florida Progress Company

FLORIDA POWER CORPORATION

===RESPONSE===
INSPECTION REPORT 86-23 VIOLATION 83-23-05 Technical Specification 4.7.8.1.b.2 requires in part that the Auxiliary Building (AB) ventilation exhaust system be tested in accordance with the test procedures of Regulatory Guide 1.52, revision 1, July 1976.
Regulatory Guide 1.52, July 1976, Position C.S.a, requires that a visual inspection of the system be made before each test in accordance with the recomendations of section 5 of American National Standard (ANSI) N510-1975.
ANSI N510-1975 section 5 specifies a list of items to visually check and lists these items in Appendix A. Included in this list is an inspection of the system's prefilters and High Efficiency Particulate Air (HEPA) filters.
Surveillance procedure SP-187, Auxiliary Building Ventilation Exhaust System Tes ting, that was wri tten to implement the requirements of TS 4.7.8.1, requires in Step 9.2.5 that prior to commencement of in-place testing, a visual inspection of the items identified in enclosure            3, Checklist for Visual Check, will be performed. Enclosure 3 includes a visual inspection of the system's HEPA filters and prefilters.
Contrary to the above, visual inspections of the AB ventilation exhaust systems's HEPA filters were not accomplished as part of the testing conducted on July 12,1983, July 20,1985, and May 29, 1986         Visual inspection of the prefilters were not accomplished as part of the testing conducted on July 20, 1985 and May 29, 1986.
This is a Severity Level IV violation (Supplement I).

===RESPONSE===
: 1. Florida Power Corporation's Position:
Florida Power Corporation concurs with the stated violation in that a visual inspection of the Auxiliary Building ventilation exhaust system       -
HEPA filters and prefilters was not conducted on July 12,1983, July 20, 1985, and May 29, 1986.
: 2. Apparent Cause of Violation:
The cause of this violation was the application of Regulatory Guide 1.52, Rev.1, July 1976, Position C.S.a.      This paragraph reads that a visual inspection should be performed. The engineer interpreted this to apply to the step in the procedure calling out a visual inspection.
I He believed that an ALARA condition existed and therefore felt he was within his scope in not performing the visual for SP-187. He documented this in the procedure and also noted that the condition of the filters would be demonstrated as satisfactory by the successful completion of tre rest of the test.
: 3. Corrective Actions:
An evaluation was made of previous test data for July 12,1983, July 20, 1985, and May 29, 1986.      The results of each test, which checks for possible degradation of the HEPA filters and their installation, shows that the allowable acceptance criteria, of SP-187 was met, therefore it is concluded that the HEPA filters were not damaged or leaking.
The Auxiliary Building Ventilation Exhaust ' System HEPA filters and pre-filters were visually inspected on September 9,1986, in accordance with Enclosure 3 of SP-187, and were determined to be satisfactory.
: 4. Date of Full Compliance:
Full compliance was achieved on September 9,         1986, when a visual inspection was performed.
: 5. Action Taken to Prevent Recurrence:
Current engineering personnel involved in perfonning surveillance procedures will be briefed on the importance of following procedures and on the process to be followed when a step cannot be completed as stated.
A note will be added to SP-187, Step 9.2.5 which will state that this step implements a Technical Specification requirement.
VIOLATION 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 I.5 recommends 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 made 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.
This is a Severity Level IV violation, (Supplement I).

===RESPONSE===
: 1. Florida Power Corporation's Position Florida Power Corporation 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 alledged 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.
VIOLATION 86-23-08 Technical                 Specification 3.9.11 requires all the missile shields to be
            - installed over the Spent Fuel                          Pool   (SFP) whenever   fuel handling operations are not in progress.
Drawing S-521-116,                    Spent Fuel     Pi t Missile Shielding,    recuires    each missile shield panel to be installed with four bolts.
Contrary to the above, during the period of January 17, 1986 through July 21, 1986, twenty of the thirty-two SFP missile shields were not installed with the required four bolts.
This is a Severity Level IV violation, (Supplement I).

