ML20138A360

Insp Rept 50-302/86-01 on 860106-10.Violation Noted: Inadequate Verification of Design Change to Borated Water Storage Tank

ML20138A360
Person / Time
Site:	Crystal River
Issue date:	02/26/1986
From:	Belisle G, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20138A353	List: ML20138A349 ML20138A355 ML20138A360
References
50-302-86-01, 50-302-86-1, NUDOCS 8603140208
Download: ML20138A360 (10)

See also: IR 05000302/1986001

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' UNITED STATES

[Sn at 'o NUCLEAR REGULATORY COMMISSION

'y , REGION si ,

y j 101 MARIETTA STREET,N.W.

• e ATLANTA. GEORGI A 30323

Report No.: 50-302/86-01

Licensee: Florida Power Corporation

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' 320134th Street, South

o St. Petersburg, .FL 33733

Docket No.: 50-302 License No.: DPR-72

Facility Name: _ Crystal River 3

Inspection Conducted: January 6-10, 1986

Inspector: f d / N 2. - 26- Efa

CM p . Date Signed

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Approved by: , -/ r [

G. A.' Belisle, Acting Section Chief Date Signed

Division of Reactor Safety

SUMMARY

Scope: This routine, unannounced inspection entailed 32 inspector-hours at the

site during normal duty hours, in the area of design control.

Results: One violation was identified - Inadequate Verification of Design

Change.

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8603140208 860307

PDR ADOCK 05000302

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

• P. Breedlove, Records Management Supervisor

• C. Brown, Nuclear Outage and Modifications Assistant Manager

• J. Bufe, Nuclear Compliance Specialist

• J. Cooper, Jr., Nuclear Surveillance and Modification and Approval Record

(MAR)TestSuperintendent

C. Dutcher, Nuclear Construction Supervisor

• B. Hickle, Operations Manager

G. Hildebrandt, Instrumentation and Control Engineer

• R. Jones, Nuclear Modification Specialist

C. King, Flour Field Engineer

• J. Lander, Nuclear Outage and Modifications Manager

R. Mahaley, Flour Project Engineer

• P. McKee, Plant Manager

C. Mizeu, Construction Verification Engineer

• V. Roppel, Manager, Plant Engineering and Technical Services

D. Ruzic, Construction Verification Supervisor

R. Wagner, Florida Power Corporation Plant Engineer

• K. Wilson, Supervisor, Site Nuclear Licensing

NRC Resident Inspectors

• T. Stetka, Senior Resident Inspector

fJ. Tedrow, Resident Inspector

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summarized on January 10, 1986, with

those persons indicated in paragraph 1 above. The inspector described the

areas inspected and discussed in detail the inspection findings. No

dissenting comments were received from the licensee. The licensee did not

identify as proprietary any of the materials provided to or reviewed by the

inspector during this inspection.

Violation: Inadequate Verification of Design Change, Paragraph 5.a.

Inspector Followup Item: Revision of Program Controls for Pework

Process, Paragraph 5.b.

Inspector Followup Item: Completion and Closecut of Appendix R Fire

Detection Installation, Paragraph 5.c.

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3. . 'Lidensee Action on Previous Enforcement Matters

. This subject was not addressed in the inspection.

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l 4 .' Unresolved. Items.

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Unresolved items .were not identified during the inspection.

5. Design Program (37702) ,

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References: (a) 10 CFR 50 Appendix B,' Quality Assurance Criteria for

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Nuclear Power Plants and Fuel Reprocessing Plants,

Criterion III

(b) 10 CFR 50.54(a)(1), Conditions of Licenses

i- (c) Regulatory Guide 1.64, Quality Assurance Requirements

j for the Design of Nuclear Power Plants i

. (d) ANSI N45.2.11-1974, _ Quality ~ Assurance Requirements for I

j the Design of. Nuclear Power Plants

. (e) ' Regulatory Guide 1.33, Quality Assurance Requirements i

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(f) ANSI N18.7-1976, Administrative Controls and Quality

i Assurance for' the Operational Phase of Nuclear Power

Plants-

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(g) -10 CFR Part 50.59 Changes, Tests and Experiments

!. (h) Technical Specifications Section 6.5, Review and Audit  !

