IR 05000400/1987009
| ML18004B757 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 03/26/1987 |
| From: | Belisle G, Michael Scott NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18004B756 | List: |
| References | |
| 50-400-87-09, 50-400-87-9, IEB-79-14, NUDOCS 8704130371 | |
| Download: ML18004B757 (7) | |
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UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTASTREET, N.W., SUITE 2900 ATLANTA,GEORGIA 30323 RePOrt NOeI 50-400/87-09 Licensee:
Carolina Power and Light Company P. 0.
Box 1551 Raleigh, NC 27602 Docket No.:
50-400 Facility Name:
Shearon Harris Inspection Conducted:
February 9-13, 1987 Inspector:
M. A. Scott f
Approved by:
Y~iC.~j.
G.
.
e is e, ie equality Assurance Programs Section Division of Reactor Safety License Noe I NPF-53, Date Signed ate igne SUMMARY Scope:
This routine, unannounced inspection was conducted in the area of design control.
Results:
No violations or deviations were identified.
8704130371 870331 PDR ADOCK 05000400
REPORT DETAILS Persons Contacted Licensee Employees L. Burns, Technical Support (TS) Engineer
- G. Forehand, Quality Assurance/Quality Control (QA/QC) Director
- W. Holly, TS Engineer M. Holveck, Harris Plant Construction Section HPCS Supervisor
- J. Lawrence, Harris Plant Engineering Section HPES Technical Assistant
- L. Loflin, HPES Manager
- V. McKay, HPES Civil Engineer
- C. McKenzie, Principal QA Engineer W. Morris, TS Engineer V. Rascoe, TS Engineer
- S. Rea, TS Senior Engineer
- C. Rose, QA Supervisor
- W. Seyler, HPCS Manager D. Shockley, QA Auditor G. Stegall, TS Engineer D. Tibbitts, Regulatory Compliance Director J.
Thompson, Operations Supervisor
- M. Wallace, Regulatory Compliance Specialist
- G. Watson, Site Vice President
- J. Willis, Plant Manager Other licensee employees contacted included engineers, technicians, operators, and office personnel.
NRC Resident Inspector
- G. Maxwell
- Attended exit interview Exit Interview The inspection scope and findings were summarized on February 13, 1987, 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 inspectors during this inspectio.
Licensee Action on Previous Enforcement Matters (Closed)
Severity Level IV Violation (50-400/86-65-01):
Failure of Licensee Management to Implement Adequate Corrective Action to Preclude Unauthorized Work The licensee's response dated October 17, 1986, was considered acceptable by Region II.
The inspector examined the implementation of the licensee's corrective action during this inspection.
Trend information, available from the licensee on unauthorized work deficiencies, showed a
marked
~ decrease in their occurrence.
Other licensee provided documentation demonstrated corrective action had taken place.
The inspector concluded that the licensee had determined the full extent of the violation, taken action to correct current conditions, and developed corrective actions needed to preclude recurrence of similar problems.
Corrective actions stated in the licensee response have been implemented.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Design Control (37702)
a.
General Previous efforts in the NRC inspection of the design control area are documented in Region II Inspection Report Nos.
50-400/86-28, 50-400/86-53, 50-400/86-67, and 50-400/86-81 (May 14, August 5, September 25, and November 4, 1986, respectively).
These inspections reviewed programmatic aspects of the site generated modification process (as discussed in paragraph 5.b) prior to the site receiving a power license.
This current inspection examined some design control program implementation after the plant recei ved its power license.
The inspector identified that the program was in a conversion state from construction to operations (see paragraph 5.b).
Due to this state of transition and the fact that few safety-related modification packages have been completed, additional inspection in this area will be required.
b.
Modifications As of the last inspection (November 1986),
a modifications program was being finalized by TS and HPES.
TS was to be the focal point for processing modifications and the close out of modification packages.
The following instructions have been altered since the August 5, 1986, inspection:
AP-102 AP-600 AP-IX-34 MOD-103 NOD-200 MOD-201 NOD-202 MOD-206 OMM-003 PLP-601 Authorization for HPCS Work (ACW), Revision 0, Change
Plant Change Request Initiation, Revision 2, Change 2/2 Control of Construction Work On Operational-Systems, Revision
Engineering Evaluations, Revision 6, Change 6/2 Review and Approval of Modifications, Revision 3, Change 3/3
'echnical Reviews, Revision 2, Change 2/1 Modification Implementation, Revision 1, Change 1/2 Temporary Modifications, Revision 0, Change 0/1 Equipment Inoperable Record, Revision
Plant Configuration Control Program, Revision 2, Change 2/1 The above procedures and program retain the same basic aspects as identified during previous inspections.
Site personnel (then and now) indicated that HPCS may take on a different role in the future, but this inspection was based on the existing program.
The changes to the program which were typified by revisions to the above procedures represented the licensee's modifying the program to site realities.
