IR 05000220/1989001
| ML17055E547 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 02/09/1989 |
| From: | Anderson C, Roy Mathew, Woodard C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17055E546 | List: |
| References | |
| 50-220-89-01, 50-220-89-1, NUDOCS 8903070066 | |
| Download: ML17055E547 (40) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-220/89-01 Oocket No.
50-220 License No.
DPR-63 Licensee:
Nia ara Mohawk Power Cor oration 301 Plainfield Road S racuse New York 13212 Facility Name:
Nine Mile Point Nuclear Station Unit
Inspection At:
S racuse New York Inspection Conducted:
Januar 3-6 1989 Inspectors:
C.
H. Woodard, Reactor Engineer, Engineering Branch, Plant System Section c)a A.< g,~,fh, R.
K. Mathew, Reactor Engineer Engineerin Branch, Plant System Section Approved by:
C. J.
Anderson, Chief Plant Systems Section, Engineering Branch date date date Ins ection Summar
Routine announced ins ection on Januar 3-6 1989 Ins ection Re ort No. 50-220/89-01 A~:
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Mil Point Unit 1.
The areas inspected included organization and staffing, quality assurance, plant modifications, technical training, management support and communications.
Results:
One apparent violation was identified regarding late reporting of a
=design deficiency relating to undersized control cables in the 125Y DC system.
gqoso7oo~a s~~~-~
PDR ADOCK 050002PO
DETAILS 1.0 Persons Contacted Nia ara Mohawk Power Cor oration NMPC
- J. J.
Bebko, Manager, Nuclear Compliance 5 Verification L. Clark, NSD, Administration
- W. R. O'Angelo, Manager, Consulting Services R.
Eastham, Acting Assistant Manager, Unit 1 Modifications
"R. Fassler, Supervisor, Quality Assurance Engineering P. Francisco, Assistant Manager, Licensing
"M. Goldych, Assistant Superintendent, Training, Nuclear Division
"D. Greene, Acting Manager, Nuclear Technology G. Gresock, Manager, Nuclear Engineering N. Holden, Generation Specialist, Nuclear Training D. J. Jakubowski, Associate Electrical Engineer
"L. A. Klosowski, Manager, Unit 1 Design J. Kroehler, Manager, Quality & Reliability Engineering
~D.
E. Sandwick, Manager, Engineering Services R. Slaow, Associate Senior Electrical Engineer
~C.
D. Terry, Vice President, Nuclear Engineering 5 Licensing D.
W. Williams, Nuclear Engineering Training Coordinator
- S.
Wi lzeck, Jr.,
Manager, Nuclear Technology R. Pasternak, Manager, Site Engineering
- Denotes those attending the exit meeting.
2.0 Objective The objective of this inspection was to assess the adequacy of the licensee's engineering program for design control, interfaces with other
-;-".":nal a.;='x;erne; or anizations, management support, staffing levels and experience, training and responses to NRC requirements and concerns.
3.0 En ineerin Su ort Or anization The Corporate Engineering staff is administratively divided into two groups, one for each unit.
The inspectors held discussions with licensee management personnel to review the division of responsibility in the Engineering Organization.
The Nuclear Engineering and Licensing Organization is divided into seven sections.
They are Nuclear Compliance and Verification, Nuclear Engineering, Special Projects, Licensing, Nuclear Technology, Site Engineering and Nuclear Engineering Services.
Each section is headed by a manager who reports to the Vice President.
The Nuclear Engineering Section is headed by Manager, Nuclear Design and is divided into four groups.
They are Mechanical, Electrical, Structural
and Modifications groups.
Each group is supervised by an Assistant Manager or Lead Discipline Engineer and consists of Project Lead Engineers, Discipline Engineers, Designers and Draft.-Technicians.
(See Attachment B
for an organization chart)
The Modification group (also called the Project Group) is the focal point for the coordination of managerial support for Project Engineering, Site Engineering and Configuration/System Engineering.
The primary function of these groups is to perform modifications and assure that design/engineering is completed based upon conceptual design infor-mation and in accordance with the Final Safety Analysis Report.
The Nuclear Technology Section manages and directs Nuclear Division activities associated with Nuclear Fuel Management, Plant Performance Improvement, Nuclear Plant Licensing, Corporate Health Physics, and Consulting Services.