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The inspector reviewed the licensee's design change program required by l

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references (a) through.(h) to. determine if these activities were conducted .

. in accordance. with regulatory ~ requirements, industry guides and standards, t

and Technical Specifications. The following criteria were used during the  !

review to assess the overall acceptability of the established program:

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~-- Procedures have been established to control design changes which  !

include. assurance that a proposed change does not involve and  ;

unreviewed safety question or a change in technical specifications as  !

required by 10 CFR-50.59.

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Procedures and responsibilities for design control. have been

' established including responsibilities and methods for conducting i

, safety evaluations.

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Administrative controls for design document control have been

established for the following:

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Controlling changes to approved design change documents

Controlling or recalling obsolete design change documents such as

revised drawings and modification procedures

Release distribution of approved design change documents

- Administrative controls and responsibilities have been established

commensurate with the time frame for implementation to assure that

design changes will be incorporated into:

Plant procedures

Operator training programs

Plant drawings to reflect implemented design changes and

modifications

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Design controls require that implementation will be in accordance with

approved procedures.

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Design controls require assigning responsibility for identifying

post-modification testing requirements and acceptance criteria in

approved test procedures and for evaluation of test results.

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Procedures assign responsibility and delineate the method for reporting

design changes to the NRC in accord:nce with 10 CFR 50.59.

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Controls require review and approval of temporary modifications in

accordance with Section 6 of the Technical Specifications and 10 CFR

50.59.

The documents listed below were reviewed to determine if these criteria had

been~ incorporated into the licensee's design change program:

Florida Power Corporation FSAR,

Section 1.7.1.3, Design Control

Section 1.7.1.16, Corrective Actions

CP-111 Documenting, Reporting, and Reviewing Nonconforming

Operations Reports, Revision 32

M0P-504 Processing of MAR Field Change Notices, Revision 2

M0P-508 Turnover of Modifications (Completed / Partial) to Nuclear

Operations, Revision 2

M0P-405 Job Completion, Walkdown, Turnover, and Nonconforming Item

Reporting, Revision 5

M0P-600 Construction Verification, Revision 3

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The . inspector randomly selected several Modification Approval Record (MAR)  !

packages and conducted a narrow: scope indepth review of the Design Change '

Program to verify procedural compliance with the accepted QA program. In 1

addition, a review for technical adequacy was conducted for the selected MAR

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packages. .The activities of the Construction Verification group during the

implementation of the' selected MAR packages were also reviewed.

The following is a listing of the MAR packages used during the above review:  !

MAR No. T84-06-05-01, Remove ES Signal to MUV-64 Valve

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MAR No. 80-09-18-01, BWST Isolation Valves Interlock

MAR No. 80-04-06-01, Condensate System Low Flow Control

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MAR.No. 81-05-33-01, Smoke Detector Placement and Location

MAR No. 77-07-01-04, Remote. Shutdown - Preoutage/ Outage Electrical

Terminations

MAR No. 82-10-19-10, Appendix R - Fire Detection Installation

.The licensee has established an enhanced design program which provides for

system /ce'nponents walkdowns prior to and during the detail design process.

i Project walkdowns are intended to establish communications between the

design office and site personnel on' a continuing basis. Topics covered as

they relate to the design efforts are as follows:

Installation

Operations.

Testing '

Inspection

Training.

Maintenance

ALARA

Other particulars associated with nuclear plant modifications.

-The enhanced design program also employs a Construction Verification group

'which ensures that completed ' design changes 'are in conformance with the

specifications, drawings, and instructions'

and associated Field Changes Notices -(FCNs)provided .

with a Verification

The Construction MAR Work Package

program was -implemented for MAR Work Packages installed during Cycle' V

refueling outage.

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Pursuant to discussions with licensee management, the inspector ' determined

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that the Construction Verification Group verified installed MAR Work

Packages. by performing appropriate construction tests, e.g. hydrostatic

testing. . Later activities of this group were confined to the review of

. completed MAR Work Package to verify the- adequacy of the' Quality Control

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(QC) inspections , and their results. . Licensee management stated that  !

