IR 05000416/1986025
| ML20213G578 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 11/06/1986 |
| From: | Julian C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20213G569 | List: |
| References | |
| 50-416-86-25, NUDOCS 8611180208 | |
| Download: ML20213G578 (38) | |
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3 Kfc UNITED STATES
/ oq'o NUCLEAR REGULATORY COMMISSION
[ REGION li g j 101 MARIETTA STREET, * 2 ATLANTA. GEORGI A 30323
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Report No.: 50-416/86-25 Licensee: Mississippi Power and Light Company Jackson, MS 39205 Docket No.: 50-416 License N NPF-29 Facility Name: Grand Gulf -
i Inspection Conducted: August 25-29 and September 8-12, 1986 Inspectors:
M. F. Runyan b* b *
U f5,~ /A ///8/N Oate Signed
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C. F. Smith
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/ Datie Signed
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\ C A- %da kw L. R. Mooreu W6/si
'Dat'e Signed
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Approved by: b' '
G. A. Belisle, ection Chief H b M [ 86
~ 4atd Signed
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Divistor of Reactor Safety
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SUMMARY Scope: This routine, announced inspection was, conducted in the areas of licensee
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actions on previous enforcement matters, the effectiveness of quality
! assurance on site, and licensee actions on previously identified inspection finding Results: No violations or deviations were identified.
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i 8611180208 861106 PDR ADOCK 05000416 G PDR
.-- _ __ _ _ ... _ ___ .______. ..._.___ _ , .._________ _ __. ..._.. _ .. _ _ ...-_ _ _ ._ .._._ _ _ . T E REPORT DETAILS Persons Contacted Licensee Employees
- W. Angle, Manager, Operational Analysis Section (OAS)
- J. Bailey, Compliance Coordinator M. Bakarich, Records and Material Support T. Barnett, Electrical Engineer, Nuclear Plant Engineering (NPE) I
- K. Black, Engineering Supervisor R. Brinkman, Radiological Engineer J. Buller, Engineer, OAS L. Burgess, Quality Assurance (QA)
R. Byrd, Licensing Engineer G. Ceaser, Manager, Nuclear Licensing T. Cloninger, Vice President, Nuclear Engineering and Support
- J. Cross, Plant Manager D. Cupstid, Technical Support Superintendent (Acting)
- L. Daughtery, Compliance Superintendent
- W. Eiff, Principal Quality Engineer, NPE
- A. Elfotouh, Assistant Engineer
- S. Feith, Director, QA G. Guimbellot, Maintenance Engineer W. Harris, Compliance Coordinator J. Henderson, Shift Technical Advisor B. Higgins, Lead Planner, Instrument and Control
- S. Hutchins, Principal Electrical Engineer
- C. Hutchinson, General Manager
- W. Iliff, Staff Consultant
- B. Jana, Engineer
- M. Johnson, Supervisor, Engineering Services
- E. Jung, Project Engineer -
0. Kingsley, Vice President, Nuclear Operations M. Krupa, Scheduling Superintendent
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A. Malone, Inservice Inspection (ISI) Coordinator l A. McCurdy, Manager Operations
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- R. Moomaw, Manager, Maintenance (Acting)
J. Muller, Mechanical Superintendent D. Pace, OAS V. Parrish, Superintendent, Chemistry / Radiological Controls
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- G. Payton, Engineer I #J. Reaves, Manager, QA Audits
- J. Robertson, Plant Licensing
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- S. Tanner, Manager, Nuclear Site QA
- F. Titus, Director, NPE
- D. Wiles, Electrical Engineer G. Zinke, Performance Engineer Group
- Attended exit meeting on August 29, 1986
- Attended exit meeting on September 12, 1986
Other licensee employees contacted included office personne NRC Resident Inspectors
- R. Butcher, Senior Resident Inspector
- W. Smith, Resident Inspector Exit Interview The inspection scope and findings were summarized on August 29 a September 12, 1986, with those persons indicated in the paragraph abov The inspector described the areas inspected and discussed in detail the inspection finding 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) Unresolved Item (416/85-27-02): Evaluations of Installed Process Instruments This item is closed based on the use of instrument failure reports to assess the overall impact of an out-of-tolerance condition on previously accepted Technical Specification (TS) surveillance and ISI test results.
l Unresolved Items l
l Unresolved items were not identified during the inspection.
l l General Background The intent of this inspection was to assess Mississippi Power and Light's i (MP&L) quality assurance effectiveness. For the purposes of this inspection, quality assurance effectiveness is being defined as the ability of the licensee to identify and correct their own problem The term I quality assurance effectiveress is used in this application, but it is not meant to be limited to the licensee's Quality Assurance Department or the Quality Assurance Program. Those elements are part of a broader focus on the licensee's commitment to quality. Other elements include all personnel, procedures, polices, training, attitudes, etc.
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The premise of this inspection was that the overall intent of quality assurance is to ensure safe and reliable operations and that the ultimate effectiveness of the licensee's program to ensure quality can be measured objectively by examining various operational performance indicators. An increase in the number or severity of licensee event reports (LER), a decline in the availability of safety systems, or an increase in the number of reactor trips, for example, indicates a problem in the licensee's program to ensure qualit It indicates, irrespective of compliance to regulatory requirements, an area where quality assurance is ineffectiv This inspection, therefore, was performance - based rather than compliance -
base In the past, the " bottom line" during inspections was whether regulatory requirements were being met. The " bottom line" during this inspection was whether the intent of the requirements is being achieve The primary information used during this inspection was the last 12 monthly Management Information Program Reports as referenced in Nuclear Production Department (NPD) Procedure 1.7. These reports track the progress of 37 performance indicators, selected by the licensee from recommendations provided by the Institute of Nuclear Power Operations (INP0). The inspectors selected 15 of the 37 performance indicators on the basis of importance to safety and functional correspondence to the 17 performance indicators recently chosen for NRC's performance indicator trial progra Each of the 15 selected performance indicators were examined for absolute value, significant trends, and relationship to the licensee's established goal This was followed by as assessment of management responses and a review of the adequacy and completion of corrective measures taken to improve performanc Information was requested by the NRC in correspondence dated August 1, 198 The following information was received and reviewed prior to this inspection:
Copies of all audits (which required a written Corrective Action Request) conducted by Quality Assurance Department personnel started or completed from May 1, 1985, to May 1, 1986. Audit checklists need not be include Copies of 20 audits where findings were identified but for which a Corrective Action Request was not required to be writte Copies of the last two Semi-Annual Status Reports to Senior Managemen Copies of the last four Quarterly Trend Report The above information supplemented the assessment of quality assurance effectivenes In the following paragraph, each of the 15 selected performance indicators is discussed in detail. Graphics for the indicators are provided in an attachment to this repor . _ - . .
6.0 Performance Indicators 6.1 Forced Outage Rate (Indicator #1)
Forced outage rate is the percentage of time planned for electrical generation that the unit was unavailable due to forced events. Directly, this indicator does not have a bearing on plant safety and is of greater interest to the licensee from the standpoint of ef ficiency and return on capita However, the forced outage rate indicates the quality of the licensee's preventive maintenance program, planning effectiveness, training,
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procurement, and other areas. All of these areas have a direct impact on safety. A unit that is consistently forced into outages is more likely to suffer failures of systems important to safety during abnormal transient Since so many various incidents and conditions contribute to this indicator, forced outage rate is one of the better indicators of overall quality assurance effectiveness.
