IR 05000416/1986022

Insp Repts 50-416/86-22 & 50-417/86-02 on 860728-0801.No Violation or Deviation Noted.Major Areas Inspected:Licensee Actions on Previous Enforcement Matters & Licensee Mgt of QA Activities

ML20214M795
Person / Time
Site:	Grand Gulf
Issue date:	08/26/1986
From:	Belisle G, Russell Gibbs, Jackson L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20214M780	List: IR 05000416/1986022 ML20214M779
References
50-416-86-22, 50-417-86-02, 50-417-86-2, NUDOCS 8609110283
Download: ML20214M795 (6)

Text

. h UNITED STATES

. [ Kf4 'o . NUCLEAR REGULATORY COMMISSION

[- n REGION ll

$ j 101 MARIETTA STREET, '*

't ATLANTA, GEORGI A 3G323

\...../

Report Nos.: 50-416/86-22 and 50-417/86-02

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Licensee: Mississippi Power and Light Company Jackson, MS 39205 Docket Nos.: 50-416 and 50-417 License Nos.: NPF-29 and CPPR-119

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Facility Name: Grand Gulf 1 and 2 Inspection Cond ted- July 28, - August 1, 1986 Inspectors: 8-85-8b L. H. J g kson Date Signed A% AA R. D.'Gibbs adec Dath Signed Approved by: k,d.[wh B!24 !S4 G. A. Belisle, # ting Section Chief Date Signed Division of Reac' tor Safety SUMMARY'

Scope: This routine, unannounced inspection was conducted in the areas of licensee actions on previous enforcement matters and -licensee . management of QA activitie Results: No violations or deviations were identifie '

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s 8609110283 860828 PDR ADOCK 05000416 G PDR

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REPORT DETAILS 1. - Persons Contacted Licensee Employees

• J., Bailey, Compliance Coordinator C. Burgess, Programs Quality Assurance (QA) Supervisor D. Canazaro, Acting Manager, QA Audits J. Cross, Site Manager

• L. Daughtery, Compliance Superintendent W. Edge, Manager, QA Programs

• Ellis, Security Superintendent '

S. Feith, Director, QA

• A. Grace, Security Training Supervisor J. Reeves, Manager, Supplier Audits

• R. Rogers, Project Manager

• S. Tanner, Manager, Nuclear Site QA

• M. Wright, Manager, Plant Support NRC Resident Inspectors

• R. Butcher

• W. Smith

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• Attended exit interview Exit Interview The inspection scope and findings were summarized on August 1,1986, .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 comments were received from the license Unresolved Item 50-416/86-22-01: Timeliness of Corrective Action, paragraph 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 (50-416/84-48-01): Failure to Implement Adequate Corrective Actio The licensee response dated April 26, 1985, was considered acceptable to Region II. The inspector reviewed Quality Control Instruction #0715T Rev.11, and verified that paragraph 6.1.19.3, requires the inspector to verify that Charpy Impact Test requirements have been met in accordance with

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Specification C-151.0 and ASME Section III NE2300. Specification C-15 and drawing C-2004 were also reviewed by the inspector and it was confirmed that closure plate materials are not required to be impact tested. 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 problem Corrective actions stated in the licensee response have been impler.iente . Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviations. One new unresolved item identified during this inspection is discussed in paragraph . Licensee fianagement of QA Activities (350608)

This inspection was conducted to provide a routine review of the corporate quality assurance (QA) organization and their functions. This was performed by conducting interviews with QA management, observation of activities in process, and a review of documentatio Program Change On June 10, 1983, Mississippi Power and Light Company (MP&L) submitted a QA program update as required by 10 CFR 50.55(f) for changes to the Preliminary Safety Analysis Report (PSAR) Section 17.1, Quality Assurance During Design and Constructio The NRC accepted the June 10, 1983 submittal with additional clarification by letter dated May 9, 1984. Unit 2 Construction activities are essentially stopped

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except for minimum preventive maintenance activities on critical equipmen The licensee stated that measures would be established to inspect / refurbish equipment and establish necessary controls if construction is reinitiated. The final decision concerning Unit 2 status is scheduled to'be made by the end of 198 Unit 1 and 2 QA activities have been combined and are located on site, under the supervision of the Director of QA (DQA).

