IR 05000324/1987005
| ML20206G341 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 03/30/1987 |
| From: | Belisle G, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20206G318 | List: |
| References | |
| 50-324-87-05, 50-324-87-5, 50-325-87-05, 50-325-87-5, NUDOCS 8704140517 | |
| Download: ML20206G341 (9) | |
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i SA fttog UNITED STATES
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D NUCLEAR REGULATORY COMMISSION
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,j 101 MARIETTA STREET, N.W.
's ATLANTA, GEORGI A 30323
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i Report Nos.: 50-325/87-05 and 50-324/87-05
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Licensee: Carolina Power and Light Company l
P. O. Box 1551 j
Raleigh, NC 27602 Docket Nos.:
50-325 and 50-324 License Nos.:
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Facility Name: Brunswick 1 and 2
Inspection Conducted:
February 23-27, 1987
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Inspector:
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C.ME14 W T Date Signed
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Approved by:
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G. Belisle,' CMeff Date Signed J
Quality Assurance Programs Section i
Division of Reactor Safety
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SUMMARY I
Scope: This routine, unannounced inspection was in the area of licensee action on previously identified inspection findings.
a Results: No violations or deviations were identified.
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B704140517 870400
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REPORT DETAILS 1.
Persons Contacted Licensee Employees J. Boone, Principal Engineer-Projects J. Brown, Resident Engineer, Engineering and Construction R. Bryant, Document Control Senior Specialist
- J. Chase, Assistant to General Manager
- W. Dorman, Supervisor-QA
- E. Eckstein, Manager, Technical Support
- K. Enzor, Director, Regulatory Compliance R. Groover, Jr., Project Construction Manager
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- M. Kesmodel, Document Control Supervisor E. Lindsey, Senior Specialist Engineer
- W. Murray, Corporate Licensing
- G. Oliver, Manager-Site Planning and Control
- T. Parlier, Principal Engineer-Brunswick Engineering Support Unit
- T. Porter, Brunswick Engineering Support Unit
- B. Poteat, Project Specialist, Brunswick Construction Unit
- R. Poulk, Senior Specialist-NRC
- J. Smith, Director-Administrative Support G. Thompson, Project Engineer-Systems
- J. Titrington, Engineering Supervisor-(Dise).
- L. Wheetley, Project Engineer (ISI)
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- T. Wyllie, Manager-Engineering and Construction NRC Resident Inspector W. Ruland
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on February 27, 1987, with those persons indicated in paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection findings.
No dissenting comments were received from the licensee.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspection.
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Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.
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Unresolved Items Unresolved items were not identified during this inspection.
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Licensee Actions on Previously Identified Inspection Findings (92701)
General The NRC's Confirmatory Order EA-82-106 imposed the requirement that CP&L'S management shall implement the Brunswick Improvement Program (BIP)
t transmitted by CP&L letter to James P. O'Reilly, Regional Administrator, USNRC, Region II, from E. E. Utley, dated October 29, 1982. Additionally, licensee management was ordered to review and assess for implementation, recommendations related to the Post Start-up Improvement Program Objective Number VII. The following BIP action items were generated pursuant to CP&L management's compliance with the order. The inspector reviewed these action items to verify the status of the commitment, and the adequacy of the implemented corrective actions.
(Closed) Inspector Followup Item 84-SC-01:
BIP 5.3.2.A, Review System Engineer Function to Provide for More Effective Systems Engineering.
The inspector conducted interviews with licensee management and reviewed the objective evidence prepared to implement the requirements of BIP 5.3.2.A.
The following documents were reviewed by the inspector in connection with this effort:
System Engineer Duties and Responsibilities
System Group Work Load Study dated August 11, 1983 CP&L Memorandum to M. D. Hill from E. A. Bishop, Subject:
Organizational Upgrade Request, dated August 12, 1983 System Engineering Training and Qualification Training Instruction:
TI-606, Volume I, Revision 001 System Qualification Card-Electrical System Qualification Card-Mechanical Roster of System Engineers showing cognizant system engineer and assigned systems.
