IR 05000400/1986035
| ML18019B069 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 06/13/1986 |
| From: | Belisle G, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18019B068 | List: |
| References | |
| 50-400-86-35, NUDOCS 8607100406 | |
| Download: ML18019B069 (18) | |
Text
yah REC(g, tp0 Report No.:
50-400/86-35 UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Licensee:
Carolina Power and Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Shearon Harris Unit 1 Inspection Conducted:
May 5-9, 1986 Inspector:
C. Smit License No.:
CPPR-158 0 te Signe Approved by:
G.
Be 'isle, Division of Ac ing Section C ie Reactor Safety at Signed SUMMARY Scope:
This routine, unannounced inspection was conducted on site and at the corporate offic'e in the 'areas of preoperational test records and audits.
Results:
No violations or deviations were, identified.
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REPORT DETAILS 1.
Persons Contacted Licensee Employees R. Baldwin, Senior guality Assurance (gA) Specialist, Performance Evaluation Unit (PEU)
- C. Hinnant, Manager of Startup
- E. Johnson, Principal Specialist, Document Services J. Keisler, Specialist, Document Services
- G. Lew, Startup Supervisor R. Lumsden, Manager, gA Services Section
- C. McKenzie, Acting Director, gA/gC Operations L. Morgan, Technical Aide II, Librarian C. Rose, guality Assurance Supervisor C. Rosenberger, Principal gA Specialist, PEU
- R. Watson, Vice President, Harris Nuclear Project NRC Resident Inspectors
- G. Maxwell, Senior Resident Inspector
- G. Humphrey, Resident Inspector
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on May 9, 1986, 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.
Inspector Followup Item; Revision of Startup Manual (SUM) Section 17.0 Startup - Document Control Program, paragraph 5.
Inspector Followup Item; Conduct of Audits of Preoperational Test Program, paragraph 6.
3.
Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.
t 4.
Unresolved Items Unresolved items were not identified during the inspection.
5.
Preoperational Test Records (39301)
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References:
(a)
CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (b)
CFR 50.54(a)(l) Conditions of License (c)
Regulatory Guide 1.88, Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records (d)
ANSI N45.2.9-1974, Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants (e)
SHNPP FSAR Section 17.2. 17, Quality Assurance Records (f)
SHNPP Technical Specification Section 6. 10, Recor d Retention (Proof and Review Copy)
The inspector reviewed the licensee's administrative controls for records generated during the preoperational test program as well as other records required by references (a)
through (f) to determine if the administrative controls were in accordance with regulatory requirements, industry guides and standards, and Technical Specifications.
The following criteria were used during the review:
Administrative controls have been established for maintaining records for the following types of activities during the preoperational testing period:
Preoperational test. procedures and results Corrective and preventive maintenance QA/QC audit and surveillance Personnel training Personnel qualification Design changes and modifications Component, systems, and structure turnover Responsibilities have been assigned to assure that the records identified above will be maintained and the retention periods have been specified.
Record storage controls have been established which accomplish the follow-ing:
Define the record storage locations for the types of records identified above.
Designate a custodian(s)
in charge of storage of each class of records.
Describe the filing system(s)
to be used to allow for the retrieval of records.
Establish a method for verifying that the records received for storage are in agreement with any attendant transmittal document M I
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Make provisions for governing access to files and for maintaining an accountability of records removed from the storage facility.
Establish methods for filing supplemental information and disposing of superseded records.
The documents listed below were reviewed to determine if these criteria had been incorporated into the licensee's administrative procedures for records control.
CP8L Corporate guality Assurance Program Manual, Section 17.0, guality Assurance Records, Revision 9.
Startup Manual (SUM) Volume I, Section 17.0, Startup Document Control Program, Revision
RMP-001, Filing Index Instructions, Revision
RMP-002, Document Distribution and Control, Revision
RMP-006, Records Storage Areas, Revision
AMM-05, Document Control - Conduct of Operations, Revision
The requirements of the startup document control program are delineated in the SUM Section 17.0.
The minimum scope of documents to which the require-ments of the startup document control program apply has also been specified.
Based on a review of the list of specified documents, it appears that administrative controls have been defined for maintaining records generated during the preoperational test activities.
The SUM Section 17.0 further assigns responsibility for defining the requirements of the startup document control program to the Manager-Startup.
Responsibility for implementing the startup document control program is assigned to the SHNPP Document Services.
Pursuant to interviews with licensee management from Startup and Document Services, the inspector determined that implementation of the startup document control program is being performed by the Startup group.
A temporary single storage record facility, identified as the Startup Library, had been established for performance of the following records management functions:
Receipt of records Storage, preservation and safekeeping of records Retrieval of records The above situation developed as a consequence of non-compliance with a clarification to Regulatory Guide 1.88, which endorses ANSI N45.2.9-1974.
The licensee position statement regarding this clarification is as follows:
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ANSI N45.2.9-1974 paragraph 5.6, Facility:
This paragraph provides no distinction between temporary and permanent facilities.
