ML20126M410
| ML20126M410 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 05/02/1985 |
| From: | Belisle G, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20126M374 | List: |
| References | |
| 50-302-85-15, NUDOCS 8506200326 | |
| Download: ML20126M410 (14) | |
See also: IR 05000302/1985015
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
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REGloN 11
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101 MARIETTA STREET, N.W.
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ATLANTA, GEORGI A 30323
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Report No.: 50-302/85-15
Licensee:
Florida Power Corporation
3201 34th Street, South
St. Petersburg, FL 33733
Docket No.: 50-302
License No.: DPR-72
Facility Name: Crystal River 3
Inspection Conducted: March 25-29, 1985
Inspector:
M
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G. A. Belisle
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Dde Yigned
Accompanying Personnel:
J. H. Moorman, Region II
M. A. Scott, Region II
Approved by: dM
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C. M. Uprighy/Sepfion Chief
Dpte S'igned
Division of Teact'or Safety
SUMMARY
Scope: This routine, unannounced inspection entailed 96 inspector-hours on site
and at FPC corporate offices in the areas of QA program review, audits, and
offsite support staff.
Results:
Four violations were identified - Failure to assure that conditions
adverse to quality were promptly corrected, Failure to escalate an audit finding
to an NCR, Failure to perform Technical Specification (TS) audits and
Criterion II reviews - within required intervals, and Failure to _ properly store
records,
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
K. Baker, Manager, Nuclear Electrical Engineering
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- D. Bates, Quality Engineer
- D. Betts, Supervisor, Quality Audits
- R. Bright, Manager, Nuclear Licensing
"W. Clemons, Nuclear Compliance Specialist
- J. Colby, Manager, Site Nuclear Engineering
- J. Frijouf, Acting Nuclear Compliance Specialist
E. Froats, Nuclear Project Management Engineer
E. Good, Senior Nuclear Licensing Engineer
D.. Harper, Licensing Assistant
S. Jesten, Nuclear Project Engineer
M. Mann, Nuclear Compliance Specialist
D. Porter, Senior Nuclear Licensing Engineer
W. Rossfeld, Nuclear Compliance Manager
R. Schmiedel, Nuclear Electrical Engineer
E. Simpson, Director, Nuclear Operations Engineering and Licensing
J. Telford, Director, Quality Programs.
D. Terrill, Senior Nuclear Licensing Engineer
S. Ulm, Nuclear Engineering Supervisor
G. Westafer, Manager, Nuclear Operations Licensing and Fuel Management
NRC Resident Inspectors
- T. Stetka
- J. Tedrow
- Attended exit interview
2.-
Exit Interview
The inspection ' scope and findings were summarized on March 29, 1985, with
those persons indicated in paragraph I above. The inspector described the
areas inspected -and discussed in detail. the inspection -. fin' dings listed
below.
Violation, Failure to. Assure that Conditions Adverse to Quality were
Promptly Corrected, paragraph 7.
The licensee denied this violation
without : providing the . inspector an - adequate ' basis by which this
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requirement had been met.
Violation, Failure to Escalate an Audit Finding to.an NCR, paragraph 8.
The licensee denied the violation 'without _ providing the inspector an
adequate basis by which this requirement had been set.
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Violation, Failure to Perform TS Audits and Criterion II Reviews Within
Required Intervals, paragraph 9.
The licensee denied this violation by
stating that FPC Criterion II reviews and TS audits were scheduled to
be performed at the same interval as routine TS surveillance
activities.
Violation, Failure to Properly Store Records, paragraph 10.
The
licensee denied this violation without providing an adequate basis by
which this' requirement had been met.
Unresolved Item, Commitment Tracking, paragraph 11.
Inspector Followup Item, Health Physics Calibration Evaluation,
paragraph 12.
The licensee did not identify as p~roprietary any of the materials provided
to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters
This subject was not addressed in the inspection.
4.
Unresolved Items
An Unresolved Item is a matter about which more information is required to
determine whether it is acceptable or may involve a violation or deviation.
One new unresolved item identified during this inspection is discussed in
paragraph 11.
