ML20214K087
| ML20214K087 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 02/20/1985 |
| From: | White R LAWRENCE LIVERMORE NATIONAL LABORATORY |
| To: | Merriweather N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| GL-83-28, NUDOCS 8612020143 | |
| Download: ML20214K087 (8) | |
Text
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'[~l Lawrence Livermore National Laboratory j
f;lJV February 20, 1985 Mr. Norm Merriweather U. S. Nuclear Regulatory Commission 50 30 101 Marietta Street, NW Suite 2900 Atlanta, Georgia
Dear Norm:
Ifere is the Crystal River report.
If after reading it you have any comments give me a call.
Sincerely, R. L. White NSSP Project Manager RLW:1s Enclosure as stated Uni,ersitv o! Cabtornsa lawrence livermore Nationallaboratory 8612O20143 850220 n o 8014 5 PDR ADOCK 05000302
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R. L. White LLNL/NRC INSPECTION REPORT CRYSTAL RIVER 3 NUCLEAR POWER PLANT DOCKET NO. 50-302 LICENSEE EMPLOYEES CONTACTED F. Zimmanck....... Supervisor, Modification Testing J. Cooper......... Manager, Modification Testing F. Sullivan....... Proj ect Engineer L. Kelly.......... Supervisor, Project Managers M. Jones.......... Engineering Aid-Modifications Group D. Beach.......... Project Engineer
- 11. Geiston........ Supervisor, Proj ect Engineers R. Carbiener...... Compliance Engineer POST MODIFICATION TESTING The inspector reviewed the licensee's post modification testing procedures and activities to ensure the requirements of Generic Letter 83-28 were being met and that the licensee's response was being implemented. The inspector examined procedures, in progress modification packages, and modification records that were complete. The inspector also interviewed responsible licensee personnel to deter.nine the adequacy of the licensee post modification 1
program.
R. L. White LLNL/NRC Crystal River 3 Compliance Procedure CP-134, Revision 2, Preparation, Approval and Performance of MAR Functional Test Procedures, is the procedure used to establish a program to assure the functional operability of systems, subsystems, and components that have been modified in design or technical characteristics. The procedure is applicable to all plant personnel.
It requires that tests be identified, changes to tests be identified, and test results that include inspection and test data be provided in the final Modification Approval Record (MAR) package. In addition to CP-134, the fol-lowing related procedures were reviewed:
Compliance Procedure CP-114, Procedure for flandling Permanent Modifications, Temporary Modifications, Modification Revisions, Field Change Notices, and Advanced Field Change Notices, Revision 41.
Compliance Procedure CP-113, Ilandling and Controlling Work Requests and Work Packages, Revision 39.
Compliance Procedure CP-115 In-Plant Equipment C1,arance and Switching Orders, Revision 49.
R. L. White LLNL/NRC Outage and Modifications Procedure, Manual M0P-502, Filing and Distribution of MAR Documents, Revision 2.
Safety-Related Engineering Procedure Number 1, SREP 1, Safety Safety Identification and Design Input Requirements, Revision 7.
Safety-Related Engineering Procedure Number 6, SREP 6, Prepara-tion and Control of a Modification Approval Record (MAR),
Revision 7.
The inspector confirmed by interviews and procedure review that the licensee program for post modification testing included the following elements:
Documents which relate to modification activities describe or reference the necessary testing prict to returning the structure, system, or component to an operable status. These documents require a signature indicating satisfactory completion of post maintenance testing before the document may be filed as a safety-related record.
R. L. White
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LLNL/NRC Criteria exist and responsibilities are delineated for review and approval of modififcations and subsequent testing. At present this responsibility is assigned to the project engineer in charge of each modification. As a large volume of modifications are planned for the upcoming outage, the project engineer is assisted by a post modification testing group which writes the procedures for post modification testing and the permanent surveillance proce-dures which will follow the completion of the modification.
Criteria exist and responsibilities are delineated for inspection and data verification of the testing by QA, QC, maintenance, engineering, or other responsible and knowledgeable personnel.
The inspection data is routed back to the project engineer who has the responsibility for acceptance of the data.
In many cases the project engineer observes the post modification testing personally although procedures allow this function to be assigned to other knowledgeable personnel.
Administrative controls exist for the preparation, documentation, reviews, approval of results, transfer and retention of safety-related modification records in the records storage facility.
The controls provide for the approval of the modification package,
R. L. White LLNL/NRC identification of the other personnel who performed the modifica-tion, and identification of the personnel who were required to inspect the work and the subsequent testing.
The inspector reviewed the documentation for several modification approval records and their related functional test procedures. The test procedures are controlled by a Procedure Review Record (PRR) and a 10CFR50.59 check list. The PRR provides a description of the change, reasons and references for the change, a safety evaluation, and a listing of the procedure approvals required.
The PRR and the functional test procedures are guided by Compliance Procedure CP-134. The following MARS and their test procedures were reviewed:
Procedure 80-11-40-1, MAR Functional Test Procedure for NNI/Y Back Up Power Supplies.
Procedure MAR 83-08-29, Revision TP1, MAR Functional Test CRD Breaker Short Trip Addition.
Procedure 80-10-66, Emergency Feedwater Initiation and Control.
I R. L. White LLNL/NRC 4,
Procedures MAR 83-08-29 MAR and 80-10-66 were still in the working stage, and as such, the procedure approvals were still not complete. However, in discussions with the project engineers and in a review of the procedures, it was noted that CP-134 was being interpreted dif ferently by different project engineers. Specifically, some engineers followed the methods outlined in CP-134 verbatim while other project engineers used it more loosely as a guide. This different interpretation appeared to be caused by the use of the words " MAR Writers' Guidelines." The guidelines, however, were procedures using the word "shall" for instruction in writing proce-dures. The problem of interpretation was discussed with the supervisor of the project engineers and also mentioneu in the exit interview. The super-visor of the project engineers stated that CP-134 would be reviewed and the ambiguity clarified. This resolution is acceptable to the inspector.
The inspector reviewed several completed MAR packages in the document room.
These MARS were revie*!d for tm ting procedures, procedure approval sig-natures, and for proper compliance with procedures. The following MARS were reviewed:
MAR 84-05-05-01, Alternate Gasket Material for RWV-34 thru 38.
MAR 83-05-21-01, Emergency Diesel 18.
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'HAR'82-07-09-01, Moving Check Valves in the High Pressure s
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A MAR 84-07-07-01, Hurricane Protection Watertight Gates 8A & 8B x
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!!o deviations were identified in the review of these completed MARS.
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The inspector reviewed the CRD breaker shunt trip addition modification package to confirm that the vendor post modification testing was incorpor-e.
ated into procedures. The test procedures were provided in Babcock and Wilcox letter from M. R. Stephens to R. A. Webb, dated June 26, 1984.
These procedures were used by the project engineer in establishing the
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reactor trip breaker post modification test procedures and the surveillance procedures.
The inspector identified no deviations or violations in the review of programs for post modification testing procedures.
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