IR 05000302/1982020
| ML20027E453 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/01/1982 |
| From: | Belisle G, Fredrickson P, Jackson L, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20027E443 | List: |
| References | |
| 50-302-82-20, NUDOCS 8211150334 | |
| Download: ML20027E453 (12) | |
Text
.
.
.
.
- gtmeroq'o UNITED STATES NUCLEAR REGULATORY COMMISSION 8"
3, REGION ll
3 g 101 MARIETTA ST., N.W., SUITE 3100
ATLANTA. GEoAGIA 30303
\\...../
,
l Report No. 50-302/82-20 Licensee:
Florida Power Corporation 320134th Street, South St. Petersburg, FL 33733 Facility Name:
Crystal River 3 Docket No. 50-302 License No. DPR-72 Inspection at Crystal River site near Crystal River, Florida, and at the Corporate Offices in St Petersburg, Florida Inspectors: [
(/
wr
h/M G
BelisFU Dhte / Signed RTM~
d/Fu P. 'E. Fredri kson Dfat6 Signed
~
W whw 9A/2L L. H'. Jpson Date Signed
~
Approved by:
'C.M. Upright /Kct19ffChief ffate/ Signed Engineering I,Mpect4'on Branch Division of Engineering and Technical Programs l
SUMMARY l
!
Inspection on August 9-16, 1982 Areas Inspected This routine, unannoun.:ed inspection involved 108 inspector-hours on site in the areas of licensee actior, on previous enforcement matters, QA program review, audits, organization and administration, onsite review committee, design changes, calibration, surveillance, maintenance, records, and licensee action on previ-ously identified inspection findings.
Results Of the 11 areas inspected, no violations or deviations were identified in eight areas; three apparent violations were found in three areas (Failure to perform l
post-maintenance testing, paragraph 12; Failure to distribute audits within l
required timeframe, paragraph 6; and Failure to meet Plant Review Committee quorum requirements, paragraph 8).
8211150334 821025
~
PDR ADOCK 05000302 G
!
_,
._
.
.
,
,
.
REPORT DETAILS 1.
Persons Contacted Licensee Employees
- G. Boldt, Technical Services Superintendent
- D. Breedlove, DC/RM Supervisor
- D. Brock, Nuclear Maintenance Supervisor
- C. Brown, Compliance Supervisor
- J. Cooper, Jr., NQA/QC Manager J. Cuneo, Training Supervisor B. Griffin, Senior Vice President Engineering and Construction
- B. Herbert, NTSC
- E. Howard, Director Site Nuclear Operations
- M. Harmon, Administration Manager
- B. Komara, Nuclear Compliance Auditor I
- D. Kurtz, Supervisor Quality Audit
- K. Lancaster, Senior Quality A;ditor
- T. Lutkehaus, Nuclear Plant Manager
- S. Mansfield, Nuclear Compliance Auditor JU. Telford, Director Quality Programs Department
- K. Wilson, Licensing Specialist Other licensee employees contacted included technicians, mechanics, security force members, and office personnel.
NRC Resident Inspector
- B. Smith
- Attended exit interview at site on August 13, 1982
- Attended exit interview at Corporate Offices on August 16, 1982 2.
Exit Interview The inspection scope and findings were summarized on August 13 and August 16, 1982, with those persons indicated in paragraph 1 above. The
licensee was informed of the inspection findings listed below. The licensee acknowledged the inspection findings.
-
Violation 302/82-20-01, Failure to perform post-maintenance testing, paragraph 12.
-
Violation 302/82-20-02, Failure to distribute audits within required timeframe, paragraph 6.
-
Violation 302/82-20-03, Failure to meet Plant Review Committee quorum i..
requirements, paragraph 8.
<
, _
__
,, - - -
..
..
._,
,
,
.
.
-
Inspector Followup Item 302/82-20-04, Inadequate Records Storage Control and Implementation, paragraph 13.
3.
Licensee Action on Previous Enforcement Matters (92702)
a.
