IR 05000400/1986053
| ML18004A431 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 07/30/1986 |
| From: | Belisle G, Moore L, Michael Scott NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18004A430 | List: |
| References | |
| 50-400-86-53, NUDOCS 8608110330 | |
| Download: ML18004A431 (22) | |
Text
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W.
ATLANTA,GEORGIA 30323 Report No.:
50-400/86-53 Licensee:
Carolina Power and Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Harris
Inspection Conducted:
ne 3-7, 1986 License No.:
CPPR-158 z~
ate Signe z/3o/'r~
Date, Signed
~o A.,
Inspectors
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S ot at Signed Results:
No violations or deviations were identified.
Approved by:
G..'e is e, A t>ng Section C ie'f Division of Reactor Safety
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SlJMMARY Scope:
This routine, unannounced inspection was conducted in the areas of design control, surveillance testing and calibration control, measuring.
and test equip-ment, and licensee action on previously identified inspection i,tems.
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REPORT DETAILS Persons Contacted Licensee Employees S.
Bohannon, Director - Special Projects
- H. Bowles, Director - Onsite Nuclear Safety
- G. Campbell, Manager - Maintenance
-"J. Dority, Supervisor - Startup
- W. Edwards, Harris Plant Engineering Section (HPES)-
Instrumentation and Control (ISC)
- G. Forehand, Director - QA/QC Construction C. Genteel, Senior Reactor Operator (SRO)
- C. Gibson, Assistant To The General Manager
- J. Harness, Assistant Plant Manager
- K. Hate', Principal Quality Assurance (QA) Engineer
- C. Hinnant, Manager - Startup
- A. Howe, Specialist - Regulatory Compliance R.
Lamb, HPES Engineer G. Lashley, Senior Specialist Electrical
- J. Lawrence, Technical Assistant - Harris Plant Engine Section (HPEMS)
- C. McKenzie, Acting Director - QA/Quality Control (QC)
G. Meyer, Regulatory Compliance T. Morton, ISC Supervisor D.
Nummy, Group Supervisor - Maintenance Procedures
- L. Ollivier, Technical Assistant - HPES J. Pell, Construction Engineer
- S. Rea, Engineer - Technical Support
- C. Rose, Project QA/QC Specialist
- W. Slover, Project Engineer - Technical Support
- F. Strehle, Project QA Engineer
- D. Tibbitts, Regulatory Compliance
- M. Wallace, Specialist - Regulatory Compliance
- R. Watson, Vice President - Harris Nuclear Project
- D. Whitehead, Operations QA Supervisor
- D. Willis, Plant General Manager B. Wilson, Power Ascension Test Director J. Witley, Maintenance Technician B. Wojnarowski, Reactor Engineering Supervisor - Actin M. Wright, Inservice Inspection (ISI) Engineer ering Materials Operations
- G. Maxwell
- S. Burris Other licensee employees contacted included office personnel.
NRC Resident Inspectors
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~Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on June 27, 1986, with those persons indicated in the paragraph above.
The inspector described the areas inspected and discussed in detail the inspection findings listed below.
No dissenting comments were received from the licensee.
Inspector Followup Item, HPES Procedures, paragraph 5.a.
Inspector Followup Item, Changes to Design Modification, paragraph 5.b.
Inspector Followup Item, Temporary Modifications, paragraph 5.c.
Inspector Followup Item, Independent Review and Corrective Action, paragraph 5.d.
Inspector Followup Item, Option or Recommendation Statements in Design Procedures, paragraph 5.e.
Inspector Followup Item, Procedural Completion for Groups Involved in Design Control, paragraph 5.f.
Inspector Followup 'Item, Design Basis Packages, paragraph 5.g.
Inspector Followup Item, Surveillance Program Procedures, paragraph 6.a.
Inspector Followup Item, Surveillance Master Schedule, paragraph 6.b.
Inspector Followup Item, Tests Not on Master Schedule, paragraph 6.c.
Inspector Followup Item, Inservice Inspection Program Vibration Testing, paragraph 6.d.
Inspector Followup Item, Identification and Control of Commitment-Related Instrumentation, paragraph 7.
The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors 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 the inspection.
