IR 05000400/1985007
| ML18018B940 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/12/1985 |
| From: | Upright C, Wright R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18018B939 | List: |
| References | |
| 50-400-85-07, 50-400-85-7, NUDOCS 8505210388 | |
| Download: ML18018B940 (12) | |
Text
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t UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Report No.:
50-400/85-07 Licensee:
Carolina Power and Light Company 411 Fayettevi lie Street Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Harris
Inspection Conducted:
February 11-15, 1985 License No.:
CPPR-158 Inspector:
R.
W. Wright Date, Signed Approved by:
C.
M. Upright ec n Chief
, Division of R acto Safety D
e igned SUMMARY Scope:
This special, unannounced inspection entailed 37 inspector-hours on site in the areas of worker concerns regarding nonconformance reporting methods and numbering system changes, construction inspection pressures, and the release for test (RFT) program Results:
No violations or deviations were identified.
85052i0388 '8503i3 PDR ADOCK 05000400
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REPORT DETAILS 1.
Persons Contacted Licensee Employees
"R. A. Watson, Harris Project Vice President
- G. L. Forehand, Director QA/QC
"G.
M. Simpson, Principal Construction Specialist
- N. J. Chiangi, Manager, QA/QC
- A. H. Rager, Manager, Construction Inspection
"D. A. McGaw, Superintendent QA
"A. G. Fuller, Principal Engineer, Pipe Hangers
'H.
F. Wagner, Senior Specialist, QA Surveillance W. Seyler, Manager, Construction Start-up L. Garner, Sub-Unit Supervisor, Mech/Instr/Coatings R.
Haney, Sub-Unit Supervisor, Pipe Hangers D. Erb, Supervisor, QA/QC Pipe Welding G. Daniel, Senior QA/QC Specialist (Mech)
P.
Cook, Jr., Central Control Supervisor NRC Resident Inspectors
"R. L. Prevatte
~Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on February 15, 1985, with those persons indicated in paragraph 1 above.
The licensee did not identify as proprietary any of the material provided to or reviewed by the inspector during this inspection.
3.
Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Worker Concerns a.
Nonconformance Reporting Methods and Numbering System Changes.
(1)
Concerns
(a)
CP&L changed from Deficiency and Disposition Reports (DDRs)
to Nonconformance Reports (NCRs) to make the nonconformance numbers look better.
(b)
One nonconformance could cover many items.
One DDR had
pages.
Findings and Conclusions, Concern (a)
As correctly stated by the concerned worker, CP&L did change their nonconformance reporting system around late December 1983, replacing three different nonconformance controlled documentation systems (DRs, DDRs, NCRs)
with one controlled nonconformance document, the NCR.
However, CP&L made this change to improve their nonconformance control program as a result of their own audit findings and Region II's concern for the increased potential for problems that could be attributed to multiple nonconformance reporting systems as discussed in inspection reports 50-400/83-24 and 50-400/83-25.
It should be noted that changing a nonconfor-mance system to improve a
gA program is not unique to CP&L in that most Region II nuclear facilities have done so during the course of construction.
Likewise, Region II believes that this change should enhance Harris Nuclear Power Plant's (HNPP)
nonconformance control system.
With the implementation of Procedure CgA-3 and the new nonconfor-mance control system, the new NCRs generated received sequential numbers beginning over again with 001.
The first new NCR was recorded as number 83-001 and as of December 12, 1984, NCR number 84-2422 had been written.
Although this numbering system may not be the best or most logical system, Region II can find no fault with it nor do we consider it an attempt to hide total nonconformance numbers.
Region II has been inspecting HNPP since its conception and is well aware of the nonconformance reporting changes that have occurred there to date.
If one is concerned with the total number of nonconformances reported since day one at HNPP, they simply have to,add all the former discrepancies (DRs, DDRs, NCRs)
along with the total number of current new NCRs written to date to arrive at this figure.
This information can be readily obtaine'd from the respective nonconformance report logs.
Findings and Conclusions, Concern (b)
Examination of a sampling of DDRs on file revealed at least two examples (DDRs 994 and 1030)
where these DDRs were written to cover numerous deficient items as alleged by the concerned worker.