(Closed) Unresolved Item (302/79-04-01):
Safety-Related Consumable /
Expendable Items. The inspector reviewed Florida Power Corporation's Safety Listing.
Section 6, Consumables, states that consumables such as lubrication oil, grease, fuel oil, snubber fluid, additive chem-icals, filter element material, gaskets, nuts, bolts, etc., which are
used in safety-related components and systems are considered safety-related.
Discussions were conducted with procurement, QA/QC, engi-neering, and quality programs personnel to assure that applicable portions of the QA program are used for identification and procurement of safety-related consumable items.
b.
(Closed) Infraction (302/80-30-01): Failure To Translate Design Inputs Into Drawings.
FPC's response dated October 3,1980, is considered
I acceptable by Region II.
The inspector reviewed Plant Procedure l
CP-114, Procedure for Preparation of Permanent and Temporary Modifi-cation, Revision 34 to assure that modification approval records (MARS)
are independently controlled. Also, the procedure has been revised to require a revision to any MAR when the installation cannot be accom-plished in accordance with the MAR.
The inspector concluded that FPC had determined the full extent of the violation, performed the necessary survey and followup actions to correct the present condi-tions, and developed the -necessary corrective actions to preclude recurrence of similar violations.
Corrective actions stated in the response have been implemented.
c.
(Closed) Deficiency (302/80-30-03):
Failure To Document Review Of Procedures.
FPC's response dated October 3, 1980, is considered acceptable by Region II. The inspector reviewed QAP 2, Preparation and Control of Administrative Procedures, Revision 5, and verified that Quality Programs Administrative Procedures are required to be reviewed on a twelve-month frequency. The inspector selected several QAP's to verify that this review was being conducted and concluded that FPC had determined the full extent of the violation, performed the necessary survey and followup actions to correct the present conditions, and developed the necessary corrective actions to preclude recurrence of similar violations.
Corrective actions stated in the response have been implemented.
d.
(Closed) Violation (302/81-11-10):
Review Of Plant Review Cemmittee (PRC) Activities. FPC's reponse dated August 25, 1981, is considered acceptable by Region II. The inspector reviewed PRC meeting minutes as discussed in paragraph 8.
The inspector reviewed AI-300, Plant Review Committee Charter, Revision 19, and CP-111, Procedure for Documenting,
.
Repert!ng and Reviewing Nonconforming Operation's Reports, Revision 22,
'
and identified that responsibilities have been delineated for review of
,
.-
,,r_.- - - - -,
-
,-r
...,,, - - -
.., - -. -
-,, -. -. -
-y
---,-.-m
,,,. - - - - _, -. -..., -.,,
,,, -,, - _,
- -
'
.
.
.
.
,
violations of Technical Specifications identified by non plant staff.
A review of PRC minutes verified that this was being accomplished.
The inspector concluded that FPC had determined the full extent of the violation, performed the necessary survey and followup actions to correct the present conditions, and developed the necessary corrective actions to preclude recurrence of similar violations.
Corrective actions stated in the response have been implemented.
e.
(Closed) Violation (302/81-18-01):
Failure To Provide Health Physics
,
l Retraining For Security Personnel.
FPC's response dated October 20, 1981, is considered acceptable by Region II. The inspector held dis-cussions with Messrs. J. Culver and P. Ellsberry, Nuclear Operations Training Department, and examined corrective actions stated in the response. The inspector reviewed the scheduling of security personnel for health physics retraining and that the badging of these personnel is based on the satisfactory completion of the retraining.
The inspector concluded that FPC had determined the full extent of the violations, performed the necessary survey and followup actions to correct the present conditions, and developed the necessary corrective actions to preclude recurrence of similar violations.
Corrective actions stated in the response have been implemented.
4.
Unresolved Itr as
Unresolved items were not identified during this inspection.
5.
