IR 05000416/1986018

Insp Rept 50-416/86-18 on 860609-13.No Violations or Deviations Noted.Major Areas Inspected:Offsite Support Staff & Review Committee

ML20203C130
Person / Time
Site:	Grand Gulf
Issue date:	06/30/1986
From:	Belisle G, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20203C090	List: IR 05000416/1986018 ML20203C084
References
50-416-86-18, NUDOCS 8607180359
Download: ML20203C130 (9)

Text

l SQCEGo UNITED STATES o NUCLEAR REGULATORY COMMISSION

^ REGION 11

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'+4 . . . . . s Report No.: 50-416/86-18 Licensee: Mississippi Power and Light Company Jackson, MS 39205 Docket No.: 50-416 License No.: NPF-29 Facility Name: Grand Gulf Inspection Conducted: June 9-13, 1986 Inspector: fM 6- 3,o - TsG Date Signed C. SmTty , ,

Approved by: 6 7-r 7 6 o G. Belisle, Acting'Section Chief 'QateSigned Division of Reactor Safety SUMMARY Scope: This routine, announced inspection was conducted at the Corporate Office in the areas of Offsite Support Staff and Offsite Review Committe Results: No violations or deviations were identifie !

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REPORT DETAILS Persons Contacted Licensee Employees

• C. Angle, Nuclear Plant Engineering - Principal Engineer

• L. Burgess, Program Quality Assurance (QA) Supervisor D. Butler, Safety and Licensing Specialist

• D. Canazaro, Acting Manager, QA Audits J. Cesare, Manager, Nuclear Licensing T. Cloninger, .Vice President, Nuclear Engineering and Support (Vice Chairman, Safety Review Conmittee)

• L. Dale, Director, Nuclear Licensing and Safety W. Edge, Manager, Programs QA J. Fortenberry, Engineer, Nuclear Fuels Section

• J. Fowler, Secretary, Safety Review Committee

• H. Green, Advisor to Vice President, Nuclear Operations J. Harrington, Supervisor, Nuclear Services S. Hobbs, Manager, Nuclear Safety and Licensing G. Ingram, QA Supervisor

• 0. Kingsley, Jr., Vice President, Nuclear Operations (Chairman, Safety Review Committee)

W. Klinger, Acting Supervisor, Supplier Audits

• J. Lee, Supervisor, Nuclear Fuels Section Dr. L. McKay, Manager, Radiological and Environmental Services T. Reaves, Director, Nuclear Support

• C. Tyrone, Manager, Nuclear Services and Fuels

• Attended exit interview Exit Interview The inspection scope and findings were summarized on June 13, 1986, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection findings listed below No dissenting consents 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 inspectio l Inspector Followup Item: Publication of NPD procedures and corrections

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to lower tier procedures, paragraph 5. Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio l Unresolved Items

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Unresolved items were not identified during the inspectio . OffsiteSupportStaff(40703)

References: (a) 10CFR50.54(a)(1),ConditionsofLicenses (b) MP&L Operational QA Manual (MPL-TOP-1A) Revision 4, Amended (c) 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (d) Regulatory Guide 1.33, Quality Assurance Program Requirements (Operations)

(e) ANSI N18.7-1976, Quality Assurance for the Operational Phase of Nuclear Power Plants (f) Technical Specifications, Section 6, Administrative Controls The inspector visited the corporate office to determine whether the offsite support staff functions were performed by qualified personnel in accordance with licensee approved administrative controls, regulatory requirements, industry guides and standards, and Technical Specifica+4ons (TS). The following criteria were used during this review to asses. 2he adequacy of the offsite support staff:

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Administrative controls were established to assign departmental responsibilities, authorities, and lines of comLJnication in con-formance with the requirements of 10 CFR 50, Appendix B, and the licensee's approved QA progra Managers, group leaders, and staff members understood their responsibilities and authoritie The above personnel were qualified for their related wor QA audits of offsite support staff activities were conducted satis-factorily and corrective actions for identified deficiencies were completed in a timely manne The documents listed below were reviewed to determine if the previously listed criteria had been incorporated into the licensee's offsite support staff operation:

