IR 05000338/1990012
| ML20044A571 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 06/21/1990 |
| From: | Jape F, Casey Smith, Matt Thomas NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20044A570 | List: |
| References | |
| 50-338-90-12, 50-339-90-12, NUDOCS 9006290234 | |
| Download: ML20044A571 (12) | |
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pQ CtOvq'o UNITED ST ATES NUCLEAR REGULATORY COMMISsiCN '
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.f REGION 11'
'h 101 MARIETTA STREET.N.W.
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t ATLANTA, GEORGI A 30323
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. Report Nos.:
50-338/90-12 and 50-339/90-12 Licensee: Virginia Electric and Power Company
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Glen Allen, VA 23060-Docket Nos.:
50-338 and 50-339 License Nos.: NPF-4 and NPF-7
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i Facility Name: North Anna 1 and 2 Inspection Conducted: May 21-25, H90 Inspector: [ m d,,/4 d,-
C,._ P J c/ n P. Thomas
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Date 51gpbd h
ber,lYk C, - P J ~ 9?9 C. 5mi th Date 519(1ed
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Approved by:ta h. e. b w L~ m-ST)
F. Jope, Section Chief Date Signed Quality Performance Section
Operations Branch I
Division of Reactor Safety SUMMARY l
l Scope:
l This routine, unannounced inspection was conducted in. the areas of design changes and modifications, and followup on previously identified items.
l Results:
The licensee's efforts to reduce backlogs of' EWRs,.DRs, and CTS items have
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yielded positive results.
The qualification and training program for system
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l engineers appears to be designed to provide the system engineers with a l
comprehensive knowledge of their assigned systems.
The licensee has been
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active in its' efforts to address the findings identified by NRC _during the design and installation and test phases of the 'SSOMI inspection. _-The licensee's administrative controls.were not very detailed in identifying a l
time frame within which DRs should be transmitted to SNSOC for operability reviews.
In the areas -inspected, _ violations or deviations were not identified.
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9006290234 900621 PDR ADOCK 05000338 I
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REPORT DETAILS 1.
Persons Contacted Licensee Employees r
J. Bailey, Supervisor, Procurement Engineering /ISI/NDE &' Engineering
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Programs, R. Boehling, Project Engineer, Nuclear Engineering Services
- M. Bowling,. Assistant Station Manager, Nuclear Safety and Licensing C.. Carroll, System Engineer D. Compton, tead Programs /ISI/NDE & Engineering' Programs
- E. Grecheck, Manager, Nuclear Engineering
.S. Harvey, Supervisor, Testing-
- D..Heacock, Superi.ntendent, Station Engineering G. Holmes, Procurement Engineering G. Kane Station Manager H. Le, System Engineer
- J. Leberstien, Senior Engineer, Licensing-J. Lewis, System Engineer-C. Mladen, System Engineer
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L. Reynolds, Drawing Update Coordinator D. Roberts, Supervisor, Nuclear Safety Engineering G. Rossetti, Design Control Coordinator
- R. Simpson, Engineer, Licensing
- C, Snow, Supervisor, System Engineering
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- R. Sturgill, Supervisor, System Engineering
- J. Wroniraicz, Assistant Superintendent, Station Engineering - Design P. Young, Procurement Engineering Other licensee employees contacted during this inspection included engineers, operators, technicians, and administrative personnel.
NRC Resident Inspectors
- M. Lesser, Senior Resident Inspector L. King, Resident-Inspector
- Attended exit interview
2.
DesignChangesandModifications(37700)
The inspectors reviewed DCPs, EWRs, and temporary modifications to verify-that safety evaluations were performed; that changes were reviewed and approved in accordance with the TS and licensee administrative controls; that applicable plant operating documents (drawings, plant procedures,-
FSAR, TS, etc.) were revised to reflect the changes; and post modification
test requirements were specified where applicable.
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(a) DC-87-24-1, Pressurizer Spray Volve Position Indication i
This modification involved installing valve position indication in the-
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main control room for the pressurizer spray valves.