The Licensing section maintains the FSAR, performs safety services, and takes the lead in maintaining communications with the NRC.
The Consulting group reviews engineering studies, performs independent reviews of designs, prepares technical and policy documents for regulatory studies and furnishes specialist support for the project.
The Fuel Manage-ment Group provides fuel supply data, analytical support and a centralized plant productivity improvement program for the plant.
The Plant Performance Improvement (plant productivity group) is responsible for developing, implementing and monitoring an equipment performance trending program.
The Nuclear Compliance and Verification section, ensures that verification and audit services are provided so that Nuclear Department Commitments are accurately stated and fulfilled.
The Site Engineering section which is located at the site is headed by the Manager, Site Engineering.
It consists of Material Engineering, ISI/IST, Technical Evaluation and Design.
This section is responsible for coordinating engineering design, modifications implementation and expediting Engineering Corporate support for plant operation.
The Inservice Testing and Inspection group is assigned to the site engineering department to improve the technical evaluation of identified problems.
The Material Engineering group performs spare parts procurement, performs commercial grade determination and dedication, and reviews all procurement specifications'he Nuclear Engineering Services section provides ongoing support services to the Nuclear Engineering and Licensing Department in the areas of Information Management, Administrative Services, Human Resource Development and Computer Services.
Mana ement Con rois Staffin and Ex erience Management controls, staffing and experience were reviewed to establish the adequacy of the license's effort to ensure that appropriate manage-ment attention and resources are assigned to problem area The Nuclear Engineering and Licensing Division strategic goals developed by the corporate organization are disseminated to each department, section and group through department managers and lead engineers.
These goals are further developed in the performance objectives for individual managers and supervisors.
These objectives include budgetary guidelines, ALARA goals and significant plant tasks identified as corrective actions/concerns to be accomplished.
The performance of the managers is evaluated based on their accomplishment of these objectives/tasks.
The licensee continues to make improvements in their engineering organiza-tion much of which is geared towards improving site engineering support for the station.
Licensee management is considering giving design authority to the Site Engineering group to develop minor modification designs for expediting engineering support for the station.
Approximately 50% of the engineering design work is handled in-house and the remaining 50% is done outside.
The various engineering discipline managers have been given the authority to approve outside consultant services, should the need arise.
This authority enhances the ability of the Nuclear Engineering Department to provide design and engineering support with the existing manpower.
Vendor or contractor engineering work activities are monitored and controlled by a cognizant project engineer.
He is responsible for coordinating work activities between licensee, gA and contractor personnel.
Site Engineering handles both Unit 1 and 2 engineering needs and is staffed by 137 people.
Twenty-seven employees are Niagara Mohawk and-the remaining are contractor personnel.
Since both units are going through an outage, a large amount of manpower is used in the ISI/IST area (This area lacked adequate coverage.during the last SALP period).
The licensee also has an aggressive spare parts engineering program to support the material needs of the plant.
Approximately 25-30% of the permanent positions are vacant in the site engineering department but are temporarily filled with contractor personnel.
P Design Engineering performs design services for the power plant.
Approxi-mately 20% of the positions in this department are vacant.
Most of the positions are temporarily filled by qualified employees from other disciplines.
About 100 different projects are in process at any given time and include minor and major modifications.
A review of modification reports for the month of October 1988 shows that there are 231 outstanding modifications requiring engineering action.
Out of these, only 22 need to be completed for the existing outage work.
The remaining packages are low priority work.
The licensee has established a priority system whereby all safety significant projects are priority 1.
Other work which affects safety systems are priority 2.
All priority 1 and 2 projects are reviewed by engineering managers during weekly and monthly meetings.
This system is effective as evidenced by the observation that all priority safety significant projects are on schedule.
The average turn around for
short, single discipline mini-projects for priority 1 activities is about 1-2 weeks'nd short, multidiscipline mini-projects is about 1-2 months.
Turn around also depends on the nature and complexity of the project.
The turn around time for large projects for priority 1 activities is about one year.
Modification projects which require spending of less than
$50,000 are approved by the assistant manager.
Higher cost projects require modifica-tion committee (C2) review for budgetary approval.