< construction verification of approximately 25% of the MAR work packages

. installed during Cycle V refueling outage was performed in this manner. '

. The1 inspector reviewed the following Nonconformance Operating' Reports

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~(NCORs) to _ assess the adequacy; of corrective action for identified

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2- nonconformances:.

Factory Mutual System QA/QC Program Monitoring Report No. 85-03, dated

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6/24/85

TNCOR No.85-102, MAR Packa'ge Discrepancies,' dated 6/25/85

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NCOR No. 85-53, Welder Performance, dated 4/18/85

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s Nonconformance Operating Report'No. 85-53 identified nonconformances in ~ the' I

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welding program- in that two welders failed to follow work instructions

, , provided with the-work package. The licensee attributes the_ root cause as .;

. failure ' to follow procedure, and corrective actions were -initiated for

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disposition of the nonconformances.

' Factory Mutual System QA/QC Program Monitoring Report No.- 85-03 identified  ;

five nonconformances with the welding activities associated with MAR

, No. 82-09-22-01. Nonconforming Operating Report No.85-102 addressed the

1 findings of this report and determined that the root cause was a failure to

follow procedure. Licensee management also determined- that the findings l

i - were significant because of generic implications. The imediate impact

entry block for the NCOR was classified as unknown, with the statement that

a review of other MAR packages. may be required to assess the generic  !

i implications. .

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The inspector discussed the-status of the review of MAR packages for generic

implications with licensee management. The inspector was informed that a

i review was conducted, and- the results were satisfactory. Based on the ,

! - review of the - corrective actions listed on the NCORs, the inspector '

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determined that the corrective actions were appropriate for disposition of  ;

the nonconformances. Additionally,. copies of the NCORs were given to the i

( Engineering Branch / Materials and Processes Section for review of technical  !

' adequacy.

Nuclear .. Modification' ..and :0utage Procedure M0P-405, Paragraph 4.2.6.6,  !

assigns responsibility to the , installer for providing a preliminary

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disposition. and. obtaining resolution of an exception if the item can be  ;

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reworked in.accordance with the~ original approved. MAR, Work Package. etc.

i This occurs prior to the review and approval of the disposition by the

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cognizant Nuclear Project Manager. Additionally. if this disposition is

! . approved by the Nuclear Project Manager, because the program defines " Rework l

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Exceptions"' as dispositions of nonconformances* in accordance with an ,;

i  : approved MAR, Work Package, etc Nuclear: Operations Engineering is not 3

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provided an opportunity for review and approval of these dispositions.

Because of the above program requirements the inspector reviewed the

processing and disposition of items appearing on the Incomplete Items List

(ICIL)/ Exceptions List Log for. the selected MAR packages. The inspector

verified that nonconformances identified in approved MAR Work Packages (i.e.

design errors); and nonconformances identified before or after the Walkdown

and System Acceptance phase of the MAR Work Package, were processed as Field

. Change Notices (FCNs). Nuclear Modification and Outage Procedure M0P-504

delineates the controls applicable to the processing of FCNs. Paragraph 4.2

describes the responsibilities of Nuclear Operations Engineering for the

preparation of FCNs and for identifying FCNs that require the Plant Review

Committee's review and approval, in addition to review and acceptance by the

Nuclear Technical Specifications Coordinator.

. Based on the above review the inspector determined that the processing of

nonconformances associated with MAR packages appears to be adequately

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controlled. However, concern was expressed regarding weakness in the

program controls delineated in M0P-405, paragraph 4.2.6.6. Licensee

management concurred with the inspector's observations and stated that

M0P-405 will be revised to require the approval of Nuclear Operations

Engineering for nonconformances dispositioned via the Rework process. This

is identified as an Inspector Followup Item and is discussed later in the

report.

Modification Approval Record (MAR) No. T-84-06-05-01 involved the removal of

the Engineered Safeguard (ES) Signal to Makeup Tank Isolation Valve MUV-64.