The pressurizer i
spray valve indicating lights were installed to resolve a deficiency.
identified during the control room design _ review conducted at North Anna.
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The inspectors reviewed this DCP in connection with the followup for IFI 89-200-02 which-is discussed in more detail in paragraph 4.c. of this i
inspection report.
(b) DCP Pilot Program
The licensee, in W.B. Rodill's memorandum, subject:
Status of the Ss0MI Design Phase Followup Items North Anna Power Stations,_ dated May 22, 1990, stated that the design change program would be revised to p)rovide. for (1) a more direct DCP preparation and review process and (2 a simpler DCP format. The inspectors determined that the due date for this revision was in the early part of 1990. Additionally, the inspectors were informed that a task group had been formed for initiating changes to procedure:
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STD-GN-0001, and the NRC would-be provided a revised schedule if it becomes
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apparent that the new DCP standard would not be implemented by June 30, 1990.
The inspectors determined that STD-GN-0001, Instuctions for DCP Preparation, Revision 9, will be approved and issued for use in a-pilot program by May 30, 1990.
The-objectives of revising-the above standard is to make the preparation and review of DCPs more efficient by imposing the following requirements:
Performance of a multi-discipline review and sign-off duri_ng early stages of DCP preparation (up-front).
l Review of source documents to ensure that design '. basis l
information is correct and has not been inadvertently changed.
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Review of design change to ensure effects of internal and external flooding are considered.-
P Completion of an Engineering Design Change < Control Checklist to ensure that an adequate evaluation / consideration of technical and licensing basis requirements have been considered.
Completion of an expanded Design Input Review checklist which
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ensures incorporation of guidance of ANSI N45.2.11-1974 and additional instructions.
The DCP closecut process will be integrated into the design engineering controls to ensure design-engineer's review of various post-modification
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acceptance requirements. The inspector's were informed that a key require-ment of the new program is that EWRs will no longer be used to initiate plant modifications, i.e., hardware changes.
Additionally, hardware changes will be implemented only via DCPs which are initiated by DCRs.
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The DCP pilot program is scheduled to start on June 4,1990, with six projects yet to be selected by licensee management.= Lessons. learned will
be incorporated into STD-GN-0001, and Revision 9 will be-issued on i
August 15, 1990, for plant use.
Concurrent'with the= issue of Revision-9
revised administrative procedures establishing requirements for use of DCRs will be issued to implement the new program.
t Pending completion of the DCP pilot program an evaluation 'of -the effectiveness of-the changes to STD-GN-001 cannot be made.
Followup
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inspections will be performed to accomplish this.
(c) Field Change Requests Trending Program The licensee is in. the process of developing a performance indicator which would provide a mea.sure of the effectiveness of design-engineering =
activities.
The inspectors determined that trending of FCRsfis used as this parameter.
A Field Change Tracking and Trending = form has been developed with various descriptions of assignable causes for FCRs.
Discussions with licensee management revealed that the following methodologies are used for preparing FCR trend charts:
Percentage FCRs preventable plotted against time.
Number of FCRs having various - descriptions per 20,000 construction man-hours plotted against time.
The inspectors determined that guidelines for assigning preventable /non-preventable cause to FCRs have not been developed.
Additionally, the methodologies used by the-licensee to prepare trend-
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charts appear to lack analytical rigor.
At the time of the inspection, no valid trends could be identified from the trend' charts prepared from data which covered a time span from January to April, 1950.
Licensee management stated that (1) development of screening criteria for preventable /non-preventable causes of FCRs and~(2) establishing mathematical rigor in the analytic process used for preparing the trend charts is an ongoing activity.
Managements' first priority is to reduce the number of FCRs.
The effectiveness of: the FCR trending program to identify design-engineering weaknesses will be reviewed by the NRC after additional development and implementation by the licensee.
(d) Procurement Engineering
The RPE is tasked with performing sound, technical, accurate, and complete engineering evaluations of safety or non-safety related spare part, component, material, or service.
Procedure ENAP-0004, Procurement-Technical Evaluation Determination, Revision 0, specifies the guidelines to be used during preparation of PTE.
