IR 05000261/1994025
| ML14181A623 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 10/13/1994 |
| From: | Casto C, Whitener H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14181A622 | List: |
| References | |
| 50-261-94-25, NUDOCS 9411010017 | |
| Download: ML14181A623 (15) | |
Text
pJ% REGU4 UNITED STATES J'
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, N.W., SUITE 2900 ATLANTA, GEORGIA 30323-0199 Report No.:
50-261/94-25 Licensee: Carolina Power and Light Company P. 0. Box 1551 Raleigh, NC 27602 Docket No.:
50-261 License Nos.:
DPR-23 Facility Name:
H.B. Robinson Inspection Conducted: September 12-16, 1994 Inspector:
.
H. Whitener Date Signed Accompanying Personnel: G. Wiseman Approved by:
A, C. Arato, Chief Date Signed Test Programs Section Engineering Branch Division of Reactor Safety SUMMARY Scope:
This routine, announced inspection was conducted in the areas of design changes and plant modifications, and engineering and technical support activities (IP 37550).
Results:
In the areas inspected, violations or deviations were not identifie The inspectors concluded that the H. B. Robinson Plant had initiated positive actions toward improving the quality of engineering service The reorganization of Robinson Engineering Support Services (RESS) is in the initial phase. The effectiveness of the reorganization of engineering services will be reviewed during future NRC inspection (Paragraph 3.a)
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The licensee had implemented a process for reviewing, prioritizing and scheduling needed design changes which considered plant safety, reliability and cost benefits. Documented technical justifications for cancellation of proposed design changes by the Plant Review Group (PRG)
9411010017 941014 Enclosure PDR ADOCK 05000261 G
were adequate to determine that the issues did not adversely affect overall plant reliability or safety. The inspectors noted that 89 Projects had been canceled since January 1, 1994, by the PR (Paragraph 2.a)
Plant Modification and Temporary Modification packages were technically adequate with sufficiently detailed 10 CFR 50.59 safety evaluation Adequate post modification test requirements were specified. The inspectors identified no significant findings for the modification packages reviewed and concluded the documentation of the modification packages was satisfactory. The completed modifications reviewed were considered adequately implemente (Paragraphs 2.b, 2.c)
The control of temporary modifications was effective. This was evident in the low number of temporary modifications and in the level of management review. (Paragraph 2.c)
CP&L had reorganized the engineering functions from a Central Design Centered organization located at the corporate offices to an on-site centered organization (RESS). This move was intended to improve consistency of performance, eliminate redundancy, improve efficiency, and simplify work processes. While the inspectors considered the present staffing level to be adequate to maintain support to plant operations and maintenance, it is too early to evaluate the effectiveness of the reorganization which is still adjusting to the new processes. The effectiveness of the engineering reorganization will be tracked during future NRC inspection (Paragraph 3.a)
Engineering training was established consistent with the Institute Of Nuclear Power Operation (INPO) guidelines. Management has only recently established emphasis on implementation of a System Engineer certification program. Overall training for engineering personnel was considered adequate but requires more emphasis on management oversigh (Paragraph 3.a)
Management initiatives were being developed to address the area of backlog reduction for engineering work item (Paragraph 2.a)
The Modification Package backlog of packages requiring closure included 20 "OPEN" Modifications with 26 exceptions to be resolved before closure. Fifteen of these exceptions required Engineering action (Paragraph 2.a)
Nuclear Assessment Department (NAD) audits, Engineering self assessments, and performance monitoring by management of engineering activities were a positive indication of management's efforts to improve engineering performance. These were effective in identifying a number of areas for improvement in the Engineering groups. (Paragraph 4)
Corrective actions in response to the audits and assessments have been developed (Action Item Plan, "Engineering Excellence '94") in order to address the improvement areas. Bench-mark management expectations and goals established for engineering performance were challenging and motivating. (Paragraph 4)
Violation 50-261/93-31-01, Failure to Update Design Documents was reviewed and close (Paragraph 5)
REPORT DETAILS Persons Contacted Licensee Employees
- B. Barnett, Manager, Maintenance Support
- J. Boska, Manager, Instrumentation & Controls Design Engineering
- G. Castleberry, Manager, Manager Electrical Design Engineering
- B. Clark, Manager, Maintenance
- D. Gudger, Engineer, Regulatory Affairs
- M. Herrell, Plant General Manager
- K. Jensen, Manager, Nuclear Steam Supply Systems (NSSS)
- R. Krich, Manager, Regulatory Affairs
- D. Lopez, Manager, Planning and Scheduling
- G. Miller, Manager, Robinson Engineering Support Services (RESS)
- R. Moore, Manager, Shift Operations
- C. Oliver, Manager, Configuration Control
- G. Walters, Manager, Support Training
- L. Woods, Manager, Technical Support Other licensee employees contacted during this inspection included engineers, operators, technicians, and administrative personne NRC Resident Inspector(s)
- W. Orders, Senior Resident Inspector
- C. Ogle, Resident Inspector
- Attended exit interview Acronyms and initialisms used throughout this report are listed in the last paragrap.
