IR 05000280/1989039
| ML18153C068 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 01/04/1990 |
| From: | Jape F, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18153C067 | List: |
| References | |
| 50-280-89-39, 50-281-89-39, NUDOCS 9001190184 | |
| Download: ML18153C068 (13) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323 Report Nos.:
50-280/89-39 and 50-281/89-39 Licensee:
Virginia Electric and Power Company Glen Allen, VA 23060
Docket Nos.:
50-280 and 50-281 License Nos.: DPR-32 and DPR-37 Facility Name:
Surry 1 and 2 Inspection Conducted:
December 11-15, 1989 Inspector ~m%(~ ~ fr--
Team Members:
R. Moore S. Ninh M. Thomas Accompanying Personnel*
F. Jape December 14-15, 1989 Approved by:
. ~ ~
~~
F. Jape,ection Chief Quality Performance Section Operations Branch Division of Reactor Safety SUMMARY Scope:
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/ Da e Signed t/t-//70 Date Signed This routine, unannounced inspection was conducted in the areas of design control, engineering support functions, and inspection of quality verification function Results:
In the areas inspected, violations or deviations were not identifie A restructuring of corporate and station engineering resources occurred in 198 The restructure has enhanced -the nuclear design control program and the onsite engineering support capabilit The system engineering program has been adequately implemented although a formal system trending methodology has not been develope Improvement was identified in performance of 10 CFR 50.59 safety evaluation Weaknesses identified in the previous SALP report related to the Engineering Work Request program have been aggressively pursue A component failure cause analysis and trending program, addressed as a weakness in the previous SALP report, has not been effectively implemente Program implementation is scheduled for January, 199 The Station Deviation Report Program (deficiency reporting program), administratively controlled by enginee-ring, was adequately maintaine Temporary modifications were adequately processed and controlled although minor programatic deficiencies were identifie PDR ADOCK 05000280 Q
The capability of the licensee quality organization to identify problems in safety related activities has improve This observation was based on improved qua 1 ity of audits and deve 1 opment of a dedicated group to survey qua 1 i ty related activities *
- Persons Contacted Licensee Employees REPORT DETAILS
- W. Benthall, Licensing Supervisor
- R. Bilyeu, Licensing Engineer R. Calder, Manager - Nuclear Engineering
- P. DeTine, Supervisor, QA Performance
- E. Grecheck, Assistant Station Manager
- R. Green, Systems Engineering Supervisor
- D. Hart, Supervisor, QA Audit
- R. McManus, Supervisor, Engineering
- E:. Smith, Jr., Manager, QA
- T. Sowers, Superintendent, Engineering
- B. Stanley, Systems Engineering Supervisor
- G. Thompson, Supervisor, Maintenance Engineering
Other licensee employees contacted during this inspection included engineers, and administrative personne Other Organizations Stone and Webster Engineering Corporation J. Hendricks, Field Support Engineer P. Liakos, Head of SWEC Design Engineering A. Plarry, Electrical Engineer NRC Resident Inspectors
- W. Holland, Senior Resident Inspector
- J. York, Resident Inspector
- Attended exit interview 2.0. Design Control Program (37700)
NDCM No. 1.1, Design Organization, Revision 4, defines the organization responsible for establishment and execution of an effective nuclear design control program and describes the lines of authority and interfaces among the various sections involve Power Engineering Services is the designated design authority for Surry Nuclear Station in accordance with the requirements of Virginia Power Nuclear Policy statement, Engineering, dated July 3, 1989. Organizational responsibilities, levels of authority, and lines of internal and external interfaces are specified in this and other lower-tier quality implementing procedure **
The inspectors determined that Power Engineering Services was reorganized on January 1, 1989 and April 1, 1989. This reorganization resulted in the formation of the following groups:
Superintendent of Engineering Station Engineering Services Supervisor Design Supervisor Configuration Management Supervisor System Engineering Supervisor Advisory Operations Engineering Technical Bulletin No. 89-04, dated March 1, 1989, provided a summary of the changes made to the NDCMs caused by the above reorganization; described the responsibilities of the new groups; and established interim procedural guidelines to be used pending completion of specific procedural change Engineering Technical Bulletin No. N-11, dated July 31, 1989, provided a second update of the Nuclear Design Control Program. Attachments 1, 2, and 3, contained a listing of those NDCMs and other lower-tier quality implementing procedures that were revised pursuant to the reorgani-zations of January and April 198 The inspectors requested information concerning compensatory measures established by the licensee to facilitate engineering technical support activiities pending revision to the procedure The inspectors were informed that no compensatory measures were require for activities performed under the ANSI N45.2-11, 1974 progra Based on review of selected NDCMS for specific design-engineering activities the inspectors concurred with the licensee 1s statemen Another reorganization of Power Engineering Services occurred on November 1, 198 This most recent restructuring of the organization is intended to