QA Program Review (35701)
References:
(a)
FPC Quality Manual, QPP 1.1 - QPP 18.1 (b) QAP 1, Organization and Responsibilities, Revision 4 (c) QAP 3, Writing Quality Program Policies and Quality Program Procedures, Revision 4 (d) QAP 5, Documenting Quality Program Records, Revision 0 (e) QAP 10, Vendor Evaluation Activities, Revision 6 (f) QAP 13, Verbal Approvals, Revision 1 (g) QAP 15, Audit and Review of Radiographs, Revision 2 (h) QAP 16, Indoctrination and Training of Personnel Involved in the Quality Program, Revision 2 (1) QAP 21, Quality Program Reporting, Revision 3
.
(j) QAP 27, Quality Program Trending Activities, Revision 3 The inspector reviewed references (a)-(j) and verified that they met requirements of the accepted QA Program (FSAR Section 1.7.6.7).
There have been no changes to the accepted QA Program since the last inspection in this area (IE Report 50-302/81-17). The FSAR is currently being updated as required by NRC regulations.
This updating may impact the QA program; therefore, this area will be reinspected during subseauent inspections. The inspector verified that program controls assure supervisory personnel are aware of regula:.ory commitments.
Within this area, no violations or deviations were observed.
.
,
-
-
r-
-
r nw,
.
.
,
,
6.
Audits (40702, 40704)
References:
(a) QPP 16.1, Corrective Action, Rcvision 5 (b) QPP 18.1, Quality Program Audits, Revision 6 (c) QPP 15.4, Reporting of Defects and Noncompliances, Revision 0 (d) QPP 2.1, Quality Program Implementation, Revision 5 (e) QAP 8, Quality Program Audits, Revision 4 (f) QAP 23, Reporting of Defects and Noncompliance, Revision 3 (g) QAP 6, Control of Quality Program Documentation, Revision 2 The inspector reviewed re ferences (a)-(g) and verified that they met requirements of the accepted QA Program (FSAR Section 1.7.6.7) and ANSI N45.2.12 (Draf t 4, Revision 2 - 1976) as endorsed by that program.
The inspector verified the following aspects of the audit program:
-
The scope of the audit program has been defined and is consistent with Technical Specification (TS) requirements.
-
Responsibilities have been assigned for the overall management of the audit program.
-
Methods have been defined for taking corrective actions when defi-ciencies are identified during audits.
-
Audited organizations are required to respond in writing to audit findings.
-
Distribution requirements for audit reports and corrective action responses have been defined.
-
Checklists are required to be used during performance of audits.
-
QA personnel conducting audits meet minimum education, experience, and qualification requirements for audited activities.
The inspector reviewed the qualifications of eight lead auditors.
The inspector also reviewed the results of audits conducted during 1981 and 1982 l
to verify implementation of the audit program.
The following audits were l
selected for review: QP 202-205, 207-215, 217, 219, and 224. During the review of the licensee's corrective action program, the inspector identified irregularities in the licensee's methods for closing audit findings. These irregularitiet concern the closure of audit findings within the required timeframe as specified in the audited organization's response, the unaccept-ability of the audited organization's response, the timeliness to receive an adequate response, and the intervention of FPC management to seek resolution of outstanding items. The licensee's procedures do not clearly delineate
,
L
.
-
.-
,
-., _
.
-_ - - -- -- -
-
- --
- -.
--
..
l
-
-
.
.
.
measures to assure that conditions adverse to quality are promptly corrected.
During discussions with the Director Quality Programs Department, the need for specific guidelines to assure that conditions adverse to quality are promptly corrected was clearly detailed.
The Director Quality Programs Department had been actively seeking a solution to this problem with the Senior Vice President Engineering and Construction.
Audit QP-224 conducted June 6-15, 1982, and issued July 16, 1982, identified (Finding 11) that status logs are not maintained for requests for corrective action (RCA).
There is no written guidance for disposition of overdue or inadequate responses to RCAs. The inspector reviewed the response to this audit finding and determined that although the response was generally ade-quate, a supplemental response was needed to assure that irregularities previously identified were specifically addressed. The Director Quality Programs Department stated that this additional response would be carefully reviewed.