5.
QA Program Review (35701)
Reference:
10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear
Power Plants and Fuel Reprocessing Plants
The inspector reviewed the licensee QA program required by the above
reference and verified that these activities were conducted in accordance
with regulatory requirements. The following criteria were used during this
review to assess overall acceptability of the established program:
Personnel responsible for preparing implementing procedures understand
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the significance of changes to these procedures.
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Licensee procedures are in conformance with the QA Program.
The procedures discussed throughout this report were reviewed to verify
conformance with the QA program.
The inspectors reviewed QA program
implementation as a part of the inspe : tion. Each specific area is detailed
in other paragraphs of this report.
Problem areas, .if identified, are
detailed in specific areas _ inspected.
Within this area, no violations or deviations were identified.
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6.
Audits (40702 and 40704)
(1) References:
(a)
10 CFR 50, Appendix B, Quality Assurance Criteria
for Nuclear Power Plants, and Fuel Reprocessing
Plants
(b) Regulatory Guide 1.144, Audit of Quality Assurance
Programs for Nuclear Power Plants
(c) ANSI N45.2.12-1977, Requirements for Auditing of
Quality Assurance Programs for Nuclear Power Plants
(d) Regulatory Guide 1.146, Qualification of Quality
Assurance Program Audit Personnel for Nuclear Power
Plants
(e) ANSI
N45.2.23-1978Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.23-1978" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.,
Qualification
of Quality
Assurance Program Audit Personnel for Nuclear Power
Plants
(f) Regulatory Guide 1.33, Quality Assurance Program
Requirements (Operation)
(g) ANSI
N18.7-1976Property "ANSI code" (as page type) with input value "ANSI</br></br>N18.7-1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.,
Administrative Controls and
Quality Assurance for the Operational Phase of
Nuclear Power Plants.
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(h) Technical Specifications, Section 6
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The inspector reviewed the licensee audit program required by references (a)
through (h) to verify that the program had been established in accordance
with regulatory requirements, industry guides and standards, and Technical
Specifications.
The following criteria were used during this review to
determine the overall acceptability of the established program:
The audit program scope was consistent with Technical Specifications
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and QA program requirements.
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Responsibilities were assigned.in writing for overall management of the
audit program.
Methods were defined for taking corrective action on deficiencies
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identified during audits.
The audited organization was required to respond in writing to audit
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findings.
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Distribution requirements were defined for audit reports and corrective
action responses.
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Checklists were required to be used in performing audits.
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Measures were established to assure that QA audit personnel met minimum
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education, experience, and qualification requirements for the audited
activity.
The documents listed below were reviewed to verify that these criteria had
been incorporated into the auditing program:
Chapter 1.7 Quality Programs (Operational), Revision 5
NQAP
Quality Program Including Audit and Followup Action Program, Code:
IADT, Revision 0
NQAP
Personnel and Training, Code:
PTQ, Revision 0
NQAP
Document and Records Control Documentation, Code:
DOCC,
Revision 0
NQAP
Nonconforming Item Control and Corrective Actions, Code:
NCON,
Revision 0
NQAP
Instructions and Procedures Requirements, Code: PCDR, Revision 0
NQAP
Vendor Qualification Audit and Surveillance Program, Code: VADT,
Revision 1
QAP-8
Quality Program Audits, Revision 9
QAP-9
Transmittal of Quality Records - Quality ' Programs Department to
the Nuclear Plant Quality Documents File, Revision 4
QAP-18
Control of Nonconformance Reports, Revision 8
QAP-27
Noncompliance Tracking, Revision 4
QAP-14
Corrective Action, Revision 5
QAP-23
Reporting of Defects and Noncompliance, Revision 6
QAP-35
Quality Programs Department Training, Revision 1
The inspector selected the following audits for review to verify audit
program implementation:
QP-226
Operational Technical Specification Conformance-
Conducted July 19 - August 16, 1982; Issued September 15, 1982
QP-237
Design and Modification Control
Conducted August 6 - September 3G, 1983; Issued October 26, 1983
QP-238
Fire Protection
Conducted June 6 - July 17, 1983; Issued August 5, 1983
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QP-249
Conducted January 9 - February 3,1984; Issued March 2,1984
QP-250
Preventive and Corrective Maintenance Program
Conducted January 30 - March 12, 1984; Issued April 11, 1984
QP-252
Measuring and Test Equipment Control
Conducted April 18 - May 10, 1984; Issued June 8, 1984
QP-253
Procurement
Conducted May 11 - June 7, 1984; Issued July 3, 1984
QP-255
Nonconforming Item Control and Corrective Action
Conducted July 16 - August 2, 1984; Issued August 31, 1984
QP-258
Personnel Training and Qu'alification
Conducted August 29 - October 19, 1984; Issued November 19, 1984
All audits reviewed were issued within frequencies permitted by controlling
procedures.
