IR 05000220/1993013
| ML20057G284 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 09/21/1993 |
| From: | Beardslee C, Paolino R, Ruland W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20057G282 | List: |
| References | |
| 50-220-93-13, 50-410-93-13, NUDOCS 9310210216 | |
| Download: ML20057G284 (10) | |
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C U.S. NUCLEAR REGULATORY COMMISSION
REGION I
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' REPORT NOS:
50-220/93-13 50-410/93-13 K
DOCKET NOS:
50-220
50-410 ic
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LICENSE NOS:
DPR-63 NPF-69
. LICENSEE:
Niagara Mohawk Power Corporation
- 301 Plainfield Road Syracuse, New York 13212
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- FACILITY NAMEi Nine Mile Point Nuclear Station Units 1 & 2
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l INSPECTION AT:
Scriba and Syracuse, New York
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- INSPECTION DATES:
August 2-6,1993 INSPECTORS:
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R. J.daolino, Sr. Reactor Engineer Date Electrical Section
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Engineering Branch, DRS q.
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C. D. Beardslee, Reactor Engineer DVte /
Materials Section f
Engineering Branch, DRS APPROVED BY:
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I W. H. Ruland, Chief, Electrical Section Dat'e '
. Engineering Branch, DRS
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9310210216 931006 L'
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Areas Inspected: Design, design changes and modifications, installation and testing of
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modifications, interface / communication, quality assurance and technical support for M-deviations / event reports (D/ERs), work requests (WRs), and licensee event reports (LERs).
Results: Generally, with the exception of the unresolved simple design change review issue, modifications and design changes reviewed by the inspector were of good quality and technically accurate. The _ technical evaluations, reportability, operability, and corrective i;
actions for D/ERs, WRs and LERs were found to be adequate. The licensee's quality assurance audits and surveillance program identified issues in the engineering and technical support area that were resolved and/or corrected in a timely manner. Good communication / interface exists between the corporate engineering and the plant staff. D/ER
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backlog has been reduced, and there is a strong effort by management to reduce long standing T-Mods.
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DETAIIE
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SCOPE OF TI4E INSPECTION..
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L The purpose of the inspection was to verify that 'ne design changes, modifications and post-
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modification ~ testing for the Nine Mile Point bnits 1 & 2 were performed in accordance with Lplant procedures, requirements and comm'..ments specified in the facilities Technical.
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Specifications, NRC rules and regulations, safety analysis report, and the quality assurance j
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l program.fIncluded in the scope of the inspection'was the assessment of the interface /
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for resolving issues.'
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communication between corporate engineering and the plant staff and the technical support
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'1.1.
? Administrative Controls for Design Changes and Modifications
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' Administrative and engineering procedures were reviewed by the inspector to determine '
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M J whether the engineering activities were specified and controlled by approved procedures.
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_i The procedures reviewed included' plant modifications, design change requests, design
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i verification, safety evaluations, design document changes, configuration management
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process, station operations review committee (SORC) reviews, deviation event reports, and
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the modification / simple design change program.
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?Th' review indicated that'the licensee's procedures provide adequate administrative
e guidelines and controls to ensure that design, design changes and modifications performed j
idid 'nat involve an unreviewedl safety question. ' Appropriate requirements and guidelines
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were provided for the 10 CFR 50.59 screening review and ' safety evaluations, design input, i
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design calculations and design. verifications, j
j The licensee's engineering staff was interviewed to determin'e their understanding of the
Tmodification and' design change process and actions ~ taken to support the plant staff.
( Observations by'the inspector and discussions with the engineering staff indicate the staff is
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familiar and knowledgeable of the procedural l requirements and guidelines.
i The inspector concluded that the licensee had established adequate procedures and programs
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ito ensure that plant design changes, modifications, and engineering activities were performed l1 6' -
in a controlled manner.