To cover temporary storage, the following clarification is added:
"Active records will be stored in one-hour fire rated file cabinets.
In general, records shall not be maintained in temporary storage (except for those records stored in the temporary Construction gA records storage facility) for more than three months after completion.
Any exceptions to this requirement must be justified, evaluated, and approved by the Manager - Corporate guality Assurance and documented.
A list of exceptions shall be maintained and available for NRC review.
Exceptions may include records needed on a continuing basis for an extended period of time and records which are cumulative in nature (e.g.,
nonconforming item logs)."
The inspector determined that an exception was taken by licensee management regarding the temporary storage of gA records for periods not greater than three months.
The following CPSL correspondence was reviewed by the inspector regarding management's decision and final position taken regarding this exception:
CPSL memorandum from R.
A.
Watson to Messrs.
T.
J.
Allen, N. J. Chiangi, W.
J.
Hindman, L. I. Loflin, R.
M.
Parsons, J. L. Willis, Subject:
Further Clarification of HNP Department Position on gA Records, dated April 27, 1984.
CP8L memorandum from C.
S.
Kinnant to E.
Johnson, Subject:
Startup Records, dated May 17, 1984.
CPSL memorandum from E.
E.
Johnson to H.
R. Banks, Subject:
Retention of Records in One-Hour Fire Rated File Cabinets, dated April 15, 1985.
These letters documented the soliciting and receipt of approval from the Manager - Corporate guality Assurance for, storage of preoperational test records in the startup library in excess of three months.
The inspector was informed that preoperational test records will be transmitted to Document Services for permanent storage upon termination of preoperational/startup test activities.
An end date for this event has not been established.
Licensee definition of gA records are records which have been given a final review performed by the organizational element responsible for generating or collecting the records.
For preoperational test activities, this final review is performed by the Joint Test Group (JTG).
The inspector determined that JTG approved preoperational test records are stored in the startup library for indefinite periods of time.
Additionally, all activities associated with receipt, storage, "preservation, safekeeping, and retrieval of records are performed by the startup library custodian.
Interviews with startup group management revealed that a written documented program for records management in accordance with ANSI N45.2.9-1974 has not
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been developed for the startup library.
Licensee management concurred with this inspection finding and have 'committed to revising the SUM Section 17.0 to correct this program deficiency.
This issue has been identified as an Inspector Followup Item and is discussed in the last paragraph of this report.
An inspection of the implementation of the startup document control program will be required to ensure procedural compliance with the SUM.
This inspec-tion will be performed upon completion on the revision to the SUM to delineate the programmatic controls for gA preoperational test records.
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Discussions with Document Services personnel revealed inadequacies in the list of exceptions referred to in CPSL's position statement on paragraph 5.6 of ANSI N45.2.9-1974.
The inspector determined that this is a generic issue previously identified by the NRC in an inspection of the records and document control program.
An inspector followup item was identified for which licensee management is taking corrective action.
Details concerning this inspection finding are documented in NRC Report Number 50-400/86-33.
One item of concern was brought to management's attention by the inspector.
Pursuant to CPRL management's position taken regarding temporary storage of gA records for periods not greater than three months, the startup library became a single storage record facility.
This structure does not meet the requirements of NFPA-232-1975.
A fire load analysis was never performed for this facility.
Smoking is not prohibited in this area; indeed, the inspector observed personnel smoking in the library.
Although current document storage controls meet CPKL's gA program requirements, the inspector requested that licensee management review this situation.
Within this area, one Inspector Followup Item was identified.
The startup library functions as a single storage facility for receipt, storage, preservation, safekeeping, and retrieval of gA preoperational test records.
A documented program delineating the requirements for records management within the startup library has not been developed by licensee management.
Licensee management has committed to revising Section 17.0 of the SUM to correct this program deficiency.
Until licensee management has revised the SUM to delineate gA preoperational test record controls in accordance with ANSI N45.2.9-1974, this is identified as Inspector Followup Item 400/86-35-01.
Audits (35741)
References:
(a)
CFR 50, Appendix B, guality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (b)
Regulatory Guide 1. 144, Auditing of guality Assurance Programs for Nuclear Power Plants (c)
ANSI N45.2.12-1977, Requirements for Auditing of guality Assurance Programs for Nuclear Power Plants
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(d)
Regulatory Guide 1.146, Qual ification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (e)
ANSI N45.2.23-1978, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (f)
Regul atory Guide 1. 33, Qual ity Assurance Program Requirements (Operations)
(g)
ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (h)
Technical Specifications, Section 6.5.4, Corporate QA
'Audit Program (Proof and Review Copy)
(i)
CFR 50.54(a)(l),
Conditions of Licenses (j)
SHNPP FSAR Section 17.2.18 Audits The inspector reviewed the licensee audit program required by references (a)
through (j) to verify that the program had been established in accordance with regulatory requirements, industry guides and standards, and Technical Specifications.