If audit findings were identified, the audited organization
responded within required timeframes.
Audits were performed with approved
checklists. Audit frequency was determined by QA personnel using allowances
stated in TS Section 4.0.2.
A violation pertaining to this method of
determining audit frequency is discussed in paragraph 9.
These TS 4.0.2
statements have also been included in QAP-8.
The inspector reviewed 1983,
1984, and 1985 audit schedules. The inspector randomly selected different
audit subjects and verified that they are being performed within TS
requirements. The_ inspector reviewed qualifications for 13 lead auditors.
Currently, four lead auditors are physically located at the corporate
offices and the remaining auditors are located on site.
The inspector questioned licensee personnel about performance of an
evaluation to determine QA program status and adequacy.
The Nuclear
Generation Review Committee (NGRC) has delegated this evaluation performance
to the Corporate Audit Subcommittee (CAS) which is headed by the Director,
Technology Services.
Consultants previously performed this evaluation for
FPC. CAS is reviewing inputs such as INPO reports, NGRC liaison informa-
tion, and LRS consultant information to form the basis for this evaluation.
Work is scheduled for completion in early April with the evaluation issuance
to senior management.
Within this area, four violations, one unresolved item, and one inspector
followup item were' identified and are discussed in the following paragraphs.
7.
Failure to Assure that Conditions Adverse to Quality Were Promptly Corrected
During audit QP-249 review, the inspector identified that the initial
response- from the audited organization was transmitted to Quality Programs
Department (QPD) personnel on March 28, 1984. At that time, there appeared
to be a disagreement between the audited and auditing organizations. This
apparent iisagreement is the basis for a violation discussed in paragraph 8.
The next correspondence relating to Finding 11 resolution was November 8,
1984, by the auditing group and November 30, 1984, by the audited
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organization. The inspector was informed by QPD personnel that from March
until November, QPD personnel and audited personnel conducted telephone
conversations and corresponded informally attempting to resolve this
finding. However, these actions did not resolve the issue and the November
correspondence still indicated that both organizations were in disagreement.
The inspector also reviewed Audit QP-250 which identified 26 findings. All
items were initially responded to on May 7,1984. Corrective actions for
findings 1, 5, 6, 7, and 8 were apparently accomplished as scheduled. QPD
requested an additional response for finding 2 on May 23, 1984.
This
additional response was reviewed by QPD as being acceptable. On July 10,
1984, the audited organization requested an extension to complete corrective
action for this item until August 31, 1984.
On September 21, 1984, the
audited organization requested ~ another extension for corrective action
completion until October 15, 1984. The corrective action for finding 2 was
completed on October 17, 1984.
QPD requested an additional response for finding 3 on May 23,1984. This
additional response was submitted to QPD on July 2,1984. The additional
response also requested an extension for corrective action completion until
August 3, 1984. The corrective action for finding 3 was reported completed
by the audited organization on August 2, 1984.
QPD requested an additional response for finding 13 on May 24,1984. On
July 6, 1984, a response was received by QPD stating that procedural
requirements had been revised on July 1, 1984; consequently, the corrective
action for finding 13 had been completed. QPD issued a request to personnel
responsible for finding 13 corrective action to provide a followup verifica-
tion stating that the corrective action was completed. QPD requested this
followup by August 6, 1984. QPD issued another request on August 14, 1984,
stating that the followup requested to be sent to QPD by August 6, 1984, had
not been received.