A violation for failure to establish measures to assure that conditions adverse to quality are promptly corrected was not issued pending the total final resolution of this audit finding; however, this area will be monitored during future inspections. With resolution of this audit finding, items 15 and 16 previously identified during inspection (50-302/80-30) are closed.
The inspector was invited to discuss management involvement in the QA Program with the Senior Vice President Engineering and Construction. During this discussion, the inspector was informed by senior management that FPC was totally committed to a strong QA program and that senior management was becoming more involved in seeking resolutions to QA concerns.
Within this area, one violation was identified.
Audits QP 214, 215, and 217 were conducted September 3-16, 1981, December 16-21, 1981, and August 17-20, 1981, respectively. These audits were issued for distri-bution on October 19, 1981, January 22, 1982, and, September 23, 1981. The distribution of audit reports specified by Technical Specification 6.5.2.11 requires that audits be distributed to management within 30 days after completion of the audit. These audits were issued 33, 32, and 34 days respectively after completion of the audits.
Failure to issue audit reports within the timeframe required by TS 6.5.2.11 constitutes a violation (302/82-20-02).
7.
Organization and Administrative (36700).
Reference:
(a) Technical Specifications (b)
FSAR (c) AI-200, Organization and Administration, Revision 22 The inspector reviewed the licensee's current plant organization and identified that significant differences exist between that organization and the organization required by reference (a).
FPC has appointed a Site Director.
Reporting to the Site Director are the following positions /
activities:
Plant Manager; Nuclear Engineering; Training; and, Licensing.
Reporting to the Plant Manager are the following positions / activities:
_
. _ _ _ _ _ _ _ -
_ - -
-
.
.
.
Assistant Nuclear Plant Manager; Modifications, fcchnical Services; Operations; Maintenance; Chemi stry and Radiation Control; QA/QC; and, Security.
Discussions with the Site Director identified that the organization previously identified was transitory and future changes were being developed. The changes would be of such a nature to increase overall personnel effectiveness.
Organizational changes have also been conducted in the Quality Programs
' Department. A new Director Quality Program Department has been appointed and the Supervisor Quality Audits, Supervisor Materials Technology, and Manager QA Engineering and Surveillance report to this position.
The inspector reviewed the qualifications of 30 plant personnel in super-visory and nonsupervisory positions and verified they met requirements of Technical Specifications.
The following is a partial listing of those positions:
Document Control / Records Management Supervisor Nuclear Shift Supervisor Nuclear Operations Engineer Nuclear Operations Technical Advisor Chief Nuclear Operator Nuclear Maintenance Superintendent Nuclear Planning Coordinator Nuclear Technical Services Superintendent Chemistry and Waste Manager Assistant Nuclear Plant Manager Nuclear QA/QC Compliance Manager Nuclear Compliance Supervisor The inspector discussed organizational changes with plant licensing and was informed that conversations have been held between the licensee and the NRC relative to these reorganizational changes.
These discussions have been ongoing since the first quarter of 1982.
Within this area, no violations or deviations were observed.
8.
Onsite Review Committee (40700)
References:
(a) Technical Specifications (b) AI-300, Plant Review Committee Charter, Revision 19 The inspector verified that reference (b) met requirements of reference (a).
The inspector reviewed Plant Review Committee (PRC) minutes 81-22 through 81-26, 81-28 through 81-39, 81-45 through 81-51, 82-01 through 82-06, and 82-27 through 82-30.
The inspector verified that PRC membership require-ments, meeting frequency, qualifications of several members, and review process were in accordance with reference (a).
'
.
.
,
Within this area one violation was identified.
PRC meetings 81-24 (conducted 0900 on June 25,1981), 81-26 (conducted 1500 - July 8,1981) and 81-39 (conducted 1400 on October 6, 1981) were. conducted with four members present.
This is contrary to Technical Specification 6.5.1.5.,
which requires a quorum of five members.
Failure to meet quorum requirements required by Technical Specifications is identified as a violation (302/
82-20-03).
9.