The following criteria were used during this review to determine the overall acceptability of the established program:
The audit program scope was defined consistent with Technical Specifications and QA program requirements.
Responsibilities were assigned in writing for overall management of the audit program.
Methods were defined for taking corrective action on deficiencies identified during audits.
The audited organization was required to respond in writing to audit findings.
Distribution requirements were defined for audit reports and corrective action responses.
Checklists were required to be used in performing audits.
Measures were established to assure that QA audit personnel met minimum education, experience, and qualification requirements for the audited activity.
The documents listed below were reviewed to determine if these criteria had been incorporated into the auditing program:
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SHNPP FSAR Section 17.2.2, Quality Assurance Program Section 17.2. 11, Test Control Section 17.2.15, Nonconforming Materials, Parts, or Components Section 17.2. 16, Corrective Action Section 17.2.18, Audits Corporate Quality Assurance Program Manual Section 1, Introduction Section 2, Organization and Responsibilities Section 15, Nonconformance Control and Corrective Action Section 16, Audits CQAD 10-3 Matrix for Determining Audit Requirements, Revision
CQAD 20-2 Procedures for Training and Qualification of QA Program Audit Personnel, Revision
CQAD 70-3 Nonconformance and Corrective Action, Revision
CQAD 70-4 Corporate QA Nonconformance Trending Reports, Revision
CQAD 80-1 Procedure for Corporate Audits, Revision
The inspector reviewed the licensee Audit Planning/Scheduling Matrix for Plant Operations for 1985 and 1986 to determine audit program scope and to verify conformance with the QA program requirements.
Pursuant to this review, the inspector determined that audits of preoperational test activities were never conducted by the Performance Evaluation Unit (PEU).
This is discussed as an inspector followup item later in this report.
FSAR Section 17.2. 11 delineates licensee commitments in regard to QA program requirements for test control.
It also states that SHNPP QA program as controlled by the Corporate QA establishes the requirements for pre-operational and operation test program.
Section 8.0 of the Corporate Quality Assurance Program Manual (CQAM)
addresses site work control; paragraph 8.4.2 further delineates requirements for construction (proof)
tests.
The inspector determined that QA program requirements for pre-operation and operations test have not been specified in the CQAM.
Additionally, a review of audit reports conducted by PEU revealed that they have not performed any audits of the preoperational test program.
The inspector discussed the above finding with licensee management and stated that the scope of the Corporate QA Program, as delineated in FSAR Section 17.2.2.3, includes preoperational and startup test activities.
Further, in conformance with licensee commitments contained in this section of the FSAR, monitoring of the preoperational test program by QA/QC personnel is required.
The inspector performed a review of the licensee's quality implementing procedures and determined that the licensee had developed a
QA program that conforms with regulatory requirements, coomitments and industry standard The previously identified program deficiency in the upper-tier quality related program document, i.e.,
CgAM Section 8.0, was brought to manage-ment's attention for their corrective action.
The following audits were selected for review to verify procedural con-formance with program requirements.
These audits were performed by the PEU and preceeded the start of preoperational testing activities:
Audit Report No.:
gAA/152-2 Activity Audited:
SHNPP Preoperations Unit 1 Date of Audit:
March 7-11, 1983 Audit Report No.:
gAA/152-3 Activity Audited:
SHNPP Preoperati ons Unit
Date of Audit:
July 11-15, 1983 Audit Report No.:
gAA/152-4 Activity Audited:
Preoperations at SHNPP Dates of Audit:
November 7-11, 1983 Audit Report No.:
gAA/152-5 Activity Audited:
SHNPP Preoperations Unit
Audit Date:
March 12-19, 1984 Audit Report No.:
gAA/X152-85-01 Activity Audited:
SHNPP Preoperations Date of Audit:
March 18-22, 1985 Audit Report No.:
gAA/152-85-03 Activity Audited:
HNP Preoperations Date of Audit:
November 11-14, 1985 Nonconformances identified by the above audits were adequately addressed and appropriate corrective actions initiated for their disposition.
Within this area, one inspector followup item was identified.
A review of the audit checklist of SHNPP Preoperations revealed that audits of pre-operational test activities were never performed.
Audit checklist section 2.5, Preoperational Test Program SUM Section 11, required the performance of audits of preoperational test activities.
The checklist was not completed because preoperational tests were not in progress during the audits.
Procedure CLEAD 80-1, paragraph 6.4.3 delineate requirements for unchecked checklist items to be identified along with the reason for the items not having been checked.
The Lead Auditor is required to perform an evaluation to determine the need for future followup of these items in subsequent audits, and to record this evaluation in a log.
The inspector determined that unchecked checklist items for preoperational test activities were not dispositioned in accordance with CLEAD 80-1.
Licensee management concurred with this inspection finding and have committed to planning and scheduling audits of preoperational test activities. Until audits of the preoperational test program have been completed, this is identified as Inspector Followup Item 400/86-35-0 ~ g Vf U