If a followup was not received by August 30, 1984, QPD
would issue a nonconformance (NCR). On August 17, 1984, a response was sent
to QPD stating that the corrective action for finding 13 had been completed
and that QPD, after verification, could close finding 13.
Corrective actions for the remaining Audit QP-250 findings are somewhat
similar to those described for findings 2 and 3.
Certain audit findings are
still awaiting corrective action resolution from 1982 (1 finding) and 1983
(21 findings). ' Corrective action due dates have been established for these
items; however, measures have not been specifically delineated to assure
prompt corrective action.
Existing procedures do not delineate how many
requests for extensions are acceptable and when items will be escalated to
higher management.
Failure to establish measures to assure that conditions
adverse to quality are promptly corrected
constitutes
violation
302/85-15-01.
8.
Failure to Escalate an Audit Finding to an NCR
During audit QP-249 performance, 16 findings were identified by the auditing
organization. Finding 11 stated that not all emergency preparedness records
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required by NQA practices are assembled as required. The audited organiza-
tion's response to this finding was submitted for NQA review on March 28,
1984. The response stated the following specifically:
"The Manager, Site Nuclear Services, has reviewed all Site Nuclear
Services records and, according to the criteria of ANSI N45.2.9 and
QP-17.1, does not consider Emergency Planning records to require
assembly in accordance with NQA Practice DOCC. AMI-03 will be reissued
to stipulate those Site Nuclear Services' records that are considered
" Quality" by approximately May 1984.
.The Radiological
Emergency Response Plan and its implementing
procedures (i .e. , Emergency Plan Implementing Procedures -(ems)) are
included in the licensing docket and are thus controlled as " Quality"
records."
The next correspondence relating to this item was a letter from the
Supervisor, Quality Audits, to the Site Director dated November 8,
1984,
which stated that Emergency Planning records need to be treated as QA
records.
This letter further stated that a follow-up report to the
Supervisor, Quality Audits, is required by December 3,1984, documenting
corrective action to be implemented relative to the contral of Emergency
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Planning records. The response from the Site Director to the Supervisor,
Quality Audits, dated November 30, 1984, stated that there is an apparent
disagreement about emergency planning documents being considered quality
records. It further stated that based on reviews of FSAR Section 1.7.1.17,
Standard Technical Specifications (STS) Section 6.10, and ANSI N45.2.9,
Appendix A, records related to emergency preparedness are not included;
consequently, the audit finding should be closed.
QAP-8, Section 6.6.2.1, states that if the audit team leader and audited
organization cannot reach agreement on the corrective actions for any
finding, the audit team leader will refer these items to the Supervisor,
Quality Audits.
If satisfactory resolution cannot be obtained by the
Supervisor, Quality Audits, within an additional 30 days, he initiates a
nonconformance report (NCR) in accordance with QAP-18. Disagreement with
this audit finding by the line organization was known in March 1984 and a
nonconformance was not written for this particular item as of the date of
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this inspection. Failure to achieve resolution of this problem through the
required NCR process constitutes violation 302/85-15-02.
9.
Failure to Perform .TS Audits and Criterion II Reviews Within Required
Intervals
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TS Section 6.5.2.9 ste.tes that audits shall be performed under the
cognizance of the NGRC
These audits encompass various areas.
For each
area listed, specific intervals are stated.
For surveillance tests, TS
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Section 4.0.2 states the following:
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- A maximum allowable extention not to exceed 25% of the surveillance
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interval, and
b.
A total maximur. combined interval time for any three consecutive tests
not to exceed 3.25 times the specified surveillance interval.
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The licensee has applied TS 4.0.2 time variations to audit frequencies in TS
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Section 6.
QAP-8 also reflects these intervals. The licensee has developed
methods to assure that audits are conducted within these intervals. Audit
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schedules are published as drawings with specific drawing numbers. These
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schedules are updated twice a year.
The application of TS 4.0.2 to TS
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Section 6 is not appropriate.