This temporary modification (T-MAR) was made permanent by MAR

No. 84-06-05-01A. Approval for the modification was requested by licensee

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management, and approval was provided by the NRC in the following letter:

NRC letter dated August 22, 1984 to Mr. Walter S. Wilgus, Vice

President of Nuclear Operations from John F. Stolz, Chief Operating

Reactor Branch #4, Division of Licensing, Subject: Crystal River 3 -

Removal of ES Signal from Makeup Isolation. Valve MUV-64

In support of their request for the above ES actuation logic circuitry

modification the licensee made the following statement; the Makeup Tank

Isolation Valve MUV-64 will be capable of being closed by operator action in

5 minutes. Additionally, the closure of this valve within the c'.ated time

will not cause unacceptable reactor coolant baron dilution c. aring

emergencies, prior to manual isolation of the valve.

Modification Approval Record (MAR) No. 80-09-18-01, BWST Isolatici Valve

Interlock, is intended to reduce the possibility of loss of pu np si ction to

the makeup pumps, and complements MAR No. T84-06-05-01 which r: moved the ES

signal from MUV-64.

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The following is a summary functional description of MAR No. 80-09-18-01

extracted from the MAR documentation:

This MAR provides an interlock to each of the two BWST isolation valves

MUV-58 and MUV-73 which opens these valves upon receipt of a low-low

level signal from the makeup tank. This interlock ensures that water

will be available to the makeup pumps in the event of a false (single

side) ES actuation that fails to open one of the two isolation valves.

In addition, the interlock ensures that water will be available to the

makeup pumps from the BWST to reduce the emptying rate of the makeup

tank to allow time for the operator to manually close MUV-64 before the

makeup tank is drained.

To maintain the function of valve MUV-103 and MUV-112, which permits

the operator to manually fill the makeup tank with demineralized water,

the setpoint of the existing interlock for the bistable MU-14 LS2

valves will be changed from low-low level to approximately three inches

above the low-low level.

Equipment being changed:

(1) Control circuit of BWST Isolation Valve MUV-73 Train 'A'

(2) Control circuit of BWST Isolation Valve MUV-58 Train 'B'

(3) Set point of MU-14 LS2

Equipment being added to the Remote Shutdown Auxiliary Rack Train A and B:

Tag No.

Description Model No. A B

Contact Output Isolator N-2A0-L2C-R MU14 LY1-4 MU14 LY2-4

Dual Absolute Alarm N-2AP+ ALM-AR MU14 LY1-3 MU14 LY2-3

A design error was identified by the licensee in MAR No. 80-09-18-01 in that

the manual override of the low-low level interlocks to MUV-58 and MUV-73 was

omitted from the original design. Field Change Notice (FCN) No. 7A was

subsequently prepared for addition of a manual bypass switch. The inspector

discussed with Licensee Ma 3gement the system operation as modified by the

implementation of the abovt MAR to ascertain the significance of the manual

override. No written technical system description describing this mode,

i.e. Makeup Tank level low-low and MUV-58, MVV-73 open, was available for

review. ~This mode of operation is not described in the FSAR. Based on the

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system configuration and the instrument set-points, the inspector determined

that the manual override is required to provide operator capability for

closing the BWST isolation valves during operation of the makeup pumps from

the BWST. A Safety Evaluation of the significance of removing operator

capability for closing the BWST isolation valves while the makeup Tank

low-low level existed was never made. This design error is identified as a

violation and is address in paragraph 5.a of the report.

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An additional design error was identified by the licensee in MAR

No. 80-C4-06-01 Condensate System-Low. Flow Control. This system is

non-nuclear safety .related and does not provide a basis for a violation.

However, it 'is presented as an example of what the inspector perceives to be

a generic problem in the design program. The intent of the MAR is to

' provide throttling capability to valve CDV ?42, i.e. as a minimum, the

seal-in contacts of the motor operator mus be deleted to provide this

capability. The MAR was designed, checked, verified, and implemented. The

, error was discovered in the field during testing. Field Change Notice (FCN)

No. 2 was subsequently prepared to delete the seal-in contacts and change

the limit switches to enable the valve to throttle from full open to full

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close positions.

