IR 05000302/1985038
| ML20137Z761 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 09/26/1985 |
| From: | Belisle G, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20137Z724 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-1.D.1, TASK-1.D.2, TASK-2.F.2, TASK-TM 50-302-85-38, GL-81-14, NUDOCS 8510080363 | |
| Download: ML20137Z761 (11) | |
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De M00 UNITED STATES J[\\ -
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REGION 11 h ', (,
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101 MARIETTA STREET, N.W.
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September 27, 1985 c
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Report No.-
50-302/85-38 Licensee:
Florida Power Corporation 3201 34th Street, South St. Petersburg, FL 33733 Docket No.:
50-302 License No.
OPR-72 Facility Name: Crystal River 3 Inspection Conducted: A,ugust 26-30, 1985
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Inspector:
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C. F. Smith
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Ba'te Signed Accompanying Personnel:
M. A. Scott, Region II A /he2c c
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Approved by:
G. A. Belisle, Acting Section Chief Date Signed Division of Reactor Safety SUMMARY Scope: This routine, unannour.ced inspection entailed 65 inspector-hours on site in the area of licensee commitment tracking of regulatory requirements.
Results: No violations or deviations were identified.
8510080363 850927 PDR ADOCK 05000302 O
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REPORT DETAILS 1.
Persons Contacted Licensee Employees J. Alberti, Manager, Site Nuclear Operations Technical Services
- F. Bailey, Manager, Nuclear Operations Modifications K. Baker, Assistant to the Manager, Nuclear Operations Engineering D. Bates, Senior Nuclear Quality Assurance Engineer D. Betts, Supervisor, Quality Audits R. Bright, Manager, Nuclear Licensing J. Bufe, Nuclear Compliance Specialist A. Clemmons, Nuclear Compliance Specialist J. Colby, Manager, Site Nuclear Engineering D. Green, Site Nuclear Licensing Specialist
- L. Hill, Manager, Site Nuclear Services E. Howard, Director, Site Nuclear Operations
- K. Lancaster, Manager, Site Nuclear Quality Assurance W. Johnson, Plant Engineering Superintendent R. Jones, Plant Modifications Specialist
- B. Komara, Nuclear Quality Control Supervisor
- P. McKee, Plant Manager
"S. Powell, Senior Nuclear Licensing Engineer
- V. Roppel, Manager, Plant Engineering and Technical Services
- W. Rossfeld, Nuclear Compliance Manager G. Westafer, Manager, Nuclear Licensing and Fuel Management C. Westbrook, Licensing Technician R. Widell, Manager, Nuclear Operations Engineering K. Wilson, Supervisor, Site Nuclear Licensing Other licensee employees contacted included engineers, technicians, and office personnel.
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NRC Resident Inspector
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Tedrow
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on August 30, 1985, with those persons indicated in paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection findings listed below. The licensee acknowledged the following inspection finding:
Inspector Followup Item:
Commitments Requiring Plant Modifications, paragraph (
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The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
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Licensee Action on Previous Enforcement Matters (92702)
(0 pen) Unresolved Item 50-302/85-15-05: Commitment Tracking. The inspector reviewed licensee corrective actions concerning commitment tracking.
This unresolved item was identified on May 17, 1985, in Region II Inspection Report 50-302/85-15. Because the violations in the report were in the QPD area, the unresolved item was found on NTTS; although the item was written with regard to other site functions. Subsections a and c of the unresolved item can be considered closed while subsections b and d remain open.
Subsection a is closed based on FPC informally notifying Region II of the high pressure valve change out schedule.
Subsection c is closed based on Region II Inspection Report 50-302/80-25, paragraph 12.b, findings, Subsection b is still being tracked by QPD as an audit finding. Subsection d remains open pending further NRC investigation.
