ML20236M467
| ML20236M467 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 11/09/1987 |
| From: | Eric Simpson FLORIDA POWER CORP. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| 3F1187-07, 3F1187-7, NUDOCS 8711130136 | |
| Download: ML20236M467 (6) | |
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- Florida Power I
C OR PO R ATIO N November 9, 1987 3F1187-07 U. S. Nuclear Regulatory Commission Attn: Document Control Desk Washington, D. C.
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Subject:
Crystal River Unit 3 Docket No. 50-302 Operating License No. DPR-72 Inspection Report 87-17 Revised Response 87-17-05 and 87-17-07
Dear Sir:
Florida Power Corporation provides the attached revised response-to NRC Inspection Report 87-17, Violations 87-17-05 and 87-17-07.
This response also contains the additional response requested at Inspection Exit for Report 87-31.
Should there be any questions, please contact this office.
Sincerely, E. C. Simpson Director Nuclear Operations Site Support WLR/sjm Attachment cc: Dr. J. Nelson Grace Regional Administrator, Region II Mr. T. F. Stetka Senior Resident Inspector
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A Florida Progress Company
VIOLATION 87-17-05 C.
TS 4.0.5.b requires the performance of IST of ASME Code Class 1, 2, and 3 pumps and valves in accordance with Section XI of the ASME " Boiler and l
Pressure Vessel Code' pursuant to the requirements of 10 CFR 50, Section 50.55a(g).
In letters dated June 4, 1982, June 14, 1983, July 1, 1985, and October 22, 1985, the NRC directed the licensee to implement their proposed IST program pursuant to the requirements of 10 CFR 50.55a(g).
Contrary to the above, as of July 9, 1987, the proposed IST program was not properly implemented in that two pumps and thirty valves identified in the program as requiring testing were not being tested.
In addition, NRC Inspection exit 87-31 identified that two check valves in the diesel fuel system (DFV-28 and DFV-36) were dropped from FPC's drawing and Inservice Testing Program (IST).
This is a Severity level IV Violation (Supplement I).
RESPONSE
FLORIDA POWER CORPORATION'S POSITION Florida Power Corporation accepts the violation.
APPARENT _QLUSE OF VIOLATION It appears that this deficiency has existed in the program since the submittal in 1982 and has been substantiated by our review process updating to the second ten year interval program. The omissions appear to have been caused by an inadequate review of the program commitment for implementation by FPC Procedures.
87-31. - It appears the drawing in the manufacturers spare parts catalog, thet indicates a check valve is installed, is incorrect.
CORRECTIVE ACTION An extensive review to determine the extent of FPC's deficiencies for compliance to its submitted program (to meet the 1974 code) is being performed.
Upon completion of this review, FPC will take the necessary actions to conform to its submitted program.
The appropriate procedures will be updated and the identified pumps and valves will be tested prior to or during start-up from Refuel VI.
Allowed changes to the program (those not warranting relief requests) may be made.
87 The fuel line in question was disassembled for inspection.
No check j
valves were at the location for DFV-28 and DFV-36.
(There are check valves further downstream).
FPC's drawing and IST program are currently correct for l
these valves.
A letter has been sent to the manufacturer to request that they l
evaluate FPC's system against the original design to ensure it is installed properly and performing its intended function.
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DATE OF FULL COMPLIANCE The identified discrepancies will be tested or otherwise resolved prior to or during start-up from Refuel VI.
ACTION TAKEN TO PREVENT RECURRENCE The entire pump and Valve program is being reviewed as a part of updating from the 1974 edition of Section XI to the 1983 edition.
Each identified pump and valve will be scrutinized to determine in which procedure it should be included.
The program document and the procedures will be reviewed to assure they are in agreement.
This will be done as a separate evolution to the l
update revision now in progress.
The Pump and Valve Program has also been developed into a computerized data base.
Under this system, errors of this type will become obvious and can be prevented.
In addition, every valve in the ASME Class 1, 2, & 3 boundaries is being checked for code category confirmation or recategorization in accordance with the requirements of the 1983 edition of ASME Section XI.
87 Further corrective action will be determined upon results of the vendor's evaluation.
VIOLATION 87-17-07 E.
TS 6.10.2.h requires records of ISI performed pursuant to the TS be retained for the duration of the Facility Operating License.
Contrary to the above, as of July 8, 1987, records delineating hydrostatic testing boundaries for ISI tests performed in the 1980 Outage #3 and the 1983 Outage #5 were not retained.
As a result, the adequacy of four hydrostatic tests performed in the 1980 Outage #3 could not be determined.
(Finding 1)
Additional findings from Inspection Report 87-26:
Findina 2: Records do not indicate valve DHV-91 was open (Valve position
'NA") part of hydro boundary could have been excluded if this valve was closed. Adequacy of hydrostatic test uncertain.
Iindina 3:
Instrument lines between valves BSV-46 and BSV-47, records do not indicate position of valves. Adequacy of hydrostatic test uncertain.
Findina 4: Records for ASME Class 3 piping do not indicate position of in-line valves, position of pump, gages, and recorded leaks do not preclude portions of the system from being isolated to hydro pressure.
Adequacy of test uncertain.
Fir.dina_1: Records for service water Class 3 piping do not indicate position of in-line valves.
position of pump, gages, and recorded leaks do not preclude portions of the system from being isolated to hydro pressure.
Adequacy of test uncertain.