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The 1986 Nuclear Production Department (NPD) goal is that the forced outage
rate remains below 10 percen Through the end of July 1986, the 1 year-to-date forced outage rate was approximately 9.5 percent. The forced
- outage rate peaked in February, March, and April at 17.5, 18.6, 15.3 percent respectively. A 104 day continuous run ended with a 43.8 hour9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br /> shutdown in Jul Forced outages occurring during the months of February, March, and
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April were caused primarily by personnel errors and maintenance
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nonconformances. Corrective actions for these problems are discussed in part. graphs 6.10 and 6.13. The licensee had not formulated specific corrective action programs to lower the forced outage rate because such efforts would fall under other, more specific, indicator The current
? forced outage rate represents average quality assurance performanc .2 Unplanned Reactor Trips While Critical (Indicator #2)
Unplanned reactor trips while critical is defined as by the licensee as reactor trips that occur while the reactor mode selector switch in the control room is in position 1 or It does not include manual reactor trips inserted by an operator anticipating an imminent automatic reactor tri This indicator provides a good measure of the effectiveness of the licensee's training program, operations and maintenance procedures, design
- control, personnel, management, procurement, and corrective action progra The 1986 NPD goal is less than 6 unplanned reactor trips. At the time of the exit meeting, five unplanned reactor trips had occurred in 1986. The chances of meeting this goal are enhanced by a planned two month outage beginning in September. Two of the five trips in 1986 were attributed to personnel error, and the other three were a combination of personnel error and equipment failure.
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The licensee has implemented a Scram (trip) Reduction Program (SRP) to
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anticipate and prevent probable unplanned reactor trips, to track corrective -
actions, and to preclude recurrence of unplanned reactor trips that have
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occurre The program has been in effect for approximately 18 months and some reduction in scrams has occurred. There were 13 unplanned reactor trips in 1985 and 5, to date, in 1986. However, this profile may be typical for a new plant such as Grand Gulf, which began commercial operation in July 198 To evaluate the true effectiveness of the SRP, at least one additional year of da'ta will be necessary. One positive observation is that none of the 1985 scrams have been repeated in 198 The SRP is not a formal program, to date, in that it is not proceduralize However, the inspector reviewed program documents and determined that the program appears to address the full scope of the issue and that it is being implemented effectively. This program assesses inputs from a wide range of sources on a continuing basis for potential recurring or generic impac Plant specific events are critiqued in detail and include a root cause analysis. Corrective actions are tracked as action items with completion dates and assigned priorities. The data format provides the capability to trend the root cause of the problem for repetitio The licensee participates in quarterly meetings of Boiling Water Roactor (BWR) owners to discuss scram frequency reductio Each licensee reviews scram reports from other licensees and exchanges information of mutual interes This information will be incorporated into the SRP.
i The inspector reviewed the following post-trip analysis reports to assess the overall adequacy of root cause analysis and proposed corrective action:
Scram N Date of Scram 19 07/03/85 30 08/07/85 31 08/22/85 32 09/16/85 35 12/31/85 36 01/01/86 37 1/22/86 38 02/12/86 40 04/07/86 In all cases, both the on-shif t and off-shif t analysis of root cause appeared comprehensive and justifiable. Short and long term corrective action was prescribed and appeared to address items of both immediate concern and broad generic issues. The OAS group was currently verifying and obtaining status on corrective actions prescribed by the post-trip analysis reports from Scram No. 1 to the presen The licensing group maintains tracking responsibility for LER commitments for corrective action. Based on the inspectors review, it appeared that corrective actions were being tracked to successful completion in a prompt manne The ISEG (Independent Safety Evaluation Group) division of QAS performs
, retrospective post-trip analysis report review The inspector discussed this function with ISEG personnel and reviewed their analysis for Scram No. 19. This review apparently met its intended functio . __ _ _ _ - - . __ _,
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There appears to be a positive feedback loop to utilize scram events experience in the operator training program. 0AS recently complied a compendium of unexpected system performances, most of which involved scrams, for use in the operator training progra The majority of scrams were caused by operator error, inadequate procedures, and design deficiencie The inspector determined that that licensee was taking adequate corrective measures to improve training, upgrade procedures, and implement design changes to improve the reliability of the plan However, the true effectiveness of these measures will be evident by the frequency of scrams that occur in the futur .3 Unplanned Saf ety System Challenges (Indicator #3)
Unplanned safety system challenges are defined in the licensee's trending program as events or conditions resulting in actuation of High Pressure Core Spray (HPCS), Low Pressure Core Spray (LPCS), Low Pressure Coolant Injection (LPCI), or Emergency Power Diesels. This indicator provides a good measure of the effectiveness of the licensee's preventive maintenance program, surveillance testing program, procedure adequacy, personnel training, and corrective action progra The 1986 NPD goal is less than three challenges per system per yea To date in 1986, there had not been any challenges to these systems. In the period from August 1985 to July 1986, two challenges occurred, both in December 1985. One (LER 85-48) involved an event in which a tree cut down by pulpwood cutters fell on a primary transmission lin This ultimately resulted in an emergency diesel start. The other (LER 85-50) occurred when HPCS was manually initiated to restore reactor level when the condensate and feedwater pumps tripped during maintenance to the intermediate hotwell level indicato The HPCS injection valve failed to ape Also, during troubleshooting efforts to determine the cause of the HPCS injection valve failure, the HPCS diesel generator automatically started. The cause of this incident was primarily, equipment failure, and secondarily, personnel erro The inspector reviewed the corrective action implementation committed to in LER 85-50. Design Change Package (DCP) 86/0012 is intended to enhance the reliability of hotwell instrumentation. This DCP has been scheduled to be performed during RF01 (Refueling Outage No. 1). Alarm Response Instruction 04-1-02-1H13-P680 was revised to ensure that hotwell level is restored manually whenever an intermediate condenser hotwell low level alarm occur The failed Agastat (Model CR0095) relay base, which caused the HPCS injection valve failure, was replaced with a model CR0002 relay base in accordance with a 10 CFR 21 commitmen In response to the HPCS diesel generator start, the licensee stated in the LER that Plant Procedure 01-5-07-1, Control of Work on Plant Equipment and Facilities, would be revised to add additional guidance on the development of work package impact statement Though the expected issue date was May 1, 1986, the revised procedure was still in draft as of September 12, 198 Although this was not a critical element of the corrective action plan, it was an example of imprecision of the licensee's corrective action syste . - _ - - - _ - -
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The inspector noted that the following six actuations of safety systems occurred in 1986 and were not trended in the management report:
LER Description 86-07 Inadvertent Residual Heat Removal Pump Start 86-10 Inadvertent Isolation of Primary and Secondary Containment 8C-11 Inadvertent Lifting of a Safety Relief Valve 86-12 Shutdown Cooling Isolation 86-13 Inadvertent Actuation of Control Room Standby Fresh Air Unit 86-17 Inadvertent Actuation of the Combustible Gas Control System The following is a breakdown of the causes for these events:
LER Cause 86-07 Technician connected test switch to the wrong terminal Inadequate independent verification 86-10 Field engineer inadvertently bumped power switch 86-11 Work performed without approved procedures 86-12 Failed Agastat relay 86-13 Unpredictable voltage spike during trouble-shooting efforts 86-17 Removal of wrong fuse The primary cause for these unintended safety system actuations has been personnel error. The licensee's corrective action for these events in this area are discussed in paragraph 6.10. Other corrective actions are detailed in the LERs. The inspector selected three of the above LERs to determine whether the supplemental corrective action committed to by the licensee had been completed and whether the intended corrective action was adequate in scope. For LERs 8G-I t , 86'13, and 86-17, the licensee provided adequate documentation to pro. .de reasonable assurance that all stated corrective action measures had either been completed, or were bring tracked with
