ML20126M410

Insp Rept 50-302/85-15 on 850325-29.Violations Noted:Failure to Assure Conditions Adverse to Quality Promptly Corrected, Failure to Escalate Audit Finding to Ncr & Failure to Perform Tech Specs Audits & Criterion II Reviews

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: ML20126M370 ML20126M400 ML20126M410
References
50-302-85-15, NUDOCS 8506200326
Download: ML20126M410 (14)

See also: IR 05000302/1985015

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UNITED STATES

p Kf rog'o NUCLEAR REGULATORY COMMISSION

[" REGloN 11

101 MARIETTA STREET, N.W.

g j

• ;e ATLANTA, GEORGI A 30323

%,...../

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 M v 4 2 85~

G. A. Belisle g Dde Yigned

Accompanying Personnel: J. H. Moorman, Region II

M. A. Scott, Region II

Approved by: dM I 8 '

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

• 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

. 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 I

Required Intervals, paragraph 9. The licensee denied this violation by I

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:

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Personnel responsible for preparing implementing procedures understand

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 N45.2.23-1978, Qualification of Quality

Assurance Program Audit Personnel for Nuclear Power

Plants

(f) Regulatory Guide 1.33, Quality Assurance Program

Requirements (Operation)

(g) ANSI N18.7-1976, Administrative Controls and

Quality Assurance for the Operational Phase of

Nuclear Power Plants.

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(h) Technical Specifications, Section 6

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:

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The audit program scope was consistent with Technical Specifications

and QA program requirements.

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Responsibilities were assigned.in writing for overall management of the

audit program.

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Methods were defined for taking corrective action on deficiencies

identified during audits.

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The audited organization was required to respond in writing to audit

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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

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:

FSAR 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 Emergency Preparedness

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 l

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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 .

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 .

this inspection. Failure to achieve resolution of this problem through the l

required NCR process constitutes violation 302/85-15-02.

9. Failure to Perform .TS Audits and Criterion II Reviews Within Required l

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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 l

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Section 4.0.2 states the following: l

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a. - A maximum allowable extention not to exceed 25% of the surveillance

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

schedules are updated twice a year. The application of TS 4.0.2 to TS

j Section 6 is not appropriate.

! 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

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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

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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10. 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

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

j 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

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 '

4- -audit closure. Some of-these original records are maintained for a year or

! longer ~ depending upon how long it takes to close the audit. Storage of

1: these records in a one-hour- fire rated cabinet is acceptable providing

l 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

l 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

[ program requirements constitutes violation 302/85-15-04.

11. Commitment Tracking

l The 'following paragraphs describe issues which collectively constitute an

- unresolved item regarding the, effectiveness of -the licensee commitment

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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 i

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

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(b) Regulatory Guide 1.33, 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:

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Administrative controls were established to assign departmental

responsibilities, authorities, and lines of communication in

conformance with requirements of 10 CFR 50, Appendix B, and the

accepted QA program.

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Managers, group leaders, and staff members understand their

responsibilities and authorities.

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The above personnel were qualified for the related work.

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

j 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

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training consisted of classroom instruction supplemented by on-the-job

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training. The majority of the technical staff are degreed engineers. A

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

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relative to the offsite support staff function with selected personnel:

, NQAP Procurement, Code: PCMT, Revision 1

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NQAP- Personal Training and Qualification, Code: PTQ, Revision 0

NQAP Internal and External Reporting Requirements, Code: REPT,-

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Revision 0

NQAP Modification Control, Code: MCTL, Revision 0

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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

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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

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Change Notice '(FCN), Revision 5

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13

EGN-1 Preparation, Review and Approval of Engineering Studies,

Revision 0

NL-06 Resolution of Safety Concerns, Revision 4

NL-07 Control of Crystal River Unit 3 Licensing Documents,

Revision 4

NL-09 Nuclear Licensing Commitment Tracking, Revision 2

NL-10 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.