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10 CFR 50 Appendix B Criterion II states in part that the applicant shall
regularly review the status and adequacy of the quality assurance program.
This has been expanded by the accepted QA program in FSAR Section 1.7.1.2
which states that FPC regularly reviews the status and adequacy of its
quality program through periodic reviews conducted at least once every two
years. As previously stated, this review is being conducted by the CAS and
is due to be . completed in 'early' April 1985. The reason this review is due
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at this time is to meet TS 4.0.2.a . requirements. Application of TS 4.0.2
a
requirements was not appropriate and this review is required to be performed
within quality program timeframes.
Failure to perform TS audits and
Criterion II reviews at required frequencies constitutes a violation
302/85-15-03.
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Failure to Properly Store Records
The licensee administrative controls for records allows record storage to
meet ANSI N45.2.9, NFPA-232, or duplicate storage requirements.
The
licensee has taken an approved exception to ANSI N45.2.9, Section 5.6 (FSAR
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Table 1-3) which states that this section does not provide a distinction
between temporary and permanent facilities. To cover temporary storage, the
following clarification is added: Active records -(those completed but not
yet duplicated or placed on microform) may be temporarily stored in one-hour
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fire rated file _ cabinets.
In general, records shall not be maintained in
such temporary storage for more than three months after completion without
being _ duplicated (for dual storage) or being placed on microform. Vault
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facilities are provided on site. Audit records reviewed at FPC corporate
offices were being- stored in a one-hour fire rated locked cabinet. QAP-9
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defines Quality Program Audits as nonpermanent records with a six year
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retention period. The audit plan, notice, and audit report are transmitted
to permanent storage upon audit report issuance.
Audit item responses, -
followup records, and closure records are retained in the QPD cabinet until
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-audit closure. Some of-these original records are maintained for a year or
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longer ~ depending upon how long it takes to close the audit. Storage of
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these records in a one-hour- fire rated cabinet is acceptable providing
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NFPA-232 1975, Standard. for the Protection of- Records, requirements are
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adhered to. - NFPA-232 1975 requires that a fire load analysis be performed
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to verify storage location adequacy. Other options av'ailable are duplicate
storage or ANSI- N45.2.9.
Failure to store records in accordance with QA
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program requirements constitutes violation 302/85-15-04.
11. Commitment Tracking
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The 'following paragraphs describe issues which collectively constitute an
- unresolved item regarding the, effectiveness of -the licensee commitment
tracking system.
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a.
Part 21 Followup Commitment
In a letter dated June 27, 1983, to NRC Region II Florida Power
Corporation (FPC) reported a 10 CFR 21 deficiency regarding the plant's
high pressure injection valves.
The letter stated that when a valve
replacement and schedule for installation is determined, FPC will
advise the NRC accordingly.
Per conversations with the NRC Project
Inspector and site Senior Resident Inspector, valve replacement will
occur this outage. To date, Region II has not received an updated
Part 21 report regarding the valve replacement schedule.
b.
Post Accident Sampling System (PASS)
Audit report QP 259, Site Nuclear Operations (Chem / Rad), issued
November 18, 1984, identified an item on the PASS.
Site audit
responses of December 12, 1984, and March 1,1985, to the item agreed
with the finding in that the "as-built" PASS does not match the system
described in the FPC commitment letter to NRC dated December 30, 1981.
Part of the installed equipment differs in design criteria (such as
ranges) from that described in the commitment letter. The audit item
had been open for approximately four months since the date of the last
site response.
Per site audit response dated March 1,
1985, site
Nuclear Compliance has action to generate the necessary correspondence
when exact recommendations are determined. Since this system is under
NUREG 0737, Post TMI Requirements (Item II.B.3), as-built or design
criteria differences should be formally identified to the NRC.
c.
NUREG 0578 Item 2.1.6.a Commitment
In subparagraph 3) on page 3 of Audit Report QP-250, Preventive and
Corrective Maintenance Program, dated April 11, 1984, a oeficiency
closure was addressed. The deficiency involved the FPC commitment to
NUREG 0578, TMI-2 Lessons Learned Short Term Recommendations, as it
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relates to Item 2.1.6.a,
Integrity of Systems Outside Containment
Likely to Contain Radioactive Material for PWRs and BWRs. The audit
report indicated a letter from FPC to NRR dated October 1, 1979, which
stated that FPC will develop and implement a leak reduction and
maintenance program.
