IR 05000400/1986067
| ML20210S053 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 09/18/1986 |
| From: | Belisle G, Michael Scott NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20210S044 | List: |
| References | |
| 50-400-86-67, NUDOCS 8610070554 | |
| Download: ML20210S053 (7) | |
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>Mitog UNITED STATES e
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. NUCLEAR REGULATORY COMMISSION
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101 MARIETTA STREET,N.W.
- C ATI.ANTA, GEORGI A 30323
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Report No.: 50-400/86-67
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Licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 Docket No.: 50-400 License No.:
CPPR-158 Facility Name: Harris 1 Inspection Conducted: September 2-5, 1986 I<
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Inspector: 71 d
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M. A. Scott,p Date Signed (p L'./
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fo Approved by:
G.-A. Belisle,' Acting Section Chief
' Date Signed Operations Branch Division of Reactor Safety SUMMARY Scope:
This routine, unannounced inspection was conducted in the area of licensee action on previously identified inspection findings.
Results: No violations or deviations were identified.
I 8610070554 860925 PDR ADOCK 05000400 G
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REPORT DETAILS 1.
Persons Contacted Licensee Employees G. Campbell, Maintenance Manager L. Capps, Technical Support, Materials
- N. Chiangi, Quality Assurance / Quality Control (QA/QC) Manager
- J. Collins, Operations Manager J. Corey, Construction Project Manager
- C. Gibson, Assistant to Plant Manager
- K. Hate', Principal QA Engineer
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- B. Herring, Technical Support, Materials.
M. Jackson, Maintenance Project Engineer
- R. Lamb, Harris Plant Engineering Section (HPES) Engineer
- T. Lentz, Technical Support Manager
- L. Loflin, HPES Manager
- L. Ollivier, Technical Assistant L. Olsen, Technical Support Project Specialist
- S. Rea, Technical Support Engineer
- D. Tibbits, Regulatory Compliance Manager
- M. Thompson, HPES Engineer
- R. Van Metre, Technical Support Manager
- M. Wallace, Compliance Engineer
- D. Whitehead, QA/QC Manager Other licensee employees contacted included engineers, technicians, and office personnel.
NRC Resident Inspectors
- G. Maxwell S. Burris
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on September 5, 1986, with i
those persons indicated in paragraph 1 above.
The inspector described the areas inspected and discussed in detail the inspection findings listed below.
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.
3.
Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.
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4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
General This inspection was performed to close out inspector followup items (IFI)
available for closure prior to operational licensing of the plant.
The items were previously identified during NRC inspections that reviewed programmatic licensee activities prior to operation.
Future inspections will close the remaining IFIs when the licensee has taken the necessary corrective action..
Section 6 of this report addresses the IFIs reviewed during this inspection.
This section also indicates the reason for closure or nonclosure of the item.
Additionally, the section provides comments regarding areas of interest surrounding the IFIs.
The inspector reviewed the following additional or altered (since the previous inspections) procedures :
Nuclear Engineering and Licensing Department Procedures,. Revision 19 3.0 Engineering Procedures Harris Plant Engineering Section Manual of Instructions, Revision 44 2.0 Administrative Instructions 3.0 Engineering Instruction MMM-012 Maintenance Work Control Procedure, Revision 5 (Draft)
HPES 3.22 Process, Control, and Resolution of PCRs, Revision 46 (Draft)
HPES 3.25 Process, Control and Resolution of FRs, Revision 46 (Draft)
AP-24 Temporary Bypass and Wire Removal Control, Revision 0, A/C 0/3 AP-102 Authorization for HPCS Work, Revision 0, Change 2 AP'600 Plant Change Request Initiation, Revision 2 AP-IX-09 Field Contract Administration, Revision 4 AP-IX-34 Control of Construction Work on Operational Systems, Revision 0 PLP-601 Plant Confirguration Control Program, Revision 2 MOD-103 Engineering Evaluations, Revision 6
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M00-200 Review and Approval of Modifications, Revision 3 MOD-201 Technical Reviews, Revision 2 M00-202 Modification Implementation, Revision 1
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MOD-206 Temporary Modifications, Revision 0 6.
Licensee Actions on Previously Identified Inspection Findings (92701)
a.
(Closed) Inspector Followup Item (86-33-03):
Transfer of Construction Records to Operations
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Based on a Carolina Power and Light memorandum (dated July 2,1986)
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from the QA/QC Director, a conpletion of transfer date has been
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established.
The memo, titled " Response to IFI 86-33-03", indicates, in part, that "a target date of December 31, 1987 was established for j
completion of the records transfer.
This date is based on commercial j
operations commencing in December 1986."
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l b.
(Closed) Inspector Followup Item (86-33-05):
Expiration of Temporary j
Changes to Procedures
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The inspector reviewed a procedure change which limited the time span
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of a temporary change.
Revision 4 to AP-007 limited active life of a
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temporary change to any procedure to 21 days and the change itself must be reviewed by a manager in 14 days of issue.
Further, temporary changes issued during outages did not expire until 21 days after the end of the outage.
Sections 5.2.14 and 5.2.15 of AP-007, which dealt with actions after a temporary change implementation and after the change was found to be
unacceptable, contained "should" statements that were more appropri-ately imperative in nature.
