IR 05000400/1986031
| ML18019B027 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/04/1986 |
| From: | Belisle G, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18019B026 | List: |
| References | |
| 50-400-86-31, NUDOCS 8606190513 | |
| Download: ML18019B027 (20) | |
Text
gyR REQy (4 Mp,0 Cy ClO Wp*yW Report No.:
50-400/86-31 UNITED STATES NUCLEAR REGULATORY COMMISSION'EGION II 101 MARI ETTA ST R E ET, N.W.
ATLANTA,GEORGIA 30323 Licensee:
Carolina Power and Light, Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400
. Facility Name:
Harris
License, No.:
CPPR-158 Inspection Conducted:
April 21-25, 1986 Inspector:
C.
Approved by:
.
Be ss e,
<t'ng Section C ief Division of Reactor Safety D te igne Date 'Soigne SUMMARY
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Scope:
This routine, unannounced inspection was conducted onsite in the areas of preoperational testing quality assurance (gA),
andi gA for the startup test program.
Results:
No violations or deviations were identified.
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REPORT DETAILS Persons Contacted Licensee Employees W. Gibert, QA/QC Specialist
- J. Harness, Assistant'lant General Manager K. Humbarger, QA/QC Technician I
A. Klemp, QC Supervisor J. McAllister, QA/QC Specialist G. McDermott, QA Technician I
- C. McKenzie, Acting Director, QA/QC P. Nesbitt, QA/QC Technician II A. Pulliam, Jr.,
QA/QC Senior Specialist T. Rogers, QC Technician I
C.
Rose, Jr.,
QA Supervisor F. Strehle, Jr., Acting Principal QA Engineer J. Troy, Daniel Construction Company, QA Engineer, Technical Service Division J. Vargo, QA Specialist C. Vincent, Jr.,
QA Technician I H. Wagner, QA/QC Senior Specialist NRC Resident Inspectors
- G. Maxwell
- S. Burris
- G. Humphrey
- Attended exit interview Exit Interview The inspection scope and findings were summarized on April 25, 1986, with those persons indicated in paragraph I 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 i nspector during this inspection.
Inspector Followup Item:
Implementation of Operations QA program requirements for surveillance of preoperational test activities, paragraph 5.
Licensee, Action on Previous Enforcement Matters This subject was not addressed in the inspectio If f
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Unreso1 ved Items Unresolved items were not identified during the inspection.
5.
Preoperational Testing Quality Assurance (35301)
References:
(a)
CFR
Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (b)
CFR 50.54(a)( 1), Conditions of License (c)
SHNPP FSAR Section 17.2, Quality Assurance During The Operating Phase (d)
Regulatory Guide 1.144, Auditing of Quality Assurance Programs for Nuclear Power Plants (e)
ANSI N45.2. 12-1977, Requirements for Auditing of Quality Assurance Program for Nuclear Power Plants (f)
Regulatory Guide 1. 146, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (g)
ANSI N45.2.23-1978, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (h)
Regulatory Guide 1.33, Quality Assurance Program Requirements (Operations)
(i)
ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (j)
Regulatory Guide 1.58, Qualification of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants (k)
ANSI N45.2.6-1978, Qualification of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants The inspector reviewed the licensee's QA program for preoperational testing required by references (a) through (k), to determine if the program had been developed in accordance with regulatory requirements, and industry guides and standards.
The following criteria were used during this review.
Procedures have been developed to conduct audits and surveillances of licensed activitie A I'
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Responsible management personnel have been assigned authorities and responsibi'lities to implement the QA program.
.Management's knowledge of the QA program and understanding of their responsibilities is adequate.
Minimum qualifications and training requirements have been developed for QA personnel.
Systems for handling deficiencies have been established and are functioning.
The Quality documents listed below were reviewed to determine if the previously listed criteria had been incorporated into the licensee's QA program for preoperational testing:
SHNPP FSAR Section 14.0, Initial Test Program Corporate Quality Assurance Program Manual, Rev.
Section 2.0, Organization and Responsibilities Section 7.0, Indoctrination and Training Section 9.0, Calibration Control Section 10.0, Surveillance Section 15.0, Nonconformance Control and Corrective Action CQAD 80-1 Procedure for Corporate Audit, Revision
CQAD 80-2 Procedure for Training and Qualification of QA Program Audit Personnel, Revision
CQAD 70-3 Nonconformance and Corrective Action, Revision
CQAD 70-4 Nonconformance Trending Report, Revision
QAP-103 Personnel Indoctrination, Training, Qualification and Certification, Revision
QAP-104 Nonconformance, Revision
QAP-105 Stop Work Puthority, Revision
QAP-201 Surveillance Program, Revision
QAP-204 Plant Modification Review, Revision
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QAP-501 Quality Assurance Engineering Document Review, Revision
SHNPP Startup Manual, Section ll, Revision
Based on the review of the above program documents, the inspector determined that measures had been established to control the conduct of preoperational testing and related activities.