Design Control (35744)
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This inspection provided an additional review of the Design Control Program previously documented in NRC Inspection Report No. 50-400/86-28 dated May 14, 1986.
The Inspector Followup Items (IFI) which follow in the text of this paragraph identify areas which will require licensee attention prior to implementation of that portion of the, program.
For the most part, the programmatic requirements of the references of NRC Inspection Report No. 50-400/86-28 (paragraph 6) have been addressed with exceptions as noted below.
Additional or altered (since the previous inspection)
procedures that were examined by the inspector are as follows:
AP-006 AP-011 AP-014 AP-024 AP-600 PLP-601 HPES 1.1 HPES 3.18 HPES 3.22 MOD-103 MOD-200 MOD-201 MOD-202 NELD 3.1 NELD 3.3 Procedure Review and Approval, Revision
Safety Reviews, Revision
Criteria for gualified Safety Reviewers, Revision
Temporary Bypass Jumper and Wire Removal Control, Revision 0, Change AC 01/3 Plant Change Request Initiation, Revision 1, Change AC 1/1 Plant Configuration Control Program, Revision
Introduction to HPES Manual of Instructions, Revision
Processing and Control of Interdiscipline Review Requests, Revision
Processing, Control, and Resolution of PCRs, Revision
Engineering Evaluations, Revision
Review and Approval of Modifications, Revision
Technical Review of Engineering Evaluations and Direct Replacements, Revision
Plant Change Request Implementation, Revision 0, Change
Design Control Procedure, Revision
Design Verification, Revision
Within this area, seven inspection followup items were identified and are discussed in the following paragraphs.
a.
HPES Procedures ANSI N18.7, Administrative Controls and guality Assurance for the Operational Phase of Nuclear Power Plants, ANSI N45.2.11, guality Assurance Requirements for the Design of Nuclear Power Plants, and
CFR 50 Appendix B, Criterion III denote requirements for modi-fication control and design interfaces.
These requirements are being further implemented as follows:
(1)
HPES has in draft form a revision of HPES 3.22 which includes:
HPES presence on the Plant Change Request Group (paragraph 3.22.3.2);
impact of Plant Change Request (PCR)
on Final Safety Analysis Report ( FSAR)
and Technical Specifications" (TS) via documentation on Form 2 of the procedure (paragraph 3.22.3.5);
Plant Change Request (PCR)
review for ALARA considerations per
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NELD 3.12 (paragraph 3.22.4.4.a.2);
the assigned engineer and project engineer now sign the PCR for "engineer" and "Technical Review," respectively, (paragraphs 3.22.4.4.f.6 and 3.22.4.8.d);
and supplemented criteria for resolution of document change PCRs (paragraph 3.22.5).
(2)
HPES was going to draft HPES 3.24 to provide control and review of Field Revisions (FR) which are changes to PCRs (see IFI "b" and IFI "f" below).
Until these procedures are approved by appropriate site personnel, this is identified as Inspection Followup Item 400/86-53-01.
Changes to the Design Modification Two groups on site had design control responsibility.
HPES provided architect/engineer responsibilities and interfaces while the Technical Support group supported the plant in the modification process.
Each group had its own procedures and blocks of responsibilities within the process of installing modifications in the plant.
ANSI N45.2. 11, section 8, addresses field changes which are equivalent to site FRs.
It states that field changes wi 11 be subject to the same design control measures that were applied to the original design.
Both HPES and Technical Support can review FRs.
An intent of HPES 3.24 wi 11 be that FRs will be reviewed against the original or existing PCR safety evaluation to assure that the FR does not invalidate or cause revision to the
CFR 50.59 safety evaluation.
MOD-202 does not address requiring this type of FR review.
Until procedures MOD-202 and HPES 3.24 are consistent in requiring FR reviews to assure that safety evaluations are valid, this is identified as Inspector Followup Item 400/86-53-02.
Temporary Modifications ANSI N18.7-1976, section 5.2.6, addresses temporary modifications.
Procedure AP-024 delineates controls for non-operable safety system temporary modifications (section 4.2).
Presently, the procedure does require that a
PCR be submitted for temporary modifications on operable safety systems.