Abbreviations used in this report are as follows:
CTS Compliance Tracking System (Computer)
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FPC Florida Power Corporation IE Inspection and Enforcement
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LER Licensee Event Report MAR Modification Approval Records NCSG Nuclear Compliance Staff Guidance NL Nuclear Licensing NOCS Nuclear Operations Commitment System (computer)
N0 CTS Nuclear Operations Commitment Tracking System (computer)
N00 Nuclear Operations Directive NRC Nuclear Regulatory Commission NTTS Noncompliance Tracking / Trending System (computer)
QA Quality Assurance QAP Quality Programs Administrative Procedure QC Quality Control QPD Quality Programs Department QPDR Quality Program Deficiency Report 4.
Regulatory and Corrective Action Commitment Tracking System (92706)
Site References:
QAP-27 Noncompliance Tracking / Trending System (NTTS), Revision 4 QAP-37 Interfacing the Nuclear Operations Commitment System, Revision 1 N00-03 Reporting Requirements Program, Revision 2 N00-09 Processing of Nuclear Operations Commitment System Correspondence, Revision 0
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N00-10 Nuclear Operations Commitment Tracking System, Revision 0 NL-02 Nuclear Licensing Verification and Validation Program, Revision 0 NL-03 Processing of NRC Correspondence, Revision 3 NL-09 Nuclear Licensing Commitment Tracking, Revision 2 CP-125 Corrective Action Procedure, Revision 4 NCSG No. 25 Handling of Action Items (Nuclear Compliance Staff Guidelines), ef fective date: March 19, 1985 a.
General The inspectors examined FPC regulatory and corrective action commitment tracking systems.
The previously identified unresolved item discussed in Region II Inspection Report 50-302/85-15 and findings of FPC generated QPDRs were reviewed during this inspection. QPDRs (85-QAS-002 to 046) which were generated in the first quarter of this year dealt with training commitments.
The computer-based tracking systems used by FPC follow many types of site generated documents.
The following identifies computer programs and responsible FPC groups:
CTS Compliance NOCS Compliance NOCTS Licensing NTTS QPD NOCS tracks programmatic commitments driven by regulatory requirements to which FPC is committed and is administratively controlled by QAP-37 and N00-09.
NOCTS contains commitments that were made by FPC to the NRC or established through FPC management direction and is administratively controlled by N00-10.
CTS is extracted data from NOCS, NOCTS, and other sources used to provide action status to all site departments and is administratively controlled by NCSG No. 25. NTTS contains accumulated data on noncompliances to regulatory requirements and is administratively controlled by QAP-27.
NOCS, NOCTS, and NTTS share common software and hardware, however, similar data in the three programs is entered and extracted by the controlling groups separately; a separate program that could sort the three programs for common elements has been discussed by FPC personnel.
Each group that controlled a program was responsible for maintaining their own data base.
Other groups such as modifications and operations training were responsible for the validity of the data they provided to the program controlling groups. Site personnel have proposed a procedure that would define the interface between the complianco and licensing groups as to NOCS program input responsibilities, i
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The inspector interviewed Tera Corporation and corporate QA audit personnel about tracking systems.
The Tera Corporation personnel generated the original data base for NOCS.
Personnel interviewed did not identi fy c.ny substantial problems with the programs.
The inspector reviewed the following selected samples of the programs' data bases:
Common corrective actions / elements between NTTS to CTS and to NOCS, and NGCS to NOCTS Known programmatic elements of the regulatory requirement base NRC IE Notices, Generic Letters, and non-enforcement items of inspection reports The corrective action status and satisfactory corrective action completion or extension.
Different on-site groups sometimes input aspects of the same commitment into their separate tracking systems. When this was identified, the inspectors reviewed the input for commitment similarity.
Within this area, no violations or deviations were identified.
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Commitments Requiring Plant Modifications As previously discussed. NOCTS is used to track either regulatory require-ments or FPC commitments which specify defined activity performance to ensure they have been either performed, completed, or responded to.
This system is controlled and monitored by the Nuclear Operations Licensing Department to assure all NRC commitments are met.