The priority for budgetary approval considers whether the modification is a priority item or if it is for regulatory compliance.
Priority 1 items and licensee commitment items are given higher priority for budgetary considerations.
The inspectors reviewed the Nuclear Engineering and Licensing personnel qualifications and experiences and concluded that they are well qualified and experienced.
The summary of qualifications ancf experience for different categories of employees is shown in Attachment C.
The inspectors discussed with the licensee the level of management required for approving a
new engineering employee.
The Manager Nuclear Design
Project Engineer, Assistant Manager or Lead Engineers have the authority to request or hire new employees or contractor engineers.
Licensee manage-ment plan to fill all open vacancies by the end of this year.
In the meantime, sufficient authority has been given to the discipline engineer-ing managers to engage outside consultants if the need arises.
The inspectors reviewed the licensee's engineering, gA and administrative procedures and other documents as shown in Attachment A.
Based on the review, the inspectors concluded that the licensee has well defined written procedures to conduct engineering functions to support the plant.
5.0 En ineerin Modifications and Nonconformance Re orts In order to assess the quality of work done in the engineering department, mini-modification and major modification packages and nonconformance requests were reviewed.
The details of the review are documented below.
5. 1 Modifications Plant major modifications and minor modifications are performed per licensee Modification Procedures ND-100, Revision B, ND-100E, Revision 1,
and Site Administrative Procedure No. AP-6.0.
A request for modification (MOD) or addition may be prepared by any staff member.
This MOD request goes to a MOD request coordinator and is reviewed for priority and the need for the modification.
The review is conducted by a committee called the
"C2 Committee" consisting of the Plant Superintendent, the Manager of Engineering, and the Manager of Nuclear Technology.
Minor modifications do not require a detailed
review process.
A safety evaluation and independent review is per-formed and the package is submitted to Safety Operation Review Committee (SORC) for approval.
After approval, the project engineer coordinates with design engineering to perform the final design work.
Documents listed in Attachment A were reviewed in detail for adherence to requirements, clarity of instructions and levels of responsibility and authority assigned to various groups and positions.
The follow-ing randomly selected modification packages were reviewed to verify the implementation and adequacy of the design and the procedures.
(1)
Modification No. Nl-86-047; LPRM Detector Lead Connection/Cable Modification.
(2)
Modification No. Nl-080-072; Alternate Rod Injection System Addition.
(3)
Modification No. Nl-88-069; Diesel Generator 102 Roof Exhaust Fan/Breaker Replacement.
(4)
Modification No. Nl-87-091; Stack Gas Monitoring System Upgrade.
(5)
Modification No. N1-486-M1512; Torus/Drywell Vacuum Breakers Position Indication (6)
Modification No. Nl-487-019; Diesel Generator Crankcase Pressure Detector Modifications.
(7)
Modification No. Nl-486-MX037; Feedwater FCV Position Indication (8)
Modification No. Nl-88-067; Reroute N2 Vaporizer Unit Drainline.
Modification packages reviewed were found to be well organized, complete and in accordance with applicable procedures.
Materials, processes, parts and equipments were identified properly and were suitable for the application.
The applicable design inputs were correctly incorporated into the design and design interfaces were sufficiently addressed.
The work performed by consultants was adequately reviewed and processed per the procedures.
The safety evaluations and independent reviews were descriptive and supported the conclusions.
Based on the above review, the inspectors concluded that the licensee's design changes and modifications are performed in conformance with the requirements of the Technical Specifications,
CFR 50.59, the Safety Analysis Report and the licensee's guality Assurance Progra Volt DC Distribution S stem During the inspection, a review was performed of two of the licensee's restart engineered modification items regarding the 125V DC distribu-tion system and the 125V DC motor generator set battery charger.
On November 18 and December 19, 1988, in accordance with the require-ments of 10 CFR 50.72 and 50.73, the licensee notified the NRC ( LER 88-20) of their discovery of a potential design deficiency in the 125V DC electrical distribution system and declared that the system was outside of its design basis.
Based upon engineering load flow and voltage drop calculations conducted during the design phase of a battery related modification, the licensee determined that the design of some safety related 12SV DC control cables is inadequate, such that inoperability of the 125V DC distribution system could result.