Technical Support personnel also stated that MOD-206 would be written and approved to include controls for temporary modi-fications on operable (ready to 'e started, used, or operational)
equipment in safety systems.
Until MOD-206 is approved to include controls for temporary modifications on operable equipment, this is identified as Inspector Followup Item 400/86-53-03.
Independent Review and Corrective Action ANSI N18.7-1976, sections 4.3 and 5.2.11, address independent review and corrective actions.
Procedure MOD-103 prescribed engineering
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evaluations of code compliance problems, nonconformances, and procurement problems.
MOD-103 provides general applicability to items which could impact safety of the plant, safety of operation, or hazard to personnel.
MOD-103 does not address what actions the evaluator will take should the evaluation indicate an operability problem with equip-ment or a reportable occurrence.
Until either MOD-103 or another procedure is modified in detail to state what evaluator action is required when unsafe or reportable conditions are identified this is identified as Inspector Followup Item 400/86-53-04.
Option or Recommendation Statements in Design Procedures ANSI N18.7-1976, section 2.2, defines the words "shall, should, and may".
Various regulatory guides and standards provide instructions regarding requirements within procedures.
The basis for writing procedures is to instruct personnel using the procedure.
Where recormendations or a branching in logic occurs within procedures, those should be clearly stated as options.
Previously, IFI 400/86-28-01, identified specific "should" statements in MOD-202.
Technical Support personnel removed the indicated
"should" statements and replaced them with "shall" statements; consequently this IFI is being closed.
During this inspection, additional
"should" statements were found in MOD-202 and MOD-103 (examples are in MOD-202, paragraphs 6.9.5, 6. 10.3, 6. 10.6, the top of Attachment J, and throughout the text of attachment M; in MOD-103, paragraphs 5.2 and 5.3.5, the first and third "should" ).
Until action is taken to clarify or remove the "shoulds" from these procedures, this is identified as Inspector Followup Item 400/86-53-05.
The licensee's attention is also directed to the
"may" statements of MOD-103 (paragraphs 1.0 and 5.3.3)
and any other option or recommen-dation statements found within site procedures.
Procedural Completion For Groups Involved in Design Control At the time of this inspection, two groups were identified as being directly involved in the site's operational phase design control or modification process.
These were Technical Support and HPES.
Construction, HPES, Nuclear Engineering and Licensing Department (NELD), and Maintenance will have new or expanded roles in the design and modification process.
These groups will interface with one another and Technical Support, process FRs, provide engineering, and write contracts for modification activities in accordance with ANSI N45.2. 11, N18.7 and other requirements.
The licensee was aware of the need for additional interface and controlling procedures and this was exemp-lified by the Technical Support group having written a preliminary draft of MOD-202 that included generic construction activities in the design control program.
Licensee personnel stated that Carolina Power and Light Construction was to remain on site for major modifications.
Maintenance would be handling minor modifications.
Construction, HPES, probably Maintenance, and NELD would be writing contracts that would
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include design control and design interface control requirements.
Procedures controlling these design activities were not in place at the time of this inspection.
Until procedures controlling design activities for all groups involved in the design process are in place, this is identified as Inspector Followup Item 400/86-53-06.
g.
Design Basis Packages Design basis is discussed in ANSI N45.2.11.
The design basis for Plant Harris was originally developed by a contractor.
The design basis documents were being consolidated into a more useful package form.
According to HPES personnel, efforts are being made to assemble and control 60 to 70 design basis packages.
This was discussed in NRC Inspection Report No. 50-400/86-28.
Until these packages, which are due to be completed in July or August of 1986 are completed, this is identified as Inspector Followup Item 400/86-53-07.
6.
'urveillance Testing and Calibration (35745)
This inspection provides an additional review of the Surveillance Testing and Calibration Program which began and is discussed in NRC Inspection Report No. 50-400/86-28 dated May 14, 1986.
The Inspector Followup Items (IFIs) which follow in the text of this paragraph identify areas which will require licensee attention prior to implementation of that portion of the program.
For the most part, the programmatic requirements of the references of NRC Inspection Report No. 50-400/86-28 (paragraph 8) have been addressed with exceptions as noted below (the IFIs).
