ML19325E339

Forwards Environ Qualification Enhancement Program Addressing Listed Areas,Including Staffing,Procedures & Training

ML19325E339
Person / Time
Site:	Crystal River
Issue date:	10/23/1989
From:	Ken Wilson FLORIDA POWER CORP.
To:	Taylor J NRC OFFICE OF ENFORCEMENT (OE), NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM)
Shared Package
ML19325E340	List: ML19325E339 ML19325E341 ML19325E809
References
3F1089-18, NUDOCS 8911060280
Download: ML19325E339 (14)

Text

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'i COhPOR ATION October 23) 1989 3F1089-18~

Mr. James M. Taylor, Director.

Office of Enforcement U. S. Nuclear Regulatory Commission .

ATIN: h= ant Control Desk -

1- Washington, D. C. 20555

Subject:

Crystal River Unit 3 l Docket No. 50-302 Operating Licence No. DPR-72 '

. Envium =rital Qualification Enhars Eni==>t F% cuu l

Dear Sir:

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Enclosed please find a description of Florida Fower Corporation's  !

Environmental Qualification Enhar w i-uit Program as L (FPC) ,

! identified in our letter dated Octr**r 17, 1989.

(- Should there be any questions, please contact this office.  ?

Yours very.truly, Kenneth R. Wilson Manager, Nuclear Licensing ,

WIR: mag .

Atts.

xc: Regional Administrator, Region II Senior Resident Inspector 8911060200 891023 M/

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POST OFFICE BOX 219

• CRYSTAL RIVER, FLORIDA 32629 0219 * (904) 5634943 A Florida Progress Company

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ENVIRONMENTAL QUALIFICATION ENHANCEMENT PROGRAM FLORIDA POWER CORPORATION

.. CRYSTAL RIVER #3  !

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SUMMARY

. Florida' Power Corporation has initiated an EQ Enhancement Program for the purpose of identifying'and implementing specific activities which will ensure the continued regulatory compliance over the life of the plant.

Thore tre six. key areas that are being addressed by the enhanced program.

. Organization / Staffing

. Procedures

. Field Verification

. Documentation

. EQ Master List

. Environment Parameters l; . Training l-ORGANIZATION / STAFFING l This activity includes new EQ positions. These positions were used L to establish an on-site EQ engineering group. A single point of accountability within Nuclear Operations was also established.

PROCEDURES An upper tier procedure has established the total scope. of responsibilities throughout Nuclear Operations. Other procedures are being developed / revised as necessary.

FIELD VERIFICATION A Field Verification Program will be conducted.to re-establish and fully document the qualified base-line configuration of EQ squipment.

DOCUMENTATION The existing Vendor Qualification Packages (VQP's) are to be  !

reorganized and supplemented so they may be more easily understood and utilized by all organizations who participate in maintaining the qualification of equipment. The Vendor Qualification Packages will be further supplemented by the development of an EQ Maintenance Manual and a set of EQ installation detail drawings.

EO MASTER LIST The EQ Master List and the Safety List will be reconciled into a single document, the Safety List. Unique identification numbers will be assigned to bulk commodity components used in EQ applications (grease, etc.). The selection of equipment included in the program will be formally documented using methodologies described in Regulatory Guide 1.89, Rev. 1, Appendix E.

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ENVIRONMENTAL PARAMETERS  ;

Florida Power will upate the information used on the Environmental Zone Data Sheets. This includes a plant specific Beta dose ,

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calculation, a review of the MSLB analysis, and revision of the zone profiles necessary to support the Enhancement Program. .

TRAINING EQ training is being performed in two steps. Engineering provided an awareness training to Nuclear Operations. Detailed training will be added/ revised to the present training programs taught by FPC's Training Departnent. The results of the enhancement will  !

provide the technical input to the Training Department's Lesson Plans. j SCHEDULE Attachment A is a schedule showing current key milestones.

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~ r DETAILED DESCRIPTION OF THE EO ENHANCEMENT PROGRAM Florida Power has in place the elements of our EQ Enhancement '

Program. Key FPC individuals have been assigned to the project.

FPC has been careful to use outside resources that have established EQ expertise and not involved in the original EQ Program.

A key to our existing program is the extensive EQ modifications performed in the 1985 installation of a large amount of new equipment known to be qualified due to its wide industry use.

Therefore, the enhancement program is not expected to result in large plant modifications.

The following is a detailed discussion of the seven groups of recommended activities.

ORGANIZATION The success of the EQ Program requires that activities and groups work together. Organizational changes were implemented to ensure the entire EQ process works in an efficient coordinated manner.

Three significant changes were made:

. Sinale Point Resoonsibility l The Director, Nuclear Operations Engineering and Projects,

! has been assigned the responsibility for CR-3's EQ Program.

l He has the ultimate responsibility for the implementation and administration of the Crystal River Unit 3 Environmental Qualification Program.

j . Environmental Oualification Enaineerina GrouD Engineering has established a dedicated site engineering group. This group is responsible for maintaining the existing Engineering Environmental Qualification Program, provide input to the enhancement activities, receive the enhanced documentation, and maintain it. This group also has the responsibility for reviewing several documents.