In order to assess the licensee's findings and evaluate the design inadequacy, the inspector reviewed the following licensee's calculations:
(1)
125V DC - Train ll Load Flow/Voltage Drop for FSAR Case
"B" Emergency Scenario (Loss of Coolant Accident (LOCA) and Loss of Offsite Power (LOOP)) dated December 9,
1987.
(2)
125V DC - Train 12 Load Flow/Voltage Drop for FSAR Case
"B" Emergency Scenario ( LOCA and LOOP) dated December 9,
1987.
(3)
125V DC - Powerboard 16 Load Flow/Voltage Drop, FSAR Case (LOCA and LOOP) dated May 7, 1988.
(4)
125V DC - Powerboard 17 Load Flow/Voltage Drop, FSAR Case (LOCA and LOOP) dated May 7, 1988.
48.7 volts 1st minute, 107 volts 2nd minute.
Loads include Remote Shutdown Panel loads.
Calculations 1 and 2 show that the voltage available to operate safety-related loads at selected panelboards during the first and second minute of the accident, beginning with a fully charged battery at 125V DC, are as follows:
h Panelboard
Panelboard
51.1 volts 1st minute, 111.6 volts 2nd minute.
Loads include Remote Shutdown Panel load Panelboard
Panelboard
45.8 volts 1st minute, 19.6 volts 2nd minute.
Loads include Battery Charger MG Set 161 41.8 volts 1st minute, 42.5. volts 2nd minute.
Loa'ds include Battery Charger MG Set 162 The calculations identify these low voltages as a potential design deficiency.
The licensee's stated purpose of calculations 3 and 4 was to determine the voltage at powerboards 16 and 17 loads during the FSAR Case
"B" Emergency Scenario.
Replacement feeder cable sizes were calculated to obtain the rated voltage at the breaker closing coils.
These calculations show that by replacing the ¹6 AWG power cable from battery boards
and 12 to power boards 16 and 17 with ¹2 AWG cable that the worst case lowest voltage available for operating the MG circuit breaker coils is 92.5 volts (assumption of 105V DC battery voltage).
A minimum of 90 volts is required for the operation of the breakers.
The inspector found no deficiencies in the licensee's calculations including the assumption for the additional power cabling required to provide adequate voltage to powerboards 16 and 17.
The licensee agreed that calculation confirmatory measurements, would be made of the actual voltages available at these powerboards prior to start-up.
Licensee's Modification Number 85-092 to install the cabling including the related Safety Evaluation 88-017 were reviewed.
No deficiencies were noted.
This modification has been completed except for the termination of the cables.
The inspector noted that during a
DBA and LOOP, as a result of the undersized cables, the MG sets would not have enough voltage at their breakers for the breakers to function and transfer to AC power, with the Diesel Generator operating.
The MG sets would be operating on OC power instead of AC, drawing down the batteries, to the point that the diesels could trip on their trip solenoids'e-energization, as the battery voltage decreased.
The licensee's LER 88-20 dated December 19, 1988 regarding the undersized cable indicates that it had not been determined conclusively by them that a reportable condition existed.
guestions remained regarding the accident scenario to be considered and the calculation assumptions.
For certain accident scenario's and calculation assump-tions the licensee determined that the batteries would supply marginally adequate voltage for the breakers to function.
Under other conditions, breaker function could not be ensure It appears that information available to the licensee on December 9,
1987 and May 7, 1988 consisting of the load flow/voltage drop analyses should have led them to report this design deficiency issue significantly in advance of their November 18, 1988 10CFR 50.72 report.
This late notification is an apparent violation of the code of Federal Regulations Section
CFR 50.72 (Violation Item 89-01-01).
Motor Generator Set Batter Char es On May 12 and June 13, 1988, in accordance with the requirements of
CFR 50.72/50.73, the licensee notified the NRC (LER 88-13) of their discovery that the 125V OC system electrical design was not in compliance with the FSAR.
The original design basis for the 125V OC system in the FSAR assumes that the battery charger motor generator (MG) sets 161 and 171 to be safety-related.
However, a
CFR 50, Appendix B determination performed during January 1983 reclassified the MG sets as non-safety related based upon the fact that their failure, in and of itself, does not prevent or mitigate offsite exposures.