~rovide services related only to nucl~ar engineering activities. The name of the group has also been changed to Nuclear Engineering Services. The Nuclear Engineering department has been Provided with additional personnel resource This staff increase has provided the capability to strengthen onsite engineering technical support via (1) On enlarged System Engineering staff and (2) Design Engineers located onsite who provide immediate support to the Nuclear Operations staff. The reorganization of November 1, 1989, resulted in the following sections which are part of the Site Engineering Office headed by a Superintendent and an Assistant Sup (Design):
Supervisor Mechanical Engineer Supervisor Electrical Engineer Lead Engineer (Civil)
Supervisor Engineering Design Supervisor Testing Supervisor System Engineering #1 Supervisor System Engineering #2 The inspectors conducted interviews with licensee management to ascertain the impact of the above reorganization on the nuclear design control program document Licensee management has prepared and issued to the
staff a document, 11Jurisdiction Statements for Station Engineering 11 dated November 27, 198 This document describes the responsibilities of the various sections within the Site Engineering organizatio The inspectors were informed that a procedure containing information described in the jurisdictional statement would be developed and issued by January 15, 199 Additional required revisions to the nuclear design control program documents have been i den ti fi ed by licensee management as the first of Nuclear Engineering's top ten objective Continued enhancements to the nuclear design control program have resulted in the restructuring of Power Engineering Services and necessitated revision to the program document Performance of des i gn-engi neeri ng-activities were adequately controlled, however, in th.at the lower-tier quality implementing procedures have not been greatly impacte These program enhancements when completed should achieve the objectives of the Engineering Quality Plan addressed in R. W. Calder's memorandum to Nuclear Engineering employees dated October 23, 198 Within this area no violations or deviations were identifie.0 10 CFR 50.59 Safety Evaluations. (37700)
Procedure Number SUADM-LR-12, Safety Analysis 10 CFR 50.59/72.48 Safety Evaluations and Justification for Continued Operation, dated October 10, 1989, provides guidance for determining when a 10 CFR 50.59 Safety Evalua-tion is required. Attachment 4 specifies screening criteria to be used in determining if a 10 CFR 50.59 evaluation should be performed. Attachment 1 provides detailed guidance for preparation of the 10 CFR 50.59 Safety Evaluatio Provisions have been made to ensure that items within the purview of the Design Authority are approved by engineering personne Paragraph 6.0 of the referenced procedure specifies qualification and training requirements for personnel who prepare, review, or approve 10 CFR 50.59 Safety Evaluation The minimum qualification and training require-ments are as follows:
Initial Qualifications B.S. Degree in Engineering or science from an accredited four year college, or:
(a) six (6) years of applied engineering at (or for) a nuclear facility in the area for which qualification is sought, or (b) six (6) years of operational or technical experience/training related to nuclear powe None of the experience counted toward meeting the four year degree requirement can be counted toward the years-of-experience requiremen ** *
Years-of-Experience Two (2) years of nuclear experience in engineering and/or operation Systems Training A one (1) or two (2) week course on plant systems given at either statio Any one of the following is deemed to meet and exceed this requirements:
(a) Operator Training (b)
Senior Reactor Operator Training (c) Shift Technical Advisor Training
- (d)
Basic Technical Staff Training Requirements for introductory training on 10 CFR 50.59 safety evaluations and annual retraining have also been establishe Responsibilities have been assigned to the Superintendent, Nuclear Training for conducting and documenting training/re-training in accordance with paragraph Additonally, he is required to provide the Assistant Station Manager, Nuclear Safety and Licensing, with a list of individuals who have been trained in accordance with the requirements of paragraph The inspectors performed independent reviews of 10 CFR 50.59 evaluations completed for selected DCP/EWRs that covered a time span from 1986 to 198 The results of this review showed an improvement in the technical adequacy of the 50.59 evaluations completed since implementation of the 50.59 training progra Within this area tio violation or deviations were note Onsite Engineering Support (37700)
In the previous year, the licensee has reorganized corporate (offsite) and station (onsite) engineering resources to improve the quality of plant engineering suppor This inspection re.viewed the staffing levels of the onsite engineering resources generally, and more specifically, the status and function of the system engineering organization and licensee actions to address engineering support weaknesses indicated in the previous Systematic Assessment of Licensee (SALP) repor The onsite engineering resources are provided by a large Engineering Services organization and several smaller engineering groups (staff of 10 to 15 each) specifically assigned to operations, licensing, and maintenance activitie For example, Safety Engineering Nuclear included Shift Technical Advisors and other engineers for direct operations suppor Licensing engineers were responsible for reportability issues and NRC interface Maintenance engineers generally support daily maintenance activities. The Engineering Services. organization staff size was approximately 90 engineer This organization was subdivided into system engineers (approximately 30),