Procedure N00-10 delineates administrative controls applicable to NOCTS. Paragraphs V.C and 0 state requirements for implementing activity verification by personnel having responsibility for the implementing activity in addition to providing status assessments of implementing activity.
The Lead Licensing Engineer performs a verification check to additionally assure FPC compliance.
NL-02 states in part that the nuclear licensing verification and validation program assures that NRC commitments made by or mandated to FPC are properly interpreted and effectively implemented by the required due date.
The following are two commitment category types that are included in this program:
Commitments requiring major plant modifications Commitments requiring corrective action Other reference procedures state in part that major plant modification projects assigned to lead licensing engineers are required to be entered into the NOCTS data base to document verification and validation reviews.
This review assures total compliance with the commitment. The following is
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a listing of the reviews included in the verification and validation process:
Item To Be Reviewed Purpose Results of Study Verification of Commitment Conceptual Design Verification of Commitment Final Design Verification of Commitment All Applicable Field Change Verification of Commitment Notices (FCN's)
Functional Test Procedure Verification of Commitment Functional Test Results Validation of Commitment The inspector performed a NOCTS review to verify compliance with licensee commitments concerning plant modifications initiated by 10 CFR 50 Appendix R requirements.
The following NOCTS MAR status was reviewed to veri fy compliance with licensee commitments:
MAR No.
Title 77-07-01-01 Remote Shutdown Room Enclosure 77-07-01-02A Remote Shutdown Preoutage Conduit Installation 77-07-01-03A Remote Shutdown Preoutage Cable Pull 77-07-01-04 Remote Shutdown Preoutage Terminations 77-07-01-05 Reactor Building Cable and Conduit 77-07-01-06 Remote Shutdown Outage Final Terminations 77-07-01-07 Remote Shutdown Panel Foundations 77-07-01-08 Remote Shutdown Raceway Interference Resolution 77-07-01-10 Remote Shutdown NNI Modification 77-07-01-11 Remote Shutdown - Atmospheric Dump Valve Controls 77-07-01-12 Remote Shutdown - Source Range Monitor 77-07-01-13 Remote Shutdown - PORV Relay Relocation 77-07-01-14 Remote Shutdown - Diesel Generator Control Isolation 77-07-01-15 Remote Shutdown - Office Demolition Elevation 134'
82-10-19-03 App. "R" - MVP-18 Junction Device 82-10-19-04 App. "R" - Tray and Conduit Protection 82-10-19-05 App. "R" - MCC & Distribution Panel Load 82-10-19-06 App. "R" - Relay Relocation and Isolation Fuses
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82-10-19-07 App. "R" - Rewire Solenoids and M0V Indicating Lights 82-10-19-08 App. "R" - Fusible Links 82-10-19-09 App. "R" - Dedicated Control Complex HVAC 82-10-19-10 App. "R" - Fire Detection Installation 82-10-19-11 App. "R" - EFP-1 Enclosure 82-10-19-12 App. "R" - RW-SW Pump Separation
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MAR No.
Title 82-10-19-13 App. "R" - MVP Room and MOV Enclosures 82-10-19-14 App. "R" - Upgrade Auxiliary Building 82-10-19-15 App. "R" - Upgrade Control Complex Areas 82-10-19-16 App. "R" - Control Complex HVAC Vertical Shaft Enclosure 82-10-19-17 App. "R" - Control Room Circuit Isolation 82-10-19-18 App. "R" - Radiant Energy Shields, Cancelled -
August Update 82-10-19-20 App. "R" - FS Water Tie In 82-10-19-21 App. "R" - Sprinkler Installation 82-10-19-22 App. "R" - Emergency Lighting 82-10-19-23 App. "R" - Containment Electrical Protection 82-10-19-24 App. "R" - Valve Circuit Protection 82-10-19-26 MCC & DP Conduit Supports (82-10-19-05) Added November 16, 1984 Pursuant to a review of the NOCTS computer printouts sheets, the inspector determined that the data base was not fully representative of the plant modifications prepared as a
result of Appendix R requirements.