However, the Appendix B determination did not provide adequate justification for reclassifying the MG sets in that battery capacity was not addressed.
Root and contributing causes of this event were reported as personnel errors and the fact that the design basis of the 125V DC system is not clearly detailed in any single plant controlled document.
Initial corrective actions involved declaring the 125V DC system inoperable and reclassifying the MG sets as safety-related.
In order to qualify the MG sets as safety-related, the licensee is performing a review of all modifications and maintenance performed to determine if the function of the MG sets was compromised.
Any components installed in the MG sets which are determined to be unacceptable will be replaced during the current refueling outage.
The inspector found that the licensee i s still in the process of conducting component evaluations to ensure their class 1E quali-fication for the safety-related MG sets.
Completion of the evaluation, the engineering report and replacement of'components is projected/required prior to start-up.
The inspector had no further questions regarding this matter.
5.2 Nonconformance Re orts NCRs
]
A" Licensee procedures for addressing nonconformances include quality assurance procedure gAP 15.01, Revision 5 and Nuclear Engineering 5 Licensing procedure NEL-017, Revision 3.
To assess the adequacy of these procedures and compliance to the requirements, the inspectors randomly selected the following nonconformance reports for a
detailed revie NCR 1-88-0083 NCR 4-87-0004 Rejectable brazed joints noted during visual inspections.
Changes to the PASS System without any prior approval.
NCR 4-87-0005 Incorrect 47X relay used in reactor feedwater pump's auxiliary oil pump control circuits.
NCR 4-88-0002 Expansion plates purchased for Rx CLC heat exchangers quality are indeterminate.
NCR 1-88-0026 NCR 1-88-0055 NCR 1-88-0073 No accept/reject criteria for
.
inspection of fuel channels.
Diaphragm case bolting does not have full thread engagement.
LPRM adapters installation does not match.
For the NCR'
reviewed, the licensee program for addressing nonconformances, providing disposition, and evaluating for root cause is clear and well defined.
The NCR document dispositions point out the safety significance of the defects/nonconformances.
The corrective and preventive actions are well documented.
The Niagara Mohawk Power Corporate (NMPC) Quality Assurance Department (QAD) is organized into five divisions with each division reporting to the vice president of quality assurance, who reports directly to the president NMPC.
The five divisions are Nuclear QA Operations, Corporate QA, Quality First, Quality and Reliability Engineering, and Non-Nuclear QA Operations.
The Nuclear QA Operations division is located at the power plant site and has the responsibility, authority and accountability for quality assurance functions at both Units 1 and 2.
This group performs the day-to-day QA functions at the plants which include the administration, coordination and implementation of ISI, NDE, visual examinations-,
administration of QA site contractors, and routine survei llances.
This on-site group is broken down with separate quality program managers for Unit 1 and Unit 2 with support staff for operations, surveillance, NDE, and quality engineering/control.
This group interfaces with the Quality and Reliability Engineering Division at Salina Meadow The Corporate QA Division is organized into two groups; QA Audits and QA Services.
This division has responsibility, authority and accountability for QAD functions related to programs and procedures, internal and external QA audits, trending, and training coordination.
The Quality First Division is a single group organization whose functions include the performance of confidential investigations of quality concerns.
The Quality and Reliability Engineering Division (QRED) is located in the Salina Meadows office complex in the same office building as the Nuclear Engineering and Licensing Division (NELD).
This division consists of three groups; QA Engineering, Materials Quality Engineering, and Procure-ment and Quality Reliability Engineering.
QRED has the responsibility, authority, and accountability for quality assurance functions associated with engineering, design, procurement, materials, and reliability. Activities which are performed to carry out this responsibility include:
Reviewing plant modification design documents for inspectabi lity,
developing quality planning to support installation of plant changes and all supporting QA aspects of modifications.
Providing for control of purchased equipment through the contractor qualifications program, source surveillance, and receipt inspection.
Providing materials engineering support in the areas of material selection, welding, corrosion prevention, NDE, and fuel QA.
Providing reliability engineering services to support the engineering departments in equipment qualification, performing studies for equipment life extension, and implementing the component/equipment reliability program.