===RESPONSE===
: 1.               Florida Power Corporation's Position:
Florida Power Corporation (FPC) agrees with the stated violation in that during the period of January 17, 1986, through July 21, 1986, twenty of j                              the thirty-two SFP missile shields were not installed with the required four bolts.
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: 2.              Apparent Cause of Violation:
SP-434, Fuel Storage Pool Missile Shields, was inadequate in that it did not require installation of four bolts for each shield.
: 3.               Corrective Actions:
i The required number of bolts were installed in the missile shields.
: 4.              Date Full Compliance:
Full compliance was achieved on October 14, 1986, when the bolts were verified to be installed on the missile shields.
: 5.              Action Taken to Prevent Recurrence:
I                                           SP-434 was revised on August 28, 1986 to require that all four bolts are placed on each shield.
VIOLATION 86-23-02 10 CFR Part 50, Appendix B, Criterion V as implemented by the approved Florida Power Corporation Operational Quali ty 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 Moni toring system to be installed incorrectly and              f ailed to identi fy the incorrect installation                                                                during subsequent i                           post-installation testing.
This is a Severity Level IV violation (Supplement I).
RESPONSE                                                                                                                                             ,
: 1.              Florida Power Corporation's Position:
4 Florida Power Corporation (FPC) agrees with the stated violation in that
.                                           (a) the Containment Hydrogen Monitoring System was installed incorrectly, I
and (b) post-installation testing failed to identi fy the incorrect installation.                                       FPC does not agree that plant modifications procedures (MARS 79-11-70-01 and 02) were inadequate.
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: 2. Apparent Cause of Violation:
(a)    Incorrect installation of the MAR appears to be a resul t of personnel error.
(b) There appears to be two possible reasons for failure of the MAR Functional Test TP-70-1 to identi fy 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.
: 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. Signoffs for each channel were in the back of the procedure.       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 tubing.
It should be noted that explicit instructions prohibiting simultaneous work in both channels were not defined in the procedure.
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 of 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.)
: 3. Corrective Actions:
(a) The piping for the Containment Hydrogen Monitoring Sys tem was reinstalled correctly.
(b) Corrective actions include final determination of the cause of the test failure. This will require a test to re-create a valve lineup where backflow through the suspected check valve can be detected.
This test will be performed during the next cold shutdown of sufficient duration or prior to start-up from the next refueling outage, whichever comes first.
The hydrogen analyzer inlet / outlet valves are containment isolation valves, that are not within the plant's Engineered Safeguards Actuation System. Technical Specifications only allow these valves to be opened with the plant in Modes 5 or 6. This prevents conduct of this test during operation.
: 4. Date of Full Compliance:
(a) Full compliance was achieved on July 31, 1986, when the Containment Hydrogen Monitoring System was re-installed correctly.
(b) Testing will be performed prior to start-up from the next refueling outage which is scheduled to begin in September 1987.
: 5. Actions Taken to Prevent Recurrence:
(a) The nuclear outage and modification craf t personnel are now oriented through a training program with emphasis on first-hand experience gained through actual performance of assigned duties. This training process should help prevent a recurrence of an inadequate installation.
(b) The results of system testing and the investigation into the cause of the initial test failure will detennine if further corrective actions are required.
DEVIATION 86-23-01 A letter to the Nuclear Regulatory Commission from Florida Power Corporation dated August 13, 1985, responded to violation 85-26-01 identified in NRC Inspection Report 50-302/85-26 and stated the following as part of the corrective actions and as part of the actions taken to prevent recurrence:
        -     The procedure for ASME Classes 2 and 3 hydrostatic testing (SP-210) was revised to include"...signoffs to verify the correct rig is included";
and,
        -     "The clearance order form will be revised to state that a copy of the clearance order must be present at the work area."
The response indicated that the first action had already been completed and that the second action would be completed by October 31, 1985.
Contrary to the above, as of July 24, 1986, these actions had not been completed .

===RESPONSE===
Corrective Actions:
A revised response concerning violation 85-26-01 was issued on September 5, 1986, to reflect the proper response to that violation.
Date of Full Compliance:
Full compliance was achieved on September 5,1986, with the submittal of the revised response to violation 85-26-01.

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Actions Taken to Prevent Recurrence:
The Nuclear Compliance Department will verify completion of corrective actions associated with NRC violations and deviations. In addi tion, the Nuclear Conpliance Department will verify that committed corr 1ctive actions are completed as specified in the response.}}