program engineers i.e. ISI/NDE (13) and Testing (10) and the onsite design engineering contingent from corporate (20).
A procurement engineering
group* (6) was being implem~nted but was not yet functioning during this*
inspection.* The total onsite engineering resource was approximately 120 personnel which included a small percentage of contractor personnel. This reorganization resulted in an increase in ons1te engineering staff size and an increase in the number of supervisors within the organization which increased management involvment in engineering line activities. Although all onsite engineering groups were not fully functional in their designated responsibilities the reorganization represented a substantial improvement in the onsite capacity for engineering suppor The system Engineer (SE) group was reviewed to assess the status of the functional group and their involvment in plant activitie The SE group was established in January 1989, utilizing guidance for activities from the applicable INPO Good Practice document, TS-41 Initial SE duties at that time were primarily performance of pl ant wa l kdowns of Emergency Operating Procedure (EOP) systems to support Unit.1 and 2 restar SE program changes implemented in July 1989, included adding a supervisor, increasing staff, and issuing a procedur~ to document SE responsibilities and dutie A jurisdictional statement for the Engineering Services organization issued in this time frame provided an adequate designation of SE interface The overall experience level of the SE group was good, encompassing a range of industry experience as startup engineers, contract engineers, and Surry Architect Engineer The training provided was generally adequate for the scope of SE function During review of SE activities it was noted that some areas of performance required further development, in particular documentation of engineering evaluations and system trendin A SE evaluation regarding a periodic test for an instrument air valve stroke limit deficiency was not documente This evaluation was the basis for voiding a work order (WO #89-299) to adjust the valve stroke as corrective action for the failed periodic tes Following discussion with the SE on this issue it was apparrent that the determination to accept the valve stroke was reasonabl The lack of documentation to support this evaluation indicates a potential SE program weakness regarding documentation of engineering evaluation It was not clear what level of engineering evaluations require documentation or how such documentation was to be accomplishe In particular, evaluations which accept system or component performance outside the specified criteria should require documentatio Discussions with SE staff indicated that system performance trending was accomplished in varying degrees of effectivenes No specific guidance on system trending was implemented which would assure consistent performance of this functio Trended parameters are determined by the individual S Not all SEs had developed trending mechanisms for their assigned systems however the SEs interviewed were knowledgable of available resources for trending information such as surveillance testing, NPRDS, and maintenanc Although the SE program had not fully matured, examples were available which demonstrated that SEs were involved in plant activity. This involvment contributed to improvement in system performance, identification
of system component deficiencies, and enhancements in periodic test activit For example, a new periodic test and post maintenance oper-ability test procedure was developed for the Emergency Diesel Generator, operating procedures for the battery chargers were revised to increase charger lifetime, pressurizer heaters efficiency was improved, and the Containment and Recirculation spray system instrumentation was improved to provide greater indication accurac The SE program was adequately implemented to accomplish the majority of its designated function These functions, as indicated by the applicable procedures, were primarily to monitor systems performance and support other related engineering activities as required. Large program responsi-bilities, i.e. !SI, NOE, EWR, Testing, MOVATS, etc., were alocated to other onsite engineering groups permitting SE focus on system performanc Duties and interfaces were adequatedly documented, staff alocation levels were adequate for the specified duties, staff experience and training were generally appropriate for designated responsibilities. Based on the interview of selected SEs, the SEs were knowledgable of their systems and well motivate The SE group has demonstrated involvment in plant activi-tie The Engineering Work Request (EWR) program was reviewed to assess the licensee response to identifed weaknesses in this area in the previous SALP report. The indicated weaknesses were associated with the processing of EWRs and the documentation of techni ca 1 review The 1 i censee has initiated corrective actions for these weaknesses and was aggressively addressing the backlog of open EWR The elapsed time since the intiation of these corrective actions was inadequate to accuratedly assess the*