Interviews with the manager of QRED and other QA and engineering personnel and documentation reviews were conducted to review their organization, staffing, qualification of personnel and performance of the activities listed above.
QRED is currently staffed by 28 NMPC and two contractor personnel.
These include:
1 Manager, 12 Quality Engineers, 7 Materials Engineers, and 10 Procurement and Reliability Engineers.
The files for eight (8)
QRED inspection/audit personnel were reviewed in order to assess their current level of training, experience, and
qualifications for performing inspections in their areas of certification.
These files included the following types of documentation:
~
Prior education and experience
~
Classroom training records Reading record checklist for QA indoctrination of new QA personnel
~
Records of demonstration of inspection capability in areas of qualification/certification
~
QA inspectors certificates of qualifications
~
QA inspectors qualifications summary per ANSI 45.2.6 The files were in order and each file was current in that the certificates of QA qualification for each active i'tern included unexpired dates for the effective period for the certification.
The Quality Assurance Program, Administrative, and Operating Procedures listed in Attachment A were reviewed.
Based upon the review, the inspectors concluded that the QRED has well-defined written procedures to perform its.functions.
As reported in Section 5 of this report, the NCR's and engineering modifications listed were reviewed for compliance with the engineering and QA program and procedures.
No deficiencies were observed.
QA audit, inspection and surveillance data are recorded and trend-coded in accordance with QA Procedure 16.20.
The major trend code categories are:
Significance (major or minor), Apparent Cause (why did it occur),
Problem Type (what went wrong)
and Program Item (which program element was violated).
The major trend codes are then broken down into detailed trend code elements.
The data is summarized semiannually into a trending report which is issued by the VP/QA to all cognizant managers and to corporate management.
The January ll, 1987 Trend Report was reviewed.
In it the most frequent cause of discrepancies was non-compliance with procedures with a negative trend.
The inspectors concluded that the licensee trending procedure program appears to be effective in providing useful management information.
Quality and Reliability and Engineering Division Corrective Action Requests 5017, 5018 and 5021 were reviewed to assess the effectiveness of the QA surveillance in identifying major engineering deficiencies and establishing the corrective actions needed to correct these deficiencies and prevent their recurrences.
Details of these CARS are included in Section 7.0 of this report.
Based upon this review no deficiencies were observe.0
~Trainin In compliance with committments to ANSI/ANS 3.2-1982, Section 3.3 and 3.7 and ANSI/ASNE NQA-1-1983 and Addenda, Section II-2, the licensee developed a comprehensive Nuclear Engineering and Licensing Department (HELD) training manual in 1986.
Implementing Procedures for the training program NEL-026 "Training Program Implementation" and NEL-015 "Control of Consultants" were also developed.
The training program covers three phases of employee development:
initial training, continuing training, and management development training.
Implementation training plans developed for the program include indoctrination, individual study, classroom training, on-the-job training, and training in the use of specific procedures.
Training of HELD personnel is controlled and administered by Nuclear Engineering Administrative Services which reports directly to the Vice President of NELD.
In this organization, there is not a training organiza-tion or department.
Training is administered by a single administrative services employee.
With this organization structure; funding, staffing, and performance of training are a direct function of the direction and emphasis placed on training by senior engineering management.
The training administrator functions only to arrange and coordinate the training requested by engineering management.
Training capabilities available to the adminis-trator include the following:
Technical training at the Company Nuclear Training Center.
Nanagement development training at the Corporate Facilities.
Procedures training in-house utilizing HELD staff and consultant personnel.
Specialized technical training in-house utilizing staff and consultant personnel.
Other in-house or outside training as requested and authorized by HELD management.
A sample of the contents of the NELD training program including the following elements was reviewed.
Indoctrination into the utility station and its activities.
Nuclear codes, standards, and regulations training.
QA and QC standards and their use.
Functions and organization of the NR ~
Plant documents including technical specifications and safety analyses.
~
Key corporate and NMPC interfaces.
Procedural training including the detailed engineering and QA procedures.
No deficiencies in the content of the sample of the training program reviewed were noted.
The HELD training coordinator provided information relative to specialized training provided to selected individuals on a need basis, such as that received when a supplier makes a major modification to a system or equipment.
In addition, selected personnel are sent to outside meetings such as INPO and EPRI.
