IR 05000302/1985043

Insp Rept 50-302/85-43 on 851209-13.No Violations or Deviations Noted.Major Areas Inspected:Licensee Action on Previous Enforcement Matters,Design Control & Tests & Experiments

ML20137S537
Person / Time
Site:	Crystal River
Issue date:	01/23/1986
From:	Belisle G, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20137S519	List: IR 05000302/1985043 ML20137S513
References
50-302-85-43, NUDOCS 8602180072
Download: ML20137S537 (10)

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UNITED STATES j NUCLEAR REGULATORY COMMISSION

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. Report No.: 50-302/85-45

' Licensee: Florida Power Corporation

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3201 34th Street, South St. Petersburg, FL 33733 Docket No.:- 50-302 License No.: DPR-72 Facility Name: Crystal River 3 Inspection Conducted: December 9-13, 1985 Inspector: M ,N /- EbSG CW Date Signed Approved by: &LJ. LJwJti-- 1- 23 - sr G. A. Belisle, Actyg Section Chief Date Signed Division of Reactor Safety SUMMARY Scope: This routine, unannounced inspection involved 34 inspector-hours on site in the areas of licensee action on previous enforcement matters, design control, and tests and experiment Results: No violations or deviations were identifie ,

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REPORT DETAILS Persons Contacted Licensee Employees

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• J. Alberdi, Manager, Site Nuclear 3ervices *

• K. Baker,~ Assistant to the Manager, Nuclear Operations Engineering

• C. Brown, Assistant. Nuclear Outage and Modification Manager R. Carbiener, Nuclear Modifications Specialist J. colby, Manager, Site Nuclear Engineering *

• J. Cooper, Jr., Nuclear Surveillance and Modification Approval Record (MAR)TestSuperintendent

• D. Eggleston, Operations Superintendent C.~ Elan, Nuclear Modification Specialist

• T. Frijouf, Compliance Specialist

• P. Haines, Nuclear Licensing

• V. Hernandez, Senior Nuclear QA Specialist W. Johnson, Nuclear Modification Specialist W. Johnson, Nuclear Plant Engineering Superintendent M. Jones, Nuclear Modification Specialist K. Lancaster, Manager, Site Nuclear QA

• P. McKee, Plant Manager

- McLaughlin, Nuclear Modification Specialist W. Newman, III, Nuclear Reliability Supervisor

• S. Powell, Senior Nuclear. Licensing Engineer

• V. Roppel, Manager, Plant Engineering and Technical Services

• W. Rossfeld,' Site Nuclear Compliance Manager NRC Resident Inspector

• T. Stetka, Senior Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on December 13, 1985, with those persons indicated in paragraph 1. above. The inspector described the areas -inspected and discussed in detail the inspection finding No dissenting comments were received from. the licensee. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio _ . __ _ _ _ _ .

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, Licensee Action on Previous Enforcement. Matters-(0 pen) Severity Level IV Violation (302/85-15-01): ' Failure to Assure That

- Conditions Adverse'to Quality.Were Promptly Corrected Licensee responses dated June 17 and September 17, 1985, denied this viola-

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tion.- The. licensee response dated September 17, 1985, did state, however, .

that several' program enhancements -for elevating unresolved quality assurance

. (QA) audit. findings had been instituted. These included a memorandum issued

, from the Vice President, Nuclear 0perations, and a revision to' QAP-8, Quality Program Audits. The memorandum from the Vice President, Nuclear Operations, was issued prior to September 17, 1985. QAP-8 was revised to include these program enhancements on September 30, 1985, and issued on October 9,1985. These program enhancements should correct the identified weaknesses in audit finding resolution. Administrative errors appear to

be the reason for the delay in issuing QAP-8 by September 17, 1985; conse-quently, a deviation is not warrante Until implementation of these

program enhancements can be fully evaluated, this item remains open.