The inspector verified that CP&L management had established administrative i
controls to better define the role of the system engineer.
A job description had been prepared that describes the functional responsi-bilities, levels of authority, and lines of communication interfaces.
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Qualification requirements had also been established, and a lesson plan had been prepared for implementing, controlling, scheduling, and monitoring the qualification and training of system engineers.
The inspector determined that of the total number of 18 CP&L employees assigned as system engineers only 12 have been qualified on a total of 20 systems.
Also, most system engineers who may be qualified on a few systems, because of re-assignment to new systams, end up having cognizance for various systems on which they are not qualified. The total number of systems for which qualification is required is 84.
In discussions with licensee management regarding the status of system engineer training, the inspector determined that there is a temporary halt to the training program.
This is caused by the existing unit outage and the need of the system engineers to support the plant outage activities.
The inspector was further informed that at end of the unit outage, a reassessment of the training requirements for system engineers will be performed to establish a more even distribution between workload and personnel resources, commensurate with the need to maintain system training.
Licensee management stated that the existing arrangement of providing system engineers with one week of training out of every four week period, cannot be maintained.
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At the exit interview the inspector brought to management's attention the
need to qualify system engineers on systems for which they have cognizance.
He further stated that while the commitment delineated in
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BIP 5.3.2.A initially has been met by establishing system engineer functions and training of system engineers, this commitment needs to be maintained by an ongoing training program that ensures qualification for assigned systems. Based on licensee management's proposal for post-outage reassessment of the training program for system engineers, this action item is closed.
(0 pen) Inspector Followup Item 84-SC-02:
BIP 5.3.2.B Consider Organi-zational Structure to Provide More Centralized Control of Engineering.
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CP&L management stated in their letter, serial: NLS-86-166 dated May 30, 1986, that the company had initiated action to reorganize engineering design and control at the corporate level.
They further stated that the Corporate Design Or9
- ation will be phased in over the next few years.
Consequent to having taken these actions, CP&L management considers item BIP 5.3.2.B closed.
The inspector conducted interviews with-site management to ascertain the nature of the actions described above.
He determined that definitive infcrmation concerning the organizational structure, functional responsibilities, levels of authority, and lines of internal and external communication interfaces were not known by site management.
This item remains open pending performance of an inspection in the corporate office to assess licensee activities regarding BIP 5.3.2.B.
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(Closed) Inspector Followup Item 84-SC-03: BIP 5.3.4, Centralized Drawing Control and Controlled Design guides for Drawings.
The inspector conducted interviews with licensee management and reviewed the following program documents to assess the effectiveness of corrective actions regarding BIP 5.3.4:
As-Built Program Guideline, ABP-14, Control and Distribution of the BSEP Drawing Schedule, Revision 0.
ABP-G, Drawing Cross Reference Card File, Revision 1.
Brunswick Engineering Support Unit (BESU) Manual of Instructions.
Section 2.3, Document Filing and Distribution.
Section 2.4, Processing and Control of Original Drawings for Incorporation of As-Built Information.
Section 2.5, Reproduction and Distribution of BESU-Generated As-Built Drawings.
Section 2.6, BESU Training / Orientation Program Section 2.9, Request / Assignment of New or Additional Drawings Numbers in the BSEP Drawing Schedule (not including Foreign Prints).
Section 2.14, BESU Controlled Documents.
Section 3.7, Preparation and Control of Q List Drawings.
Section 3.12, QA Records.
ABP-14 establishes the requirements and responsibilities for storage, update, and controlled distribution of BSEP Drawing Schedule.
This schedule consists of a sequential listing intended to include all Brunswick Steam Electric Plant (BSEP) drawings.
Responsibilities have been assigned for issuing new drawing and sheet numbers, and for main-taining and protecting the Master Drawing Schedule.
The inspector determined that licensee management is in the process of establishing a computer based document control system.