DDR 994 consists of approximately
attachments describing a
generic problem with Bergen-Patterson shop welds on numerous
identified seismic I pipe supports which were found deficient during inspection of the installed hangers and at receipt inspection.
DDR 994 was issued on 7/30/82 and eventually closed 3/9/84.
DDR 1030 issued 7/29/82 and closed 2/22/84 consisting of approximately 33 attachments which described generic field weld problems identified with numerous seismic I pipe supports.
These fields welds were previously accepted by gC inspectors and found deficient during reinspection of the hangers.
The licensee notified Region II on August 13, 1982, that they considered these two generic DDRs to be significant conditions reportable under
CFR 50.55(e).
The corrective action taken for these significant deficiencies (CDR 82-95 and CDR 82-96)
were subsequently examined by Region II (Inspection Report 400/85-01)
and considered satisfactory for closure of these items.
CFR 50, Appendix B, gA Criteria for Nuclear Power Plants, does not require the licensee to write a separate nonconformance report for each:deficiency identified.
Criterion.XVI states that each deficiency shall be promptly identified and corrected.
For significant conditions adverse to quality (CDRs), the cause of the condition and corrective action shall be documented and reported to appropriate levels of management.
These conditions were satisfactorily met for these nonconformances and the subject DDRs were handled in a proper manner.
The licensee recognized that these deficiencies were of a
generic nature resulting in significant issues that required a consistent corrective action approach.
The NRC is not concerned with "bean counting"; however, every deficiency must be identified, receive proper review, corrective action, reinspection, and verification.
The inspector randomly selected the following hanger deficiencies from the subject DDR attachments and examined the corresponding licensee corrective action documentation which resolved these deficiencies.
DDR No.
994 Attachment No.
10
38
52
60
~Han er No.
PD-H-494 SW-H-2639 CX-H-284 CS-H-3570 PD-H-3517 MS-H-8 BR"H-1948 PM-H-411
DDR No.
Attachment No.
Han er No.
1030
7
16
27
PD-H-359 CT"H-434 CC-H-1220 CS-H-201 PD-H-536 SW-H"338 AF-286 b.
Construction Inspection (CI) Pressures (1)
Concerns (a)
CI" was being pressured against writin'g nonconformances.
CP&L tried to get rid of certain inspectors who wrote too many nonconformances.
One of these inspectors wrote 1000 NCRs in one month.
(b)
Pressure on CI can be seen based on 90% turnover rate (2)
Findings and Conclusions, Concern (a)
Interviews conducted December 11-14, 1984, with 15 HNPP personnel (6 construction engineering, 5 construction inspection, and
QA/QC personnel disclosed no known cases of licensee inflicted pressures upon inspection personnel such that they could not perform their QA function of identifying and documenting defi-ciencies.
(Reference Region II Inspection Report 400/84-45)
During Region II interviews with the concerned worker, he mentioned that an excessive number of DDRs had been written (during a specified time frame)
by a
HNPP inspector (A); then later mentions that another inspector (B) had issued about 1000 NCRs during the same period.
The concerned worker alleges that CP&L tried to get rid of these inspectors.
Since the Region II inspector was not certain the concerned worker meant to specify one particular type of nonconformance, he took the conservative approach and examined both the DDR and respective NCR Report Logs for the interim period specified.
During this time frame, inspector (A) wrote ll DDRs and
NCRs for a total of
nonconformances.
Discussions with site personnel who knew inspector (A)
revealed that he was a
good inspector, well qualified, and to their knowledge left CP&L employment on his own due to family considerations and another job offer.
Inspector (B)
wrote
DDRs and
NCRs during the same period.
One of these NCRs was cancelled (found not to be a violation)
and two others were upgraded to DDR level nonconformance The inspector concluded that there was nothing unusual about the b
f f
i b
11~i<<i f
nor by inspectors (A) and (B) during the specified time frame.
As time advances, the number of construction activities and inspections generally increase with a corresponding increase in the number of deficiencies found.