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unexpired deadline dates. In all cases, the corrective action appeared adequate in scope, addressing both specific and generic concern As an overall assessment in this area, the frequency of safety system actuations is well within stated goals and represents high quality performance. Corrective actions for each incident appear comprehensiv Corrective actions are also completed in reasonable time frame __ . _ _ _ _ _ _ _ . _ - -_ - _ _ _ _ _ _ . . _ _ _ _ _ . _ _ _ _ . - - _ _ _ _ _ _ _ _ _ _ _ . . - - - _ - - - - -
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6.4 Safety System Unavailability (Indicator #4)
Safety system unavailability is defined by the licensee as the percentage of unavailable hours for emergency diesel generators, Reactor Core Isolation Cooling (RCIC), and HPCS. This indicator provides a good measure of the effectiveness of the licensee's preventive maintenance program, corrective maintenance, procurement, and design contro The 1986 NPD goal is less than one percent unavailability for each safety syste Through the first seven months of 1986, RCIC had been unavailable approximately 2.0 percent of the time, HPCS for approximately 1.1 percent, emergency power diesel division 1 for 1.0 percent, and emergency power diesel division 2 for 0.3 percen The inspector's effort in this area was focused on the RCIC system which had been unavailable at a rate approximately twice the stated goa The following is the RCIC maintenance history for 1986:
Month Length of Unavailability Reason March 1.5 hr RCIC turbine trip April 45 hr Minimum flow valve 34.7 hr Trip throttle valve May 24 hr Flow indicator July 5.8 hr Bypass line valve bypass Corrective action has generally been to fix the broken component, but some efforts have been taken from a more programmatic standpoint. The inspector was informed by the plant manager that RCIC reliability has received the attention of top level management and that ways to improve RCIC performance have been discussed. This feedback from the performance indicator to a plan for corrective action is a highly positive sign that the performance indicators are being used as an effective management tool. Management's assessment of the RCIC reliability question concluded that three major factors had contributed to its increased unavailabilit First, extensive preventive maintenance necessitated some unavailability. Second, corrective maintenance on throttle linkages and other associated components had caused a large amount of down time. Third, there existed an excessive time lag between the time that a Maintenance Work Order (MWO) was completed and the Operations Department declared the system operable. A memorandum was issued to the ef fect of lessening this time perio During the 1986 refueling outage, a modification is planned for the RCIC warm-up bypass line valve which was leaking and was the cause for the hour unavailability in July. This is an open-ended modification to replace the valve with a more suitable valve. This may be an example where a design j error directly affected a performance indicator.
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The RCIC system was recently the focus of a major QA appraisal which was termed an operations readiness assessment and was issued February 21, 198 Unlike typical QA audits, this effort was technical in nature and identified concerns in the areas of maintenance, operations, design changes, QA, and training. Several problem areas had a direct impact on system availabilit Corrective Action Request (CAR) 2214 identified that inadequate attention was being given to evaluating the cause of system malfunctions. The root cause of this deficiency was that the plant had two procedures, 01-5-01-1, Control of Work on Plant Equipment and Facilities, and 01-5-07-30, Evaluation of Component Malfunction, which collectively complied with ANSI N18.7-1976 requirements but were not administratively linke As a result of corrective action, Procedure 01-5-07-1 will be revised to administratively link the two procedures and require each MWO to be screened to determine if a component malfunction analysis is neede The RCIC report identified a weakness in the area of maintenance trending, specifically that the Maintenance History System (MHS) was not being fully utilized to trend maintenance history as a tool for refining preventive maintenance schedules. The inspector discussed this issue and observed MHS usage. The inspector concluded that MHS is not currently used to enhance equipment reliability, track or trend repetitive failures, or predict maintenance. With the purchase of new software and the establishment of an interface with the Nuclear Plant Reliability Data System (NPROS), MHS utilization is scheduled to be enhanced. These efforts and increased awareness of system capabilities should ensure that MHS is fully utilized in the near futur The inspector reviewed the current NPRDS status and concluded that this system is being utilized to enhance equipment reliability by tracking and trending repetitive failures. NPRDS is being used to perform periodic routine system checks. Currently, an evaluation of HPCS is in progress, in which all associated limiting conditions for operation (LCO), maintenance nonconformances (MNCR), surveillance tests, incident reports, LERs, and MW0s issued during the study period are being analyzed for system reliability consequences. This effort is voluntary in nature and is not a response to a perceived problem with HPCS, but is rather a preventive measure that displays an advanced approach to Q The low pressure safety systems, Low Pressure Core Spray (LPCS) and Low Pressure Coolant Injection / Residual Heat Removal (LPCI/RHR), were not trended within this performance indicato The inspector performed a cursory review of LCO reports to determine whether significant availability problems existed with these systems. Based on the review, the LPCS system appeared highly reliabl However, numerous problems had occurred with LPCI/RHR, including line breaks, loose bolts, valve leakage, and failed relay A detailed followup of this issue was beyond the scope of this inspection but may be included in future inspections of this typ . s
As an overall assessment of this area, it appears that quality assurance effectiveness in assuring safety system availability and reliability is average to good. It is reasonable to expect that the positive attitude toward quality and improved utilization of MHS and NPRDS will result in improved availability of safety systems in the futur .5. Licensee Event Reports (Indicator #9)
Problems identified via operational events were documented and evaluated in incident reports (IR) or licensee event reports (LER). Guidance for this program was provided by Administrative Procedure 01-5-06-5, Incident Report / Reportable Events, Revision 14, and Compliance Section Procedure 09-5-03-2, Incident Reports / Reportable Events, Revision 6. Incident reports were initially reviewed by the Compliance section to determine reportability and responsibility for evaluatio Evaluations could be assigned to the plant staff or 0AS personne irs and LERs are tracked and closed by compliance. Following evaluation by the responsible organization, the IR/LER is reviewed by OA AS additionally reviews the reports for repetitive events or trend indications and from this analysis make specific corrective action recommendations for identified problem These recommenda-tions require a response trom the responsible organization within a given time period. 0AS trending provides information to plant management as well as corrective action recommendation for identified problem The inspector reviewed a sample of recent LER The review encompassed event evaluation (root cause determination and corrective action),
corrective action tracking, and closecut documentation / verification. From this sample the inspector determined that an adequate review and tracking process was employed to identify and correct problems in this area. A concern identified by the inspector was the tendency to extend corrective action completion date Commitment dates were extended in cases of software changes as well as hardware change LER closecuts were based on completed and documented corrective action, assignment of maintenance nonconformance reports (MNCR), or initiation of a design change packag The corrective actions were then tracked under the program to which they were assigne The licensee demonstrated an adequate process for identification and correction of plant operational problems utilizing data provided by LERs and ir .6 Collective Radiation Exposure (Indicator #10)
Collective radiation exposure is defined by the licensee as the total amount of whole body radiation exposure received by all personnel at Grand Gul This indicator provides a measure of the effectiveness of management planning, personnel training, procurement and the availability of spare parts, and the quality of MWO procedure The 1986 NPD goal is less than 800 man-rem. Collective radiation exposure for 1986 through September 10 was 49.2 man-rem. The bulk of radiation exposure for 1986 will occur during the refueling outage which began September ..
