IR 05000397/1989003
| ML17285A283 | |
| Person / Time | |
|---|---|
| Site: | Columbia  |
| Issue date: | 02/16/1989 |
| From: | Caldwell C, Johnson P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML17285A282 | List: |
| References | |
| 50-397-89-03, 50-397-89-3, NUDOCS 8903030504 | |
| Download: ML17285A283 (14) | |
Text
U. S.
NUCLEAR REGULATORY COMMISSION REGION V
Report No.
Docket No.
License No.
Licensee:
Facility Name:
Inspection at:
Inspection on:
50-397/89-03 50-397 NPF-21 Washington Public Power Supply System P. 0.
Box 968 Richland, Washington 99352 Washington Nuclear Project No.
(WNP-2)
WNP-2 Site, Benton County, Washington January 9 through 13, 1989 Inspector:
C.
W. Q'wel, Project Inspector Approved By:
P.
H. g hnson, Chief Reacto Projects Section
Date Signed (i~(r Date Signe Ins ection Summar
Ins ection on Januar 9 - 13, 1989 Re ort No. 50-397/89-03)
Areas Ins ected:
Routine project inspection of licensee quality assurance program implementation, followup of inspector identified items, licensee action on items of noncompliance, and licensee event report followup.
Inspection procedures 35502, 92701, 92702, 93702, and 30703 were covered.
Safet Issues Mana ement S stem (SIMS Items:
None
-2-Results:
General Conclusion and S ecific Findin s:
In general, the licensee's QA program has undergone substantial revision since the end of the last SALP period.
The inspector noted a number of enhancements that show a positive trend in effectiveness of the QA program.
The inspector was concerned regarding the number of repeat problems identified in QA audits and surveillance reports, and the back-log of open audit and surveillance findings.
However, the licensee's program has identified and trended repeat problems, and the Supply System was making a concerted effort to reduce the backlog of open corrective action followup items.
Si nificant Safet Natters:
None Summary Of Violations:
None 0 en Items Summar
Three followup items and two violations were reviewed and closed during this inspection.
One followup item and one deviation were reviewed that will remained open awaiting further licensee action.
No new items were identifie DETAILS Persons Contacted Licensee Personnel
- G. D. Bouchey, Director, Licensing and Assurance C. N. Powers, Plant Manager
- L. J. Garvin, Manager, gA Programs and Audits
- J.
W. Baker, Assistant Plant Manager
- C. H. NcGi lton, Manager, Operations Assurance Programs R. L. Koenigs, Plant Technical Manager
- D. R.
Kobus, Plant gA Manager A. G. Mosler, Licensing Manager
- S. L. McKay, Operations Manager N.
R. Wuestefeld, Assistant Plant Technical Manager
- S. L. Washington, Lead Compliance Engineer
- D. A. Kerlee, Principal gA Engineer
- J. A. Arbuckle, Compliance Engineer Other Personnel
- J. Irish, Program Analyst, BPA
- Denotes those attending the final exit meeting on January 13, 1989.
The inspector also contacted licensee operators, engineers, technicians, and other personnel during the course of the inspection.
Evaluation Of Licensee Qualit Assurance Pro ram Im lementation (35502)
The purpose of this review was to evaluate the effectiveness of the licensee's implementation oi the quality assurance program, and to determine whether, based on this evaluation, a follow-up regional inspection is warranted.
This effort consisted of a comprehensive review of several program audits and surveillances.
In addition, discussions with the Supply System's Program and Audits, Operational Assurance, and Engineering Assurance personnel and management were held to determine whether recent changes in personnel and program direction were enhancino the effectiveness of the quality programs in finding problems and weaknesses in Supply System activities.
This inspection did not evaluate the licensee's operating experience review (OER)
program or activities performed by the nuclear safety assurance group (NSAG).
Some inspection of the OER program was performed and documented in inspection report (397/88-32).
This review also did not include Supply System licensing activities.
Surveillances Reviewed The inspector reviewed recent surveillances that were performed of maintenance, surveillance, and operational activities as follows:
2-88-215,
"Residual Heat Removal (RHR)-V-41C Mundane Task Report 0'-00012" 2-88-224,
Pumps Operability Test (guarter1y)"
2-88-208,
"Motor Operated Valve Work" 2-88-252,
"Control Room Shift Turnover" 2-88-235,
"Standby Service Water Loop A Valve Position Verification" 2-88-218,
"Damaged and Overranged Gauges" 2-88-205, "Plant gA Overview of R-3 Modifications" 2-88-187,
"INC Maintenance Hacklog" 2-88-084,
"Design Review" The inspector noted that most of the surveillances had substantive findings regarding activities conducted in the plant.