Nuclear Production Department (NPD) Policy Manual, Revision 0 Section Management Principles and Philosophies Section NPD Organization and Corporate Support I

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Nuclear Production Department Procedures Manual

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Section NPD Procedures Manual, Safety Related, Revision No. 1 l Section Performance Monitoring - Management Information

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Program, Revision No. 2 Section 1.10 Professional Qualifications Review, Revision No. 1 Section 1.11 Objectives and Goal Program, Revision No.1

Nuclear Support Administrative Procedures Manual i Section Nuclear Support Organization and Responsibilities, ,

! Revision 1

. Section 1.5- Deficiency Identification and Reporting, Revision 0 i

Section Training of Nuclear Support Staff Personnel,

Revision 3-

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Section Screening for Evaluation of Deviations and i .

Deficiencies, Revision l'

i Section Design Change Initiation, Revision 0 Section 1.12 Safety and Environmental Evaluations, Revision 2

Section Nuclear Services Section, Revision 1

! Section Nuclear Fuels Section, Revision 1  ;

j Section Radiological and Environmental Services Section, i

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Revision 1 Section Environmental Surveillance Program Organizational Structure and Responsibilities,, Revision 3 Nuclear Licensing and Safety Administrative Procedures Manual

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Section Nuclear Licensing and Safety Organization and Responsibilities, Safety Related, Revision 1, Draft

A Section Nuclear Licensing Section, Revision 1

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Section Nuclear Safety and Compliance Section, Revision 1

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QAP 1.30 General Office QA Organization and Duties, Responsibilities, and Authority of General Office QARs, Revision 9

! MP&L's Topical Report (MP&L-TOP-1A), Sections '1.0 and 2.0,' describe the

functions of the offsite support organizations participating in the nuclear QA progra The Nuclear Production Department (NPD) Policy Manual and the

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i NPD Procedures Manual are upper-tier program documents that collectively implement requirements of the Topical Report. Guidance in the performance j of activities common to all NPD organizations are delineated in the NPD '

Procedures Manual. Additionally, progransnatic requirements and responsi-l

, bilities related to monitoring and assessing overall plant performance in l board functional areas directly related to plant safety and reliability are j addressed in this program docunent. 'The inspector determined that numerous

! procedures contained in the NPD Procedures Manual have not yet been

! published. This issue is identified as an Inspector Followup Item and is discussed later in the report.

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Pursuant to requirements delineated in upper-tier QA program documents, the 4 inspector conducted interviews with licensee personnel from the following i offsite support groups to ascertain the degree of confonnance with QA 1 program requirements: .

. Nuclear Services and Fuels Radiological and Environmental Services Nuclear Licensing

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Nuclear Safety and Compliance ,

l Audits QA i'

Programs QA

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The inspector determined during the course of these interviews that each

support organization had a QA program documented by written procedures which

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control activities defined in the Topical Repor In addition, each offsite

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support group's organizational structure, functional responsibilities, levels of authority, and lines of internal and external interfaces were ,

documented in writing.

I' The inspector identified discrepancies in paragraph numbers referenced in

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lower-tier quality implementing program documents for connitments delineated ,

! in the NPD Policy and Organization Manual. These discrepancies were caused j by replecing the NPD Policy and Organization Manual with the NPD Policy Manual and the NPD Procedures Manual. -However, licensee personnel were

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fully familiar with QA program documents and identified those sections of the upper-tier program documents wherein commitments and their responsi -

bilities were defined. The inspector _ determined that these editorial

discrepancies were minor administrative errors and did not impair effective

implementation of the QA program. Correction of these discrepancies j requires completing the phase-out of the NPD Policy and Organization Manual 4-and editorial corrections to the lower-tier quality implementing procedure This issue is discussed in the last paragraph of this report.

j Training 'was provided to licensee employees in the fonn of general employee

, training and required reading list Typical of this is the training ,

i program for Nuclear Support Staff Personnel documented in Nuclear Support

Administrative Procedure -No.1.6. ' Members of this technical staff are j degreed engineers who were knowledgeable of their functional responsibili-j ties and ongoing technical issues concerning Grand Gulf Nuclear Station.