4. . Design Program (37702)

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References: (a) 10 CFR 50 Appendix B, Quality Assurance Criteria. for Nuclear Power Plants and Fuel Reprocessing Plants, i Criterion III (b) 10 CFR 50.54(a)(1), Conditions of Licenses (c) Regulatory Guide 1.64, Quality Assurance Requirements for the Design of Nuclear Power Plants (d) ANSI- N45.2.11-1974, . Quality Assurance Requirements for the Design of Nuclear Power Plants

) (e) Regulatory -Guide 1.33, Quality Assurance Requirements

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(Operations)

(f) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (g) 10 CFR part 50.59, Changes, Tests and Experiments (h) Technical Specifications Section 6.5, Review and' Audit

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The inspector reviewed the licensee design change program required by 7' - references- (a) through (h) to determine if these activities were conducted

! in accordance with regulatory requirements, industry guides and :tandards,

and technical specifications. The following criteria were used during the review to assess the overall acceptability of the established program:

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Proce'dures have been established to control design changes which

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include assurance that a proposed change does not involve an unreviewed safety question or a change in technical specifications as required by 10 CFR 50.5 Procedures and responsibilities for design control have been established including responsibilities and methods for conducting safety evaluation Administrative controls for design document control have been established for the following:

Controlling changes to approved design change documents Controlling or recalling obsolete design change documents such as revised drawings and modification procedures Release distribution of approved design change documents

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Administrative controls and responsibilities have been established commensurate with the time frame for implementation to assure that design changes will be incorporated into:

Plant procedures Operator training programs Plant drawings to. reflect implemented design changes and modifica.tions

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Design controls require that implementation will be in accordance with approved procedure Design controls require assigning responsibility for identifying post-modification testing requirements and acceptance criteria i approved test procedures and for evaluation of test result Procedures assign responsibility and delineate the method for reporting design changes to the NRC in accordance with 10 CFR 50.5 Controls require review and approval of temporary modifications in accordance with Section 6 of the Technical Specifications and 10 CFR 50.5 The documents listed below were reviewed to determine if these criteria had been incorporated into the licensee design program:

Florida Power Corporation FSAR Section 1.7.1.3, Design Control Section 1.7.1.16, Corrective Action l AI-400 Plant Operating Quality Assurance Manual Control Document, Revision 59 l

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CP-11 Procedure for Handling Permanent Modifications, Temporary Modifications, . Modification Revisions, Field Change Notices, and Advanced Field Change Notices, Revision 42 CP-111 Documenting, Reporting, and Reviewing Nonconforming Operations Reports, Revision 32 CP-134 Preparation, Approval, and Performance of MAR Functional Test Procedures, Revision 7 AI-700 Conduct of Nuclear Plant Engineering and Technical Services, Revision 26 M0P-500 Modification, Revision 1 M0P-501 Site Approval of MAR Work Packages, Revision 4 M0P-504 Processing of MAR Field Change Notices, Revision 2 M0P-508 Turnover of Modifications (Completed / Partial) to Nuclear Operations, Revision 2 M0P-401 Control of Work Requests, Revision 4 M0P-402 Preparation of Work Packages, Revision 6 M0P-405 Job Completion, Walkdown, Turnover, and Nonconforming Item Reporting, Revision 5 M0P-600 Construction Verification, Revision 3 Nuclear Operations Modification Procedure 2, Modification Procedure, Revision 1 Safety Related Engineering Procedure 8, Corrective Action, Revision 5 Engineering Guideline No. 7, Engineering Disposition of Field Change Requests, Revision 0 The licensee has assigned responsibility for HAR preparation, which l documents the safety evaluations and review and approval of nuclear plant modification activities, to the on-site /off-site Nuclear Operations Engineering organization. The inspector conducted interviews with licensee management from the on-site Nuclear . 0perations Engineering group to ascertain their functional responsibilities, levels of authority, ~ and