The inspectors reviewed the following QA procedures and verified that changes were approved at appropriate management levels and that document control requirements have been met:

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Procedure Title Revision NSL 3.11 Administrative Procedure Reporting of R2 Defects and Deficiencies - Safety Related PEP-2 Interface of 10 CFR 50.55(e) and 10 CFR R1 Part 21 b. Licensee Reviews of QA Program Effectiveness The inspectors verified that the licensee has regularly reviewed the status and adequacy of the QA program. To determine this, the inspectors reviewed the audit program and the following:

QA Semi-Annual Status Reports to Management by DQA for July 1985 -

December 1985 and Draft July 198 The criteria used to evaluate QA Program effectiveness is consistent with 10 CFR 50 Appendix B, Criterion XVIII, Audits. The reports also include evaluations and recommendations based on general engineering practice and good judgement. The procedural requirements are stated in general terms consistent with 10 CFR 50, Appendix B, Criterion XVII Discussions with the Manager of QA Programs (MQA) indicated that the effectiveness of the QA program is also evaluated by audits by Middle South Services, Inc. (MSS). Followup of audit findings is required and is being implemente c. Corporate QA-Site QA Interface The site QA staff conducts the routine and corporate audits and eval-uates the corrective action requests (CARS). Feedback from CARS, material nonconformance reports (MNCRs), production quality deficiency reports (PQDRs) is supplied to Corporate QA personnel who are respon-sible for trendin The inspectors reviewed the QA trend analysis report for the first quarter of 1986, the draft QA trend analysis report for the second quarter of 1986, and a Monthly Presidents Performance Monitoring Report dated June 1986. These reports confirmed that there are a large number of open MNCRs and a significant number (approximately 265) have been open for more than one year. This is also discussed in paragraph d. Design Assurance Responsibility The objective of this inspection was to determine the licensee / Architects Engineer (AE) organizational responsibilities for design assurance. The inspectors reviewed the MP&L's ?anization to understand the internal and external interfaces for dAsign contro The inspectors determined that MP&L Grand Gulf Nuclear Station (GGNS)

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PSAR Section 18 requires the licensee to audit.Bechtel (AE/ Constructor)

at least annually to evaluate the effectiveness of the design assurance activities performed by Bechtel. The primary means of determining the effectiveness and acceptability of AE design assurance activities is by MP&L's auditin Design Audits for Construction on Unit 2 have been stopped pending a construction decision scheduled for December 1986. Design assurance responsibilities were not reviewed during this inspectio Audits The inspectors reviewed MP&L's- QA program documents, audit procedures, and records. This review verified that the QA program encompasses internal and external organizations and functions within a reasonable time period. ~ The QA staff is sufficient in number to effectively conduct planned audit QA procedures provide measures for conducting audits, review of corrective actions, audit team size and composition, use of specialists from other organizations, auditor tracking and followup of inspection findings, and reporting audit findings to upper management. The inspectors reviewed the following audits:

Monitoring Audit Report (MAR) 85/0028 Monitoring Audit Report (MAR) 86/0013 Audit BWR0G 85-01 Audit of Bechtel (Gaithersburg) BCGA 85/01 Nonconformance Control During a Review of the Quality Assurance Directors Semi-Annual Status Report to Management (December 1985) licensee QA personnel identified a significant problem. The report discussed the large number of open (MNCRs) and addi-tionally, addressed concerns over the length of time that these deficiencies had been outstanding. At that time there were 664 open MNCRs of which 267 had been open for over a year. The report recommended establishing an MNCR task force to work on this problem. Additional investigation into this area by the NRC inspectors revealed that the MNCR task force had been established and had initiated several actions, including streamlining of deficiency reporting site procedures, to reduce the number of outstanding MNCR However, the inspectors review of the numbers of outstanding MNCRs as of July 21, 1986, noted virtually no improvement (657 MNCRs open and 254 open for more than a year). The inspectors reviewed the following MNCRs and CARS in order to verify the existence of an effective corrective action system for identified deficiencies:

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MNCRs CARS 071-83 2232 010-86 2228 0140-84 2211 0798-83 2233 0107-85 2213 0630-85 2170 0629-84 2203 0298-84 0896-83 0865-83 0854-83 0844-83 (Ref. LER 83-141)

0825-84 0826-84 0827-84 0828-84 0829-84 0830-84 0831-84 The inspectors did not identify deficiencies with CAR However, reviewing the open MNCRs raised additional concerns over the large number of open deficiencies requiring "as built" drawing revisions to match existing hardware and a significant number of MNCRs reporting hardware deficiencies in the fire protection are All of these concerns were discussed with senior management at the site and verbal commitments were obtained to reduce the total numbers of outstanding MNCRs and correct all of the fire protection deficiencies and as built drawing problems by the end of the first refueling outage scheduled to start in September of this yea This problem involving the large number of outstanding MNCRs is being identified as an unresolved item 416/86-22-01, Tineliness of Corrective Action, until management implements corrective actions during the refueling outage.