. Engineering Studies

. Conceptual Designs

. Specifications

. EQ Related Modifications

. Environmental and Seismic Qualification Program Manual

. EQ Related Instruction Manuals

. EQ Related Vendor Technical Manual

. Vendor Qualification Packages

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• I The' group reports to the Manager, Site Nuclear Engineering and is comprised of:

. Supervisor

. Senior I&C Engineer

. Senior Mechanical Engineer

. Senior Procurement Engineer

. Equipment Qualification Specialist

. Established A Dedicated EO Enhancement Pro-lect Oraanization The Manager, Nuclear Elect /I&C Engineering has the overall responsiblity for the Enhancement Program. Resources within our Configuration Management group, craft personnel, Site Engineering, Nuclear Operations Engineering, and site project management have been included in the project team. Expert outside resources are supplementing the FPC effort.

PROCEDURES Various- procedures must be written / revised to support the Enhancement Program and the new on-site EQ engineering group.

. Procedure NOD-39 has been added to the Nuclear Operations Department Manual to establish the single point of accountability and interface activities in the organization i (copy attached).

. A Nuclear Engineering Procedure (NEP-232) has been issued to cover EQ walkdowns (copy attached).  !

. Eleven Nuclear Engineering Procedures are being revised to support the recently established EQ engineering group and support the EQ Enhancement Program. These will be issued by October 31, 1989.

. Various plant procedures are being reviewed to include the site EQ group. These will be revised by October 31, 1989.

FIELD VERIFICATION FPC has put in place an organization to support the Field Verification. Support is being provided by the Impell Corporation.

Their specific tasks are:

. Review the existing FPC walkdown information to maximize the wa'Lkdown efficiency. This activity is complete.

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. Prepara an EQ walkdown issua document. This document defines l' the important criteria, by device, that the walkdowns must inspect to. Its basis is a review of Qualification Test i Reports, Instruction Manuals, NRC Information Notices, and '

I Vendor Bulletins, etc. This document is being prepared in i sections and is approximately 75% complete at this time. )

.- Prepare a procuroment " Hit List". This is - a list of materials / spare parts that need to be available to support the walkdowns. This is especially important to support the repair l of any equipment found in an unqualified condition. This L document has been issued and will be revised as necessary.

L . Prepare a " weep-hole" criteria for Crystal River Unit 3. This l- document defines the physical configuration requirements for l " weep-holes". This document will be used by the walkdown team to establish the location of any weep holes, have them drilled, and verify their acceptance. The criteria is

( complete and issued. Any walkdowns completed before the

issuance of the criteria will be revisited and brought into compliance. l Prepare walkdown packages l . in accordance with Nuclear i Engineering Procedure NEP-232. These packages are developed i

to define what must be inspected by the walkdown team. Each i end device has a package. All walkdown packages for inside the containment are cor.plete and are being scheduled for Refuel 7; 75% of the packages for walkdowns outside the containment are complete. The remaining packages will be l-complete before they are needed.

. Perform the actual walkdowns. The walkdowns are performed by a group consisting of: EQ Engineer from IMPELL, FPC engineering person, and a craft person. This is the minimum makeup of a walkdown team. The walkdown teams have received l special training. A pilot walkdown was completed on August-1, 1989 to prove procedures, methodologies, and qualification of personnel. Walkdowns outside the containment will be complete before Refuel 7, unless access is restricted due to the plant operation, and walkdowns inside the containment will be done during Refuel 7. The walkdowns are on schedule.

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DOCUMENTATION  ;

.Tenera Engineering Services has been hired to organize / prepare all 1 documentation for the Enhancement Program. They will perform 100% l technical review of the EQ information including: existing VQP's, Instruction Manuals, walkdown documentation, and test reports.

There will be several deliverables from this task.

. Vendor Qualificationi Packages (VQP's). New VQP's will be developed to ensure Crystal River Unit 3 is documented to be in compliance with our regulatory commitments. These VQP's

, will be developed by equipment type (e.g., Rosemont 1153 Series B Transmitters). The format of the VQP's is:

. Cover Sheet

. Revision Log

. Open Items Log

. Table of Contents

. Summary of Qualification j . SCEWS

. Equipment Evaluation Checklist

. Analyses

. Environment Test-Reports l . Maintenance Data Sheets l . Evaluation of Regulatory and Vendor Bulletins j . Miscellaneous Documents The above items will be contained in a binder (s) for easy retrievability. The walkdown documents will be filed

! separately in file drawers by equipment tag number. The draft VQP's are being prepared approximately 13 per month with y completion of all V0P's in the draft stage by December 1989.

I Final VQP's will 'be issued after the walkdowns are I incorporated. The scheduled completion is 60 days following Refuel 7.

. EQ Maintenance Manual. Through the VQP's development activity, EQ maintenance required will be defined. This information will be formalized in an EQ Maintenance Manual.