(3)
Findings and Conclusions, Concern (b),
The inspector examined HNPP Construction Inspection (CI)
organization charts dated April 9, 1981, and August 4, 1983, and compared them to the current CI organization chart dated January 28, 1985.
Discussions were conducted with various responsible CP&L personnel concerning reasons for personnel transfers, resignations, reductions in force, and the termination of certain personnel within the above time frame.
The following statistics were derived from the review:
Since the Below Listed Date 4/9/81 8/4/83
% CI Personnel Still Morking
~ll 48'"
70.8
% CI Personnel Still Employed At HNPP in Different Ca acit 77.1" 90.6
"Percentages shown above do not reflect
Law Engineering Test Company employees who were phased out when dam work was completed.
Based on the above review and discussions, the inspector concluded that the HNPP CI organization appeared to have a
normal construction attrition rate for a
hybrid (Daniels, CPCL, Thompkins/Beckwith)
inspection organization.
The Region I.I inspector, did not find any unusual or suspect conditions of termination.
Release For Test (RFT) Program (1)
Concern Construction is turning over systems to the startup group without 50 percent of the documentation.
(2)
Findings and Conclusions The HNPP Startup Manual Volume I, Section 6,
Harris Project Construction Section/Harris Plant Operations Section (HPCS/HPOS)
Interface, and Administrative Procedure AP-X-03, R4, Systems Turnover, describe the method for establishing RFT and Final System Turnover (FST) boundaries and the process for accomplishing
system turnovers.
Also in Section 6 of the Start-up Manual is the procedure for performing and controlling work after equipment is released from Construction to HPOS.
Initially, the construction turnover of a
system or a partial system was accomplished in the form of one turnover (RFT Program)
which would include documentation.
This initial program was in effeet unti 1 November 1983 and approximately 304 (safety and non-safety)
systems were turned over.
The problem with the single turnover program was that everything followed a series type or step-by-step progression for completion (i,e.,
complete work, review paper, resolve discrepancies, signoff, give to start-up, perform test and check out, perform pre-op, turnover to operations)
allowing great potential for schedule slippages due to delays in any one of the elements described in the program above.
After November 1983, CPKL decided that a
dual turnover system would be employed, with the first turnover being the RFT (during this period flushing of pipes, calibration of instruments, and logic check out could be performed),
and the second turnover being the FST (releases start-up to perform their preoperational tests since all the documentation would be statused and assembled).
This dual turnover system is more efficient in that it allows parallel work efforts rather than a series of efforts.
As noted above, no matter which system of final turnover is used (or iginal single or dual system),
documentation had to be statused, accounted for, and assembled.
Statused documentation allows and includes known missing or incomplete documentation that will be tracked on an exception list for final turnover.
However, at final turnover of a system to start-up, the only documentation that will be allowed to be on the exception list is that which does not have the potential for impacting or invalidating any preoperational test.
Those allowable remaining exceptions against final turnover are added to the start-up work list (SWL), given a
priority date for completion, resolved, and removed from the SWL.
Region II considers this mode of system turnover to be acceptable and has no problem with certain documentation being missing at final turnover on the basis'hat it does not effect preoperational test results, it is statused, tracked, prioritized, resolved, and removed from the SWL.
All safety systems turned over under the old program will stay turned over as RFT, but the licensee is also having them undergo a
Final System Turnover (FST) in accordance with current turnover procedures.
Discussions with the Manager of Construction Start-up revealed that only one safety-related system (5196 FS1, Uninterruptible AC Systems, Class lE)
has been FST accepted to date.
The inspector examined the RFT Exception List Log for this system and found that all exception list items but one were closed
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e II
~
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s ts at FST acceptance (provide seismic and environmental report for equipment UPS-IV and IDP-IB-SIV) and this item has been added to the SWL for this system.
~Summar:
The inspector did not encounter any evidence to substantiate claims 5a or 5b of the concerned worker.
Al'though documentation was missing at final turnover as alleged in 5c, this was permissible as explained above.
Within this area, no violations or deviations were identifie tE
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