effectiveness, however the scope of the actions demonstrated the licensee's responsiveness to NRC initiatives and recognition of program deficiencie The EWR procedure, SUADM-ENG-01 was revised to assure appropriate technical reviews were completed prior to EWR closeout and return of the system or component to operable statu An additional program change was the establishment of a 90 day time limit for administrative closeout of an EWR fol1owing completion of the EWR specified activity, i.e. evaluation or modification completio These program changes directly address the deficiencies of incomplete technical reviews and EWR closeout without documentatio The latter defidency was related to the closeout of backlogged EWR as part of the restart effor Some of these EWRs were completed but were not administratively closed for an extended time period resulting in difficulty in retrieving documentatio Subsequently, EWR closures during the restart effort were, in some cases, based on engineering judgment rather than full documentatio The 90 day closure time 1 imit addressed this performance deficiency by requiring closure while the applicable documentation and cognizant personnel are availabl The procedure for 10 CFR 50.59 safety evaluations was revised to provide more detail in the check list identifying potential system impact of specific change *
A broad samp1e review of EWRs which would identify the effectiveness of the above program changes was not accomplished during this inspection however, some EWRs reviewed provided an observation regarding the range of performance by differing onsite engineers. A modification EWR (#89-299)
associated with component cooling water supports provided a detailed and thorough 10 CFR 50.59 safety evaluation and good documentation of modifi-cation installation and functional test activit An EWR (#89-488) which addressed a charging pump services water pump opera bi 1 i ty contained inaccurate information and changed the operable performance range of the pump without sufficient documented basi The resulting change was in a conservative direction therefore no safety significance was apparent in this case however the inaccuracies in this evaluation indicated an inatten-tion to detail associated with the technical content of the evaluatio These examp 1 es provided no basis to assess the current overa 11 accept-ability of the EWR program performanc However they do illustrate the range of quality (good and marginal). achieved by different individuals utilizing the same program guideline A review of the EWR backlog indicated that the licensee has b~en agressive in addressing the existing backlo The actual numerical backlog has not substantially decreased over the last year however there has been an increase in the volume of EWRs generated and processed in 1989, in part due to deficiencies identified during the restart efforts. Additionally, the focus of.resources on restart issues resulted in an increased backlog of nonessential EWR Review of the EWR process indicated that a potential safety related concern would have been identified by an initial engineering screening when the EWR was submitted. This screening identifies potential operability concerns and establishes an initial priority. The EWR program at Surry is not a problem identification mechanism which provided additional assurance that no unidentified safety problems were contained in the EWR backlo Efforts to eliminate the EWR backlog included periodic reviews by a management committee to evaluate the need of backlogged EWRs and the dedication of eight engineers in December 1989, to process the existing backlo *
In conclusion, the licensee has agressively addressed engineering support weaknesses related to the EWR progra Corrective actions included program changes, management focus, and a location of resources. * The
. effectiveness of this actions will be assessed in future inspections which interface the EWR progra Review of the EWR process controls at this time provided no indication of unidentified safety concerns within the existing EWR backlo Corrective actions to address a technical support weakness associated with component failure cause analysis and trending addressed in the previous SALP report have not been effectively implemente This weakness had been previously identified by the NRC and the licensee. A self initiated corrective action implemented in December 1988, was not effective. This corrective action was to issue procedure guidance, SUADM-ENG-10, and assign responsibility for this activity to the System Engineering grou The failure to adequately resolve this deficiency was
i den ti fi ed by the license Present corrective action was in process during this inspectio The corporate organization developed a root cause evaluation training program in November 198 Training for the plant technical staff was being conducted during this inspection time frame. * The res pons i bi l i ty for component failure cause analysis and trending was reassigned to Maintenance Engineering. Maintenance Enginee-ring was developing a draft procedure, SUADM-M-48, and anticipated implementing the failure analysis and trending program in January 199 This program will be reviewed in future inspection activit.