The inspectors reviewed work products and conducted interviews with selected RPEs to determine the extent of the engineering / technical support provided by this organization.
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The following procurement engineering actions were reviewed by. the inspectors:
PTE No. NA-90-00439, Air Operated Damper Control Motor (Powers PM
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-331-6X4APowerStrokeMotor)
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PTE No. NA-90-00331, 6"/4" Restriction Orifice Plate Assembly
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PTE No. NA-90-00425, Splice Kit, Nuclear Plant, Type V
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-PTE No. NA-90-00410, Overload R914y PTE No. NA-90-00403,-Insulation Heat Shrink Cable' End Sealing Kit l
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The inspectors determined that the correct technical and quality -
requirements had been specified for materials involved in the above ~
procurement actions. -The capability of the Procurement Engineering staff
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to identify safety significant issues was demonstrated-by ' PTE No.-
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NA-90-00439.
This PTE was related to the dispositon of a deviation report-that documented the procurement and use of non-safety related pneumatic operatorsonUnit1SafeguardExhaustFanDischargeDamper(A00-HV-1301A&B).
Resolution of this deficiency required prompt and well. coordinated actions by. Procurement Engineering and Design Engineering personnel.
Damper A0D-HV-1301B was replaced on the night of May 24, 1990, with an instock actuator identical to the orignial with a supporting commercial grade dedication package.
Additionally, JC0 No. 90-08, was written to
address deficient damper A00-HV-1301A which had not yet been replaced by
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a dedicated actuator.
The actions of the Procurement Engineering / Design
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staff demonstrated (1) an indepth technical evaluation of the Engineering (2) timely response to an operations problem from a nuclear
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issue and safety standpoint.
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An evaluation of the licensee procurement engineerino program was not performed. However, the inspectors identified inad~"i e interface between Procurement Engineering and-Design Engineering ft u.urement activities
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based on review of the 75 percent completed design,nange package.
Licensee management agreed to include Procurement Engineering in the
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review of the final design change package to identify any material' changes that may have occurred since review of the 75 percent completed design change package.
Within this area no violations or deviations were identified.
3.
Plant Engineering Support The inspectors reviewed several activities which give an indication of I
plant support provided by station engineering. These activities included l
system engineering, EWR backlog, drawing update, JC0 backlog, temporary
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modifications, commitment tracking system (CTS) items, and deviation reports.
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(a) System Engineering The system engineering group was reviewed to assess its involvement in plant activities.
System engineering is a part of~the station engineering organization.
The role of system engineering is delineated in North Anna Site Engineering Services _ implementing procedure NASES-1.06, Station
' Engineering organization, Revis_ ion 0.
System engineering is to provide in plant day-to-day engineering support to other departments on _ specific system questions and to monitor system performance to optimize system reliability and efficiency.
Support to station departments includes assisting in the development and review of station modification;' assist in preparing JCOs; responding to DRs and CTS items; providing engineering support for maintenance activities; perform major engineering functional tests; support preparation of system root cause evaluation; and etc.
The plan to improve system performance and reliability is one of, the goals discussed in the Engineering Quality Plan dated January 10, 1990.
The Quality Plan was developed by the licensee's corporate engineering management in order to focus on the weak areas within engineering that
. nged 1[nprovement and enhance the strengths.
Selected plant systems have been assigned to each system engt-*,
The systems have been prioritized on the basis of known' reliabiliv, *blems in the past and relative importance to safety and generation.
The quality plan goal for 1990 requires an initial effort to. develop qualification modules for seven priority one systems, and to identify seven new systems to develop qualification modules.
In addition to identifying the priority one systems, selected components have been designated for. development of qualification modules. The goal of the qualification process.is to ensure.
that each qualified system engineer has a consistent, demonstrable, and documented knowledge of the systems and components assigned to them.
Once the initial qualification modules have been developed.- the system engineers are required to develop system review procedures (SRP) and system tracking and trending (STAT) procedures.
These procedures will be used to eyeluate system performance and reliability.