Additional or altered (since the previous inspection)
procedures that were examined by the inspector are as follows:
OMM-001 Conduct of Operations, Revision 2, Change A/C 2/3 PLP-103 Surveillance and Periodic Test Program (in draft)
Within this area, four inspection followup items were identified and are discussed in the following paragraphs.
a ~
Surveillance Program Procedures ANSI N18.7-1976, section 5, details requirements for procedures and the surveillance program.
The standard requires that each procedure shall be reviewed and approved prior to use.
Procedures are required to reflect actual conditions that exist at the plant.
Further, the standard requires that surveillance tests be scheduled.
The following types of procedures were in draft, not reviewed/approved, not written, intended for rewrite, or not schedule Ck
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Procedure Status, Notes in draft intended for rewrite intended for rewrite intended for rewrite not reviewed/approved not scheduled in draft in draft not written intended for rewrite PLP-103 GPs OPs OPTs OSTs EST EST 211 ISI 203 ISI 204 APP-ALB-010 1,
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Surveillance was required by Technical Specification (TS).
Surveillance was required by Final Safety and Analysis Report.
At the time of the inspection GP-1, 2, 3, 5, 7, and
were inclusive of these general procedures (operations).
This number was subject to change based on TS modifi-cations.
OPs and APPs (annunciator procedure)
number one each for TS surveillance test.
This is subject to change.
Five to ten percent of Operational Surveillance Tests (OSTs)
have yet to be approved.
EST 203 to 214 and 811 were not scheduled on Regulatory Compliance master schedule.
See subparagraph c below.
EST 211 dealt with auxiliary relief valve testing.
ISI 203 was the inservice inspection program which was in draft (revision 2).
Revision 3 would be issued after licensee submitted program changes to NRC headquarters and then incorporates comments.
ISI 204 was to deal with steam generator tube eddy current inspection (see subparagraph c below).
NOTES:
l.
2.
3.
4.
5.
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8.
9.
b.
Surveillance Master Schedule Until procedures are written to reflect Technical Specification surveillance requirements this is identified as Inspector Followup Item 400/86-53-08.
The licensee had submitted Technical Specification (TS) changes to the NRC over a long period of time.
An interim stabilization point in this review and approval cycle (see paragraph 5 of NRC Inspection Report No. 50-400/86-28)
was to be reached 'n July 1986.
At this time comments and surveillance requirements would be approved.
Due to TS related approval problems and other site problems, (e.g.,
task assignment holes for some surveillance tests within the computer matrix) the master schedule (surveillance and periodic data base)
is not complete.
Until the schedule matrix can be completed to accurately
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reflect surveillances required by TS, this is identified as Inspector Followup Item 400/86-53-09.
c.
Tests not on Master Schedule The licensee stated that several ASME Boiler and Pressure Vessel Code,Section XI, required surveillance tests such as the steam generator tube eddy current tests would not be included on the master schedule.
The licensee also stated that snubber inspections (which can fall under Section XI or TS)
and environmental monitor ing testing may not appear on the schedule.
The licensee stated that the above type tests will be manually or computer (PRISM program)
scheduled and administratively controlled by some means yet to be determined.
Additionally, the schedule and frequency of the ESTs indicated in paragraph
"a" (203 to 214 and 811)
have yet to be provided by the Inservice Inspection group to Regulatory Compliance personnel.
Until these tests and any un-accounted for tests are scheduled by some means and administratively controlled, this is identified as Inspector Followup Item 400/86-53-10.
d.
Inservice Inspection Program Vibration Testing The ASME Boiler and Pressure Code,Section XI, (required under
CFR 50.55)
requires vibrational testing of safety related pumps.
As discussed in NRC Inspection Report No. 50-400/86-28 and as stated by the licensee during this inspection, vibration testing procedures and training of personnel had not been initiated.
To obtain adequate reproducibi lity of vibration data such that meaningful test results can be obtained, training in testing techniques and methods is required.
The licensee has transferred personnel within HPES to the ISI group to begin training initiation.
Until vibration testing aspects are in place, this is identified as Inspector Followup Item 400/86-53-11.
7.