Design Changes and Plant Modifications (37550) Planning and Development of Plant Modifications The inspectors reviewed the design change development process used for identifying, screening, evaluating, and approving plant modifications to improve reactor safety and plant operation. The inspectors also held discussions with licensee personnel regarding the plant modification (PM) prioritization process. The licensee has a corporate program that addresses projects including modifications for all three nuclear sites. This program was described in the "Carolina Power & Light Company (CP&L) Nuclear Plant Modification Program" manual (NPMP), and the CP&L Nuclear Generation Group (NGG) "Project Management Manual" issued for trial use March 1, 1994. The project management and modification manuals provide complete and detailed policies and guidelines for
the development and management of plant modification Modification and design control documentation reviewed by the inspectors during this inspection to determine the adequacy of the modification program included:
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Carolina Power and Light (CP&L) Nuclear Plant Modification Program (NPMP), Revision 4, November 199 NGGM-303-05, Phased Project Approval and Authorization, Revision 0, November 199 PLP-064, Engineering Service Requests, Revision 0, June 199 MOD-004, Plant Drawing Preparation, Revision, and Approval, Revision 10, November 199 MOD-005, Plant Modifications, Revision 10, June 199 Plant Modifications Status Report, September 199 Master Projects Index Report - All Current Projects, September 199 Master Projects Index Report -
Projects Canceled in 1994, September 199 The inspectors determined that plant modifications were prepared by the Design Engineering Unit located primarily on-sit Proposed design projects that led to plant modifications were primarily requested through the Engineering Service Requests process by the on-site Technical Support Unit. Responsibility had been assigned to Projects Management and Engineering Services Unit for maintaining the status of plant projects and modification The modification process consisted of three phases (Study, Design, and Implementation) of the Plant Modification Package development, review, and approval. A Robinson Plant Review Group (PRG)
reviewed and approved proposed plant modifications for inclusion in the Master Project Index and the Robinson Five-Year Pla The PRG was a plant management group comprised of primary senior Site Managers established to evaluate plant projects and make recommendations for development, deferral or cancellatio Prioritization under the PRG review and approval process involved cost benefit analysis, assignment of schedule index for implementation activities based on areas which included nuclear safety, industrial safety, unit availability and reliability, unit capacity, radiation exposure (ALARA), and plant design enhancement to improve operation or maintenanc The inspectors reviewed selected modification project proposals identified in the PRG meeting notes and minutes of January 4; March 15; June 9, 10, and 17; and August 25, 1994, to verify that the PRG performed the technical reviews in accordance with the NPMP. In addition, the inspectors reviewed the results of a June 1994 project management review effort which included the review of 204 outstanding projects. From this review 60 projects were approved for an estimated budget for 1995 -1999, 39 required further study (not budgeted), 44 underwent scope reductions to close in 1994, 14 were changed to other budgeted routine work, and 47 were cancele The inspectors noted that a total of 89 proposed projects had been canceled since January 1, 1994. The inspectors reviewed the following modification projects canceled by the PRG to determine if the basis for cancellation was acceptabl Project/Modification N Project Description 94-001/M-1157 Emergency Diesel Generator (EDG)
Fuel Oil Transfer Solenoids Power Supply Up-grade 89-028/M-1141 Liquid Waste Processing (E&RC Building) Sump Tank Instrumentation 91-031/M-1123 Generator Voltage Schedule and Metering Problems Modification 89-138/M-1112 Replacement of "B" Battery 88-157/M-1036 Install a New EDG Lubrication Oil Keep Warm System Up-grade 92-208 Install a Permanent Containment Temperature Monitoring System 93-010 Provide Self Cooling for Charging Pumps The inspectors noted that the canceled projects included several canceled modification projects for which engineering had partially completed the design work. A review of the man-hour expenditure on these projects indicated that approximately 34,000 engineering manhours had been expended over the three-year period 1991 to 1993. About 85% of this total had been expended on the "B" Battery replacement project, 89-138/M-1112. The licensee indicated that, although some previously expended engineering resources had been lost, the cancellation of old modification