Station Deviation Reports (SOR) The inspector reviewed the Licensee* SOR.program and backlog status in an effort to assess how the engineering staff responds to concerns/problems identified in the plant. A SOR is used to notify management of the need to correct a problem 6r potential problem which include changes to a component, structure, system or drawin Any plant staff member can initiate a SOR and the shift supervisor is responsible for the review of SDRs, and to determine the safety implications and notification The shift technical advisor is responsible for reviewing the shift super-visor1s determinations and screening SDRs to identify unanalyzed plant conditions. The Safety Engineering Nuclear (SEN) group reviews SDRs for reportability and safety significance and identifies concerns that should be addressed in the disposition of SDR SEN has primary responsibility for assuring that SDRs are investigated, processed, and resolved in accordance with the applicable plant procedure, SUADM-0-12, Operations Department Notifications, dated October 12, 198 The licensee currently uses a deviation report flowchart and threshold screen criteria to enhance the processing of SDR However, this proc*ess was not accurately described in the above procedur Th~ licensee has acknowledged the discrepancy in the procedur The inspector was informed that the procedure will be revised to correct the discrepancy and will be implemented in January 199 A review of SOR backlog status revealed that approximatly by 3715 SDRs for both units were generated during the period of January 1 through December 12, 1989, and 1152 were still outstandin Of the 3715 SDRs, 1427 SDRs were assigned to the engineering staff for resolution and 273 SDRs are still outstandin *
Overall, SDRs generally appeared to be properly maintained, processed and resolved in a timely and systematic manne Temporary Modifications (TM)
Review of the control room TMs log books indicated that as of December 11, 1989, there were approximately 43 active. TMs for both unit Of 43 TMs, 15 TMs were older than one year. The inspector determined that
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there was an apparent weakness in strict procedure complianc Procedure SUADM-0"".11, Function Bypass and Temporary Modification Control, dated May 31, 1989, stated that an EWR should be submitted and attached to the appropriate TM log sheet for a TM that is iritended to remain in use or has been installed more than three month There were approximately 16 TMs older than three months which did not have an EWR or appropriate EWR attached in the temporary log sheet. This problem was previously identified by the licensee and documented as a QA audit finding, #89-08-02, issued in November 198 Other concerns were identified with the TM program implemen-tation related to bypassing permanent modification contro TMs are not intended to fulfill the function of permanent modification The concerns-include:
(1) the program did not address how long a TM was to remain active and there was no requirement for management approval to extend active TMs beyond their estimated date and (2) the program did not erisure controlled copies of the control room drawings to reflect installed TMs, especially, safety-related TMs more than one year ol Six TMs were selected for detail review to determine the effectiveness of the licensee 1s process control and documentation of TM The following six TMs were reviewed:
TM#
Sl-88-11959 Sl-89-12 Sl-89-16 Sl-89-165 S2-89-126 S2-89-147 DESCRIPTION
- 1 & #2 EOG Air Intake Lowers Spent Resin Transfer System Temporary Liner Temporary Liquid Waste Ion Exchanger Hose FP Air Compressor To Upstream 1-VS-329 HCV-CC-202A Blocked Open Open Contact on 2R-RC-MOV-2595 Overall, the licensee' TM process control and documentation was generally completed as per plant procedur It was noted that the control room TMs log books are periodically reviewed by system engineer and SNSO.
