IR 05000416/1983022
| ML20024F326 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 06/23/1983 |
| From: | Belisle G, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20024F309 | List: |
| References | |
| 50-416-83-22, NUDOCS 8309090278 | |
| Download: ML20024F326 (8) | |
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UNITED STATES 30,,
NUCLEAR REGULATORY COMMISSION
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Q ATLANTA. GEORGIA 30303 Report No: 50-416/83-22 Licensee: Mississippi Power and Light Company Jackson, MS 39205 Docket No: 50-416 License Nos: NPF-13 Facility Name: Grand Gulf 1 Inspection at Grand Gulf site near Port Gibson, Mississippi Inspector:
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_6[I[/3 G. A. Belisle W
Date/ Signed Approved by:
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_I B f C. M. Uprigh't, Secfifh Chi fates)tned Engineering Progrants Bra Division of Engineering d Operational Programs SUMMARY Inspection on May 23 - 27, 1983 Areas Inspected This routine, unannounced inspection involved 32 inspector-hours on site in the area of design changes.
Results Of the one area inspected, one apparent violation was identified (Failure to provide bases for the determination that design change packages (DCPs) did not involve an unreviewed safety question, Paragraph 5.a).
8309090270 030816 PDR ADOCK 05000416 G
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REPORT DETAILS 1.
Persons Contacted Licensee Employees J. Albert, Senior Engineer
- J. Bailey, Compliance Coordinator D. Beard, Maintenance Engineer A. Butt, Construction Engineer
- J. Cross, Assistant Plant Manager
- L. Daughtery, Compliance Superintendent W. Edge, Programs QA Manager
- S. Feith, Operations QA Supervisor R. Fron, Principal Civil Engineer
- C. Hayes, Plant Quality Superintendent J. Hrivnak, Construction Engineer
- D. Hughes, Regulatory Compliance D. Hunt, Training Superintendent-
- S. Hutchins, Principal Electrical Engineer
- C. Hutchinson, Nuclear Support Manager R. Keeton, Operations Superintendent C. Laskhari, Construction Engineer
- C. McCoy, Plant Manager
- F. Walsh, Maintenance ' Engineering Supervisor K. Wright, Project Leader
- J. Yelverton, Site QA Manager Other licensce employees contacted included technicians, operators, and office personnel.
NRC Resident Inspector A. Wagner, Senior Resident Inspector
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on May 27, 1983, with those persons indicated in paragraph 1 above. Additionally, a telephone conversation was conducted June 1,1983, between the inspector and the Assistant Plant Manager. This conversation clarified inspector-followup item 50-416/83-22-05. The licensee acknowledged the following inspection findings:
Violation 416/83-22-01: Failure to Provide Bases for the Determination that DCPs Did Not Involve an Unreviewed Safety Question, Paragraph.
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Inspector Followup Item 416/83-22-02:
Review Updated Training for DCPs, Paragraph 5.b.
Inspector Followup Item 416/83-22-03: Review Updated Procedures, Paragraph 5.c.
Inspector Followup Item 416/83-22-04: Review Updated Drawings, Paragraph 5.d.
Inspector Followup Item 416/83-22-05: Review Actions for Unreviewed Safety Questions, Paragraph 5.e.
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Licensee Action on Previous Enforcement Matters Not inspected.
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Unresolved Items Unresolved items were not identified during this inspection.
5.
Design Change Program (37702)
References:
(a)
10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear n 9wer Plants and Fuel Reprocessing Plants (b) Regulatory OJide 1.64, Quality Assurance Requirements for the Des y n of Nuclear Power Plants (c) ANSI N45.2.11-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants (d) Regulatory Guide 1.33, Quality Assurance Program Require-ments(Operation)
(e) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (f) Technical Specifications, Section 6, Administrative Controls The inspector reviewed the licensee's design change program required by References (a) - (f) and verified that design change activities were con-ducted in accordance with regulatory requirements, industry guides or standards, and Technical Specifications. The following criteria were used during this review:
Procedures have been established to control design change requests
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(DCRs)anddesignchangepackages(DCPs).
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Procedures.and responsibilities for DCRs and DCPs have been esta-
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blished.
Administrative controls for DCR and DCP document control have been
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established.
Administrative controls assure that DCPs are incorporated into plant
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procedures, operator training, and updating applicable drawings.
Controls have been developed that define channels of communication
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between design ~and responsible organizations.
Administrative' controls require DCR and DCP documentation and records
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be collected and stored.
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Controls require implementation of approved DCPs be in accordance with approved procedures.
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Controls require post-modification testing be performed per approved test procedures and the results evaluated.
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Responsibility has been assigned for identifying post-modification testing requirements.
Responsibilities and methods for reporting DCPs to the NRC in accor-
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dance with 10 CFR 50.59 have been identified.
The Senior Resident Inspector has reviewed jumper controls. This review is documented in his monthly inspection reports.
Documents listed below were reviewed to verify that these criteria had been
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incorporated into DCR and DCP activities..