projects that were considered no longer needed should have an overall positive effect in the management of the engineering workloa Based on discussions with licensee engineering personnel and review of the above documentation, the inspectors concluded that the licensee had an adequate prioritization and review process for identifying and implementing plant design changes. The proposed modification projects had been prioritized and categorized by the PRG according to the safety significance of the plant change. The descriptions of the basis and technical justifications for cancellation of projects were adequate to determine that the issues did not adversely affect overall plant reliability or safet Plant Modifications Four modification packages which had been installed with turnover to Operations and closure after November 1993, were selected for review. The inspectors reviewed the modification packages listed below to: (1) determine the adequacy of the safety evaluation screening and the 10 CFR 50.59 safety evaluations, (2) verify that the modifications were reviewed and approved in accordance with Technical Specifications and applicable administrative controls, (3) verify the modifications were installed and had proper sign offs, (4) verify that applicable design bases were included and design documents (drawings, vendor manuals, plant procedures, FSAR, etc.) were revised, (5) verify that the modifications were properly turned over to operations, and (6) verify that both installation testing and post modification test requirements were specified and that adequate testing was performe Modification N Title/Description of Work M-1075 Upgrade Service Water Piping Supports for Screen Wash to Seismic Class M-1085 Provide Nitrogen Supply to the Steam Generator PORV's to Act as a Backup for Instrument Ai M-1098 Replacement of Source Range Monitor Pre-amplifie M-1154 Installation of Manual Valves for Isolation on the Primary Sampling Syste The inspectors reviewed in detail and verified that: both the design package and installation package were included in the plant modifications; the modification field work was complete;
applicable design input information such as seismic requirements, environmental qualification, industry codes, etc., were addressed; the packages contained additional information such as the design basis; and affected plant documentation such as operator/control room drawings were revised before turnover to Operations. This review also verified whether selected affected instrument set point index drawings, vendor manuals, computer equipment data base (EDBS), fire protection Safe Shutdown Analysis (SSA), Alternate Dedicated Safe Shutdown Procedures (DSP) and FSAR tables and figures had been updated to accurately reflect the modification The inspectors performed field inspections for some of the modifications and verified that the modifications were installed in accordance with the requirements specified in the applicable modification package. The inspectors identified no findings for the modifications reviewed and concluded the modifications packages were satisfactor Temporary Modifications The inspectors reviewed the licensee's temporary modification (TM)
process to determine its adequacy for controlling and tracking temporary changes to the plant's configuration. This process provided a method for making changes of limited scope for a limited time to the "as installed" configuration of plant systems, structures, or components. Although anyone may request a TM, requests normally came from Operations or Maintenance to Technical Support. Technical Support assigned a TM Coordinator (normally the appropriate System Engineer) to evaluate the need for the change and to generate an Engineering Service Request (ESR) to Design Engineering (NED) to prepare the TM design. The System Engineers reviewed the TM package and coordinated the implementatio Procedure, MOD-018, Temporary Modifications, Revision 11, in conjunction with the NPMP manual provided the requirements and controls for the initiation, approval, evaluation, installation, removal, and tracking of temporary plant changes. The ESR initiated the development of the design and implementation packages which contain the essential reviews and evaluation These packages are accompanied by a Modification Traveler which identified those required reviews and approvals to be performed and indicated the plant managers final approval of the T Based on review of MOD-018, the inspectors concluded that the licensee had provided adequate directions for administrative control of the temporary modification proces From a list of installed TMs the inspectors selected four installation packages for review. The TMs were examined