Findino 6:
Position of in-line valves BSV-99 and BSV-100 were not identified. Adequacy of test cannot be verified.
Findina 7:
Position of in-line valves were not identified.
Position of pump, gages, and record leaks do not preclude portions of system from being isolated from test.
Adequacy of test uncertain.
Findina 8:, sheet 1 to SP-210, " Data and Approval Sheet" Item 4 entry for hydro pump attachment location have been marked through, signed and dated.
However, no new entry was made (records complete).
This is a Severity Level IV Violation (Supplement I).
RESP 0ESE FLORIDA POWER CORPORATION'S POSITION Florida Power Corporation accepts the violation.
APPARENT CAUSE OF VIOLATION i
There exists at Crystal River Unit 3 a generic problem with hydrotest boundary documentation as required by MP-137, System Hydrostatic Pressure Testing.
A review of hydros related to MAR packages has revealed the same deficiency in documentation.
As a result of these findings an in-depth review of all safety-related hydrotests is being performed.
The available information indicates that the records are missing due to the procedural requirement of attaching marked-up drawings to the procedure for transmittal to quality files.
CORRECTIVE ACTION 1.
A review of all 1980 and 1983 hydros revealed that of the 31 tests performed in those two years, four were cited as having insufficient records and therefore no credit can be taken for the performance of these tests.
The four tests noted in the citation, all occurred in 1980.
The tests are:
a.
BS System, BS Pump 1B Discharge Piping; b.
Nuclear Services Closed Cycle Cooling (SW) System, SW lines to Air Handling Heat Exchanger (AHHE) 31 and 328 (penetration 370 and 371);
c.
SW System, SW to Reactor Coolant Pump (RCP) 1C Bearing and Seal Cooler (penetration 325 and 326); and, i
d.
SW System, SW to RCP-1B Bearing and Seal Cooler (penetration 364 and 365).
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i Two of these items (b and d) were reperformed in 1985 and sufficiently documented.
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.The BS pump 1B' discharge piping will be repeated in Refuel VI.
-l The SW pipe to RCP-1C will be repeated.in Refuel VI, 2.
The segment of pipe between DHV-91 and RCV-53 does not require a hydrostatic ' test, per ASME Section XI, 1980 Edition and Engineering Question EQ-87-1370, 3.
This itea is still being reviewed.
-4.
Based on an indepth review of this test, portions of the'SW System will be retested 'during. Refuel VI under the following. work requests:
- 88094, 88095, 94355 - 94357,. 93739, 95208, 95209, 95211 - 95215, 95391'- 95397.
5.
The portion of this system that cannot be verified will be tested during.
Refuel VI under work request #93732.
l 6.
Based on an in-depth review of this test, sufficient evidence exists to I
-indicate the. position of BSV-99 and BSV-100' as being open.
No retest is required.'
7.
Based on an in-depth review of this test, sufficient evidence exists for the proper valves. positions, and the piping effected has been properly identified. No retest is required.
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8.
Based on an in-depth review of this test, although the identification of l
" hydro pump" attachment is not clear (a nitrogen bottle was used),
sufficient evidence exists to indicate that the entire test was performed satisfactorily. No retest is required.
DATE OF FULL COMPLIANCE Full compliance will be, achieved prior to implementation of the second ten-year ISI Program.
ACTIONS TAKEN TO PREVENT RECURRENCE In 1985 crtensive changes were implemented in the method of documenting the hydro testing.
This occurred when the ISI section promulgated and issued procedure SP-210 for the ISI. hydros.
This revision should prevent future
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' documentation problems.
These same changes in documentation requirements - have been implemented into MP-133, Systemi Pneumatic pressure Testing and MP-137, System Hydrostatic Pressure Testing.
I In addition to' the above, an independent in-depth programmatic review of all safety-related hydrotests is being performed by a contract organization.
FPC is also documenting, through its Nonconforming Operations Reports (NCOR) other
,nonconformances as they are identified by the contract team.
To date, LER
'87-18 has been submitted as a result of this evaluation.
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I A review of hydros associated with plant modifications (MARS) ' and work I
requests is.in progress and will be completed by December 1, 1987 j.
SUPPLEMMEL MGERTIGE l
The following are' additional code violations identified-as' a result of this i
extensive review:
- 1. ~ In 1980, hydros were performed that did not comply with the 1974 edition' of Section XI as required - by Technical Specifications and
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Title 10 of. the Code of Federal Regulations.
The deficiencies 1
i included - violation of the pressure hold time requirement and test temperature. These were' generic deficiencies in the program.
There were. additional specific failures to properly document - test boundaries and application of incorrect test pressure.
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2.
In 1983, a relief request was submitted to perform hydros in accordance with the 1977 edition of Section XI.
The relief request i
l was implemented prior to its approval in violation of Technical i
i Specifications.
These were again specific failures in boundary documentation and test pressures.
3.
A standard operating procedure for the 1985 Refuel V outage led to some tests having valves within the test - boundary to be in test position but undocumented.
The 1985 hydros were controlled by Safety Clearances.
Due to ALARA concerns, valves within the test boundary j
that were not moved from their " normal" position.were not tagged. The position of each was verified by the test supervisor during the set-up
.for the test, but was not a specific sign-off step.
Thus, the position of some valves in the main process lines is not documented.
Upon conclusion of the contractor's review, those hydros determined not to have sufficient evidence of being properly. performed will be re-hydroed.
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