3 (GGNS). The inspector determined that design control responsibilities

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related to nuclear fuel and core design had been recently assigned to the

Nuclear Fuels Section. - At the exit interview, the inspector stated that additional management attention would be- required regarding- the training

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provided personnel within this group in light of the new responsibilities 1 assigned - to the Specifically, the minimum training ~ requirements j delineated on Attachment III to Nuclear. Support Administrative procedure

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No.l.6 would have to be supplemented by training in requirements of ANSI N45.2.11-1974,10 CFR 50.59 Safety Evaluations, and implementing procedures of the sectio Within this area, one Inspector Followup Item was identified. The licensee is presently replacing the NPD Policy and Organization Manual with the NPD Policy Manual and the NPD Procedures Manua These two program documents collectively implement licensee comitments delineated in the QA program Topical Report. Additionally, support organizations, procedures, and section procedures reference comitments delineated in these upper-tier program document The inspector determined that numerous procedures to be contained in the NPD Procedures Manual have not yet been published. A review of the "NPD Status of Procedures in Review as of June 6,1986" report was performed by the inspector. Pursuant to this review, until the licensee has completed publication of procedures delineated in this report and editorial discrepancies in lower-tier implementing procedures are corrected, this is identified as Inspector Followup Item 416/86-18-01.

6. Offsite Review Comittee (40701)

References: (a) 10 CFR 50.54(a)(1), Conditions of Licenses (b) MP&L Operational QA Manual (MPL-TOP-1A), Revision 4 Amended (c) 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (d) TS, Section 6.5.2, Safety Review Comittee (e) Regulatory Guide 1.33, Quality Assurance Program Requirements (0perations)

(f) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants The inspector reviewed the licensee offsite review comittee program required by references (a) through (f) to determine whether the program had been established in accordance with regulatory requirements, industry guides and standards, and TS. The following criteria were used during this review to assess the overall acceptability of the established program:

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The Safety Review Comittee (SRC) membership and qualifications were as required by T The SRC held meetings at the required frequency with the required quoru The SRC reviewed those items specified in T .- .

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The SRC had cognizance of audits performed in the areas specified by TS.

- SRC meeting minutes were prepared ar.d issued within the required timeframe.

The documents listed below were reviewed to determine if these criteria had been incorporated into the offsite review program:

Nuclear Production Department Policy Manual, Revision 0 Nuclear Production Department Procedure NO. 1.5, Safety Review Committee (SRC), Revision 3 MP&L Safety Review Committee Training /In-doctrination Manual, January 1986 Grand Gulf Nuclear Station SRC meeting minutes from January 13, 1984 (Meeting 84-1) to May 20, 1986 (Meeting 86-10)

The Charter for the GGNS SRC is contained in TS Section 6.5.2. The SRC is a standing committee composed of members who are MP&L management and super-visory personnel, a representative from Middle South Services, Inc., and consultants to MP&L. The structure of the SRC is in accordance with licensee commitments delineated in ANSI 18.7-1976, paragraph 4.3.2.

The inspector conducted interviews with the Chairman and Vice Chairman of the SRC and other SRC members to ascertain the conduct of operations of the SRC. The inspector determined that two SRC Standing Subcommittees have been established with review responsibilities for the following:

Subcommittee 1 Safety Evaluations performed under the requirements of 10 CFR 50.59 Plant Safety Review Committee (PSRC) meeting minutes and reports Subcommittee 2 Corrective Action Requests (CARS) Closecut Notifications

.ievisions to the QA Master Audit Plan QA Audit Program Plan and quarterly Audit Schedule and change thereto The subcommittees are staffed by personnel who are SRC full committee member The subcommittees meet as frequently as required to discharge their responsibilities; a minimum schedule of once every six months has been established. Written reports of reviews conducted by the subcommittees are

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prepared and presented to the SRC full committee for discussion and/or closure.