The licensee issued a change during the inspection period which was reviewed by the inspector that replaced the conditional statements.
c.
(Closed) Inspector Followup Item (86-33-07): Control of Shaft Keys The inspector reviewed licensee actions concerning shaft key controls.
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The licensee stated that the materials group of the technical support
sections identified all motor shaft keys in storage and those motor
shafts nn safety related equipment which would require keys. The keys i
that had been attached to motors in storage were stated by the licensee to have been assigned unique identifiers and stored separately. Shaft
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keys procured or yet to be procured were stated by the licensee to have l
been entered into the equipment data base computer program as repair j
parts.
The end use process for repair parts is administratively controlled by procedure MMM-012.
The licensee stated that the motor vendors were being contacted for additional key specification infor-nation.
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Procedure MMM-012 generally required that repair parts be obtained via this instruction.
Repair parts were required to be drawn from stores under unique identifiers. Repair parts not identified in the equipment data base (i.e., uniquely identified for safety related applications)
must be procured or obtained via an engineering evaluation process described procedurally in a technical support section instruction.
As the operational procedures become effective, older instructions are being phased out.
Engineering Work Requests (EWR) used to obtain engineering evaluations were still in existence as those evaluations proceed.
M00-103, which utilizes Plant Change Requests (PCR) for evaluations, will replace EWR procedures.
Regulatory Compliance was responsible for cancellation of EWR procedures at the time of this inspection.
d.
(Closed) Inspector Followup Item (86-33-08):
Inconsistent Designation of Procurement Requisition Forms The inspector reviewed PMC-001 (AC 2/2 of May 29,1986), Procurement and Cataloging of Parts, Material, Equipment and Services.
This procedure was consistent in its terminology with regard to procurement forms.
e.
(Closed) Inspector Followup Item (86-53-01): HPES Procedures The inspector reviewed selected HPES procedures as stated in paragraph 5.
Procedure HPES 3.24 which was listed in NRC Inspection Report No.
50-400/86-53 was issued by the licensee as HPES 3.25.
f.
(0 pen) Inspector Followup Item (86-53-02):
Changes to Design Modification This item remains open based on the need for further licensee action.
MOD-202 was revised to reference Field Revision (FR) review per HPES 3.25.
HPES 3.25 was issued containing some wording problems with regard to ANSI N45.2.11; the procedure did not assure that the FR would be subject to the same design control measures that were applied to the original design. This was discussed with the licensee and the licensee showed the inspector an unapproved draft potentially correcting the problem.
Based on the draft status of the procedure and the fact that the licensee wanted to consider expanding the pertinent segment of the instruction after an impending engineering training session, the item was left open.
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(Closed) Inspector Followup Item (86-53-03): Temporary Modifications
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The inspector reviewed M00-206.
This procedure addressed temporary modifications on operable equipment.
h.
(Closed) Inspector Followup Item (86-53-04):
Independent Review and Corrective Action
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The inspector reviewed a revision of procedures dealing with evalua-tions.
AP-600 was revised to assess operability requirements that a Plant Change Request (PCR) may alter.
MOD-103 was changed to assess PCR reportability potential.
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(Closed) Inspector Followup Item (86-53-05):
Option or Recomendation Statements in Design Procedures The inspector reviewed selected Technical Support and HPES procedures for conditionality statements.
Conditionality statements had been deleted.
Again, due to the out of place "should" statements found in AP-007 (see subparagraph
"b" above), the licensee's attention is directed to any other option or recommendation statements to be found within site procedures.
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(Closed) Inspector Followup Item (86-53-06):
Procedural Completion for Groups Involved in Design Control The inspector performed a comparison of selected standard requirements to actual site programmatic requirements.
Standards such as ANSI N45.2.11 and N18.7-1976 reflect general, minimal requirements which the licensee has adopted via their accepted quality assurance program. The inspector verified that programmatic attributes of the standards have been incorporated into site applicable procedures.
During the preoperational phase, procedures have developed at the site as requirements have been identified, as site groups have determined their interface points, and as perceived needs have arisen.
Engineering aspects of design control have been given the greatest programmatic effort.
The engineering procedures require that all groups utilize the PCR administrative method in the -modification process; other site applicable procedures minimally evoke the engineering procedures. A loose framework of contractural controls was present to bind outside contractors to site requirements. Although the framework is present, construction project engineering was preparing an additional administrative instruction (tentatively identified as AP-33) which should solidify the contractural procedural framework. At the time of the inspection, quality assurance was the final reviewer in the PCR and contract process, k.
(Closed) Inspector Followup Item (86-53-07):
Design Bases Packages The inspector reviewed the procedural control of design input on site.
The initial architect-engineer has turned over the design input, which contains the Plant design bases to HPES. Administrative procedures are present to control use of the original design input.
As stated by the licensee, the original architect was hired to develop design bases packages from the aggregate corpus of the input to facilitate use and summarize information on a system level.
The
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licensee stated that the design bases were retrievable for design use and general plant application.
The packages were stated as not being required for the design process.
The inspector did not examine the implementation aspects of the process.
Previously when the IFI was written, the licensee had indicated that the design bases packages would be completed by August 1986.
Since that time, review personnel had been reallocated to other projects of higher priority.
The target date for completion of the design bases packages has slipped to approximately December 1986.
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