Inspection of Quality Assurance and Quality Verification Activities (35702)
The previous SALP indicated a weakness in the capability of the licensee's quality organization to iqentify problems in safety related activities. Review of the audits listed below indicates an improvement in the quality of audits performed by the quality organization. A QA Perfor-mance Group began functioning in February 1989, to provide additional capability to identify problems in performance of safety related activitie The inspectors reviewed selected QA audits of various site activitie Audit findings and the responses to the findings were also reviewe The inspectors reviewed the following completed audit reports:
S88-15 S89-08 S89-09 S89-16 Design Control Operations Administration Inservice Inspection Records and Procedures
,.*
In ~ddition to reviewing the above audits, the i~spectors also reviewed audit S89-23, Design Control, which was still in progress at the conclusion of this inspectio QA personnel stated that audit S89-23 was initiated by the QA department because of the reorganization of the site engineering organization which occurred in January 198 Through review of the audit reports and discussions with site QA personnel, the inspectors made the following observation The audits reviewed by the inspectors were considered to be thorough, in-depth, and effective in identifying problem areas. The QA audit group is incorporating performance based activities into QA audit The inspectors noted that the audit reports provided more detail and informa-tion on areas audi~ed and findings identified, as compared to audit reports from previous year Corrective action veri fi cation had been a weak performance area for the quality organizatio Responses to audit findings were being reviewed more closely for corrective action adequacy and timelines The inspectors noted a significant increase in escalated actions by QA for inadequate corrective actions and responses to audit finding The inspectors noted some audit findings where acceptable responses had been received but the findings still remained ope QA personnel stated that audit findings are remaining open after receiving acceptable responses because QA personnel were verifying the effectiveness of the corrective actions following implementatio The inspectors noted that the QA audit schedule for 1990 did not show an increase in QA audit activities, even though the SALP indicated there was a weakness in the quality organization's capability to identify problems in safety related activities.* The audit schedule met minimal TS requirement QA personnel stated that the QA Performance Group is being used to supple-ment the activities of the QA Audit Group by doing performance based observations of activities above and beyond the regulatory requirement Corporate QA management recognized a need for the QA Performance Group and the group's use in providing additional capability to identify problem The QA Audit Group will primarily be used to perform audits of the regula-tory required activitie One of the functions of the QA Performance Group is to perform QA performance based observations for the QA Manager and Station Manager, or as requested by other station management through the site QA Manage Performance Methodologies that will provide guidance to Performance Group personnel for observation activities are being developed under the guidance of the Corporate QA Manage The Performance Group issued monthly reports to document the results its observation The inspectors reviewed the following QA Performance observation reports:
April 1989 May 19, 1989 November 16, 1989 December 5, 1989 Operations Maintenance Maintenance Operations The observation reports reviewed were thorough and contained considerable detail on the activities observe Based on the audit reports and observation reports reviewed, the inspectors determined that the licensee's quality verification activities are continuing to show improvemen No violations or deviations were identified in the areas inspecte.
Exit Interview The inspection scope and results were summarized on December 15, 1989, with those persons indicated in paragraph The inspectors described the areas inspected and discussed in detail the inspection results. Proprie-tary information is not contained in this repor Dissenting comments were not received from the license.
Acronyms and Initialisms ANSI-DCP-EWR-NDCM-SALP-SDR-SE-SNSOC-TM-TS-QA-American Nuclear Standards Institute Design Change Package Engineering WOrk Request Nuclear Design Control Manual Systematic Assessment of Licensee Performance Station Deviation Report System Engineer Station Nuclear Safety and Operating Committee Temporary Modification Technical Specification Quality Assurance