Additionally, the status of the plant modifications could not be determined from the information provided by the N0 CTS. Licensee, management stated that the verification and validation program was never fully implemented.
Consequently, entries into the NOCTS data base for Appendix R plant modifications were put on " HOLD".
Licensee management further stated that Appendix R commitments were met ia the design change program which ensured the implementation of plant changes mandated by Appendix R requirements.
The inspector reviewed correspondence between Nuclear Licensing and the Nuclear Modifications Supervisor to verify the adequacy of the information transmitted concerning completion and closecut of Appendix R plant modifications.
The following documents were reviewed in connection with this effort:
FPC Interof fice Correspondence dated August 8,1985, from E. M. Good, Senior Nuclear Licensing 'ngineer to Mike Jones, Subject:
Crystal River 3, Nuclear Licensing MAR Completion Verification FPC Interoffice Correspondence dated August 30, 1985, from F. R. Bailey to E. M. Good, Subject:
Crystal River Unit 3, Nuclear Licensing MAR Completion Verification.
Information transmitted to Nuclear Licensing from the Nuclear Modifications Supervisor consisted of attachments with columns for entries of MAR identification number, Field Installed date, Functional Test Complete date, and Training Complete date.
Of the 162 modifications listed, adequate information was provided to verify completion of approximately 20 percent, either check marks or missing date entries were shown for the remainding plant modifications.
The inspector conducted interviews with the Nuclear
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Modifications Supervisor and his staff.
At the inspector's request, they presented the following additioral QA Records Transmittal forms for Appendix R modifications:
MAR NUMBER Status 82-10-19-03 Complete 82-10-19-04 Partial 82-10-19-05 Complete 82-10-19-06 Complete 82-10-19-07 Complete 82-10-19-08 Not identified 82-10-19-10 Not identified 82-10-19-11 Not identified 82-10-19-13 Not identified 82-10-19-14 Partial
.82-10-19-16 Not identified 82-10-19-17 Not identified 82-10-19-20 Complete 82-10-19-21 Complete 82-10-19-22 Complete 82-10-19-23 Not identified.
82-10-19-24 Not identified 82-10-19-26 Complete The following Appendix R modifications transmittal forms were not available from the list provided by the Modifications Supervisor; however, a search was in process to find these transmittal forms:
82-10-19-09 82-10-19-12 82-10-19-15 82-10-19-18 (shown cancelled on Refuel V MAR List)
An inspector followup item was identified based on this review and is discussed in a later paragraph.
The inspector reviewed the NOCTS computer printout sheets to determine the status of selected NUREG 0737 commitments other than training or LERs.
Entries were identified for the commitments selec.ed. However, for the most part, the status of the commitments were shown as incomplete by having no entry in the " Complete Date" field. Licensee management attributed this to a lack of maintenance of the data base caused by failing to provide entries of completion dates for commitments that have been closed out.
The following is a listing, not intended to be all inclusive, of commitments reviewed in this area:
Commitment No. V0039 Statement of Commitment: Verification of NUREG 0737 I.D.1 Control Room Design Reviews
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Implementation to start July 1,1985. All displays (including alarms)
and controls added to the control room as a result of the TMI Action plan requirements for reactor coolant system vents will be considered in the human factors analysis required by NUREG-0737, Item I.D.1,
" Control Room Design Reviews".
Commitment No. 04342 Statement of Commitment:
Per NRC Letter 8/19/82, FPC made the following EFW commitment:
Emergency Feedwater program to include NUREG-0737, Item II.3.1.2., IREP, Generic Letter 81-14:
N) Tech Spec for the EFS will be submitted at least 90 days prior to the implementation of EFIC (scheduled for refuel V).
Commitment No. V0064 Statement of Commitment:
Verification of NUREG 0737 II.F.2 instrumentation for detection of inadequate core cooling a.
Analysis:
Complete evaluation by 02/15/84 b.