to verify that adequate safety evaluations and technical reviews were performed and testing was specified where applicable. The following TMs were reviewed: - 94-701 Install alternate transformer for MCC-7 to supply temporary power to LP-35 and LP-35 Provide a supply of deep well water to cool the Primary Air Compresso Repair body to bonnet steam leak on PRV-1324B-R-18 discharge flush valve addition to correct an operator work aroun TM 94-710 related to the repair of a steam leak using the furmanite process of injecting a flowable sealant into the valve flange area. The leaking valve, PRV 1324B-2, provides a method for controlled steam dump to the condenser. The valve is non safety and has no direct contact with a safety system. The licensee's safety analysis addressed the concerns of NRC Generic Letter 90-05, chemical content of the sealant, maximum allowable force of injection, maximum volume of sealant, and maximum number of injection attempts. The inspectors concluded that use of the furmanite process was acceptable in this cas From review of the above installation packages the inspectors determined that the licensee had adequately analyzed the problems; developed acceptable temporary solutions; evaluated the impact of proposed changes on other systems and plant operability; performed adequate 50.59 safety reviews; provided installation instructions; and specified acceptance testing where applicabl The inspectors reviewed the temporary modification log and determined that there were thirteen TMs installed in the plant at this time. By procedure, the restoration date for a TM can not extend beyond the next refueling outage. The TMs reviewed were scheduled for restoration at the next refueling outage (RFO 16).
If an extension or change of condition was desired, a Field Revision to the TM would be processed. The inspectors considered thirteen TMs an acceptable leve Based on this review the inspectors concluded that the licensee had implemented the temporary modifications in accordance with the plant procedure.
Engineering and Technical Support Activities Organization, Staffing And Training CP&L had reorganized the engineering functions from a Central Design Centered organization located at the corporate offices to an on-site centered organization located at each of the nuclear plants. The intent of this reorganization was to establish a consistent organization at each of the three CP&L nuclear sites, increase the efficiency of engineering services, and reduce cost On-site engineering and technical support services at Robinson were provided by RESS. Under this organizational structure, RESS included the Design Engineers, Technical Support (System and Test Engineers), Component Engineers (Specialists and maintenance engineers), and Projects and Engineering Services groups. This effectively combined the design, implementation, engineering test, and systems management functions under one engineering manage The inspectors held discussions with licensee personnel and reviewed documentation of plant activities to evaluate engineering involvement in support of plant operation and maintenance. This support included items such as preparing and implementing plant modifications and temporary modifications; monitoring component and system performance; and performing safety evaluations, engineering evaluations, and root cause analysis, et Realignment of the engineering organization involved moving Design Engineering to the site; moving Technical Support to RESS; combining Project Controls and Project/Programs into one Project and Engineering Services group; and moving Craft Resources to the plant organization. These moves were intended to improve consistency of performance, eliminate redundancy, improve efficiency, and simplify work processes. There had been some staff reduction in the realignment of the engineering organization. At the time of this inspection, the RESS staffing level was 140 personne This included approximately 54 Design Engineers, 57 Technical Support Engineers, and 27 Project Management Engineers. While the inspectors considered this staffing level to be adequate to maintain support to plant operations and maintenance (Robinson is a one nuclear unit site),
it was too early to evaluate the effectiveness of the reorganization which is still adjusting to the new processes. For instance, some of the managers had only been in place for two week In recent self assessments and NAD assessments, the licensee had identified a number of problems in the engineering organizatio As a result engineering management had developed a systematic approach to address identified problems which consisted of scheduled action items assigned under the sponsorship of engineering managers. This program, Engineering Excellence '94, has been defined, scheduled, and initiated (See paragraph 4).