The inspector reviewed the SRC meeting minutes for the period January 3, 1984 to May 20, 1986 and verified that the scope of activities reviewed were consistent with the requirement of TS Section 6.5.2.7.

The meeting schedule of the SRC is delineated in TS Section 6.5.2.5 which requires the SRC to meet at least once per calendar quarter during initial year of unit operation and at least once per six months thereafter. Based on the review of the SRC meeting minutes, the inspector verified that the TS schedule for SRC full committee meetings were me Tell committee SRC meetings are presently conducted once every two months.

Discussions were conducted with corporate office QA personnel to ascertain the interface requirements with the SRC with regards to TS Section 6.5.2.8.

The inspector verified that QA audit reports, QA audit schedules, and Corrective Action Requests Closecut Notifications were provided to the SRC.

The following documents were reviewed in connection with this effort:

Memorandum to Mr. John Fowler, Secretary SRC, from S. M. Fieth, Director, QA, Subject: Last Quarter 1985 Scheduled / Completed Audits, Scheduled Audits for First Quarter 1986, and the 1986 Audit Program Plan, dated February 4, 1986 Memorandum to Mr. John Fowler, Secretary SRC, from S. M. Fieth, Director, QA, Subject: Completed Audits for First Quarter 1986 and Scheduled Audits for Second Quarter 1986, dated May 14, 1986 Corrective Action Requests / Audit Logs transmitted to SRC/PST.C/NPE-0AS from QA covering period from September 10, 1985, to June 11, 1986 Monthly Memorandum to Mr. J. G. Cesare, Secretary, SRC, from W. E. Edge, Manager, Programs QA, Subject: Monthly Transmittal of Audits for Review for period covering May 1, 1985, to July 1, 1985 Based on the scheduled audits for the second quarter of 1986 that was presented to the SRC, the inspector selectively determined that the following audits are scheduled to be performed for the next SRC meeting on July 16, 198 Audit # PROC-86/01 Audit Date: 6/2-13/86 Audit Subject: Internal Procurement Activities Audit #MSRC-86-01 Audit Date: 5/27-6/9/86 Audit Subject: Safety Review Activities Audit #BSGA-86/01

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Audit Date: 6/17-20/86 Audit Subject: Bechtel Power Corp. Gaithersburg, MD. Engineering Services i

Audit # GASS-86/01 Audit Date: 6/16/86 Audit Subject: Gasser Associates, Olney, MD, Quality Services Pursuant to the review of the implementation cf TS Section 6.5.2.8, wherein audits are conducted under the cognizance of the SRC, it appears that a closed loop management control system for identification and correction of problems has been established by MP&L management.

The licensee conducted an assessment of SRC activities which is documented in Report No. 0A-85/010 dated April 4,1985. This report assessed SRC activities defined in TS Sections 6.5.2.7 and 6.5.2.8 against two NRC Inspection Reports of the performance appraisal of two operating plants.

Twelve recommendations were generated as a result to enhance and strengthen some SRC activities. The inspector was informed that one program enhance-ment recommended was the requirement fcr SRC members to participate in the conduct of audits. It was the inspector's understanding that SRC members would participate as observers but not as members of the audit team. MP&L's management stated that the intent was to provide SRC members with some knowledge of the audit process.

Management's involvement in ensuring quality was further demonstrated by the structured and documented training program for SRC members. This training program had a required reading list and another requirement that SRC members be certified before participating in SRC activities.

At the exit interview, the inspector referred to MP&L's menorandum PMI-85/11382 from 0. D. Kingsley, Chairman, SRC, Subject: SRC Meeting Format. This memorandum stated that in attempting to make the SRC meetings more meaningful, less reliance would be placed on the review of written naterials and more on oral report The inspector cautioned against excessive use of oral repcrts that could result in the lack of objective r evidence of activities affecting quality. Licensee management was receptive to this caution and affirmed that SRC activities would be capable of verification by examination of evidence.

Within this area, no violations or devictions were identifie ._ __-