While reviewing the status of the qualification process and during discussions with system engineering nersonnel, the inspectors learned that the system engineering group has exceeded the initial goal of the quality plan by identifying more than seven priority one systems and developing qualification modules for the systems.
The SRP and STAT procedures were in the process of being developed at the time of this inspection 'and are scheduled for implementation during the second calendar quarter of'1990.
During discussions with selected system engir@ s, the inspectors noted that the system engineers were knowledgeable of their essigned systems and activities affecting those systems.
The inspectors determined that system engineering was actively involved in plant activities and providing support to other departments. Development and implementation of the goals outlined in the Engineering Quality Plant are positive indications of the licensee's efforts to improve the overall quality of engineering support provided to the plan..
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(b) EWR Backlog / Work Related Activities
I Licensee management's activities related to EWR backlog were'
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reviewed by the inspectors.
Objective evidence reviewed during this
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effort included:
North Anna Power Station EWR Log, Active EWRs Procedure ADM-3.7, EWR, dated December 28, 1989
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Monthly Engineering Assessment. Report dated ~May 8, 1990
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Review of objective evidence and discussions with engineering personnel revealed that the licensee has been successful in reducing the EWR; backlog.
The inspectors determined, however, that cancellation of non-issued-EWRs
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t as described in ADM-3.7, does not require a documented basis. The. absence of requirements for documenting the basis for cancellation of EWRs was-identified as a programmatic weakness.
The licensee has recognized the need for developing administrative controls that provide for processing, scheduling. and tracking. design-engineering organization EWR related activities.
A design-engineering work; management system is presently being developed to meet this need.
Discussions with
design-engineering personnel revealed.an adequate staffing level will be
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achieved by July 1,1990, based on' employee offer acceptances as' of May 23, 1990 Personnel presently on staff were found to be experienced and -
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qualified.
Design-engineering personnel attend plan-of-the-dayJmeetings
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to ensure an adequate degree of. involvement in nuclear operat%n issues.
The inspectors were informed that this establishes ownership and provides accountability on the part of the dcsign-engineering organization for resolution of station problems.
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The inspectors identified the day-to-day involvement of the' design-engineering organization with nuclear operations staff as a. strength.. Evaluation of the effectiveness of the work-management system' to provide timely and
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technically adequate support to the operating unit will be performed when the system has been fully developed and implemented, q
Within this area no violations or deviations were performed.
(c) Drawing Update Status Activities Administrative procedure ADM-6.10, Annotation and Revisio'n of Station-drawings, dated September 7, 1989, establishes requirements for annotating, revising, and distributir.g station drawings.
Paragraph 4'.0 specifies the categories of drawings and delineates the required time frames for revising these drawings.
The inspectors verified that the established time frames for revision of the various categories of drawings were at least as restrictive as the licensee's comitments to the NRC contained in letter serial number 740, to Mr. James P. O'Reilly, dated December 18, 1984.
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The inspectors reviewed the _line/bar-graphs associated with the drawing.
update. status activities..
Additonally, discussions' were held with engineering personnel having responsiblility for. implementing the requirements of ADM-6.10.
The inspectors determined that the-licensee has been successful in reducing the number of outstanding unrevised drawings.
At the time' of the, inspection ADM-6,10 was being-revised to incorporate more restrictive requirements for timely update / revision of station drawings.
Within this area no. violations or deviations were identified.'
(d) Justifications'for Continued Operation The licensee stated that a backlog of open but inactive JCOs had. developed because there was no administrative guidance which addressed closure of
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JCOs which,were no longer needed.
Toward the beginning of the current SALP assessment period, Station Engineering initiated actions to evaluate all open JC0s and provided information to SNSOC to support closure of those JCOs that were no longer needed.
Subsequent to that review, administrative procedure ADM-3.9, 10 CFR 50.59 Safety Evaluation and JC0s, Revision date October 5,1989, was issued which provided guidance on preparing, tracking, and closing JCOs.
The inspectors-reviewed selected JC0s to verify that the basis for closure of the JCOs was adequately -
documented.