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' internal"and external interface requirements in connection with design change program activities. The inspector determined.that station designed modifications are - performed within the limits of the resources of the-

on-site Nuclear Operations Engineering group. - All- other nuclear plant modifications are performed by the off-site Nuclear Operations' Engineering organization;or their engineering consultan ;In-1984.ths licensee established what is referred to as a'n enhanced design program. This program.provides for systems / components walkdowns prior to and during. the detail . design process. Project walkdowns, as they are

. called,: are intended to establish communications between the design office:

.and site personnel on a continuing basis. Topics covered as they relate to

'the. design efforts are.as follows:

. Installation ,

Operations Testing Inspection

. Training Maintenance-ALARA 0ther particulars associated with nuclear plant modification

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The inspector inquired as to whether or not project walkdowns.were performed for. MARS that were installed during Cycle V refueling outage. Licensee-management stated that because of the advanced stage of the detail design

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process, project walkdowns were not performed. 'The interface of the on-site:

Nuclear Operations Engineering with the' Nuclear Modification and Outage c ,

group was reviewed and discussed with licensee management. In particular, the implementation of' corrective action by. on-site Nuclear Operations .

Engineering for identified design nonconformances.and/or the processing and

disposition

of Field Change Notices were ' discussed. Based on - these 1-discussions and a. review of the program documents,-controls'for corrective  !

action and' Field Change Notices appear to be adequat ,

The licensee has established a Nuclear Outage and Modification Program which l controls modification installation and testing activities.- This program .j also controls the interfaces of the Nuclear Outage and Modification '

organization with design, operating, and procurement organizations to assure

.that adequate controls are exercised over all' aspects of the modification effort. . A Nuclear- Modification Project Management Group from within this organization administers all work -activities for MARS. These activities start 'with the 'on-site receipt of-'an approved MAR package and continues -

until each MAR package has been installed, - tested, turned over to Operations, and closed out. Individual Nuclear Project Managers are given sole responsibility for' the administration of assigned MAR packages from initial on-site receipt to final close ou >

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The inspector conducted interviews with selecced Nuclear Project Managers assigned responsibility for the following MAR packages. These MAR packages have not yet been closed out for various reason . MAR #77-07, NNI Cabinet Modification MAR #80-02-80, CX Solenoid Replacement,

. MAR ~#80-04-06, Condensate. System Low F1ow MAR #81-05-33, Smoke Detectors Discussions concerning the outstanding items associated with each MAR package were conducted with licensee managemen Further discussion concerning the administration of the Incomplete Items List (ICIL) and exceptions identified during the construction verification phase of the design program were also held. .The inspector reviewed the programmatic controls for transforming ICILs/ Exceptions into Field Change Notices and ensured that the~ program requires the participation of Nuclear Operation Engineering in the resolution and disposition of nonconformances.' Based on discussions with the licensee management and a review of the program documents, the programmatic controls appear adequate with the following exceptio Nuclear Modification and Outage Procedure M0P-405, paragraph 4.2.6.6, assigns responsibility to the installer for providing a preliminary disposition and obtaining: resolution of an Exception if the item can be reworked in accordance with the original approved MAR, Work Request / Package, procedure, et This - occurs prior to the review and approval of. the disposition by the cognizant Nuclear Project Manager. Additionally, if this disposition is approved by the Nuclear Project Manager, because the program defines " Rework Exceptions" as dispositions of nonconformances-in accordance with an approved MAR, Work Package, etc., Nuclear Operation Engineering is not provided an opportunity for review and approval of these disposition The inspector discussed the significance of introducing unintended design-changes into approved MAR packages via the disposition of " Rework Exceptions" by the installers, concurrent with the Nuclear Project Manager's l approval. Licensee management confirmed that. all nonconformances were dispositioned by use of Field Change Notices (FCNs) which afforded Nuclear Operations Engineering the opportunity for review and approval of these FCN This potential problem is fully addressed and documented in Inspection Report No. 50-302/86-0 The licensee Construction and Verification group is assigned responsibility

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to ensure that completed work is in conformance with specifications, drawings, and instructions provided with a MAR Work Package and associated FCN This feature of the enhanced design program was implemented for MAR

