IR 05000302/1978008

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IE Insp Rept 50-302/78-08 on 780403-06.Noncompliance Noted: Improper Storage Facility for QA Records & Failure to Follow Procedures Re Design Changes & Mods
ML19317G255
Person / Time
Site: Crystal River Duke Energy icon.png
Issue date: 04/22/1978
From: Bradford W, Kellogg P, Skolds J
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML19317G235 List:
References
50-302-78-08, 50-302-78-8, NUDOCS 8002280882
Download: ML19317G255 (8)


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  • SM "8h UNITED STATES

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NUCLEAR REGULATORY COMMISSION y

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Report No.:

50-302/78-08

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Docket No.:

50-302

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License No.:

DPR-72 Licensee:

Florida Power Corporation i

P. O. Box 14042, Mail Drop C-4 St. Petersburg, Florida 33733

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Facility Name:

Crystal River 3 Inspection at:

Crystal River 3 Site, Crystal River, Florida

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Inspection conducted: April 3-6, 1978 Inspectors:

W. H. Bradford J. L. Skolds Acco:panying Personnel:

P. J.

11ogg Approved by:

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N ear Support Section No. 2 Reactor Operations and Nuclear Support Branch Inspection Summary Inspection on 4/3-6/78: (Report No. 50-302/78-08)

Areas Inspected:

Routine, unannounced inspection of Quality Assurance Program review; document control and record storage; design, design changes and modifications; and general plant operations which included fuel movements during defueling operation.

The inspection involved 54 inspector-hours by two NRC inspectors.

Results:

In the four areas inspected no items of noncompliance or deviations were identified in 2 areas; two apparent items of noncompliance (deficiency - improper storage facility for QA records Details I, paragraph 6; infraction - failure to follow procedure ancerning design changes and modifications, Details II, paragraph 5).

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RII Rpt. No. 50-302/78-08 I-1 DETAILS I Prepared by:D.

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W.H.~Bradford,geactorInspector

/ D/te Nuclear Support 4ection No. 2-i

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Reactor Operations and Nuclear i

Support Branch Dates of Inspection: Ap 1978 s

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Reviewed by:

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Nuclear Support Section No. 2 Reactor Operations and Nuclear Support Branch 1.

Individuals contacted

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Florida Power Corporation G. P. Beatty, Jr., Nuclear Plant Manager

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  • P. F. McKee, Technical Services Superintendent
  • T. C. Luckehaus, Performance Engineer Supervisor
  • J. Cooper, Compliance Engineer

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  • G. M. Williams, Compliance Plant Engineer
  • P. D. Breedlove, Office Manager C. G. Goering, Compliance Engineer

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  • G. L. Clarr, Compliance Auditor Arnold Reeder, Shift Supervisor Hoyt Koon, Electrical Supervisor Jack Nelson, Instrumentation and Control
  • J. R. Wright, Radiation Control and Chemistry Supervisor
  • Denotes those present at exit int.erview.

2.

Licensee Action on Previous Inspection Findings

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Closed - Unresolved Item 77-21-02 t

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This unresolved item, identified in IE Report No. 50-302/77-21 pertains to record storage and accountability.

The inspector reviewed certain records and documents, and held discussions with

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the licensee to verify controls had been established to insure that

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there was a method for record accountability.

This item is considered closed.

3.

Unresolved Items None identified during this inspection.

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RII Rpt. No. 50-302/78-08 I-2 I

4.

Exit Interview

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The inspector met with licensee representatives (denoted in paragraph 1)

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at the conclusion of the inspection on April 6, 1978.

The inspector summarized the scope and findings of the inspection.

5.

Quality Assurance Program Review The inspector reviewed the licensee's QA program to determine whether recent changes to the program were in conformance with Appendix B to 10 CFR 50, as well as applicable codes, standards,

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guides and licensee cour itments. Within the areas inspected, no l

items of noncompliance or deviations were disclosed.

l The Florida Power Corporation Quality Assurance Program changes over the past year consisted of revisions to reflect organizational

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changes and responsibilities, provide reference updates and to include 10 CFR 21 evaluations and reporting requirements.

The inspector had no further questions.

6.

Document control and Records

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The inspecree examined the licensee's records to verify that the control, storage, retention, and retrieval of records and documents was in conformance with Section 6.10 of the Technical Specification, Regulatory Guide 1.88, Section 7 and 18 of ANSI N45.2-1971, ANSI N45.2.9-1974, and Criterion V, VI and XVII of Appendix B to 10 CFR 50, as Laplemented by section 1.7.6.7.1(Q) of the FSAR.

Within the areas inspected, one item of noncompliance was identified.

Criterion XVII of Appendix B to 10 CFR 50 as implemented by Section 1.76 (Florida Power Corporation Quality Manual, approved by the NRC on May 31, 1977) of the FSAR, requires that completed Quality Assurance records be retained and stored in adequate facilities in accordance with ANSI N45.2.9-1974, which states in part that " permanent i

and temporary record storage facilities shall be so constructed to protect the contents from possible d'mirwetion by fire and should

be afforded the equivalent protecF cn of MFPA Class A, four hour

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rated facility." Contrary to tFO g.+ove, en April 4,1978, certain QA records which consisted of 4 1 a.

4: operating records for 1977 r

and a portion of the plant opegating recorde for 1978 were stored in a temporary record storage vault vhich.hei two doors which had fire ratings of 1 1/2 hour each.

O This is a deficiency. (78-08-01)

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RII Rpt. Nc2 50-302/78-08 I-3

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8.

Fire Prevention and Protection The inspector reviewed certain Administrative Procedures, Surveillance Procedures, Maintenance Procedures, held discussions with the

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licensee, and toured certain portions of the plant to determine the status of the fire prevention and protection system.