Measuring and Test Equipment (MSTE) Program (35750)
References:
(a)
(b)
(c)
(d)
(e)
(g)
CFR 50.54(a)(1),
Conditions of Licenses
CFR 50, Appendix B, guality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants Shearon Harris Nuclear Power Plant Final Safety Analysis Report Regulatory Guide 1.33, guality Assurance Program Requirements (Operations)
ANSI N18.7-1976, Administrative Controls and guality Assurance of the Operational Phase of Nuclear Power Plants Regulatory Guide 1.30, guality Assurance Requirements for the Installation, Inspection and Testing of Instrumentation and Electrical Equipment ANSI N45.2.4-1972, IEEE Standard, Installation, Inspection, and Testing Requirements for Instrumentation and Electric Equipment During the Construction Phase of Nuclear Power Generating Stations
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(h)
Corporate guality Assurance Program, Section 9,
"Calibration Control" The inspector reviewed the MME program required by references (a) through (h) to determine if the program had been established in accordance with regulatory requirements and industry guides and standards.
The following criteria were used during this review to determine the overall acceptability of the program established:
Responsibility was delegated and criteria established to assign and adjust calibration frequency for each type of N&TE.
Formal requirements existed for marking the latest calibration data on each piece of equipment.
The program assured that each piece of equipment was calibrated on or before the date required or stored in a location separate from inservice N8TE.
Written requirements prohibited the use of M8TE which had not been calibrated within the prescribed frequency.
When MSTE was found out of calibration, the program required documented evaluations to determine the cause of the out-of-calibration condition and the acceptability of items previously tested.
The program assured that new MSTE was added to the inventory lists and calibrated prior to use.
The documents listed below were reviewed to determine if these criteria had been incorporated into the MSTE program:
MMN-OOl, Maintenance Conduct of Operations, Revision 2, Change
NMM-004, Process Instrument Calibration, Revision 3, Change 2060 MMM-006, Measuring and Test Equipment Calibration Program Revision 4, Change 4/I Within this area, one inspector follow item was identified.
The inspector reviewed the NOTTE program for equipment defined in reference (c) which excluded permanently installed operating equipment.
The program for this portable equipment appeared adequate to meet regulatory requirements.
The inspector, however, noted a discrepancy between the definition of NSTE in references (c)
and (h).
Reference (h)
included permanently installed process equipment used for safety relate'd and/or Technical Specification related functions.
Reference (c) excludes this equipment.
Additionally, the program as established in MNN-006, does not address the equipment.
The calibration control program for installed process equipment performing safety related and/or Technical Specification related functions was incomplete and is identified as an inspector followup item.
Procedure MMN-004 provides a format for calibration procedures for installed equip-ment, however the equipment involved in the program has not been fully
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identified.
The calibration control program for installed instrumentation performing safety related or technical specification related functions requires the following for completion:
l.
Identification and control by maintenance of all process instrumen-tation used to verify component operability for Technical Specification and/or FSAR commitments.
2.
Identification by operations of those instruments which will impact Technical Specification conditional requirements.
Pending completion of these items, this will be identified as Inspector Followup Item 400/86-53-12, Identification and Control of Commitment Related P'rocess Instrumentation.
8.
Licensee Action on Previously Identified Inspection Findings (92701)
a.
(Closed)
Inspector Followup Item 86-28-01:
Improper Wording in Procedure NOD-202.
The specifically addressed
"should" statements addressed by the identifying inspector were replaced with "shall" in Procedure NOD-202.
b.
(Cl osed)
Inspector Fol 1 owup Item 86-31-01:
Implementati on of Operations QA Program QA Requirements for Surveillance of Pre-operational Tests Activities This IFI addressed the following two aspects of Operations QA Program Requirements:
(I)
Surveillance of preoperational test activities not performed by permanent operational QA/QC procedures.
(2)
Functional responsibilities not clearly delineated within the QA Supervisor line organization.
The first item was closed based on inspector review of a letter signed by C. L. NcKenzie, Acting Director - QA/QC, stating that preoperational test activity surveillances were performed by QA/QC procedures since February 1986.
The second item was closed based on inspector review of position descriptions for QA positions and the current organizational chart of the QA site personne It ~
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