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TEMPORARY. MODIFICATIONS j
IThe inspectors reviewed the licensees Temporary Modification (T-mod) program to assure j
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that temporary installationsLwere ~ performed and controlled in accordance with the licensee's
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Procedure ~ GAP-DES-03; Revision:1, " Control of Temporary Modifications." The procedure
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modifications. ~ These controls include the completion of adequate technical design reviews,
-l 10 CFR 50.59 Safety Evaluations, appropriate drawing and procedure changes, and guidance J
on limiting the backlog of longstanding'(greater than six months) T-mods.
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A review of several T-mod packages indicated that the licensee performed adequate technical reviews and 10 CFR 50.59 Safety Evaluations, and controlled the T-mods from installation to
clearance in accordance with the appropriate procedure. Although the procedure contained
' limited guidance on maintaining a low backlog oflongstanding T-mods, a review of the Unit E
1 and 2 T-mod log demonstrated a decreasing number of longstanding T-mods, a decreasing number of T-mods initiated, and a decreasing average time in service.
Temporary modifications are being controlled in accordance with the appropriate procedures
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and a strong effort has been made to limit the backlog of longstanding T-mods.
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SIMPLE DESIGN CHANGES A Simple Design Change (SDC) is a process used to handle a design change that is limited in.
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scope and straight forward in design and installation. The SDC program is controlled by Procedure NEP-DES-320, Revision 2, " Design Change Initiation." This procedure
delineates the process to determine whether a change to the plant should be treated as a modification or a SDC, and gives procedural guidance on processing a SDC.
A SDC is processed by an assigned engineer, who is responsible for initiating a " Simple Design Change Package Checklist." The checklist provides a systematic approach to aid the
engineer in completing a SDC package. A complete package consists of appropriate design
. inputs, calculations,. design output documents,10 CFR 50.59 Safety Evaluations, and other
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miscellaneous material. When the package is complete, an independent reviewer is required to review the package prior to releasing it for installation.
Two of the sample SDC packages reviewed by the inspector, SDC SC2-0249-92, Revision 0, entitled, " Replace Valve in Instrument Air System," and SDC SC2-0303-92, Revision 0, entitled, " Replace Water Cleanup Flow Transmitter," appeared to be incomplete at the time the licensee's independent review was performed. A comparison, by the inspector, of
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completion dates for documents required to complete an SDC package and the licensee's independent review date indicate some of the documents required to complete the referenced SDC packages were done after the licensees independent review. The inspector noted that one of the SDC packages, SDC SC2-0303-92, was administratively released. However, the design change had not yet been put into service in the plant and therefore did not present a safety problem.
L The SDC control Procedure NEP-DES-320 does not clearly indicate whether the licensee's review'of an incomplete SDC packages is acceptable, but other procedures are in place that prevent SDC release for implementation until the safety evaluation is complete. The licensee initiated immediate corrective action by issuing a Deviation / Event Report (DER) to determine the cause of the deficiency and to clarify the control procedure.
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This item'is unresolved pending NRC review of licensee's evaluation and corrective action
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With the exception of the above mentioned inconsistencies, the inspector concluded that the SDCs reviewed were generally complete and contained adequate technical reviews and safety evaluations.
4.0 COMMUNICATION / INTERFACE CONTROL
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Good communication exists between the corporate engineering personnel and the plant staff.
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This was evidenced by staffing of site and system engineering functions to improve overall
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- plant performance by providing a focal point for identification and resolution of performance
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issues on a system basis and strengthening interdepartmental coordination. Communication between operations, maintenance and engineering was established through morning meetings
'at each unit and also a combined meeting for both units. :In addition, nuclear engineering / engineering interface meetings were held quarterly. Plant manager.and engineering manager meetings were held biweekly to resolve and prioritize engineering work o
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. activities.' The inspector attended a combined plant staff meeting and noted that representatives from site and system engineering, corporate engineering, plant operations and the maintenance staff attended the meeting..During this meeting, representatives from different sections of each unit discussed plant status, daily action items, problem areas and outstanding technical issues. The inspector determined that this meetin<, provided an effective method of communication / interface between different divisions of both units. The
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active participation of management representatives from different organizations at these
- meetings complimented the effective communication at Nine Mile.