The initial concern of the audit was that a
complete preventive maintenance program was not established to address
how leaks were to be prevented.
Deficiency closure was based on site
procedures and on an . interpretation of an NRR letter to FPC dated
May 5, 1980. The NRR letter indicated that verification of procedures
which implement 'the licensee's program would be documented in a
separate inspection report. This separate inspection report was not
documented in Audit Report QP-250.
The basis for the audit report
deficiency closure was not clear. Closure of this deficiency questions
whether or not the program meets the commitments of the FPC letter to
NRR dated October 1,1979, or that the current program was clarified to
NRR via correspondence.
d.
_ Commitment System
Audit Report QP-247 issued February 2,1984, identified as findings a
number of FPC commitments, requirements, and regulations that were not
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being met.
These noncompliances are catagorized as follows:
five
audit findings concerned FPC comitment letters to the NRC; one audit
finding concerned 10 CFR 50, Appandix B, Criterion V; one audit finding
listed above also deals with 10 CFR 50, Appendix R; one audit finding
concerned an FSAR requirement; and one audit finding. concerned a
commitment documented in NRC Inspection Report 79-19 exit interview.
The FPC comitment letter dates varied from 1975 to 1982.
For audit
findings 04, 07, - and 09 where the intent of the. commitment had been
changed, a modifying letter was sent to the NRC after the audit
findings were issued. Of the nine audit items, eight had been closed
by the time of this inspection. The closure of findings varied from
approximately 10 to 12 months (finding 02 had yet to be officially
closed by the auditors). Closure of the remaining open finding (02)
was confirmed via a telephone conversation with the site Nuclear
Compliance Manager on April 3; 1985. Responses to four audit findings
contained statements indicating that personnel were unaware of the
particular commitment, requirement, or regulation.
Responses to one
audit finding indicated that personnel complied with the comitment yet
there was a dependency on the knowledge of the individuals involved
without procedural back-up.
Audit QP 259 dated October 18, 1984, finding 14, identified a need for
the site ccmpliance group comitment tracking computer program to be
auditable.
The Nuclear Operations Commitment System (NOCS) upgrading
and its attendant procedure N00-9, Processing of Nuclear Operations
Commitment System Correspondence, was the basis for finding 14 closure
on February 15, 1985. An IOC of February 20, 1985, (NOSD 85-0025) from
the Site Nuclear Operations Director indicated concern that site
personnel are ignoring the NOCS.
The Director further stated the
following:
"In the future when a NOCS-identified commitment is not met, I
want to be notified; and 1 intend to treat these failures as a
procedural deficiency in that .there is no reasonable excuse for
ignoring this tool."
The audit findings and other issues indicated above involve a general
concern regarding incomplete tracking of commitments and untimely
resolution to licensee identified findings. Until management controls are
implemented to provide an effective system which assures complete tracking,
timely resolution, and technically sound closecut of.all commitments, this
concern will be identified as unresolved item 50-302/85-15-05.
12. Health Physics (HP) Calibration Evaluations
The inspector reviewed audit QP-252 in which one comment by the auditor
suggested that HP strengthen their procedure to' require a resurvey in areas-
affected by an out-of-calibration survey meter. At present, when a survey
instrument is out-of-calibration, the situation becomes very obvious and a
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noncompliance is prevented by the use of another instrument. The inspector
questioned the auditor as to why this audit comment was not a finding. The
auditor responded that HP personnel. provided supplemental information to
as ure that calibration controls were in conformance with FPC program
requirements; therefore, a finding was not warranted.
The inspector
attempted to interview HP personnel but due to scheduling conflicts was
unable to verify that the HP calibration program is in conformance with
regulatory requirements. Until the HP calibration program can be verified
to be in conformance with regulatory requirements, this is identified as
inspector followup item 302/85-15-06.