The licensee QA program which covers preoperational testing activities had been developed in accordance with FSAR commitments and regulatory requirements.
The inspector conducted interviews with personnel from the operations QA/QC organization to ascertain if they understood their basic responsibilities.
All personnel interviewed knew their functional responsibilities.
Available position descriptions for personnel occupying various positions within the onsite QA/QC organization were reviewed by the inspector.
Indoctrination, qualification, and training requirements for QA/QC personnel were also inspected.
The inspector determined that, for the most part, onsite Operations QA/QC personnel are transferees from the construction QA/QC organization.
These personnel are trained and certified to the construction quality assurance procedures which delineate the administrative controls for performing their job functions.
The inspector observed that licensee management is presently preparing draft documents for assigning functional responsibilities to organizational units within the onsite operations QA/QC group.
The inspector determined that a formal written description of the organizational structure, functional responsibilities, levels of authority, and lines of internal and external interfaces have not been prepared for the onsite operations QA/QC group.
Updated position descriptions for,the QA Supervisor and the Principal QA Engineer were not available for review by the inspector.
This issue was discussed with licensee management and is addressed further in the last paragraph of this report.
The surveillance reports listed below were examined to determine if these audit activities had been planned, scheduled, and implemented as required by the licensee's procedures, regulatory requirements, and industry guides and standards:
Report No:
S-85-293 Date(s)
Performed:
September 6-8, 1985 Surveillance Activity:
RHR Cold Preoperational Test Procedure No. 1-2085-P-Ol Revision
Report No:
86-069 Date(s)
Performed:
December 27, 1985 - February 14, 1986 Surveillance Area:
Hot Functional Testing - Test Procedure 2005-P-01
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Report No:
86-031 Date(s)
Performed:
January 20-21, 1986 Surveillance Area:
Primary Sampling System Preoperational Test Procedure No. 1-2115-P-Ol Report No:
S-85-245
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Performed:
August 1-5, 1985 Surveillance Activity:
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Report No:
S-85-158 Date(s)
Performed:
May 30-31, 1985 Surveillance Activity:
RHR Pump 1A-SA Unit II1 Report No:
S-85-166 Date(s)
Performed:
April 26, 1985, May 23-25, 1985 and June 3, 1985 Surveillance Activity:
Class IE Uniterruptible Power Supply Pre-op Test Report No:
S-85-268 Date(s)
Performed:
August 13-20, 1986 Surveillance Activity:
Reactor Makeup Water System Preoperational Test Procedure No. 1-2010-P-Ol Report No: S-85-059 Date(s)
Performed:
February 13, 1985 Surveillance Area:
Preoperational Test Program Report No:
86-068 Date(s)
Performed:
January 30-31, 1985 Retest, February 6-8, 1986 Surveillance Area:
Steam Dump Hot Functional Test Preoperational Procedure No. 1-3035-P-03 Report No:
86-033 Date(s)
Performed:
February 1-2, 1986 Surveillance Area:
Main Steam Turbine Report No:
86-035 Date(s)
Performed:
Surveillance Area:
January 27 - February 4, 1986 Steam Driven Auxiliary Feedwater Pump (Terry Turbine)
5 Cold Starts Required Report No:
86-028 Date(s)
Performed:
January 22-26, 1986 Surveillance Activity:
Chemical and Yolume Control System Hot Functional Test Report No:
86-023 Date(s)
Performed:
January 19-22, 1986 Surveillance Area:
Pressurizer Pressure and Level Control Preoperational Test - Procedure No. 1-2005-P-04
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Examination of the above reports revealed that the surveillances had been planned, checklists were utilized, findings were documented and transmitted to management, and corrective actions had been initiated for problems identified.
The majority of the surveillances were conducted under the administrative controls of the construction quality assurance program.
The licensee's commitment delineated in the FSAR, Section 17.2, states that the SHNPP QA program during the operations phase applies to all activities affecting quality such as preoperational testing, startup power testing, operations, maintenance, modifications and refueling.
The inspector conducted interviews with licensee management concerning this deviation from the FSAR commitment.
The inspector was informed that in the absence of implementing procedures for the operations QA/QC onsite group, surveillances were conducted of preoperational tests using the implementing procedures of the construction QA/QC organization.
Pursuant to the above discussion with licensee management, the inspector reviewed the following construction QA/QC procedures to ascertain the adequacy of administrative controls applicable to preoperational test activity survei llances.
CQA-27 System Turnover, Revision
CQA-28 QA Surveillance, Revision
CQA-3 Nonconformance Control, Revision
Based on the review of the construction QA/QC procedures, the inspector determined that adequate measures were established for identifying and tracking test deficiencies and for initiating corrective actions.
With completion of the development of the QAP's for the operations QA/QC site organization, surveillances are now conducted using the QAP's.