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- TECIINICAL, TRAINING L
The engineering technical staff training program established in January 1992, covers approximately 74 technical issues. This program is expected to be completed within 3 years.
' The program includes training in nuclear reactor systems, safety evaluations, process control, i
root cause analysis, QA fundamentals,' and other specialized training.
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The scheduling and program _ for completion of the required training was the responsibility of-the functional group supervisor. The continuing training program guidelines were provided in Procedure ACAD 91-017. The Nuclear Engineering Branch Business Plan, Revision 2, l
for Nine Mile Units 1 & 2, was focused on providing the training necessary through
- continued line management involvement and upgrading the technical capability of the i
organization. Completion date for providing input to develop a preliminary 1994 training schedule for the branch was October 1993. Approval for the 1994 training schedule was
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expected in December:1993.
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LThe continuing training program for engineers was determined by the engineering advisory
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. committee. An engineering matrix was developed based on requirements, needs and training
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- inputs from supervisors. The training 'and qualification' program developed to address
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Ltraining needs of the engineering and technical staff appears to be comprehensive and
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- designed to enhance the knowledge and skills of the' engineering personnel. Licensee
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engineering personnel interviewed and observed by the inspectors appear to be technically
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- competent and familiar within their areas of responsibility.
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ENGINEERING SUPPORT FOR D/ERS, WRS, AND LERS
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jThe' inspector reviewed several randomly-selected Deviation / Event Reports (D/ERs),
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Licensee Event Reports (LERs), and Work Orders (WRs) to determine whether the
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engineering disposition was technically accurate based on established requirements and to
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assess the engineering and technical support in'their resolution.
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The review indicated that the' licensee has made significant progress in reducing the D/ER backlog. The engineering dispositions including the preliminary screening, reporting and
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operability reviews were satisfactory. The WR review by the inspector confirmed that-
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changes were performed'through the routine maintenance work request program. The review
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ven5ed that the maintenance _ work did not involve design changes or modification to the plant.4ERs reviewed by the inspector indicate that the root cause investigations were
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' thorough and. technically accurate.. Reportabilty and operability were properly performed and
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conducted. The capability to resolve technical issues'and provide quality engineering product
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O 7.0 Q ALITY-ASSURANCE / SURVEILLANCE AUDITS - UNITS 1 & 2 i
L The licensee has an active auditing andl surveillance program to evaluate engineering
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performance. Audits over the past year have included Nuclear Engineering and Licensing
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' Audit No. 92004-RG/IN, Operations and Technical Support Audit No. 92008-RG/IN, and q
- Service _ Water System Audit.No. 93007. The audits include simple design changes,
assignment of responsibility, project awareness, administrative controls, engineering trainmg,
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testing and calibration.-
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lResults of the audits and surveillances provided for a self-assessment of engineering-performance including identification of strengths and opportunities for improvement. The
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p audit revealed a weakness in;the review of product documents including closure of D/ERs for which c6rrective action was incomplefe. Discussions with theLQA staff indicated that the
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weaknesses identified in the engineering programs were being addressed by engineering
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t management. ' The inspector concluded that the licensees _QA group had adequate
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E-involvement to monitor and implement appropriate corrective action.
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N 8.0 CONCLUSION -
In summary, modifications and design changes reviewed were generally of good quality and
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technically _ accurate. Engineers and project personnel were fully aware and knowledgeable in
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- modifications and design changes. The 10 CFR 50.59 screening process, safety evaluation, design input, SORC, and technical review were thorough and in accordance with applicable procedures and regulatory requirements. Good communications exist between engineering
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- backlog in D/ERs and time in service for T-Mods.
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- 9.0 UNRESOLVED ITEMS t
'.. Unresolved items are matters about which more information is required to ascertain whether
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they are acceptable items or violations. One unresolved item is discussed in detail
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.Section 3.0.
E 10.0 EXIT MEETING
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At the conclusion of the inspection on August 6,1993, the inspector met with licensee L
- representatives denoted in Attachment 1. The inspector summarized the scope and the inspection findings at that time. The licensee acknowledged the inspection findings.