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1 The inspector d!scussed the outage As Low As Reasonably Achievable (ALARA)
budget with the 3uperintendent of Chemistry /Radcon. Although the goal of 800 man-rem remains in effect, a large ISI weld inspection job was originally calculated to result in exposure beyond the goal. However, after careful reconsideration, it was determined that this job will result in only approximately 200 man .em and that total exposure for the year will fall in the range of 500-525 mar-re The quality assurance effectiveness implications of collective radiation exposure cannot be fully evaluated until final exposure results are known and the specific reasons for incurring greater or lesser quantities of radiation than reasonably expected are investigate L 6.7 Status of Licensing Commitments (Indicator #22)
This performance indicator in the Management Information Program System (MIPS) represented 30 day past due open commitments and unconfirmed closed commitments based on the Licensing Commitment Tracking System (LCTS) status of all NRC commitments. The July 1986 status indicated 17 past due commitment The inspector reviewed these overdue commitments and identified that the majority were met but that the documentation of ;
completed action was incomplete. Due to the above review, this indicator f appeared to be a measure of the speed of the administrative closure process !
rather than a measure of licensee performance in meeting commitment l The governing procedure for the LCTS, Nuclear Licensing and Safety
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Administrative Procedure 2.7, appeared to prov:de adequate controls for 4 monitoring the completion of licensee commitments. Particularly notable was tha requirement to provide monthly reports to management of open commitments
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designating responsible organizations. Maintaining management attention on open commitments provided a deterrent to overdue commitments. A less
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positive deterrent to overdue commitments was the tendency to extend
! commitment dates. As with LERS, extensions involved corrective actions in software as well as hardware. The inspector did not identify a formal l provision for escalation of overdue commitment items althcugh this function could be performed informally through management direction as a result of r
the monthly report previously discussed. The LCTS appearea to adequately provide the final mechanism in the identification and correction process, i.e. verification and closecut, for those items which have comreitment dates assigne ,
6.8 Maintenance Work Orders (Indicator #24)
MW0s were trended by MIPS with respect to quantit The volume decreased from a high of 2387 in October 1985 to the present level of 1238 for July 1 1986. This reduction was attributed to: (1) removal of component rework items, (2) administrative closeouts, (3) reevaluation of proposed work, t and (4) MWO activity as temporary alterations transferred to temporary alteration statu The projected plant goal of a maximum of 800 MW0s for 1986 had not been achieved. A substantial reduction in the number of MW0s
- was expected from the September 1986 refueling outage.
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Malfunctions of components were trended by NPE and Plant Staff. NPE trended malfunctions on the NPRDS utilizing INP0 guideline Trending on this system was done on an industry-wide scale. Trending information by plant staff was provided via the MHS and the MWO tracking system. The MHS provides a data base which planners can access for special notes on previous maintenance task problems or to expedite the planning process. This system aided planners in preventive maintenance scheduling but did not provide a trending function for corrective maintenanc The MWO tracking system provided the most useful information source for identifying maintenance work redundancy. This system provided a maintenance work data base for reviewing maintenance on specific components which would provide identification of redundant work. These indications could then be used to reschedule preventive maintenance or change operating procedures to increase equipment i reliabilit A weakness in the problem identification process was noted by the inspector i and addressed by site QA in a readiness assessment repor The inspector reviewed a sample of MW0s and identified inconsistent root cause analysis on 4 MW0s, thereby compromising the input to the MHS and MWO tracking data bases.
l The onsite QA staf f identified this weakness in the RCIC Operational
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Readiness Assessment performed from December 8,1985, to January 17, 198 Corrective Action Request (CAR) 2214 was issued to address this findin The response to this CAR identified that the cause of this problem was the inadequate link between the MWO program and the component malfunction program. As discussed .n paragraph 6.4, resolution of the CAR included a commitment to revise the associated procedures to link the twe programs and provide specific training to planners on these revisions. Additionally, the MWO procedure revision will require all MW0s to be screened to determine if component malfunction analysis is neede In conclusion, the plant possessed an effective mechanism for identifying and correcting problems within the MWO Program with the exception of the i identified weakness of the input to the trending and tracking systems.
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Resolution of CAR 2214 should correct this weakness and result in an ef fective process for the identification and correction of problems in the maintenance work are .9 Temporary Modification Status (Indicator #25)
Temporary modifications or alterations are trended via the MIPS for total
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number. The number of open temporary alterations at Grand Gulf was 74 which was beyond the goal of 40 for the plant. This number has remained near 60 or above for the previous 12 month period. Of the 74 open temporary
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alterations, 48 have been in place greater than one yea Although the majority of the alterations have been incorporated into DCPs, only four or five are scheduled for installation as permanent plant changes during the
- upcoming refueling outage. Review of temporary alteration safety reviews
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identified that not all alterations were safety relate Management i appeared to have effectively dispositioned incorporation of temporary alterations in accordance with importance to safety and constraints of time
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. and budge The number of alterations reflected by this performance MIPS indicator, which is a failure to meet plant goals, did not appear to indicate a compromise in plant quality effectiveness.
, Management awareness of temporary alterations was maintained via the Operations Superintenden In accordance with Plant Administrative Procedure (PAP) 01-S-06-3, Control of Temporary Alterations - Safety Related, Revision 18, responsible sections were required to submit either a i DCP number incorporating an alteration of justification for the continued installation of the alteration six months after initial installation.
- Additionally, a monthly report was submitted to the Plant Manager which i listed all temporary alterations over one year old. The procedure also required alterations to be physically inspected monthly by the shift superviso The requirements of the temporary alteration procedure, PAP 01-S-06-3, j appeared adequate for alteration control; however, the inspector was f concerned with the potential for these controls to be bypassed. Temporary
- modifications could be installed via an MWO by making a change per procedure of a MWO and permitting the work order to remain open. Discussion with management indicated that a recent effort to decrease outstanding MW0s
! resulted in transference of these maintenance alterations into the temporary alteration program. Management also indicated that although this practice of maintenance alterations was no longer employed, the potential remains for this applicatio The inspector's concern was that these maintenance alterations would be outside the reviews to which temporary alterations controlled by PAP 01-S-06-03 are subjec With the exception mentioned
- above, the licensee appeared to maintain ef fective program controls to
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ensure that installed temporary alterations did not compromise the quality of plant operation .10 Personnel Error Incident Reports (Indicator #33)
Personnel error incident reports were trended separately by the MIPS, Compliance, OAS, and the QA Quarterly Trend Analysis Report. Site personnel collect and transfer data to corporate personnel for assimilation and overview evaluation for the MIPS. The information in this program regarded primarily the volume of personnel errors. Monthly reports provided periodic updates on trends of this performance factor. For example, the January 1986 report identified a steady rate of two personnel error incident reports per month which would result in exceeding the plant goal of nine per year by Jul The April 1986 report indicted an all time high of five personnel error
! incident reports in a single mont The report stated that management
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expected this number to decrease because of reduced errors via the SRP. The
- July 1986 report indicated the total for the previous year to be 14 errors,
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which exceeded the yearly goal of The MIPS provided information to
- corporate management of performance in this area. Generally, direct
! corrective action does not result from this trending program; rather, management attention is focused on problem area __ __ _ _ . . . _ _ _ _ . _ _ _ _ . . _ _ . . _ _ . . _ _ _ . _ . . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ . _ . _ _ _ _ _ _ _ . _ _ _ . _-
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Trending by the Compliance group, QA, and 0AS was more detailed due to discrete breakdown of types of personnel errors and identification of t responsible groups. The Compliance trend analysis results were distributed onsite and reviewed at the plant staff weekly meetings. 0AS trended the ,
data for root cause identification after which corrective action was
recommende The most detailed trend analysis was performed by QA and results were evaluated and distributed in a QA quarterly trend report, Personnel errors in the analysis were broken down into 13 subgroups, which provided more adequate root cause determinatio These trend analysis programs supply information to various levels of corporate and site management on personnel error incident reports. The program provided an effective mechanism to identify problems in this area and the change in the trend could be utilized to determine the effectiveness of specific corrective action or increased management attention in problem areas.