For example, surveillance report 2-88-208 contained several significant findings concerning motor operated valve limit switches.
The surveillances reviewed also identified several recurring plant problems.
For example, surveillance report 2-88-187 identified recurring deficiencies with terminations and timely completion of instrument calibrations, and surveillance report 2-88-084 noted recurring problems with design calculations for basic design changes in the residual heat removal (RHR)
system.
The inspector also noted that gA was conducting reviews of operations activities such as shift turnovers, as documented in surveil-lance report 2-88-252.
This type of effort had not been performed in the past and was considered a positive trend in surveillance activities.
However, the inspector noted that the individual performing the survei 1-lance was not reactor operator (RO) or senior reactor operator (SRO)
qualified.
The inspector considered that additional effectiveness of the surveillance program may be achieved by having qualified ROs or SROs performing survei llances of operations activities.
Audits Reviewed The inspector reviewed recent audits that were performed by the licensee in areas" of known weakness such as engineering design, modification control, and corrective actions a follows:
88-446, "Plant 2 Compliance to Technical Specifications and Licensing Conditions"88-434,
"Design Modification Control and Associated Engineering Activities"88-426,
"WflP-2 Corrective Action"88-445,
"WNP-2 Corrective Action 5 Corporate Nuclear Safety Review Board (CNSRB) Activities"88-457, DRAFT, "Plant 2 Corrective Actions" C
The inspector noted that the audits reviewed had substantive findings regarding activities conducted by the various organizations audited.
For example, audit 88-434 was very critical of the modification process; and audits88-426, 88-445, and 88-457 identified a number of recurring deficiencies.
The inspector reviewed the responses from the audited organizations to audit findings and considered that a
number of the responses were less than adequate.
In a few cases, the responses were submitted after the due date (about a week overdue)
and some responses did not adequately address the concerns identified in the audit report (primarily audit 88-434).
As a'result, the inspector perceived that a few personnel might consider the gA organization to be in an adversarial role.
With regard to the discrepancies above, the inspector noted that gA had implemented a program to elevate untimely responses to the proper levels of management for resolution, had rejected inadequate responses, and had pursued submittal of better responses or corrective actions when necessary.
The inspector noted that ir, several of the audit reports reviewed, audi-tors attempted to identify the root cause of the problems found concern-ing the audited activity
.
For example, in audit 88-434, the gA auditors attempted to identify the root cause of the problems associated with the design modification process.
However, the inspector noted that the audited organizations did not always specifically respond to the root cause determination in the audit response.
Although the inspector noted that a root cause determination could not be done for all audit find-ings, the inspector encouraged the licensee to continue with this effort to try to identify the fundamental root cause for large scale problems and to ask the responsible organizations to respond to these root cause assessments.
The inspector compared the findings in audits88-426 and 88-445 on corrective actions.
In addition, the inspector discussed the results of the most recent corrective action audit,88-457, that was being prepared for'issue.
The inspector noted a number of recurring problems with such issues as licensee event report (LER) corrective action fnllowup, nonconformance report (NCR) closure times, Technical Specification compliance, and evaluation of NCRs for safety significance.
Many of these recurring problems were identified in the past by the NRC.
The inspector.
was concerned that these repetitive deficiencies were still occurring, but noted that gA had compiled a matrix of findings from audits in various areas and had highlighted problems with common themes.
These'recurring problems were then being identified to responsible levels of management ir ar attempt to demonstrate that inadequate corrective actions had been taken in the pas The inspector noted that there was auite a backlog in followup and review of corrective actions for deficiencies identified, particularly in the audit area.
This backlog was due to several circumstances, primarily personnel availability.
The inspector noted that the licensee was attempting a concerted effort -to reduce the backlog of items, including the solicitation of an independent contractor to help in one area.
The inspector considered that timely evaluation of corrective actions was necessary to prevent further recurring problems.
The inspector noted that the Supply System had allocated additional resour-ces to ensure that personnel were available to make quality assessments and provide timely followup and evaluation of corrective actions.
The inspector encouraged licensee representatives to continue their evalu-ation of resource allocation so that quality assessments and timely followup can continue.
The inspector noted that a few managers have specifically requested audits or surveillances of selected activities within their area of responsibility.
The inspector encouraged line managers to continue to utilize the quality groups in this fashion to evaluate perceived problems in their area of responsibility.