Management's involvement in ensuring an orderly transition from the administrative controls of the construction QA program to the operations QA program is demonstrated by the following memorandums which delineate management's policies and interface agreements:
CPSL memorandum from C. L. McKenzie to C.
H. Mosely, Jr., Subject:
Use of QA/QC Harris Plant Procedures by Harris Operations gA/QC Personnel, dated May 9, 1985.
CPSL memorandum from C. L. McKenzie to N. J. Chiangi, Subject:
Harris Plant QA/QC Responsibility Matrix - Startup and Operations Phase Activities, dated September 18, 1985.
CPSL memorandum from G. L. Forehand/C.
L. McKenzie to N. J. Chiangi/C.
H. Mosely, Jr., Subject:
Implementation of the Operations QA/QC Procedure, QAP-103, dated January 2,'1986.
CPSL memorandum from C. L. McKenzie to J.
L. Willis, Subject:
QA Review of Procedures, dated January 20, 198 ~ ~
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CP&L memorandum from G. L. Forehand/C.
L. McKenzie to N. J. Chiengi/
C.
H. Mosely, Jr., Subject:
Nonconformance Control Interface Agree-ment, dated March 24, 1986.
At the exit interview, the inspector stated that in accordance with the commitment delineated in SHNPP FSAR Section 17.2, the operations QA program is required to be implemented at least 90 days prior to the fuel load date.
Based on licensee projected fuel load date, the inspector identified April 25 as the deadline for fully implementing the requirements of Section 17.2 of the FSAR.
Within this area, one inspector followup item was identified.
Surveillances of 90% of the preoperational test activities were conducted under the administrative controls of the construction QA program.
The licensee is required to fully implement the requirements of the operations QA program no later than April 25, 1985.
Until the licensee has delineated functional responsibilities within the QA Supervisor line organization; and surveillances of the remaining preoperational test activities are conducted in accordance with the implementing procedures of the operations QA/QC organization, this is identified as Inspector Followup Item 400/86-31-01.
6.
QA For Start-up Test Program (35501)
References:
(a)
CFR
Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (b)
CFR 50.54(a)(l) Conditions of License (c)
SHNPP FSAR Section 17.2, Quality Assurance During the Operating Phase (d)
Regulatory Guide 1.33 Quality Assurance Program Requirements (Operation)
(e)
ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (f)
Regulatory Guide 1.68 Initial Test Programs for Water Cooled Nuclear Power Plants The inspector reviewed the licensee's quality assurance program for start-up testing required by references (a)
through (f) to determine if activities are in conformance with regulatory requirements, commitments in the application, and industry guide and standards.
The following criteria were used during this review:
Requirements have been established and procedures
'or checklists developed for inspection of the following activities on a regular basis by the onsite Quality Assurance organization:
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The documents listed below were reviewed to determine if the previously
.listed criteria had been incorporated into the licensee's gA program for startup testing.
SHNPP FSAR Section 14.0, Initial Test Program Corporate guality Assurance Program Manual, Rev.
Section 2.0, Organization and Responsibilities Section 7.0, Indoctrination and Training Section 9.0, Calibration Control Section 10.0, Surveillance Section 15.0, Nonconformance Control and Corrective Action C(AD 10-3 Matrix for Determining Audit Requirements, Revision
CLEAD 80-1 Procedure for Corporate Audit Revision
CLEAD 80-2 Procedure for Training and gualification of QA Program Audit Personnel, Revision
C(AD 70-3 Nonconformance and Corrective Action, Revision
C(AD 70-4 Nonconformance Trending Report, Revision
JAP-103 Personnel Indoctrination, Training, gualification and Certification, Revision
gAP-104 Nonconformance, Revision
gAP-105 Stop Work Authority, Revision
gAP-201 Surveillance Program, Revision
gAP-204 Plant Modification Review, Revision
gAP-501 guality Assurance Engineering Document Review, Revision
SHNPP Startup Manual, Volume 1, dated January 4,
1'980
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The inspector interviewed licensee QA personnel to determine the extent of surveillance activities conducted during preoperational testing as well as the QA progra~ to be implemented during the start-up test program.
Based on these interviews and a
review of the site operations QA/QC implementing procedures, the inspector determined that adequate program controls had been established to support the startup test program.
Responsibility for the conduct of audits of startup test program activities has been assigned to Performance Evaluation (PEU) in the corporate office.
These audits are conducted under the controls of procedure CQAD 80-1 which delineates requirements for the conduct of plant audits in accordance with the Corporate QA program.
The determination of the audit requirements for the Harris Plant is delineated in paragraph 6.0 of CQAD 10-3.
Examination of the implementing procedures of the Corporate Quality Assurance Department revealed that adequate measures have been established for defining the requirements of the audit program during the startup phase.
An inspection of the audit schedule, audit matrix, and other documents developed in order to implement the requirements of the audit program for SKNPP during startup testing wi 11 be performed in the corporate office at a
later date.
Within this area, no violations or deviations were identifie ~ l fI I
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