I Management action from the negative trend in personnel errors was evident in Interplant Communication (IPC) 86/094 dated April 13, 1986, from the Plant Manager to all Grand Gulf Nuclear Station (GGNS) employees. The memorandum stated that personnel must understand that they are personally responsible and accountable for their action The inspector reviewed two incident reports which occurred subsequent to this communication which resulted in
, disciplinary action for personnel erro In one cas,e, a licensee employee was given two days off without pay and interviewed by management including a vice president. In the ather case, a contractor personnel error resulted in termination of the individual's contract. Additionally, this memorandum established a Management Review Group to evaluate each incident. The memorandum issued by the Plant Manager and subsequent disciplinary actions demonstrate a complete cycle of problem identification and corrective action necessary to maintain quality operation at Grand Gulf Nuclear Statio .11 Spare Parts Availability (Indicator #26)
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Spare parts availability is defined by the licensee as the ratio of part
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availability to part requiremen This indicator provided information concerning QA effectiveness regarding the procurement process and control of
- purchased material and equipment. A review of this indicator revealed that
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MP&L management has consistently exceeded the plant goal of 95 percent over a one year time spa The inspector conducted interviews with licensee management to ascertain the reason for this successful performance.
l Licensee management explained that success in exceeding plant goals for
! spare parts availability was due to several causes. A documented Inventory
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Control and Spare Parts Program had been developed and implemented at GGNS.
! A materials Specialist group had been assigned responsibility for determin-
! ing and evaluating spare parts requirements in addition to providing i
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information concerning maintenance and storage requirements for spare parts.
i Evaluation of spare parts requirements by the Material Specialist group is conducted in accordance with the following guidelines:
Effect on plant availability should equipment remain out of service while awaiting parts Equipment redundancy Cost effectiveness Equipment history Equipment service conditions Lead time for acquiring spare parts i
The use of a computerized Inventory Management System also provides MP&L management with a current and accurate spare parts inventory. The inspector was also informed by licensee personnel that materials procured for Unit 2, which are presently stored in the Unit 2 construction warehouse, are used to supplement the spare parts needs of Unit 1.
>
6.12 Design Change Status (Indicator #27)
i QA Trend Analysis Reports for the first and second quarters of 1986 identified problems in the design change program because of the number of change notices (CNs) issue The inspector conducted interviews with licensee management to ascertain the purpose for which the Design Change Status indicator is used, and to determine how licensee management identifies and corrects real or potential problems within the design change program.
- The Design Change Status indicator provided information concerning the
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number of design changes packages for which engineering design was still in progress; the number of design change packages for which engineering design was completed and which were issued for construction; and finally the number of design change packages that were identified for the current month. This indicator is used by MP&L to determi.1e the workload of Nuclear Plant
- Engineering and to allocate resource commitments.
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The QA Trend Analysis Report established the method for trending CNs i associated with DCPs in order to identify, report, and initiate corrective actions for deficiencies identified within the design change program. The
- QA Department, in the detailed evaluation of DCP CNs, assigned the following root causes for the issuance of CNs.
l The DCP was inadequate in some way that may require improvement in the areas of initiation:
Change the DCP due to an inadequate design Change the DCP to incorporate additional information omitted in
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the original DCP but is required for DCP completion Correction to wording / typo or drawing errors f
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The DCP was inadequate in some way that may require improvement in the areas of review /walkdown by either Plant Staff or Nuclear Plant Engineerin Incorrect part/ material called out by the DCP Wrong procedure or spec called out by the DCP Change DCP due to conflict during installation Change DCP because plant conditions in the DCP don't match actual plant conditions The DCP was adequate; however, these changes were made to facilitate work, add additional work, or due to changes in work scop Change DCP to allow additional work not affecting design
- Change DCP to enhance current design requirements Change DCP due to change in design scope The QA Trend Analysis Report for the second quarter of 1986 identified that 14.3 percent of the CNs were caused by inadequacies in the initiation of the DC A positive trend was identified, however, in that there was a reduction in documented DCP CNs over the first quarter of 1986. CNs issued because of inadequacies in the areas of review /walkdown by either NPE or i plant staff were 40.5 percent. Finally, 42.5 percent of the CNs issued were caused not by inadequacies in the DCP, but by other cause The Quality Engineering Section of NPE had also identified numerous deficiencies within the engineering design process. At the request of NPE, these self-identified deficiencies were documented by the QA organization to ensure initiation of corrective action within the CAR administrative controls. Further details concerning CARS written against NPE are described in paragraph 6.1 MP&L management had additionally identified problems with the engineering design services of its contractors. NPE held several meetings with General Electric (GE) management concerning the lack of quality and lack of attention to detail in GE designs. The need for GE design quality improvement was
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emphasize Deficiencies in the Bechtel engineering design services were also identifie In a meeting of MP&L management and Bechtel personnel on March 14, 1986, the following concerns were expressed by MP&L management:
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MP&L is concerned that original documentation may not be in a retrievable. format to support plant need MP&L is also concerned
- about the lack of personnel on the project with historical knowledg MP&L is a concerned that too many small errors are appearing in Bechtel issued designs. MP&L stressed the need for more attention to detail and the need to be meticulous in all aspects of design work. MP&L provided examples where problems occurred due to either no or inadequate walkdowns of the design. MP&L feels that walkdown performance needs to be improved. MP&L emphasized that quality cannot be sacrificed to meet schedule i
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s MP&L indicated, that there needs to be more . sensitivity to operatibnal considerations. Designs nave been issued 3sich caused operational difficulties during implementatio These, problems could have been avoided if more attention had been given to operational aspects,. MP&L indicated that to strengthen their o gadi:ation in this area, they will add two. Senior Reactor Operators (SR6) to the Engineering group to '
review designs for operational consideratio MP&L is concerned about the number of experienced people who have left ,
the project and its impact on continuity. They indicated their concern for various Unit 2 individuals who were not assigned to Unit 1 after suspension of Unit In response to the findings contained in the QA Quarterly Trend Ana fysis
, report, NPE will be instituting a' pilot program for trending CNs during the cycir 1 refueling outage. The intent of this pilot program is to establish a preliminary data base and more accurately define root causes for CNs. The inspector reviewed MP&L's memorandum NPEI-86/01598 and att'achment regarding this pilot program. Additional corrective action plans developed by NPE for implementation within the wtrk site control process include the fn11owing:
Enrollment O l' NPE personnel in the Shift Technical Advisor (STA)
training classe Enrollment of NPE personnel in systems operation training classe Appointment of an experienced SR0 to the NPE organization to provide expertise in evaluating DCPs, CNs, MNCRs for operattonal considerations, and preparing guidelines to be used by Nr! personnel *
during,the design proces Establishing the requirement for performing system walkdowns prior to designproce(sinitiationardpriortoimplementingaDC '
' Development of System Design Criteria (SDC), with 27 SDCs for selected nuclear safety related systems y;heduled to be coreleted by February 198 ._
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Upgrade and/or rewrite of NPE administ n tive procedure Corrective action plans developed by MP&L contractors included a GE document entitled, " Engineering Program for Improved Engineering Design Releases",
presented to MP&L's management on June 24, 1986. DCPs prepared by Bechtel are now being prepared in accordance with NPE administrative procedure ,
Requirements for the performance of Huards Review, Tire Hazards Analysis, '
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Nuclear Safety Evaluations, and Technical Specification applicability ~
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reviews during the design process are documented in .ha following letter and
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attachments:
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Bechtel Power Corporation letter from R. W. Jackson, Project Engineer, to Mr. F. W. Titus, Director, Nuclear Plant Engineering, Subject:
Middle South Energy Inc. Grand Gulf Nuclear Station Unit 1, Bechtel Job No. 15026, File: 0262/8011, Design Interface Meeting, MPB-85/0880 dated January 3, 198 Bechtel Power Corporation letter from R. W. Jackson, Project' Engineer, to Mr. F. W. Titus, Director, Nuclear Plant Engineering, Subject:
Middle South Energy Inc. Grand Gulf Nuclear Station Unit 1, Bechtet Job No. 15026, File: 0262/0280, Meeting Notes 86-04 of March 14, 1986, Meeting MPB-86/0224, dated March 25, 198 An assessment of the effectiveness of the implementation of the contractor's corrective action plans within the design interface controls was not performed by the inspecto The problems identified within the engineering design process are numerous and, of necessity, involve various scheduled dates for implementing corrective action plans within the worksite control proces Deficiencies which are documented and dispositioned via CARS are addressed in paragraph 6.14 . The inspector's assessment of lack of adherence to scheduled dates for deficiencies to be dispositioned via the CAR process is applicable to
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engineering design problem The inspector interviewed the SRO assigned to NPE to ascertain the status of the operational consideration program requirements used during the design process. The inspector determined that reviews of DCPs, CNs and MNCRs t have been performed by the SRO for the past six months. However, no guidelines have been prepared by the SRO for use by NPE personnel during the design process. Additional interviews were conducted with selected NPE engineers to ascertain the training provided to these individuals. Based on these interviews and a review of the training folders, the inspector determined that NPE has an ongoing training program for staff member Enhanced training such as STA and systems operation training have not been started, although engineers have been scheduled to attend the next clas At the exit interview MP&L management was informed of the delay in implementing corrective action plans regarding establishing operational guidelines and provisions for enhanced training to NPE engineers. The inspector stated that additional management attention is required in this are .13 Material Nonconformance Report Status (Indicator #28)
Material nonconformances (MNCRs) are defined by the licensee as deficiencies in characteristics, documentation, or procedures which render the safe use or safety-related material unacceptable or indeterminate. This definition includes items which do not meet design / procurement specifications or i contract specification . - . _ .. .