! Work Packages installed during the Cycle V refueling outage. The inspector

' conducted discussions with the Nuclear MAR Test Supervisor who has been 1 assigned responsibility for these activitie A listing of post-modifica-tion - tests performed for completed MARS was reviewe Additional t

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discussions concerning the corrective actions for nonconformances (Exceptions) identified during post-modificetion tests were also hel Licensee management confirmed that nonconformances identified during post-modification testing are processed in. accordance with M0P-405. Licensee management ~further stated that nonconformances identified after turnover of the modified system / component to operations are processed in accordance with CP-11 .

Pursuant- to discussions with' licensee management concerning the general topic of corrective action, and the implementation of the Construction Verification program, a narrow scope in-depth inspection of this area will be required to be performed in order to verify the effectiveness of this part of the enhanced design program, c Within this area, no violations or deviations were identifie . Tests anc Experiments (37703)

References: (a) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants

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(b) 10 CFR 50.59, Changes, Tests and Experiments (c) 10CFR50.54(1)(1), Conditions of Licenses (d) Technical Specification 6.5, Review and Audit (e) Regulatory Guide 1.33, Quality Assurance Requirements (Operations)

(f) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants

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The inspector reviewed the licensee's tests and experiment programs required by references (a) through (f) to determine if the program was in conformance with regulatory requirements, commitments in the application, and industry guides and standards. The following criteria were used during this review to assess the overall acceptability of the established proaram:

- A formal method has been established to handle all requests or proposals for conducting plant tests involving safety related component Provisions have been made to assure that all tests will be performed in accordance with approved written procedure Responsibilities have been assigned for reviewing and approving test procedure l

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A formal system, including assignment of responsibility, has been established to assure that all proposed tests will be reviewed to determine whether they are as described in the FSA Responsibilities have been assigned to assure that a written safety evaluation required by 10 CFR 50.59 will be developed for each test to assure that it does not involve an unreviewed safety question or a change in Technical Specifications (TS).

The documents listed below were reviewed to determine if the previously

' listed criteria had been _ incorporated into the licensee's tests and experiments program:

Florida Power Corporation FSAR Section 1.7.1.11, Test Control Section 1.7.1.16, Corrective Action AI-400 Plant Operating Quality Assurance Manual Control Document, (P0QAM), Revision 59 CP-134 Preparation, Approval and Performance of MAR Functional Test Procedures, Revision 7 The- inspector reviewed the licensee's tests and experiments program documents to determine if a test program had been established to assure that all testing required to demonstrate satisfactory in service operation of structures, systems, and components had been . identified. Additionally, all testing is performed in .accordance with approved written procedure The inspector verified that provisions had been established for performing

. written safety evaluations (required by 10 CFR 50.59) for special tests to assure that unreviewed safety questions or changes to the TS do not exis The scope of the program documents, which delineate the controls 'for the

= plant test program, is described in AI-400 and the controls are as follows:

Volume X - Surveillance Procedure Volume XVI - Performance Testing Procedures Volume XV,Section IV - Pump and Valve Program Additional requirements of the test program are delineated in CP-134 for MAR Functional Test procedure The inspector conducted interviews with licensee management to ascertain the administrative controls applicable to the performance of special tests as defined in 10 CFR 50.5 Licensee management stated that special tests are conducted within the controls of the test program described in any of the above documents. Administrative controls for special test, per se, have not-been established. The inspector verified that required Nuclear Safety

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Evaluations for' Unreviewed Safety Question determination (USQD), and Technical Specification reviews and approvals are performed for special .

tests. Based on discussions with licensee management and a review of th program documents, the administrative controls appear to be adequat The licensee's post-modification functional test requirements delineated in CP-134 are intended to verify that modified system / subsystems and/or -

components. meet the design acceptance criteria. An inspection of the -

implementation 'of the post-modification test program will be required to assure procedural and regulatory compliance.

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Within this area, no violations or deviations bere identifie .

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