Princi al Enhancements To Increase A Effectiveness As a followup to discussions held during recent management meetings, the inspector discussed program and personnel changes, and reviewed associated documentation in detail with responsible personnel in the Licensing and Assurance Organization.
The inspector noted a number of enhancements to the program implementation.
Some of the more noteworthy changes were as follows:
Standardization of assessment and finding forms used by ouality groups Increased staffing allocation Utilization of a performance based inspection program Increased interface among groups (e.g.,
program audits sent to plant QA and surveillances sent to Operational Assurance for inclusion in respective audits and surveillances)
Trending of repeat or recurring problems t1onthly meetings held and reports issued to consolidate findings, to prepare a concise message or theme, and to identify such things as recurring problems to management Quarterly meetino held with the Yianaging Director to discuss such corcerns as recurring problems Quality finding, concern, and observation data revised to a more understandable format
gA plans to tabulate audit findings and organizational responses in an attempt to better evaluate problems and responses (self critique)
Increased communication between quality groups and plant personnel gA borrowing specialists from other groups and sites to perform audits, Establishing audit and surveillance specialists in various functional areas Addition of an NRC and INPO Commitment List Training exchange program for personnel Plant probabilistic risk analysis used for audit and surveillance preparation
~Summa r Based upon the documents reviewed and discussions held with Supply System personnel, the inspector considered that the licensee's quality groups were headed in a positive direction.
The recent enhancements provided evidence that the Supply System was attempting to increase the effectiveness of the ouality oversight groups.
The inspector considered that, in general, the quality groups appeared to be identifying more substantial findinos during the performance of audits and survei11ances; taking a more forceful role in conveying identified problems to the plant; and elevating large problems (such as recurring deficiencies)
to sufficiently high levels of management for resolution.
However, the inspector perceived that, in a few cases, there was still some resist-ance to gA findings as evidenced by overdue or inadequate responses.
The inspector considered that the true test of the Licensing and Assurance organization's effectiveness would be final resolution of recurring deficiencies, a continued reduction in the backlog of correc-tive action followup items, and more gA involvement to identify problem precursors before they reach NRC attention and concern.
As a result of this review, the inspector concluded that current and projected resi-dent, project, and team inspection efforts are adequate to assess the implementation of quality programs and effectiveness of the Supply System's quality oversight groups.
No violations or deviations were identified.
3.
Licensee Action On Previous NRC Ins ection Findin s (92701)
a.
(0 en Followu Item 88-32-01
, "Oiscre ancies/Concerns Re ardin ATWS Modification This item identified several discrepancies/concerns with the Anticipated Transient Without Scram (ATWS) modifications that were
installed in the plant.
In particular, the following items were identified:
The ATWS recirculation pump trip (RPT) logic scheme was different from those approved by NRR for other plants.
Several ROs and SROs were not aware of the manual reset or the minimum time to reset of the ATWS alternate rod injection (ARI).
Discrepancies were identified by the licensee in the ATWS Criteria Design Implementation Review document.
An out-of-service time limit for the standby liquid control (SLC) system needed to be determined, or justification needed to be provided in a design basis calculation or document.
The inspector found that ROs and SROs had been trained on the manual reset function of the ATWS ARI.
However, in discussions with NRR and responsible licensee personnel, the inspector found that NRR had not accepted the ATWS RPT logic scheme and that the licensee was evaluating the need for changes.
This item will remain open pending resolution of the ATWS RPT logic scheme, resolution of discrepancies identified in the ATWS Criteria Design Implementation Review Document, and resolution of the out-of-service time limit for the SLC system.
Closed)
Followu Item 88-09-01
, "Licensee Action To Ensure E
Re uirements re Met When Per orm~nq Surveys ances This concern was raised as a result of a terminal box that was found open after completion of an operations surveillance in the panel.
As a result, the inspector was concerned that the necessary environmental qualification (Eg) controls may not have been estab-lished for operations surveillance procedures.
The inspector discussed this issue with responsible personnel who indicated that operators had been reminded of the need to restore equipment to original configuration upon completion of surveil-lances.
In addition, the inspector toured the plant and did not find any terminal box covers loose or open.
The licensee also completed a review of Technical Specification surveillance proce-dures in March 1988 to ensure that the necessary Eg controls were established.
This item is closed.
(Closed Followu Item 88-20-01
, "Licensee's Evaluation Of Need For Additiona Train>n Of Ins ectors This item identified that the licensee would evaluate the inspec-tor's concern that PA inspectors were not familiar with or trained on motor operated valve testing and associated equipment.
However, they were performing survei llances on these activities.