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0QAM Policy 3 Design Control
' QAP 3.10 Review of Design Documents Generated by Off-Site Organizations
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01-S-07-04 Plant Changes and Modifications, Revision 8 09-S-01-08 Control of Design Change Activities, Revision 0
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01-S-07-01 Control of Work on Plant Equipment and Facilities, Revision 9 01-S-05-06 Distribution and Control of Plant Drawings, Revision 10
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t 09-S-07-2 Implementation of Modifications and New Design Requirements, Revision 0 l'
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09-S-07-3 Design Change Notice Procedure, Revision 4 09-S-07-06, Control of Retest Requirements, Revision 2
.01-301 Design Interface Definition, Revision 1 01-302 Design Review of Contractor Prepared Design Documents, Revision 3 01-303 Evaluation of Changes to Nuclear Plant Engineering Issued Design, Revision 3 01-304-Performance cf Design and Preparation of Design Change Packages, Revision 5 01-305 Preparation and Control of Engineering Calculations /
Analysis, Revision 3 01-306 Preparation and Control of Engineering Specifications, Revision 2 01-307 Preparation and Control of Engineering Procedures, Revision 3-01-501 Document Control, Revision 3 01-901 Control of Special Processes for Design Change Packages, Revision 0 The inspector reviewed design change measures established for processing DCRs and DCPs. This program has undergone considerable updating since previous inspections in October 1981 and May 1982. During the latter part of 1982, the licensee established _a design change task group to clearly define and obtain status of outstanding design changes.
-'A comprehensive search identified 2044 design changes. The licensee has closed three DCPs as of the date of this inspection.
-The offsite QA group conduct; audits of Nuclear Plant Engineering (NPE)
activities. NPE has prime n sponsibility for design changes. NPE has been audited February 22 - 25, 1982; September 27 - October 6, 1982; and
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. March 21 - April 19, 1983. Monitoring audits were conducted September 27 -
October 18, 1982, and April 26, 1983. A total of 54 nonconformances were identified during these audits. Most of these nonconformances have been closed. One nonconformance is due to be closed in July 1983.
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The inspector conducted numerous interviews with training, operations, maintenance, offsite and onsite QA, NPE, and design change task group personnel. The following are generalized comments resulting from these interviews:
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The inspector has a high degree of confidence that design changes are being properly processed.
Established measures, if rigidly adhered to, will assure adequate status and closure of existing DCRs and DCPs.
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The inspector has a high degree of confidence that licensed pesonnel will be adequa sly trained on DCPs. This is due, ir. part, to the-training group researching DCPs for training requirements independently of the DCP task group.
Operations and maintenance personnel are in the process of updating
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-procedures to reflect DCP installation. The DCP task group notifies these personnel of DCP installation and closecut. When formally notified, procedures are then updated. With large numbers of DCPs
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being processed, additional resources may have to be allocated to these groups to insure adequate procedural updating. This was discussed at the exit interview with management personnel.
Drawing updating to as-built conditions is being done by the DCP task
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force.on a system basis. -Once all DCPs are identified pertaining to a system, drawings will be as-built (red lined) by the DCP task force.
Final issuance of drawings will be processed by NPE.
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A licensee QA audit is planned to verify full implementation when more DCPs are completed.
Within this area, one violation and four inspector followup items were identified and are discussed in the following paragraphs.
a.
Failure to Provide Bases for Determination that DCPs Did Not Involve an Unreviewed Safety Question The inspector selected eight DCPs that were in process of being closed out. Two of the DCPs selected (82/3588, replace handswitches for standby diesel generator on panel 1H13 - P864, and 82/3596, replace 28VDC coil relays with 20VDC coil relays in APRM, SRM, and IRM trip circuits) did not provide adequate bases for determination that an unreviewed safety question was not involved. 10 CFR 50.59(a)(2) states that a proposed change, test, or experiment shall be deemed to involve an unreviewed safety question, (i)
If the probability of occurrence or the consequences of an accident or malfunction of equipment important to safety previously evaluated in the safety analysis report may be increased;
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(ii)
If a possibility for an accident or malfunction of a different type than any evaluated previously in the safety analysis report may be created; or (iii) If the margin of safety as defined in the basis of any Technical Specification is reduced.
These requirements are included in procedure 01-304 Attachment 3 but they are presented as questions prefaced by the word is. Both of these This indicates that the answers in (i)y stating "see Ttem 1 abcve" (1).
design change packages answered (ii) b contained adequate bases for answeringboth(i)and(ii). The answers for (i) were not adequate to provide bases for answering (ii) but were adequate for answering (1).
This failure to provide bases required by 10 CFR 50.59 constitutes a violation (416/83-22-01).
b.
Review Updated Training for DCPs Training lesson plans are being updated to reflect current as-built plant conditions. Training personnel are reviewing DCPs independently of the DCP task group to ensure that training requirements of 10 CFR 55 Appendix A are met. At the date of this inspection this effort was approximately 70% complete. Until the training staff completes their review of DCPs and updates their training program to reflect these changes, this is identified as an inspector followup item (416/83-22-02).
c.
Review Updated Procedures Operations and maintenance personnel are updating procedures in their functional areas that are impacted by DCPs. They receive notification of pending DCP completion and then update procedures accordingly. To date, a very small percentage of DCPs' have been totally completed.
Until a larger percentage of DCPs are closed out and procedures are verified to be updated, this is identified as an inspector followup item (416/83-22-03).
d.
Review Updated Drawings DCPs are in the process of being completed. Drawings are being updated to reflect as-built condition once a determination is made of the status of all DCPs on any given system. The licensee has identified the status of outstanding DCPs as previously discussed. Until drawings accurately reflect as-built conditions, this is identified as an inspector followup item (416/83-22-04).
e.
Review Actions to Unreviewed Safety Question Procedure 01-304, Paragraph 6.7, details requirements for completing 10 CFR 50.59 safety evaluations. This paragraph does not address a course of action to be taken if a DCP constitutes an unreviewed safety
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question. The inspector reviewed DCP 81/044 (Consnunication system
. between existing radio network and -the containment /drywell) where an
- apparent unreviewed safety question was identified. This DCP was not treated any differently than any others. Until the licensee establishes measures to assure proper handling of apparent unreviewed safety-questions required by 10 CFR 50.59 and Technical Specifications, this is identified as an inspector followup item (416/83-22-05).
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