The procedure changes mainly consisted of documenta-tion routing changes and the changing of several forms.
Several changes were the result of nonconformance reports (addressed in a
later paragraph).
Several changes also addressed modification package development.
Ten of one hundred and eighty modifications (Plant Change Requests, PCR) being worked under the Operating Plant'rogram (NOD - 200 and 202)
have been closed.
Of these none were greater than Class E which was the least significant safety class.
The inspector determined that there were not enough completed packages to provide an adequate sample for review.
Apparently, the packages were not closed due to an internal TS review process which was correcting the packages'ontents in an attempt to make them uniform (match the procedural changes indicated above)
and due to procedural problems with NOD-20 Procedure MOD-202 indicated the steps required to be performed to return/initiate system equipment to service.
Procedure OMM-003 contained similar instructions.
These two procedures were incom-patiblee in that OMN-003 required work and testing be complete before a
piece of equipment/system was declared operable while MOD-202 required the same steps plus several more steps.
The additional MOD-202 steps included procedure,:drawing, and training changes and the Plant Manager's signature.
Modifications had been declared operational per ONM-003 without the technicality of the Plant Manager's signature.
The licensee stated that all other required MOD-202 steps had been completed (upper portion of Form 3 of the procedure)
prior to the OMN-003 operability declaration.
The licensee stated that operational site procedures were in draft form to rectify interprocedural problems.
The licensee was backfitting operations modification (PCR) packages.
In the sample examined by the inspector, several different documents and forms were being added to the packages after they had been collected in document control.
It was explained by the licensee that these additions were the results of minor programmatic changes, the package development learning curve, and attempts to standardize the package's content.
However, no packages reviewed by the inspector contained added material that affected equipment or systems that were already operable.
Field Change Requests (FCRs) were used during construction to control modification packages and were still being generated by the site.
The FCRs and PCR were being processed by HPES and HPCS.
The FCR is not processed or controlled by TS as is the PCR.
The FCR was not described in the site's programmatic modification instructions (such as MOD-200 and 202),
but was in HPES and HPCS procedures.
The existence of parallel paths for modifications is acceptable as long as they are prescribed by procedure, do not contradict one another, provide the same output, and contain the same regulatory require-ments.
The inspector did not evaluate the FCR program, but was assured by the licensee that it was the same program used in construction.
The licensee stated that FCRs were not being worked on operational systems.
FCR use on operational systems would require interface controls (ANSI N45.2. 11 requirements)
with site procedures and system entry controls.
FCR use on safety-related systems (such as FCR-P-4834 and FCR-SM-342) will be evaluated during the next inspection.
The licensee stated that FCRs were used in lieu of PCRs for expediency since the time of TS processing was eliminate The inspector examined gA nonconformance, audit, and surveillance reports during the inspection.
The following are the documents reviewed:
Audit, Surveillance, or Nonconformance Number Surveillance 87-026 Date of Issue 02/09/87 Comment
.
Contained a (Open)
concern regarding IE Bulletin 79-14; four PCRs addressed Regulatory Guide 1.29 work Nonconformance 87-020 Nonconformance 87-012 Surveillance 87-008 Nonconformance 87-006'onconformance OP-86-0171 Nonconformance OP-86-0167 Nonconformance OP-86-0162 02/06/87 01/19/87 01/15/87 01/09/87 11/17/86 11/12/86 11/10/86 Wrong quality class on Regulatory Guide 1.29 PCR (Open)
Aux Feedwater pump was modified prior to initiation of PCR-824 (Open)
Work performed to unapproved PCR 316 (Open)
Same as above Construction personnel did not understand PCR process (Closed)
PCR 375 declared operable without gA/gC participation in the walkdown and without required documentation in file (Closed)
Field Revision to PCR-171, involving hangers not generated per PCR program (Closed)
Audit, Surveillance, or Nonconformance Number Oate of
"Issue Comment Nonconformance OP-86-0098 Nonconformance OP-86-0097 Audit 0AA/0100-86-05 10/06/86 10/07/86 12/02/86 PCR-234 (invoking FCR-I-3147) work request was not reviewed by gA (Closed)
Modification work performed without approved PCR-234 (Closed)
Concern involving FSAR changes not being in PCR-423 file (Open)
From the above gA findings, it appeared that modification program were having difficulty.
procedures involved corrections for many of Training of personnel was documented to have necessary.
The inspector noted an absence of generated FCRs.
the mechanics of the Changes to program the above problems.
occurred when deemed nonconformances on HPES HPCS generation of work packages for modification performance was not examined during this part of the inspection, but will be reviewed at a
later date.
For work that construction. was to perform, HPCS took the HPES initial design package and developed the work package for the craftsman.
This work package contained detailed work instructions, gC hold points, bill of materials, and test instructions.
Within this area, no violations or deviations were identified.