The inspectors considered this a positive step toward achieving management goals for the Robinson engineering organizatio Engineering Support Personnel (ESP) training, while considered adequate, was below management expectations. Management attributed this condition to a lack of management attention and oversight. Training was one of the focus areas identified in the Engineering Excellence '94 action plan. The licensee had set up a training course modeled after the INPO guidelines which consisted of three phases: Orientation, Position Specific, and Continuing training. The licensee indicated that 11 Technical Support Engineers will complete Orientation training by October 15, 199 Fifty Design Engineers were enrolled and scheduled to complete Orientation training by the end of 1995. Licensee records showed that there were engineers certified for six systems. Management goals were to have engineers certified on 10 systems in 1994'and complete certification of engineers for 50 systems in 1995. In discussions, engineering management indicated that certification was an honorary title which recognized outstanding performance, system expertise, and system ownership. The lack of certification in no way implied that an engineer was not qualified for the assigned system The inspectors concluded that management was aware of problems in the training area and was moving to provide the emphasis and oversight to correct the issue Engineering Support The inspectors interviewed licensee personnel and reviewed station records to evaluate engineering involvement in support of day-to day plant operations. The type of records reviewed included, but were not limited to, the following (some documents are listed by character of information rather than title):
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RNP Organizational Charts
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Progressive Organization Changes
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New Processes Within NED (CP&L Memo)
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CP&L Memo (6/24/94), Nuclear Generation Group Reorganization
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CP&L Memo (8/15/94), Reorganization Within The Nuclear Generation Group
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CP&L Memo (8/16/94), RESS Administration & Program Assignments
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Engineering Excellence '94, and Action Plan
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Managers Expectations
Technical Support Management Manual, TMM-001, Technical Support Conduct Of Operations
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Technical Support Management Manual, TMM-104, System Engineer Walkdown And Assessment Procedure, Revision 0
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RESS Monthly Performance Report (August, 1994)
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RNP Operations and Technical Support Morning Reports (Daily Activity Reports
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Miscellaneous Engineering Activity Reports
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Miscellaneous Training Records Technical Support Management Manual, TMM-001, Revision 9 described the mission, standards, administration, organization, responsibilities, and duties of the engineer For System Engineers some of the principal duties involved monitoring system performance; trending performance parameters; periodic walk-downs of assigned systems; involvement in work on assigned systems such as maintenance, modifications or testing; writing test procedures; analyzing test results; identifying and resolving system deficiencies; and recommending action to improve system reliability and availability. Also, the system engineers performed root cause analysis; recommended plant modifications to NED; reviewed proposed modifications; wrote post modification tests; and developed and implemented TMs. Temporary modifications was an area where the System Engineer provided real time support of plant operations because most TMs were made to assist operation In the review of the above documents and discussions with licensee personnel, the inspectors concluded that engineering provided adequate and timely support to maintenance and operations for day to-day activities and emergent issues. Examples identified included:
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Operations reported that a charging pump was operating erratically. Check out of the controller indicated that the instrument was functioning correctly. Engineering analysis of the plant conditions showed that T-Average was about degrees low. Instead of operating on the full power plateau of the controller demand curve the pump was operating at the knee of the demand curve resulting in the erratic behavio T-Average was corrected and the condition resolved on lin Frequent ESRs had been generated by Maintenance asking for evaluation of seismic concerns related to some planned maintenance evolution. This resulted in delay of maintenance projects and an impact on engineering resource Design engineering was in the process of developing criteria and bounding conditions under which Maintenance can work without requesting engineering evaluation Supports were found unattached on tubing which formed a part of the Isolation Valve Seal Water System and the sensing lines for Residual Heat Removal System flow transmitter FT 605. In both cases these were safety related systems which, if found inoperable, placed the plant in a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> Limiting Condition Of Operation. In both cases Technical Support provided a timely Expert Operability Analysis and was able to demonstrate the systems were operable, thus preventing plant shutdow The inspectors observed that good engineering communications had been established with the operations department. An Engineering Technical Support duty representative was available on a 24-hour basis to expedite engineering assistance to operations. Also, Technical Support representatives attended the operations morning meetings to learn the latest plant needs. This information was carried to the Technical Support meetings for actio The inspectors considered the communications a positive initiative and essential to Technical Support Engineering's role in supporting plant operation.