No items of noncompliance or deviations were observed.

The fire inspection was not completed during this inspection.

This inspection will be continued at a later date.

9.

Plant Tour The inspector toured varicus areas of the plant to observe the following:

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Plant cleanliness b.

Fuel inspection in the Fuel Storage Building

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Operating activities in the Reactor Building c.

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Fire detection and fire protection systems in various portions of the plant which included the control room, cable spreading room and auxiliary building.

No items of noncompliance or deviations were found.

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RII Rpt. No. 50-302/78-08 II-1

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s DETAILS II Prepared by:-

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J. L. Skolds, Reactor Inspector Date Nuclear Support Section No. 2

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Reactor Operations and Nuclear Support Branch Dates of Inspection:

r 3-6, 1978 Reviewed by:

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f.,A.Kellogg7 Chief f

/ Dacd Nuclear Support Section No. 2 Reactor Operations and Nuclear Support Branch 1.

Persons Contacted Florida Power Corporation

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G. P. Beatty, Jr., Nuclear Plant Manager

  • P. F. McKee, Technical Services Superintendent
  • J. Cooper, Compliance Engineer
  • G. M. Williams, Compliance Plant Engineer
  • P. D. Breedlove, Office Manager

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C. G. Goering, Compliance Engineer

  • G.

L. Claar, Compliance Auditor Hoyt Koon, Electrical Supervisor Arnold Reeder, Shift Supervisor

  • Denotes those present at the exit interview.

2.

Licensee Action on Previous Inspection Findings Unresolved Item (Open) Jumper Controls (77-18/I-2)

The licensee revised CP-114 (Procedure for Control of Permanent Modifications, Temporary Modifications and Deviations) and issued Revision 11, dated March 2, 1978.

This revision was in response to comments made in RII Report No. 50-302/78-04, Details I, paragraph 2.

The inspector reviewed the revised CP-ll4, the control room jumper log and interviewed the Operations Supervisor.

Revision 11 to CP-ll4 adequately responded to the comments made in RII Report No.

50-302/78-04.

All jumpers in the jumper log were reviewed by the Operations Department to assure conformance to Revision 9 to CP-ll4.

However, Revision 9 jumper control log sheets were still being used by Operations personnel even though Revision 11 was in effect since s_

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March 2, 1978.

Unresolved Item 77-18/I-2 remains open.

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RII Rpt. No. 50-302/78-08 II-2

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3.

Unresolved Items U resolved items are matters about which more information is required

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i-order to ascertain whether they are acceptable items, items of noncompliance or deviations.

An unresolved item disclosed during the inspection is discussed in Paragraph 5.

4.

Exit Interview The inspector met with licensee representatives (denoted in paragraph 1)

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at the conclusion of the inspection on April 6, 1978; the inspector swanarized the scope and findings of the inspection.

5.

Design, Design Changes and Modifications The inspector reviewed documentation and interviewed personnel

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concerning design changes and modifications to determine conformance to 10 CFR 50.59 as implemented by Compliance Procedure 114 (CP-ll4).

The documentation reviewed included the Modification Approval Record (MAR), the Modification Safety Evaluation, the associate work requests, testing instructions and results.

System drawings were checked to ensure they had been updated.

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CP-ll4 Section 3.2.1 requires the Technical Support Engineer a.

to perform a safety review of the MAR in accordance with 10 CFR 50.59.10 CFR 50.59(b) requires that the licensee maintain records which include a written safety evaluation which provides the bases for the determination that the change, test or experiment does not involve an unreviewed safety question.

Contrary to this, the following safety-related modifications had no safety evaluation performed:

MAR No.

Title 77-1-24 DH and MU Valves 76-12-22 RC/NNI 77-2-30 DO Setpoint Change

77-2-10 Install Orifice, Nuclear Service Closed Cycle Also, numerous MARS had safety evaluations performed that did not provide the bases for the determination that an unreviewed safety question was not involved.

Examples of this problem

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include the following:

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KII Rpt. No. 50-302/78-08 II-3

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MAR No.

Title 76-12-37 Heat Trace Cable 76-11-16 Remote Meter RMG-19

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76-11-23 PPC Hydraulic Snubbers

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77-11-04 EFP Recire Orifices b.

CP-114. requires that plant drawings be updated to reflect changes to the plant as a result of the design changes and modifications.

Contrary to this the following drawings were not updated as required:

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Drawing No.

MAR No.

Title FD-302-082 77-11-04 EFP Recire Orifice

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FD-302-681 77-10-06 Flow indicator WD-139-FI

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The items noted above have been designated an infraction.

(78-08-02)

c.

ANSI 18.7-1976 Section 5.2.7 requires that maintenance or modification of equipment be preplanned and performed in

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accordance with written procedures, documented instructions or drawings appropriate to the circumstances.

The inspector noted that on numerous Work Requests (WR) associated with MARS, the work instructions were " perform per the MAR". The MAR did not in all instances provide sufficient detailed

instructions to perform the safety-related modification.

The following were examples of this problem:

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MAR No.

Title 76-12-37 Heat Trace Cable 76-11-23 PPC Hydraulic Snubbers It was noted however that on more recent MARS reviewed by the inspector, detailed work instructions were being provided in the modification package and that this problem was being j

corrected.

d.

Enclosure 1 to CP-114 (Rev. 11) is the Modification Approval Record form that is required to be used according to the

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procedure. However at the present time a different form is being used to document design changes and modifications per CP-ll4.

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The above item has been designated an Unresolved Item (77-08-03).

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Plant Tour j

The inspector toured various areas of the plant to observe the following:

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Plant Cleanliness

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b.

Fusi inspection in the Fuel Storage Building c.

Operations Activities in the Reactor Building No items of noncompliance or deviations were found.

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