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! For deficiencies involving physical defects, acceptability test failures,
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incorrect or inadequate material documentation, or failure to comply with
'N prescribed manufacturing processing, inspection or test procedures are documentedo 'n an MNCR. The administrative controls for the MNCR process are intended to ensure that MNCRs are reported (if required), investigated, tracked, reviewed, and that corrective action is take Requirements have also been established for the periodic review of MNCRs to determine the cause of equipment malfunction and to detect trends adverse to
qualit The initial review and disposition of MNCRs are performed by an engineering organization. MNCRs dispositioned " accept-as-is" or " repair" are reviewed by Nuclear Plant Engineering (NPE) to verify conformance with
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. the original desig Indicator #28 shows that as of July 31, 1986, there were more than 650 open MNCR The inspector reviewed a computer printout, entitled, "Open MNCR Report," dated August 8, 1986, and determined that a total of 680 MNCRs were open as of that date. To further define the scope of activities required to close the open MNCRs, the inspector reviewed a computer printout dated September 10, 1986, which listed open MNCRs presently within NP Initial receipt date of tbg MNCRs' within NPE varies from January 1, 1980, to September 9, 1986; with; the greater majority having been received sometime in 198 The large nuhber of open MNCRs had preciously been identified by the NRC and concern was expressed to MP&L management regarding this matter. This issue was identified as an Unresolved Item and is documented in NRC Inspection Reoort No. 50-416/86-22,and 50-417/86-02. A verbal commitment was given by MP&L management during that inspection to reduce the number of open MNCRs greater than one year old to between 50 and 100 by Decembe- 31, 198 The inspector conducted interviews with licensee management to ascertain the status of corrective action' plans developed to closeout these open MNCR Licensee management informed the inspector of this prior commitment and stated that a completed review of the MNCRs had subsequently been performed to' ascertain what organizations have responsibility for closur Additionally, a review of the MNCR program revealed a programmatic deficiency which does not ensure closure of MNCRs after completion of work performe_ via Design Change Implementation Packages (DCIP) or MW0 Plant Quality Deficiency Report (PQDR) #189-86 was written to document this deficiency and initiate corrective action via a revision to Procedure 01-S-03-2, Material Nonconformance Report-Safety Relate t MP&L management had assigned an employee on a full time basis to administer the review and disposition of the open MNCR The proposed corrective action plan envisages the use of two or three contract personnel to support this staff member s in ensuring that paper flow is unrestricted and immediate
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attention is give to MNCRs assigned for closure to the responsible f organization. This proposed plan is being developed because of limitations on MP&L personnel resources caused by refueling outage (RF01) scheduled activitie ., _ _ - - - - _ - - - . . - - _ - - - -
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Additional corrective actions taken to date include a 100 percent review of 250 MNCRs greater than one year old to assess their safety significance. No safety significance was identified during this revie Corrective actions will be specifically addressed to force closure of 300 MNCRs which have been identified as being greater than one year old, in order to comply with the verbal commitment. At the exit interview licensee management stated that the NRC would be kept informed of the progress made in closing open MNCR In the event the verbal commitment cannot be met, a meeting with the NRC will be held for further review and evaluation of this subjec The inspector anticipates an increasing negative trend in this performance indicator because of numerous plant activities that normally occur during refueling outage Depending on how successful MP&L management is in achieving closure of the above MNCRs, the absolute value of this performance indicator may show a deteriorating condition for open MNCRs in the short ter .14 QA Nonconformance Performance Indicators (Indicator #29)
Licnesee management established various administrative processes that provide for safety and technical review of identified deficiencie The Corrective Action Request (CAR) is an administrative process to document program deficiencies, allegations, and supplier nonconformances identified by the QA organizatio Potential nonconformances identified by other organizations are normally dispositioned by other administrative processes such as Material Nonconformances Reports (MNCRs), Plant Quality Deficiency Reports (PQDRs), or Quality Deficiency Reports (QDRs). The QA organization may determine that a nonconformance being dispositioned by these processes is of such safety significance that it would be more appropriately documented as a CA An upgrading of the safety significance of the identified deficiency would be performed by the QA organization and it would be dispositioned in accordance with the requirements of the CAR proces The inspector determined that the administrative controls used for documenting and initiating corrective actions for identified deficiencies are being change The PQDR process, which is restricted to the plant staff, is used for documenting all safety related procedural and programmatic deficiencie Deficiencies identified by offsite support organizations were documented and dispositioned via the CAR process. Overuse of the CAR process by these organizations reduced the significance attached to problems that were dispositioned by this method. Licensee management decided, therefore, to establish a two-tiered administrative process to be used for documenting and dispositioning identified deficiencie The CAR process is the higher-tiered administrative control and is used for documenting and dispositioning identified deficiencies that require im' mediate management attention. A new process, the Quality Deficiency Report (QDR), will be used by both onsite
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and offsite support organizations to document and initiate corrective actions for problems previously processed by PQDRs and CARS. The corrective action program presently employs PQDRs, QDRs, and CARS. Upon completion of the program change the PDQR process will be eliminated, and only QDRs and CARS will be use The inspector conducted interviews with licensee management and reviewed the procedure that delineates administrative controls for CARS to assess the program adequacy. One area of weakness was identified by the inspector.
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The QA organization may upgrade safety-significant conditions adverse to quality that are associated with an identified deficienc Documentation and initiation of corrective action would be performed via CAR The inspector determined that written criteria, to be used by QA personnel performing this evaluation, have not been established by MP&L managemen The inspector was informed that this determination is based on the experience of the person performing the evaluation. On the recommendation of the inspector, MP&L's management agreed to assess the need for specific guidance to be used during this evaluation proces The inspector reviewed selected open CARS to assess the adequacy of the corrective action program in connection with:
Root Cause Analysis for identified problems Development of corrective action plans for identified deficiencies."