Design Changes and Modification Program (37700, 37702)
References:
(a) CP-114, Procedure for Preparation of Permanent and Temporary Modifications, Revision 34 (b) CP-113, Procedure for Handling and Controlling Work Requests, Revision 31 (c) CP-115, In-Plant Equipment Clearance and Switching Orders, Revision 37 (d) OPP-3.1, Control of Activities Affecting Design, Revision 5 (e) OPP-11.1, Control of Test Activities, Revision 5 (f) 3 REP-1, Safety Identification and Design Input Require-ments, Revision 4 (g) SREP-2, Design Development, Revision 2 (h) SREP-3, Interface Design Control, Revision 2 (i) SREP-5, Document Approval and Control, Revision 2 (j) SREP-6, Preparation and Control of a Modification Approval Record, Revision 2 (k) SREP-7, Design Auditing, Revision 3 (1) SREP-8, Corrective Action, Revision 1 (m) SREP-9, Control of Records Retention, Revision 1 The inspector reviewed the licensee's procedures for conducting design changes and the design change and modification program and verified appro-priate requirements for:
initiatf or, review, and approvals; unreviewed safety question examination; fire pNtection; controlling design interfaces; controlling changes to design documents and plant procedures; and post-modification acceptance testing.
The following safety-related design changes were reviewed to verify implementation of these requirements.
!
MAR 81-05-28, Relocate CAV-1, 3, 4, 5 and 126 MAR 80-07-65, Replace RCP Pin MAR 81-03-62a, Provide HPI and LPI Redundant Flow Indicator MAR 80-06-73, Modify Reactor Head Cable Access Platform.
Within this area, no violations or deviations were identifie <
,
,
'
.
.
.
10. Calibration (56700)
References:
(a) CP-107, Test Equipment, Standards and Calibration Control, Revision 16 (b) Test Equipment List (Computer Printout)
Utilizing the licensee's calibration program as described in references (a)
and (b). the inspector verified that selected instruments and measuring and test equipment (M&TE) had received calibration according tc the following criteria:
-
For completed calibrations, the documentation was complete, acceptance criteria met, proper revision used, and calibration conducted by qualified individuals.
-
For calibration procedures, reviews are as required by Technical Specifications, controls are established to meet limiting conditions for operation, equipment is returned to service, calibration equipment is traceable, and acceptance values are within required limits.
-
For M&TE, equipment is controlled by site procedures, calibration frequency-is maintained, storage of equipment is proper, and accuracy is traceable to the National Bureau of Standards or other independent testing organizations.
The inspector determined that implementation of several program areas had previously been reviewed by the NRC resident inspectors.
Discussions with the residents identified that a review of the M&TE program implementation had not specifically been conducted. Consequently, the inspector selected several torque wrenches, micrometers, and electronic test instruments and verified that the required calibration controls had been imposed.
Within this area, no violations or deviations were observed.
11. Surveillance (61700)
References:
(a) Technical Specifications (c) SP-443, Master Surveillance Plan, Revision 50 Utilizing the licensee's surveillance program described in references (a)
and (b), the inspector verified that selected plant surveillances met the following required criteria:
"
-
Technical Specification surveillances were covered by approved proce-dures which contained appropriate prerequisites, acceptance criteria, and instructions to insure that systems or components are restored to operation following testin '
'.
-
.
,
,
-
Completed surveillance tests had been reviewed in accordance with facility administrative requirements, were performed within the required frequencies, were properly handled when tested items failed acceptance criteria, and were performed by qualified individuals.
The inspector determined that implementation of several program areas had previously been reviewed by the NRC resident inspectors.
The inspet. tor reviewed the system whereby Technical Specification requirements are inte-grated into surveillance procedures and verified that the licensee has a documented cross-reference index between the surveillance requirements and the surveillance procedures.
Within this area, no violations or deviations were observed.