Outside employee self-improvement courses and training are normally the responsibility of each individual employee.
The training program -and its implementing procedures and related documentation were reviewed with the licensee to determine the current status of training for NELO personnel.
Based upon interviews with licensee training, engineering and QA personnel and upon the findings in licensee's QA Corrective Action Reports (CARs)
50. 17, 50. 18 and 50.21, the inspector determined that the licensee had identified problems in the implementation of their training program.
Licensee findings reported in CAR 88.5018 on October 5, 1988, included the following deficiencies in training:
Classroom training records sampled indicate that individuals have received less than twenty percent of the designated classroom training The On-The-Job Training Program as required in the training matrices has not been implemented.
The training required by the reading list section of the training matrices could not be verified.
The responsible managers are not keeping current the training criteria and requirements for training as evidenced by deficiencies in the training matrices.
The training staff (one person)
appears to be inadequate.
The workload appears overwhelming and includes non-training assignments.
Nuclear design personnel display evidence of lack of familiarity with applicable design bases (i.e.
codes and standards)
and procedural requirement Corrective Action Reports (CARs)
5017 dated October 5, 1988 and CAR 5021 dated December 1,
1988, document licensee QA findings of significant deficiencies in the training of contract engineering personnel.
The deficiencies involved permitting consultant engineering personnel to proceed to work prior to receiving the required indoctrination and training.
Licensee corrective action committment response to the CARs include the following:
~
Immediate corrective actions by management which includes the requirement that personnel (including contractors)
receive proper training and direct supervision before performing work detailed in the procedures.
~
Established cut-off date schedules for the identification of documentation of training needs and implementation of training to meet these needs.
Organizational and staffing improvements to support training needs.
Specific dates were established for accomp'li shing each of the detailed corrective actions in the CARs with the last corrective action date being February 15, 1989.
The CAR responses also include root causes and actions to be taken to prevent recurrences.
Root causes cited include insufficient attention to training by HELD managers, leads and supervisors, and cumbersome procedures.
Corrective actions include new procedures, emphasis from the Vice President HELD to the department managers on the need to properly train personnel and a weekly staff meeting review to assess training.
Review of the licensee's new (December 28, 1988) procedure training schedule, observations of classroom training sessions in progress, and discussion held with the training coordinator indicate that some progress is being made to overcome the training deficiencies cited in the CARs.
However, the corrective actions taken thus far are in their infancy and some have correction dates extending into February 1989.
As a consequence, evaluation at this time of the implementation of the committed corrections in the training program is premature.
A request was made for the training coordinator to provide a current status list of the training required and training completed for twelve
-.
selected engineering personnel.
The data was available but it required several hours of dedicated effort to extract this information.
At the present time there appears to be no easy way to determine the training status of personne The findings of the. inspection were discussed with the licensee's representatives periodically during the inspection.
An exit meeting was conducted on January 6,
1989 at which time the findings of the inspection were presented.
At no time during this inspection was written material concerning the inspection findings provided to the licensee by the inspectors.
The licensee did not indicate that any proprietary information was involved within the scope of this inspectio ATTACHMENT A DOCUMENTS REVIEWED HEL-010,, Revision 0, Nuclear Engineering and Licensing Department Organization.
NEL-011, Revision 1, Preparation and Control of NEL Procedures.
NEL-012, Revision 1, Controlled Departure from NEL Procedures'EL-014.A, Revision 3,
Document Control and Distribution.
NEL-014.D, Revision 1, Control and Distribution of Calculations.
NEL-015.F, Revision 2, Preparation of Request for Contractor guality
.gualification.
NEL-015.J, Revision 1, Test Control.
NEL-016, Revision 2, Corrective Action Requests.
HEL-017, Revision 3, Control of Hon-Conforming Items.
HEL-018, Revision 3,
Problem Report Program.
NEL-018A, Revision 0, Engineering Initiated Hold/Release Orders.
NEL-019, Revision 1, Certification of Engineering Inspection Personnel.
NEL-022, Revision 3, Design Calculation Preparation.
HEL-0022A, Revision 2, Detailed Guidelines for Design Calculations.
NEL-024, Revision 1, gualification of Nuclear Engineering and Licensing Department Personnel.