The JCOs reviewed were properly documented and closed.
(e) Temporary Modifications Administrative procedure ADM-14.1, Jumpers, (Temporary Modifications),
dated October 13, 1988, establishes requirements and specifies controls for the use of jumpers.
Responsibilities for implementing the program have been assigned; a 10 CFR 50.59 Safety Evaluation is required to be performed prior to installation; and requirements for obtaining SNS00 approval prior to installation have been imposed.
Based on review of ADM-14.1 and discussiors with engineering personnel the inspectors determined that the scope of the Temporary Modification program was well defined.
Additionally, appropriate checks and balances have been imposed to ensure nuclear safety, and the requirements for implementing the program have been clearly stated.
An evaluation of the implementation of the program was performed by review of (1) North Anna Unit 1 Jumper Log, and (2) copies of selected Jumper Initiation and Description Forms for open temporary modifications.
No deficiencies were identified during this review.
The inspectors determined, from review of the Temporary Mod status bar graphs, that the licensee has successfully reduced the number of Units 1&2 outstanding temporary modifications.
Within this area no violctions or deviations were identified.
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(f) Comitment Tra king System-The inspectors reviewed selected CTS items that are assigned to engineering for review and resolution.
One of the weaknesses identified during the licensee's assessment of'its engineering department was the excessive number of CTS items that were extended past their due dates. Approximately one-half.of the CTS items answered by engineering in 1989 were extended.
The licensee's assessment of ' this area indicated that the excessive-number of extensions were due in part to a lack of planning by the engineers and a high tolerance by _ engineering management.
Another contributng factor may have been inadequate engineering staffing levels.
In ' order to reduce the number of CTS extensions, engineering management:
has lowered its threshold for granting extensions, supervisors and engineers -
are held accountable for their scheduling and planning, and staffing levels q
in station engineering have been increased.
Begining in April 1990,
engineering management established a goal of an average nine extensions per month, as opposed to the nearly 25 per month averaged in 19.89.
The inspectors reviewed the CTS items assigned to engineering that 'were. due in April 1990, and found that there were no extensions required.
i (g) Deviation Reports The inspectors reviewed deviation reports (DRs) assigned to engineering for resolution since the beginning of the current SALP period.
In general, the number of open DRs -was considered low. The licensee has.been workingt to reduce the number of open DRs that were more-than 30 days old.
Per administrative procedure ADM-16.1, Station Deviation Reports, Revision date October 11, 1989, the cognizant station group has 30 days to respond to DRs assigned to them.
The number of DRs assigned to engineering that are greater than 30 days has been decreasing during this SALP period.
While reviewing procedure ADM-16.1, the inspectors ~noted a minor
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weakness where the procedure does not.specify a time frame within which applicable DRs must be ' submitted to SNSOC for operability determinations.
During discussions of this matter, licensee personnel stated that this weakness had been previously discussed by SNSOC.
This matter will be addressed when ADM-16.1' is revised -in conjunction with the administrative procedures upgrade - program that is currently ongoing for both North Anna and Surry Power Stations.
4.
ActionsonPreviousInspectionFindings(92701)
a.
(0 pen) IFI 50-339/90-05-11, Protective Devices on Safety Class Buses not coordinated (EP-1, Unresolved Item 50-339/89-200-11)
Technical Report No. EE-0021, Coordination of Load Center Circuit Breakers, Revison 0, documented a lack of coordination between the 4160V load center feeder breakers and the load center main breakers for all potential faul ts.
The licensee has performed additonal engineering analysis to correct the above design deficiency.
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Conceptual engineering (Type 2) Report IR No. 2122A, Load Center Circuit
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Dreakers, dated May 15, 1990, provides a detailed analysis of the emergency
bus-breakers.
It also includes reconenendations for setting changes to the
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following protective relays on the 4160V switchgear.