Implementation of developed corrective action plans within the work site control proces The following documents were reviewed by the inspector in connection with this effort:
MP&L memorandum PMI-86/6325 from W. E. Edge, Manager, Programs QA, Subject: QA Open Item /NRC Action Items List 86/32, dated August 26, 198 MP&L memorandum QAMI-86-0480 from W. E. Edge, Manager, Programs QA, Subject: QA 0;;en Items /NRC Action Items List 86/33, dated September 5, 198 MP&L memorandun PMI-86/5138 from S. M. Feith, Director, Quality Assurance, Subject: Open Corrective Action Requests (CAR) Report, dated July 3, 198 . .
The following CARS v?re also reviewed:
CAR Number CAR Number 2209 2210 2232 2170 2182 2171 2236 2172 2177 2234 2237 2213 1005 2214 2230 The above CARS identified numerous problems with the engineering design process. Included among them were improper sequencing of activities during the design process, inadequate design interface control, missing or inadequate documentation required to substantiate the performance of engineering evaluations and/or the qualification of equipment, and discrepancies in the as-built program. Additional deficiencies identified addressed procedural noncompliance relating to various activities performed by NPE and plant staff and failure to provide personnel trainin Root cause analysis for deficiencies documented on the above CARS appeared to be adequately performed. The analysis involved an evaluation of the work site control regt.1rements in connection with the following interfaces:
Personnel-Procedural interface Plant-Procedural interface Plant-Personnel interface Deficiencies involving any of the above interfaces were analyzed to determine the root cause and appropriate corrective action plans were developed to specifically address the identified deficienc Corrective action plans included the following:
Enhancement of personnel training Procedure rewrite and/or upgrade process Engineering Review Team (ERT) walkdown of plant systems A Drawing Configuration Control progra Implementation of the corrective action plan within the work site control process appeared to be ineffectiv Based on the review of the selected sample of CARS, the inspector assessed implementation of corrective action plans as lacking timeliness. Numerous requests for extensions to implement corrective action plans were made by responsible organizations and were granted by the QA grou It is recognized that activities for some corrective action plans involve a long lead time and/or can only be performed during unit outag However, a review of the CAR Status forms revealed an apparent lack of control regarding adherence to scheduled dates
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for deficiencies to be dispositioned within the CAR process. Procedure QAP 16.10, " Corrective Action Requests," paragraph 7.0 permits the granting of extensions by the QA organization. This procedure does not specifically address a method that ensures the closure of CARS that are outstanding because of lack of timely corrective actio Indicator #29, QA Nonconformance Performance Indicator, shows approximately 48 CARS open as of July 1986. MP&L memorandum PMI-86/6325, attachments A, B, and C, contain a total of 110 CARS that are open as of August 26, 198 Additionally, MP&L's memorandum QAMI-86/0480, attachments A, B, and C, contain a total of 122 CARS that were open as of September 9,1986. This represents an average monthly increase in excess of 36 CARS over the time frame. This monthly increase includes CARS other than those assigned to NP Unit 1 is presently in a shutdown mode undergoing a cycle one refueling outage. With the increased number of activities associated with refueling outages, an accelerated degradation rate of Performance Indicator #29 may occur, i.e. , increased rate of generation of CARS over the immediate futur At the exit interview, MP&L management was informed of the apparent lack of timeliness in implementing corrective action plans within the CAR process and the need for additional management attention in this are .15 Design Document As-Built Status (Indicator #30)
Discussion with NPE personnel identified an error in the graph relating to Performance Indicator #30. The correct identification for the vertical axis should ba " Number of Closecut DCPs", in lieu of, " Number of Drawings."
Because a DCP may contain more than one drawing, the absolute value of this indicator may be any multiple of the value show To better assess the situation the inspector conducted interviews with NPE personnel and reviewed the following documents:
Bechtel Eastern Power Corporation letter from R. W. Jackson, Project Engineer to F. W. Titus, Director Nuclear Plant Engineering, Subject:
System Closecut Status List, dated August 19, 198 Listing of Drawings associated with MNCRs in NPE for drawing update (as-built).
Listing of Drawings associated with MNCRs to be received from Plant Staff by NPE for drawing update (as-built).
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The following is a breakdown of the drawings on the System Closecut Status List received from Bechtel:
Drawing Type Number Percent Complete Upper Tier Drawings 15 1.15?;
Seismic Conduit Support 33 2.53%
Vendor Drawings 35 2. 68?;
Supports 147 11.28?;
Field Sketches 205 15.73fs Miscellaneous Lower-tier Drawings 216 16.58?;
Conduit Supports 652 50.04?;
Total 1303 The total number of drawings (Bechtel and others) identified as requiring update is 1338, of which 40 at most are upper-tier drawing Problems with configuration control have been recognized by MP&L managmen CAR 2232 was written on July 3, 1986, to identify discrepancies in the as-built drawing progra In response, plant staff management stated that an on going as-built program to correct drawing discrepancies was started on February 2, 1985, and reference was made to PQDRs 85/23, 85/32, 85/33, and 85/3 The inspector's review of the above DDQRs opened in mid-February 1985 revealed various causes which contributed to configuration control problem Among them were plant maintenance responsible engineer (RE) failure to red-line P& ids to make them as-built, RE omission of certain parts of drawings that required as-built status when closing DCPs, and RE neglect to ensure vendor drawings were shown as built. During the process of closing the PQDRs, additional problems similar to those identified on the PQDRs were found. A task force of NPE and plant staff reviewed, updated, and corrected over 6000 drawings. Additional corrective actions included the revision of procedures and the transfer of responsibility for plant configuration control from plant maintenance engineering to NPE Plant Modification and Control (PM&C). The PQDRs were closed by Plant Quality Section on August 5, 198 Because of numerous questions, concerns, and problems raqarding plant configuration, NPE is presently performing a special configuration control assessmen NPE has decided to issue periodic supplements to an initial report dated August 22, 198 These supplements are intended to fully document the assessments and recommendations. The initial report stated the following: Reconciliation of Control Room Stick File Drawings, Latest Engineering Issued Revision and As-Built Condition of the Plant - NPE initiated a reconciliation ef fort for the approximately 4200 upper-tier (control room stick file) drawing This initial review indicated roughly 600 upper-tier drawings which were not the latest engineering issued
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drawing Plant Staff then performed a reconciliation review of the upper-tier mark-ups versus the later engineering revision This
"first cut" revealed about 350 potential problem drawing A more detailed effort was then put forth to resolve these drawing problem The final break down of these 350 drawings was as follows: (all figures approximate)
150- Resolved as being no problem 50- Engineering revisions showed additional changes that were not readily identified as to basi These were all resolved by NP Incorrect as-built mark-up by plant staff 20- Incorrectly as-built by engineering (MCNRs issued to resolve these)
The remainder were miscellaneous cause b. P&ID's are not consistently showing instrument root valves shown on
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SOI Valve Line-up Sheets - This was identified by NRC Senior Resident
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Inspecto Initially, no root valves were shown on P& id Per conversation with I&C about Ih years ago, Bechtel was directed to add root valves, but no priority was assigne c. Accuracy of As-Built Information - Numerous discrepancies have been identified between as-built condition of plant and the condition shown on drawings. Some of these discrepancies are attributable to drafting errors but some are also due to " softness" of as-built information -
provided by Plant Staff. The standard statement contained in DCIPs is that the DCP was installed as designei except as shown on the attached mark-up or associated CNs. No complete as-built package is provide NPE recommended three corrective actions to specifically address the issues identified abov The first includes joint NPE/ Plant staff walkdowns of one or more selected systems. This reverification program is intended to establish a base-line confidence leve The second involves the review of P& ids against the isometric drawings to identify missing root valves. System walkdowns would be performed to resolve any identified discrepancie The final proposed corrective action regarding the accuracy of as-built drawings recommended certification of information provided to NPE for drawing update. The Design Change Implementation Package (DCIP) would also be required to contain all documents required by the DCP to substantiate final as-built statu The inspector conducted interviews with NPE personnel to ascertain the overall scope of corrective action plans developed and/or implemented to rectify configuration control problems. MP&L management stated that a Computer Aided Design (CAD) system had been procured and installed to f acilitate the drawing update. The inspector conducted a tour of the CAD work stations and interviewed licensee personnel regarding its operational statu The inspector was informed that the system is
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fully operational and all 4200 upper-tier drawings have been entered into the data base. Discussions concerning the integrity of the data base and the legibility of plant drawings were also conducte The inspector was also advised that 650 drawings, which will be impacted by implementation of DCPs during RF01, have been scheduled to be updated using the CAD syste The inspector determined that the recommended corrective action of the Reverification Program is still in the development stage. It is being proposed that contractor personnel be used to perform walkdowns of selected systems. A firm decision as to the number of personnel to be used has not been made. The following systems have been selected by MP&L to be walked down: High Pressure Coolant Injection (HPCI);
Reactor Core Isolation Cooling (RCIC) and Standby Gas Treatment (SBGT).