Design applicability to be determined on corppletion of analysis.
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Pre-operational testing applicability to be determined on completion of analysis.
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Operational testing applicability to be determined on completion of analysis, i.
Calibration applicability to be determined on completion of analysis.
Commitment No:
V0038 Statement of commitment:
In the letter of April 15,1983 (3F0483-12)
to NRC, FPC committed to install a safety parameter display system (SFDS) per NUREG-0737, Item I.D 2.
FPC also committed to develop procedures which describe the timely and correct safety status assessment when the SPOS is not available. Operators will also be trained to respond to accident conditions both with and without the SPOS.
FPC committed to start engineering by 9/1/83; procurement by 12/1/82; completion target dates of these activities were cited as 8/27/84 and 12/26/84, respectively.
The target date for starting installation / training is 8/31/84, with a completion target date of 7/1/85. FPC committed to annually revise this schedule in April to make future schedule commitments as necessary. A) Analysis B) Design C)
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Commitment No. 04378 Statement of Commitment:
On November 7,1982, Reactor Coolant Flow Transmitter RC-14A-FT2 failed due to a shorted capacitor.
On November 9,1982, RC-148-FT2 failed due to an inoperable bellows. The capacitor and bellows were replaced.
Long range corrective action is to replace present Bailey flow transmitters with Rosemont flow transmitters.
Commitment No. 04252 Statement of Commitment: An engineering evaluation will be performed to determine if additional corrective action is necessary for the EFW ultrasonic flow indicator on Steam Generator B (FW-313-FI) that malfunctioned.
Engineering evaluation (See Rev. 1 of LER) determined that ultrasonic flow indicators FW-313-FI will be replaced with a
. conventional flow indicator.
This change out is scheduled for refuel V.
Commitment No. 04235 Statement of commitment:
Ultrasonic flow indicators will be replaced with conventional instruments during EFW system upgrade scheduled for refuel outage V.
Commitment No. 01792 Statement of Commitment: On March 21, 1982, the emergency feedwater ultrasonic flowrate indicator was inoperable contrary to Technical Specification 3.7.1.2.
As a result, the following actions were taken:
the power supply was replaced. Long, term corrective action will be to replace the ultrasonic flow transmitter with conventional flow transmitter currently scheduled for refuel V.
Commitment No. 00459 Statement of Commitment:
With regard to inoperability of DHV-111 because of an inoperable flow switch, FPC committed to perform an engineering evaluation to determine further corrective action. Letter LFM84-0073 dated 3/6/84 documented results of engineering evaluation.
CRS RE #84-13 listed resulting corrective action as:
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Replace existing flow switch with electronic controls 2.
Change out helical gears in the valve actuator An inspector followup item was identified based on this review as is discussed in a later paragraph.
The inspector reviewed the following document in connection with the closecut of licensee commitment caused by LER:
FPC Interoffice Correspondence dated August 14, 1985, from Dan Green to C. R. Westbrook, Subject:
Closecut of Comtrol Commitment r
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Pursuant to a review of the NOCTS computer printout sheets, the inspector verified that the status of selected commitments were shown as complete and within the due date shown by the NOCTS.
Within this area, one inspector followup item was identified. The NOCTS in conjunction with the Nuclear Licensing verification and validation program is intended to assure that NRC commitments made by or mandated to FPC are properly interpreted and effectively implemented by the due date. The NOCTS was not used to assure timely implementation of Appendix R modifications during cycle V refueling outage. Additionally, modifications caused as a result of NUREG 0737 requirements were not monitored by NOCTS to ensure compliance with regulatory commitments.
The inspector concluded that the status of licensee commitments could not be ascertained, nor compliance with regulatory commitments determined from the NOCTS. The licensee takes credit for meeting the regulatory commitments through the design change program which implements plant modifications relative to Appendix R and NUREG 0737 requirements. Until an inspection of the design change program is performed to verify compliance with regulatory commitments, this is identified as inspector followup item 302/85-38-01.
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