-i Cubicle Relay-QTY 15H2 SIV-GE IJCV
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15J2 SIV-GE IJCV
25H2 SIV-GE IJCV
25J2 SIV-GE IJCV-
15H8 5IV-GE IJCV
15J8 SIV-GE IJCV
25H8 SIV-GE IJCV
25J8 SIV-GE IJCV
l Reconinended changes are also to be made to the following 480V breaker trip settings:
Cubicle Trip Unit'
QTY 14H1-1 2000A OD-4
i 14J1-1 1200A OD-4 3'
The results of the study documented in-IR. Report'No. 2122A'has concluded
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that no new protective devices are required, and the above breaker and relay setting changes will allow adequate -equipment protection while ensuring proper coordination between devices.
However, additional '
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investigation is ongoing concerning the basis of a 1.2 second time delay
used with overcurrent CJC relays of breakers-15H11,15J11, 25H11, and 25J11. A change in this time delay may be required to ensure coordination
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between the EDG breakers and off-site power source while the EDG is being l
tested.
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Proposed corrective actions to be implemented by the licensee are different from that described in NRC report number -50-338,339/90-05.
Additionally, the scope of the proposed corrective actions has expanded to include the off-site power source.
This item will remain open pending review by NRR to determine the technical adequacy of the licensee's actions.
b.
(0 pen)IFI 50-338, 339/90-12-01, Pressurizer-0ven~ Seismic Analysis (IFI 89-200-01).
i This item remains open pending further review of the licensee's seismic evaluation.
c.
(Closed) IFI. 50-338, 339/90-12-02, Pressurizer Spray Valves Postion
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IndicatingLights(IFI 89-200-02).
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i During discussion of this item with licensee personnel it w6s stated that the pressurizer spray valves PCV-2?55A and PCV-2455B for Unit 2 are modulating valves which are normally kept open approximately five to-ten.
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percent during normal plant operation with some pressurizer heaters on.
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Limit switches are not normally installed on modulating-valves.
In this
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The limit switches on the valves in question were set at approximately the same position that the.
valves are normally kept open.
The licensee. further stated that the-limit switches cannot be ~ accurately set et a specific quantitative value, which is the reason one spray valve was indicating an intermediate position while the other spray valve indicated closed, even though both valves were slightly opened in the intermediate position.
Licensee personnel stated that the limit switches will be checked during the upcoming Unit 2 refueling outage -scheduled for the fall of 1990.
If-necessary, the limit switches will be reset and the spray valves will be functionally tested.
The limit switches for the Unit 1 pressurizer spray valves PCV-1455A and PCV-1455B were set and tested per DCP 87-24 after questions were raised'
concerning the Unit 2 spray _ valves during-the test and installation phase of the SSOMI.
The inspector observed the valve-position indication for these valves in the main control room and found that valve PCV-1455A indicated green light (closed) and valve-PCV-1455B indicated both green and red light (intermediate postion).
When the inspector-questioned operations personnel in the control room, it was stated that volves PCV-1455A and PCV-1455B were both open very-slightly.
The inspectors noted that position indication of the Unit 1. spray valves was similar to the postion indication observed by the SS0MI team for the Unit 2 spray valves.
The valves-position indications also coincide with the licensee's explanation as to the discrepancy between the valve position indicating lights.
Therefore, this item is considered closed.
4.
Exit Interview The inspection scope and results were summarized on May 25,1990, with those persons indicated in paragraph 1.
The inspectors described-the areas inspected and discussed in detail the inspection results.
Proprietary information is not contained in this report.
Dissenting comments were not received from the licensee.
5.
Acronyms and Initialisms CTS Comitment Tracking System DCP Design Change Package DCR Design Change Request DR Deviation Report EWR Engineering Work Request FCR Field Change Request FSAR Final Safety Analysis Report
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'IFI Inspector Followup Item ISI Inservice Inspu. tion JC0 Justification for Continued Operation-NDE Nondestructive Examination PCV Pressure Control Valve PTE Procurement Technical Evaluation RPE Responsible Procurement Engineer SALP Systematic Assessment of_ Licensee Performance SNSOC Station Nuclear Safety Operating Committee SRP System Review Procedures SS0MI Safety System Outage Modification Inspection STAT System Tracking and Trending TS Technical Specifications
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