13. Offsite Support Staff (40703)
References:
(a) 10 CFR 50, Appendix B, Quality Assurance Criteria for
Nuclear Power Plants and Fuel Reprocessing Plants
,
Quality Assurance Program
Requirements (Operations)
(c) ANSI N18.7-1976, Quality Assurance for the Operational
Phase of Nuclear Power Plants
(d) Technical Specifications, Section 6
The inspector visited site and corporate offices to determine whether the
offsite support staff functions were performed by qualified personnel in
accordance with licensee administrative controls, regulatory requirements,
industry guides and standards, and Technical Specifications. The following
criteria were used during this review to determine the overall acceptability
of the established program:
Administrative controls were established to assign departmental
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responsibilities,
authorities,
and
lines
of communication
in
conformance with requirements of 10 CFR 50, Appendix B, and the
accepted QA program.
Managers,
group
leaders,
and
staff members
understand their
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responsibilities and authorities.
The above personnel were qualified for the related work.
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The inspector interviewed the following Florida Power Corporation personnel:
Quality Programs
D. Bates, Quality Engineer
D. Kurtz, Senior Nuclear Quality Assurance Specialist
J. Telford, Director, Quality Programs
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Nuclear Operations Engineering and Licensing
K. Baker, Manager, Nuclear Electrical Engineering
R. Bright, Manager,. Nuclear Licensing
E. Froats, Nuclear Project Management Engineer
E. Good, Senior Nuclear Licensing Engineer
D. Harper, Licensing Assistant
S. Jasien, Nuclear Project Engineer.
R. Schmiedel, Nuclear Electrical Engineer
E. Simpson, Director,_ Nuclear Operations Engineering and Licensing
D. Terrill, Senior Nuclear Licensing Engineer
S. Ulm, Nuclear Engineering Supervisor
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G. Westafer, Manager, Nuclear Operations Licensing and Fuel Management
The above personnel were interviewed to determine the offsite support staff
adequacy. All employees appeared to understand their res;,onsibilities and
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authorities and could identify the documents which delineate this informa-
tion.-
In most casey, division and department managers had promulgated
l
written office procedures to their staffs.
Inter-office communication
i
appeared to be satisfactory.
All employees had received training. This
4
training consisted of classroom instruction supplemented by on-the-job
training.
The majority of the technical staff are degreed engineers. A
3
small percentage are registered as professional engineers.
The office
I
support staff . appeared to be interfacing satisfactorily with the onsite
!
staff. Offsite' personnel routinely visit the site to coordinate their work.
The various departments and divisions within the corporate office appeared
to be interfacing satisfactorily.
The inspector reviewed the following procedures and discussed their content
relative to the offsite support staff function with selected personnel:
,
NQAP
Procurement, Code:
PCMT, Revision 1
,
NQAP-
Personal Training and Qualification, Code: PTQ, Revision 0
,
NQAP
Internal and External Reporting Requirements, Code:
REPT,-
1
Revision 0
NQAP
Modification Control, Code: MCTL, Revision 0
N00-3
. Reporting Requirement Program, Revision 1-
>
- _
SREP-1-
Safety Identification and Design Input Requirements,
j
Revision 7
SREP-3
l Interface Design Control, Revision 4
.
.
i
SREP-6
Preparation and Control of a-Modification Approval _ Record
j
(MAR), Revision 7-
I
SREP-10
10 CFR Part 21, Revision 4-
SREP-17 _ Preparation, Review, and Approval of Safety-Related Field
Change Notice '(FCN), Revision 5
-
L
.
_
!
i
r
.
.
13
EGN-1
Preparation, Review and Approval of Engineering Studies,
Revision 0
Resolution of Safety Concerns, Revision 4
Control of Crystal River Unit 3 Licensing Documents,
Revision 4
Nuclear Licensing Commitment Tracking, Revision 2
Control of Changes to the Quality Program Description,
Revision 1
These discussions, indicated that appropriate personnel had adequate
knowledge of these procedures and how they interfaced with other organiza-
tional units.
' '
Within this area, no violations or deviations were identified.