NEL-026, Revision 2, Engineering Training Program and Implementation.
NEL-027, Revision 4, Design Verification.
NEL-029, Revision 3, Notification under
CFR 21.
NEL-043, Revision 0, Equipment Failure Trending.
NEL-044, Revision 0, Equipment Performance Trending.
NEL-101, Revision 0, Nuclear Engineering and Licensing Department Procedures Program.
HD-015. 1, Revision 1, Preparation of Engineering Specification ND-100.A, Revision 1, Project Report Format and Preparation.
AP-6.0, Revision 6, Procedure for Modification and Addition.
ND-IOO.B, Revision 2, Conceptual Engineering Package Preparation.
ND-110, Revision 1, Project Communication and File Documentation.
ND-130, Revision 3, Design Input.
ND-140, Revision 2, Design, Changes to Plant Configuration or Modifications of NMP1.
QAP-1.01, Revision 9, Quality Assurance Department Organization.
QAP-2.01, Revision 2, Verification of Education and Experience of QA Department Personnel.
QAP-2.02, Revision 0, Qualification of Auditors and Lead Auditors.
QAP-2. 10, Revision 8, Training.
QAP-2.60, Revision 4, Qualification and Certification of QA Inspection and Test Personnel.
QAP-18. 10, Revision 10, Quality Assurance Department Audits.
QAP-16.03, Revision 5, Corrective Action Requests.
QAP-16.20, Revision 8, Tracking and Trending QAD Findings.
QAP-15.01, Revision 5, Control of Non-Conforming Items.
QATR-1, Revision 3; Quality Assurance Program Topical Report for Nine Mile Point Nuclear Station.
CFR 50.59 - Changes, Tests and Experiments.
Regulatory Guide 1.64, Revision 2, June 1976, Quality Assurance Requirements for the Design of Nuclear Power Plants.
ANSI N45.2. 11, Quality Assurance Requirements of the Design of Nuclear Power Plan s.
Final Safety Analysis Report, Niagara Mohawk Power Corporation, Unit 1, Revision 6.
ANSI/ANS-3.2-1982, Administrative Controls and Quality Assurance for Operational Phase of Nuclear Power Plants.
Technical Specifications, NMPC Unit ATTACHMENT 8 VICE PRESIDENT NUCLEAR ENGINEERING AND LICENSING I
I Manager Nuclear Compliance and Verification I
Manager Nuclear Engineering I
I Manager Spec ia I Projects Manager Licensing I
Manager Nuc lear Technology I
I Manager Site Engineering I
I Hanager Nuclear Engineering Services Manager Nuclear Design I
Materia I Engineering IS l/IST Technica I
Des ign Evaluation Unit
I I
Assistant Manager Hechanica I
I I
I I
Assistant Manager Clectrica I
I I
Assistant Hanager St rue turn I I
I I
Assistant Manager Modifications I
I Mechanica I Projects Lead Engineer Mechanical Engineers Mechanical Project Designers Designers Draft Technicians I
I Hechanica I System and Analysis Lead Engineer I
I Mechanical Engineers Hechanical Project Designers Designers Draft Technicians I
I Projected Lead Eng ineer I
I Structura I
Eng ineers Designers Draft Technicians I
Technica I
Lead Engineer I
I Structura I
Eng ineers Oes i gne rs Draft Technicians I
l&C Lead Engineer I
I Electrical Engineers Designers Draft Technicians I
I Power Lead Engineer I
I Electrica I Eng ineers Designers Draft Technicians Electr ica I Engineers Hechanica I Engineers Nuclear Engineers Chemica I Engineers Configuration Management
ATTACIINENT C No. or
~pec i e
Leve I Senior Nanagers qua.lificacicn Bache I o rs tlasters PNO Associate 50'%6%
7%
7%
Average Years n
iicebic Experience
Average Years
~ettcn Ex erience
5 No. of 50%
Average Yea rs Outside A
Iicable Ex erience No. of PE Licenses
Supe rv 1 so rs/Lead s Bache lors
- 50%
boasters
- 29%
Assoc i a te
-
14%
61%
124 Engineers/Techs Designers Masters Associate Bachelors PhD
- 26%
7%
57%
1%
26