This system is intended to provide centralized control of information regarding current as-built status of the plant's equipment and major design documents.
It will also provide the capability to initiate track, implement, and properly document plant modifications and other plant change.-
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Discussions were conducted with licensee management regarding existing controls for receipt, inspection, storage, protection, and distribution of documents from the Engineering and Construction Document Control Center (E&C DCC). The inspector also conducted 'a tour of the E&C DCC and work areas of the Brunswick Engineerin; Support Unit (BESU) As-Built Section.
Consequent to the tour of the E&C DCC, the inspector determined that the
heat pump that provides temperature control for the facility is not operating properly. Although this facility is not regarded as a lifetime storage facility for QA records, proper environmental controls are required for preservation of records stored there. The improper operation
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of the heat pump was therefore brought to CP&L management's attention for corrective action.
Based on review of program documents and discussions with licensee
management, item BIP 5.3.4 is closed.
(Closed) Inspector Followup Item 84-SC-04; 84-SC-05:
BIP 5.6.1, i
Centralize Document Control and Records Management; BIP 5.6.2, Site Procedures for Document Control and Records Management,
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The inspector reviewed the following documents to determine the effec-tiveness of the corrective action implemented to address the above BIP
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action items.
Operating Manual Administrative Procedure, Section 8.0, Plant
Records, Volume 1, Revision 101.
Plant Operating Manual, Volume 1, Book 5
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Procedure No:
001, Indexing of Correspondence and Plant Records, Revision 0.
o Procedure No:
003, Reproduction, Distribution, and Account-ability for Plant Records, Revision 0.
J Construction Procedures Manual Procedure No:
AP-VII-01, Document Control, Revision 9.
Procedure No. AP-VII-15, Quality Assurance Records, Revision 2.
The inspector verified that CP&L management had assigned responsibility to the Document Control Supervisor for overall responsibility for maintaining plant records. Administrative controls for record management and document control have been delineated in writing.
The program documents for quality assurance records state that permanent storage and maintenance of QA records is accomplished at the BSEP document control center.
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The established upper tier quality implementing procedures are the records management procedures contained in the Plant Operating Manual Volume 1, l
Book 5.
Based on a review of selected procedures from this group the
inspector determined that licensee commitment, delineated in the Corporate Quality Assurance Manual (CQAM), Section 17.0, QA Records, appears to be adequately implemented.
The inspector conducted a tour of the plant DCC to verify that the
environmental conditions and fire suppression systems are as described in
the accepted quality assurance program.
A discussion regarding the
humidity control instruments revealed that licensee management was performing the periodic calibration on site.
The inspector requested information concerning the pro'cedure employed during calibration and was informed that it was similar to that employed by the instrument vendor for
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off site calibrations. Additional discussions were conducted concerning logging of instrument readings for the two installed humidity instruments
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and provision for comparing instrument readings to assure proper instru-ment operation. The inspector verified that the BSEP DCC is in accordance
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- ith licensee commitments.
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At the exit interview the inspector directed CP&L management's attention to CP&L memorandum Serial:
BSEP/QA/QC-86-308, Subject:
Revision to
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BNP QA Program, dated November 3, 1986. This memorandum is a request from
the QA organization to the licensing group to have the E&C DCC incor-porated in the QA program for collection storage, and maintenance of QA records.
The inspector stated that BIP 5.6.1 and BIP 5.6.2 specifically address the need for centralization of records management and document control on site.
CP&L management has met this commitment as verified by the inspector and as stated in CP&L letter serial: NLS-86-166 dated May 30, 1986, to Dr. J. Nelson Grace, Regional Administrator, NRC.
The imple-
mentation of the proposal to convert the E&C DCC from a temporary storage facility of QA records not greater than 90 days, to a lifetime storage i
facility is contradictory to CP&L statement of position delineated in the above letter.
Additionally, both storage facilities presently operate independently of each other with final storage of completed QA records being accomplished at the plant DCC.