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=ATI'ACHMENT 1 -
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PERSONS CONTACTED -
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NiaganLMohawk Power Corooration
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S. A'garwal, Pr6 ject Engineer.
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- * J.;Darweesh(ISEG Engineerj..
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i L. Barsuch, Acting Plant Mod. Coordinator-Unit 1 -
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!S.f Dhar, Engineer ; _.
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P. Francisco, DBR Task Manager-Unit 1 l
t* LC. Jasinski,' Izad Engineer-Unit 2 -
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' * 1L. Klosowski, General Superintendent -
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- P. Mangano, Supervisor Site Engineering-Unit 2 i
Mi McGinley, Engineer ;
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L.' Mott, Project Designer.
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. i A.]Pinter; Site Licensing Engineer
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- D."Sandwick, Supervisor-Project Management-Unit 1 ss
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/J. Simmons,12ad Instrument Engineer
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~ L D.' Steyenson, Modification Coordinator-Unit 2'
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A K. Sweet, Technical. Manager-Unit li
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7. McMahoniSupervisor Electrical Design-Unit 1 1l T
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A F.-Underkuffker, System Engineer-Unit 1
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7 *c L.; Vaurs,: MATSi g
in L*,K.LWard,; Manager-Engineering Unit 2
' *iW. Yaeger, Manager-Engineering Unit 1
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. ~. (: A.' Zallnick(Supervisor Site Licensing-
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- ; f-Asterisk ~(*) denotes personnel present at exit meeting of hugust 6,1993
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ATTACHMENT 2
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- DESIGN CHANGES AND MODIFICATIONS REVIEWED
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1. T-mod 92-062, Unit 2 2. :T-mod 89-063, Unit 2 3. ' T-mod 89-019, Unit 2 4. SC2 0160-91, Rev.1 - Weld Overlay Repair of HPCS Nozzle 5. SC2-0249-92, Rev. 0 - Replace Valve in Instrument Air System 6. SC2-0303-92, Rev. 0 - Replace RWCU Flow Transmitter
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' 7. SCl-0157-91, Rev. 2 - Replace Liquid Poison Level Switch and Level Transmitter
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' AUDITS 1. QA Audit Report 93007, Unit 1 Service Water System
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2. Nuclear Engineering and Licensing Audit 92004-RG/IN 3. - Operations and Technical Support Audit 92008-RG/IN n
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. PROCEDURES
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' 1. NIP-SEV-01, Revision 01, dated March 30,1993 L
2. ' NIP-IrrM-02, Revision 00, dated August 31,1992 3. NIP-PSH-04, Revision 00, dated October 8,1993 4.. NEP-DES-221, Revision 01, dated March 26,1993 p
5. NEP-DES-320, Revision 03, dated January 4,1993
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6.' NEP-DES-335, Revision 01, dated March 17, 1992
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7. NEP-DES-350, Revision 01, dated April 5,1992
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8. NEP-DES-372, Revision'02, dated June 18, 1993 9.' LNEP-PTM-304, Revision 00, dated January 2,1992 10. NDD-PTM, Revision 00,~ dated May 3,1991 11. N1-TDI-11, Revision 01, dated August 6,1993 ~
12. : N1-TDI-4, Revision 00, dated May 11,1993
LICENSEE EVENT REPORTS h
Unit 2 1. 93-01, Actuation of Emergency Safety Features (ESP) due to Equipment Failure.
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- 2. : 93-02, Tech. Spec. Violation - Relay orientation and procedure error.
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_3. 93-03, Missed surveillance test.
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' ' Attachment 2
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Unit 1
- 1. - 93-01, Operation in excess of 100% rated core thermal power.
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. 2. 93-02, Automatic scram on High Neutron Flux Signal.
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3. 93-03, Local. leak rate test exceeds regulatory requirements.
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4. 93-04, Loss of Effluent Monitoring.
5. 93-05, Tech. Spec. Violation -. Inadequate jumper control.
6. 93-06, Reactor scram on Intermediate Range Monitor - High Neutron Flux.
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