12. Maintenance (62700)
References:
(a) CP-113, Procedure for Handling and Controlling Work Requests, Revision 31 (b) CP-115, In-Plant Equipment Clearance and Switching Orders, Revision 37 (c) SP-370, Quarterly Cycling of Valves, Revision 13 (d) SP-435, Valve Testing During Cold Shutdown, Revision 5 The inspector reviewed the licensee's procedures for conducting maintenance and subsequent testing required as a result of maintenance which is described in references (a) through (d). The inspector selected fourteen work requests and verified the following:
that valves are being tested; stroke times are being met; procedures are being complied with; acceptance criteria are being met; and, documentation is complete. Each we equest involved corrective maintenance on primary containment isolat
,gives.
Reference (a) paragraph 5.3.6 requires the Shift Supervisor.. issure post-maintenance testing of nuclear safety-related equipment.
He then initials the work request in Part III, Post-Maintenance Test block, after the word " accept."
Work request number 30995 involved maintenance of valve SWV-110 which was not able to be opened remotely from the contol room on February 24, 1982.
The work performed was listed as " valve plug unstuck from seat. Functional checked three times from remote and four times from control room."
The post-maintenance test block on the work request was initialed as accept-able; however, a stroke time test of the valve was not performed after maintenance as required by Technical Specification 4.6.3.1.1.
Failure to stroke time the valve is identified as a violation (302/82-20-01).
!
l
-, -
_. -
r
,
,
.
.
13.
Records (39701)
Reference:
Doc. Cont./ Rec. Mgmt. Procedure Number 15, Revision 0 Based on a violation identified in NRC inspection report 302/82-15, the inspector reviewed the physical storage of quality records in both the
" Rusty Building" and the " Blue Building."
In addition to the temperature and humidity control problems in the " Blue Building" identified in this report, the inspector noted that this facility also did not meet other requirements from ANSI N45.2.9-1974, which the licensee has committed to through the accepted QA Program. The Program commits to NRC Regulatory Guide 1.88, which endorses this Standard.
Paragraph 5.6 of ANSI N45.2.9 describes the requirements for the storage facility.
This paragraph requires an adequate fire protection system and limits the number of vault penetrations.
The Blue Building vault has no automatic fire extinguisher system and contains a window-type air conditioning unit, which, in itself presents a fire hazard.
A review of the Rusty Building vault revealed records boxes stacked on the floor, which is contrary to the shelving requirements of paragraph 5.4 of ANSI N45.2.9. After the storage inspection the inspector reviewed records control procedures; specifically. the reference to determine the licensee's precedural implementation of the records handling requirements addressed in the accepted QA Program.
The reference described several aspects of ANSI N45.2.9, but did not address the problem area requirements identified by the inspector. The problem appears to be programmatic, with no detailed plant or corporate procedure which implements the accepted QA Program commitment in the record storage area.
NRC Inspection Report 302/82-15 identified an example of this problem for the storage of radiograph type records.
In that the problem identified during this inspection is very similar to the previous unanswered violation, an additional violation is not issued for the remaining portion of this records problem. The licensee committed to respond to the overall records cor. trol problem in response to the violation identified in NRC Inspection Report 302/82-15.
For tracking purposes, this area is identified as an inspector followup item (302/82-20-04).
14.
Licensee Action On Previously Identified Inspection Findings (92701)
a.
(Closed) Inspector Followup Item (302/77-23-04):
Certificate of Contormance for Quality Purchased Chemicals.
The inspector reviewed several purchase orders and verified that chemical specifications, specifically maximum chloride content, had been addressed on the purchase order and certified by the supplier, b.
(Closed) Inspector Followup Item (302/80-30-15): Escalation of Delayed or Unsatisfactory Response to Quality Progam Audits.
This item is discussed in paragraph 6.
c.
(Closed) Inspector Followup Item (352/80-30-16):
Management of the Audit Program. This item is discussed in paragraph 6.
.
,.
.
.
.
d.
(Closed) Inspector Followup Item (302/80-30-17): Engineering Review of MARS (QP-159-5). The inspector reviewed QP-159, finding 5, and plant actions to resolve this item. This item was closed December 18, 1980, by the licensee's audit review process.
,
l l
l