In addi-tion, from the generic standpoint, gA inspectors were not trained
on many of the specialized processes that took place in the plant, yet they performed surveillances on activities using these processes.
The inspector discussed this item with the gA Manager who stated that the Supply System would have several gA engineers attend motor operated valve analysis and test training which is scheduled to take place before the next refueling outage.
In addition, for long range goals, the licensee was attempting to identify the appro-priate level of instruction necessary to ensure competent gA engi-neer performance observations of specialized activities.
The pending training program for gA personnel was expected to consist mainly of training already in place for plant technicians.
The inspector considered that the licensee was responsive to this concern.
Therefore, this item is closed.
d.
Closed'ollowu Item 87-28-01
, "Licensee Commitments With Re ard To Refresher Trainin For Journe en Technicians This item identified that the work schedule had had not provided most journeymen a chance to attend refresher training.
The inspector discussed this item with responsible personnel who indicated that a refresher training program was being developed along with an upgrade to on-the-job and entry level training.
The maintenance department was attempting to establish a cycle that would allow approximately 10Ã refresher training time for all maintenance personnel.
The inspector considered that the licen-see's actions were appropriate.
This item is closed.
No violations or deviations were identified.
4.
Licensee Action On Items Of Noncom liance (92702)
a.
Closed) Yiolation 88-32-03), "Failure To Pre are A
Noncon ormance Re ort or drau
~c ontro nit iscre ancies."
This item identified two instances wherein neither a problem defi-ciency report nor a nonconformance report was prepared to identify plant problems experienced with the control rod hydraulic control units (HCUs).
For corrective action, the licensee performed the following actions:
All HCU hold down bolts were torque checked..
Engineering calculations were performed to verify the seismic operability of the worst-case nonconforming condition, Planr. procedure (PPM) 1.3. 12, "Plant Problems
- Problem Evalu-ation Request,"
was revised to define and specify the use of a
'l
problem evaluation request (PER).
The PER is a document whose purpose is to establish a controlled method to formally commu-nicate the existence of a plant problem for management action.
In addition, as a result of this problem the licensee was also requested to evaluate the operating experience review (OER) program for its effectiveness in assuring that proper actions are taken when discrepancies are found during OER reviews.
As a result of the licensee's evaluation, a note was added to PPN 1.10.4, "Exter-nal Operating Experience Review," to specify that at any point in the OER process, a problem evaluation report (PER) should be initi-ated if there is reason to believe that an item of noncompliance may exist.
1he inspector considered that the licensee's actions in response to these matters were appropriate.
Therefore, this item is closed.
b.
(0 en) Deviation (88-32-02
, "Failure To Com lete Calibration f
>ese enerator an Leve Instruments C.
This item identified that the licensee did not complete calibration of the diesel generator (D/G) fuel oil tank level instruments within the specified time.
As a result, the instruments were not operable.
The licensee planned to complete calibration of the D/G fuel oil tank level instruments during the next refueling outage.
This item will remain open pending completion of work.
(Closed Violation 88-20-02
,
"Two Exam les of Failure To Pre are A Nonconformance Re ort
'his item identified two instances wherein licensee personnel did not prepare a nonconformance report for plant problems.
The first example involved a
new fuel bundle that was dropped and the second involved problems with torque switches and degraded grease in motor operated valves.
For corrective action, the licensee revised PPN 1.3.12, "Plant Problems - Problem Evaluation Request,"
to define and specify the use of a PER.
In addition, the affected torque switches were replaced and the licensee inspected a number of valves to ensure that their torque switches were operable.
With regard to the degraded grease, an interim inspection was conducted for selected valves in the steam tunnel.
For long term action, the licensee has an open item on the plant tracking log to inspect and change the grease in all the motor operators of all safety function valves in the drywell and main steam tunnel during the next refueling outage.
The inspector considered that the licensee's actions and long term plans were adequate to resolve this item.
This item is closed.
No additional violations or deviations were identifie.
Licensee Event Re ort (LER Followu (93702)
The following LERs were closed based on in-office review:
LER 88-27, "Reactor Water Cleanup System Isolation On High dP Flow" LER 88-32, "Inadvertent Closure Of Reactor Core Isolation Cooling Steam Supply Line Containment Isolation Valve" No violations or deviations was identified.
6.
~fN (30i03i On January 13, 1989, an exit meeting was held with the licensee representatives identified in paragraph 1.
The inspector summarized the inspection scope and findings as described in this report.
The licensee did not identify as proprietary any of the information reviewed by or discussed with the inspector during the inspection.