It is also recognized that each time some maintenance is performed on an EQ device, whether it is EQ maintenance or not, there is a potential for violating the qualification of a device. Therefore, the EQ Maintenance Manual dispositions all suggested maintenance activities in both the qualification documentation and Vendor Instruction Manual. This manual will be complete in December 1989 and will be issued in January 1990.

. Installation Drawings. This is a series of drawings to be developed to graphically depict the minimum acceptance installation configuration required to maintain environmental qualification for each type of equipment (Attachment B).

These will be complete in December 1989 and will be issued in January 1990.

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o e EO MASTER LIST IMPELL Corporation has been hired to develop an EQ Master List completely independent of the existing Master List. The two lists will be reconciled.

Shutdown Logic Diagrams (SLD's) will be prepared for each design

' basis event postulated in accordance with 10CFR50.49. One SLD will be prepared for each event considered, depicting each system credited in the Safety Analysis and identifying the safety function (s) support by the system.

Impell will then develop Safety Function Diagrams (SFD's) . Each system identified on the shutdown logic diagrams will be evaluated to determine the set of equipment which must function in order to fulfill the design basis safety functions considered in respective shutdown analyses.

The SFD are comprised of composite SFD's, detail SFD's, and an associated equipment data base. ,

. SFD will identify system redundancies, interfacing system dependencies, and automatic functions relied upon for design basis event mitigation. ,

. Composite SFD's will identify the actions required of all active components within a system, as well as the condition of significant passive components essential to the overall systems response to a postulated event.

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. A data base is also prepared for each component as appropriate:

. Component Tag Number i . Component Name l . Component Function / Safety Function l

. Component Active / Passive Designator

. Power Supply i . Associated Relays l . Associated Limit Switches 1 . Associated Cables l . Component Location l

. Associated Flow Paths

. Associated Components

. Component Operating Times

. Associated Splices, Junction Boxes, etc.

Analysis of the above three items will result in the new EQ Master

, List. As can be seen, this list will have a well-documented base l that will be easy to use and provide consistent results.

l The new Master List is scheduled to be complete and reconciled to i the old list by the end of January 1990.

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1 ENVIRONMENTAL PARAMETERS l Some specific environmental evaluations are being performed to

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strengthen the Equipment and Seismic Qualification Program Manual.

. A general area Beta dose calculation specific to Crystal River Unit 3 is being performed. This activity has just started.

.. A' technical review of the profile for the main steam line break inside' containment will be done. The initial effort is done and is now being verified.

. Update any ' zone profiles as necessary. None identified at this time.

. A temperature monitoring program is being developed by our new EQ Site Engineering group. This will ensure temperature changes are recognized and incorporated in.the qualification program.

r TRAINING Florida Power recognized the need to provide EQ awareness training to the technical staff in 1988. During the evaluation of our EQ Program completed in June 1989, it was recognized that more training was required than planned and to a larger group than just the technical organization. The Enhancement Program provided the -t awareness training and establishes the interface for comprehensive training by the Training Department. -

The awareness training was performed in August 1989 with approximately 245 Nuclear Operations personnel present. The training was in three modules:

. MODULE 1 - INTRODUCTION l a) Introduction 1; b) Definitions

! c) E.Q. Regulations l d) E.Q. Program Implement.ation e) Division of Responsibilities f) Summary ll . MODULE 2 - TECHNICAL REQUIREMENTS l a) Introduction b) Activities Which Necessitate Program Update c) Modifications i d) Maintenance Feedback e) Replacement Equipment l f) Noncompliances i

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. p MODULE 3 - MAINTENANCE a) Introduction i b)' . Responsibilities of Maintenance People c) Configuration >

d) Aging Degradation e) Limitation on Typical Equipment Limitorque operators ASCO Solenoid Valves i NAMCO Limit Switches '

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Terminations

'f) Summary  ;

Each module is approximately one hour in duration. Video tapes have also been produced to allow those not present during the course to view.

The following groups were represented at the awareness training:

. Engineering

. Fuel & Safety Analysis  ;

. Configuration Management ,

. Plant Technical Support i

. Plant Maintenance .

. Quality Programs I

. Purchasing & Contracts

. Material Control

. Records

. Training

. Compliance

. Licensing All technical people in Nuclear Engineering have received the training. ,

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l The Site Nuclear Services Supervisor EQ has the responsibility to provide input to the . Training Department for EQ technical requirements. He also reviews the EQ Lesson Plans.

MISCELLANEOUS There are several activities being implemented with the Enhancement 1 Program not covered above:

. The new VQP files being generated will include a microfilm copy in Records Management along with two controlled hard copies. One copy will be located at Crystal River and the other at General Office Complex in St. Petersburg.

. EQ equipment is being tagged in the plant. Basically, the conduits feeding the equipment will have a colored identification strip placed on them.

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)! . All modifications for Refuel 7 wil.1 be reviewed to ensure they l

'a have no impact to the EQ Program or the impact was properly I considered and included in the modification.

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