Quality Assurance (QA) Assessment and Oversight The inspectors reviewed QA Program assessments, RESS performance management evaluations, and assessments of the Nuclear Engineering Department and Site TS Engineering's safety related activities conducted by the Nuclear Assessment Department (NAD) organization. The assessments and audits were part of the overall CP&L quality assurance program at Robinson. The inspectors reviewed results of the following NAD quality assurance activities that were either completed or in progress:
R-SP-94-01, July 8, 1994, Robinson Engineering Products Assessment
R-TQ-94-01, March 29, 1994, Robinson Training and Qualification Program
R-ES-94-03, June 30, 1994, Robinson System Engineering Assessment
R-94-08, April 21, 1994, Robinson Significant Operation Experience Reports Assessment The inspectors found that the NAD organization had been heavily involved in independent monitoring of Engineering activities. Quality audits and performance monitoring of engineering activities were effective in identifying several major areas for improvement in the engineering group Corrective actions in response to QA audits and assessments were being addressed through the initiation of the Engineering/Technical
Support Near-Term Improvement Pla Details of this Improvement Plan was discussed with NRC Region II Management on August 29, 199 Most Engineering groups had recently begun performing self assessment These assessments were developed for the RESS Self Assessment Plan for 1994 in accordance with Plant Procedure PLP-057, Revision 3, "Self Assessment."
The inspectors reviewed several RESS Engineering Program self-assessments including: Configuration Management Practices, RESS-94 01, March 1994; Design Basis Document (DBD) Application and Maintenance, RESS-94-02, May 1994; RESS Training, RESS-94-04, August 1994; and RESS Monthly Performance Report, September 199 Based on these reviews, the inspectors' concluded that the NAD audits, engineering self-assessments, and performance monitoring by management of engineering activities were a positive indication of management's efforts to improve engineering performance. These audits and assessments were effective in identifying a number of areas for improvement in the engineering groups. Corrective actions in response to the audits and assessments have been developed (Engineering/Technical Support Near-Term Improvement Action Item Plan - "Engineering Excellence 1994") in order to address the improvement areas. The inspectors considered the bench-mark management expectations and goals established for engineering performance both challenging and motivatin Violations or deviations were not identified in the areas inspecte.
Licensee Action on Previous Inspection Findings (92702)
(Closed) Violation 50-261/93-31-01, Failure to Update Design Documents The inspectors reviewed and verified completion of the corrective actions listed in the licensee's response letter dated January 15, 1994, RNP-94-0099. The inspectors verified that the licensee had updated the Priority A drawings addressed in the violation by January 31, 199 Review of drawing change reports for January 13, February 3, and April 7, 1994, indicated there were no overdue Priority A drawings during that time period. Revised Modification Procedure MOD-004, Revision 10, was issued on May 18, 1994, to clarify drawing update priorities and provided a request for an allowable management approved extension for up to 20 days on drawing updates. Approved extensions were tracked by the Configuration Control Unit Manager. Based on this review, the inspectors concluded that the RESS drawing control program was adequate. This item is close.
Exit Interview The inspection scope and results were summarized on September 16, 1994, with those persons indicated in paragraph 1. The inspectors described the areas inspected and discussed in detail the inspection result Proprietary information is not contained in this report. No dissenting comments were received from the license Violation 50-261/93-31-01, "Failure to Update Design Documents,"
was reviewed and close.
Acronyms and Initialisms CP&L Carolina Power and Light DBD Design Basis Document DSP Dedicated Safe Shutdown Procedure E&RC Environmental & Radiation Control EDBS Engineering Data Base System EDG Emergency Diesel Generator ESR Engineering Service Request FSAR Final Safety Analysis Report INPO Institute Of Nuclear Power Operation IP Inspection Procedure LCO Limiting Condition Of Operation MCC Motor Control Center NAD Nuclear Assessment Department NED Nuclear Engineering Department NGG Nuclear Generation Group NGGM Nuclear Generation Group Manual NPMP Nuclear Plant Modification Program NRC Nuclear Regulatory Commission NSSS Nuclear Steam Supply System NRCS Nuclear Revision Control System (computer)
PLP Plant Procedure PORV Pressure Operated Relief Valves PRG Plant Review Group PRV Pressure Relief Valves QA Quality Assurance RESS Robinson Engineering Support Services RNP Robinson Nuclear Plant SSA Safe Shutdown Analysis TM Temporary Modification TS Technical Support