Modification ~ Approval . Record (MAR) No. 77-07-C .-04, Remote Shutdown -

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Preoutage/ Outage Electrical Terminations involved extensive field wiring of

components on the Remote Shutdown Panel. A review of this MAR Work Package

identified numerous problems encountered . in the field. Some of these

problems were attributed to errors in the Engineering Instructions prepared

, by design engineering. Because of _ the large number of nonconformances

j . identified, and which were dispositioned as FCNs, the number of FCNs

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associated with this MAR package is extraordinarily high. This is

l indicative 'to the inspector of weaknesses in the design program;

specifically the verification of design process.

l Within this area one violation and- two inspector followup items were

' identified and are describe in the following paragraphs.

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a. Inadequate Verification of Design Change

i Modification Approval Record (MAR) No. 80-09-18-01 is an extension of

MAR No. 84-06-05-01A and provides added assurance for reducing the

, possibility of loss of pump suction to the makeup pumps. This MAR

.provides an interlock to each of the two BWST isolation valves MOV-58

l and MUV-73 to open these valves upon receipt of a low-low level signal

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from the makeup tank.

I A design error was made in that a manual by-pass switch to be used for

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defeating the low-low level signals was omitted from the initial

' design. This switch is required to provide manual capability for

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closing the BWST isolation valves during the. time it takes for the

! low-low level interlocks to change state. ,

, The modification Safety Evaluation prepared for MAR No. 80-09-18-01 L

1 pursuant to 10 CFR_50.59 did not address the significance of removing

! the closing of' the BWST isolation valves from the operators control.

The. Verification Report prepared for MAR No. 80-09-18-01 indicated that

the verification method was by design review. However, this . design

review process failed to identify a deficiency in- the design. This

failure of the design control measures to provide for verifying the

adequacy. of design by prformance of design reviews is identified as

i violation 50-302/86-01-01.

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b. . Revision of Program Controls for Rework Process

The inspector expressed concerns regarding the design change program

requirements delineated in M0P-405 Paragraph 4.2.6.6. This has to do

with the disposition of ICIL and Exception Items via the Rework

. Process, without the review and approval of Nuclear Operations

Engineering. The Licensee has concurred with the inspectors concern

and has agreed to revise M0P-405 to ensure participation of Nuclear

Operations Engineering in the disposition of nonconformances via the

Rework process. Until M0P-405 has been revised to delineate the new

requirement, this is identified as Inspector Followup Item

50-302/86-01-02.

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c. Completion and Closecut of Appendix R MAR

MAR No. 82-10-19-10, Appendix R - Fire Detection Installation has been

implemented in the field. A review of this MAR Work package by the

inspector, however, identified the following documents as missing:

Cable Pull and Termination Sheets l

Anchor Bolt Installation Sheets ,

The inspector informed licensee management that since all MAR

documentation was not included in the MAR package this would be  !

identified as an Inspector Followup Item 50-302/86-01-03. L

6. Licensee Action on Previously Identified Inspection Findings (92701)

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(Closed) Inspector Followup Item 302/85-38-01: Commitments Requiring Plant

Modifications

The inspector reviewed a licensee computer printout, MAR Responsibility and

Control Report, and discussed the status of MARS initiated pursuant to (

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Appendix R recu'rements, or NUREG-0737 commitments. The licensee has t

devised a code tenich defines the status of MARS /FCNs as either in closure  !

(#6); Field complete awaiting accumulation of data (#5); or Field complete  ;

in MAR office (#4). Lower code numbers (i.e. #3 through #1) indicates the  :

MAR /FCN as being in the planning stage or the early stage of development by [

design engineering.

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A review of the above computer printout and random check of MAR Work l

Packages still in the MAR office (#4 and greater), appears to' indicate that

the majority of above MARS have been field installed and are in various '

stages of closeout. The computer printout appears to accurately assess' the i

. status for the MAR packages measured by the inspector. .

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