The implementation of the proposal delineated in CP&L memorandum serial: BSEP/QA/QC-86-308 will require the establishment of administrative controls to delineate record type and
permanent record storage location, in addition to interface controls for document flow between both lifetime storage facilities.
The inspector was informed that it is not the intent to convert the
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E&C DCC to a lifetime storage facility for QA records.
Rather, it is
required that this storage facility be upgraded in be incorporated in the
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accepted QA program for storage of QA records greater than 90 days. An outstanding nonconformance generated by the QA organization against the construction group was responsible for initiating this request.
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Based on objective evidence reviewed, discussions with licensee manage-ment, and the inspector's understanding of the intent of memorandum serial: BSEP/QA/QC-86-308, these action items are closed.
(Closed) Inspector Followup Item 84-SC-06:
BIP5.6.3, Centralize Plant Modification Document Filing or Provide Better Document Control Procedures.
Pursuant to a review of Engineering Procedure ENP-03, the inspector i
determined that licensee management had established administrative
controls for processing and controlling plant modification activities.
Paragraph G.2, Turnover, delineates the requirements for the preparation
of turnover packages and provides necessary information to document
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i satisfactory installation and acceptance testing of a plant modification.
Requirements for transfer of turnover packages to the plant DCC for permanent storage of QA records is also addressed.
Additional reviews of the following program documents corroborated the
requirement for permanent storage of plant modification turnover packages in the site's central vault:
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a BESU Manual of Instructions Section 3.12, Attachment 1, BESU QA Records Index, Revision 6 i
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Procedure #AP VII-15, QA Records, Revision 2 The inspector conducted discussions with licensee management and toured l
the plant DCC to verify implementation of the administrative controls regarding turnover packages. Selected turnover packages were reviewed with regard to storage location within the vault and the contents of the turnover packages. Records management control was also verified for one turnover package to assure proper documentation of turnover package receipt and inspection by vault personnel.
In further discussions with licensee management, the inspector was informed that insufficient understanding of the design process by Management Assessment Corporation (MAC) personnel may have contributed to
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the generation of this action item.
Licensee management further stated that examples cited by MAC to support this action item may have been
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design documents kept within the work area of the cognizant design i
organization after modification installation, in order to support resolution of exceptions to modifications. Also, these drawings are kept
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by the engineers to provide support for operating maintenance activities
subsequent to the modification becoming operable.
Based on review of objective evidence and discussions with licensee maragement, this action item is closed.
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(0 pen) Inspector Followup Item 50-325/86-08-01, 50-384/86-09-01, Revision of Program Documents to Reflect Organizational Changes.
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On September 18, 1985, CP&L senior management made a presentation to NRC senior management to address significant personnel and _ organizational
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changes in CP&L Nuclear Operations program.
These changes impacted various organizational units, including Manager, Engineering Support Nuclear Plants I and II, and Manager Nuclear Engineering Projects.
An inspection conducted March 10-14, 1986, revealed inconsistencies i
between program documents and organizational structure.
Also, in
accordance with 10 CFR 50 Appendix B, Criterion 5, section guidelines (referred to in the report as section instructions) were being prepared.
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The above inspector followup item was therefore opened to assure revision
of the upper-tier and lower-tier program documents to reflect organizational changes and completion of section guidelines.
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A CP&L telephone conversation memorandum File: 'B-X-0544, dated April 10, j
1986, documents a conversation between the inspector and CP&L personnel
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regarding this inspector followup item.
In this memorandum CP&L
management states that they see no need for this inspector followup item f
and consider this item closed.
l Discussions with site management revealed ongoing organizational changes in the corporate engineering design organization.
This fact is attested to by CP&L management in their letter Serial:
NLS-86-166 to l
Dr. J. Nelson Grace, wherein they stated that the corporate design i
organization will be phased in over the next few years. In the absence on site of definitive information concerning organizational structure,
functional responsibilities, levels of authority, and lines of internal and external communication interfaces, this item is left open pending an inspection to be performed in the corporate design office.
Within this area, no violations or deviations were identified.
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