MP&L is committed to have all upper-tier drawings updated by the end of RF01. Corrective actions taken to date by MP&L Management include not only CAD systems, but also the revision / development of procedure Based on the review of the following procedures, adminictrative controls for updating engineering design documents and drawings appear adequat NPE Procedure No.01-315, Updating /As-Building GGNS Design Documents, Revision 4 NPD Procedure No. 5.9, Plans Configuration Control Safety Related, Revision 0 01-S-16-1, Plant Design Changes and Modification, Safety Related, Revision 0 Despite the corrective action plans that have been developed and implemented, additional management attention is required to address potential problems within the configuration control progra Specifically, because of numerous identified discrepancies between plant configuration and plant drawings, expeditious implementation of the Reverification Program is required.
l At the exit interview the inspector informed MP&L management of the i necessity to ensure that accurate information is provided by PM&C for use in drawing updat The inspector was assured that adequate controls are in place to control the flow of information across the interface between NPE and PM& . Conclusion l
The licensee has established the means to adequately identify problems of safety significance at the Grand Gul f facilit This includes the identification of adverse trends in performance indicators, quality assurance findings, and line staff internal finding The licensee has established programs for corrective action to resolve identified
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deficiencies. Though tnese programs appear to be adequate in scope, in several cases they have not been implemented with the intended or desired promptness. The closure of MNCRs and CARS are two examples where corrcctive action has not been expeditiou Based on performance indicator data for the last twelve months, the licensee's program to ensure quality (all inclusive quality assurance) has been average to good. Given the current positive attitude toward quality and programs in place, it can be reasonably expected that future performance indicator data will display continued improvement in the licensee's quality assurance effor . Licensee Action on Previously Identified Inspection Findings (Closed) Inspector Followup Item 416/84-40-01: Records Management System Implementing Procedure The inspector reviewed Volume 1, Section 13 of the GGNS plant administrative procedure and verified that working level procedures for Record Management System operations had been prepared. Based on the review of selected procedures delineating controls for document receipt, document indexing, date base verification, and data entry, this item is closed.
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!l ENCLOSURE (Page 1)
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f DOICATOR fi Forced Outage Rate l 1986 NPD Goal = < 10%
Percent 100
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NPD Gcal go .
Yeaa-to-Cate I
70 -
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Six-M, nth M0ving Averag ~
Monthly 2 Foaced Outage Rati, f 30 .
- .:aa< 1 18.6 I 20 17 .
E se' 1 J 0 0 0 0
- e*c*W*# # e*W # s* # #
Forced outage rate is the percentage of time Month !
Iplannedforelectricalgenerationthatunitwas .
unavailable due to forced event t I
DOICATOR #2 Unplanned Reactor Trips While Critical l 1986 NPD Goal = <6 per year Number of Trips j
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I 15 14 -
NFE Gal
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13 - -
12 -
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11 -
Year-to-Date 10 -
sumammmes I ~
Six-Manth 8 -
M;ving Averagc 7 - - -
6 -
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5 -
Monthly Trips 4 -
j xea 3 -
~ i 'i x i i 1 0 0 D " C
f W c# ## 6W#WW#&###
Reactor trips while critical are trips that Month that occur while the mode switch in the control ecco is in position 1 or _ _ . _ _ , . _ . . . . . . _ . _ . .. _ __._ ___ .. . .
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ENCLOSURE (page 2)
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I L IM)ICATOR 93
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Unplanned Safety Systems Challenges 1986 NPD Goal = <3 per system per year
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Number of Challenges r- 25 ,
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NPD Goal
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Yeaa-to-Dats
- i 15 -
\ Six-Month Moving Averagt
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10 -
Monthly Challengcr
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0 0 0 0 h0 0 0 0 0 0 0
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Ikelanned esfety systes challengee are evente or Month conditions resulting in actuation of HPCS.LPCS, .
~ LPCL or Emergency Powe m
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E ... anosuat page o INDICATOR # 4 Safety System Unavai1abi1ity l 1986 NPD Goal = < 1% per system per year l Monthly Unavailability Percent l
E HPCS/DIV3 l *
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8.s E
RCIC ,8,,
.. ****
o.78 E
I g DIV i ,o ,
-
t E
E I
" 2 l DIV 2 r o.04 2.4 l
,
o,82 , , , , , , ,
'o 1 2 3 4 5 E
} Safety Syctem Unavailability is the YTD Unavailability HPCS/DIV3: .65% RCIC: 1.2%
E percentage of Power, Emergency AC unavailable RCIC, and hours for HPC DIV1: .6% DIV 2: .2%
E '
~____T._________ _ _ _ _ -E
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ENCLOSURE (Page 4)
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IlOICATOR 99
,
Licensee Event Reports 1986 Plant Goal =< 36 per year
~
PPD Goal I 50 -
. ......
~~ ~
's, Year-to-Datt I 40 - \. . ... .... .-
g
""'"""
Moving Averagc l
,
20 -
Monthly LEhe
.
10 -
8 7
, 5 s E -
4 3 _ _ _ , 222 . ,
'U *' 'C UU I* C'I
se*e*se n o e n s Month I Licensee event reporte(LERs) are autaitted to the PE: by if&L as required by 10 CFR 50.7 I IPOICATOR # 10 Collective Radietion Exposure l 1986 NPD Goal = <800 MANREM per year Man-nem 120 -
NF~ Schi 110 - - --
100 -
90 . Year-to-Dete 80 -
Six-Month 70 -
. ,_
Moving Aveaagt 60 -
50 -
4 ~ Monthly Exposure 30 -
g E M -
1 U U 10 3,g ' 3,p 5 aa " = = > EI M 15555 RRlec 555R s #*#*#* # # # p* # p+ p p Collective radiation exposure is the total Month eeount of whole-body radiation exposare received Ebyc11personnelatGGN E
- - - -
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s
,
ENCLOSURE (Page 5)
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l INDICATOR #21 I Violations l
Number of Violations E Levt * \
Leu ' ;g
'
ics - .;;
~
hLeve! ;I
~
Leve; ;
I 15 -
10 -
0 s e* e* ** e* # e* se#sess Month EAviolationisanoncompliancetoaregulatory ,
r. uire-n l IPOICATOR #22 l Status of Licensing Commitments Open Commitments 100 gg, gat 7, 90 - The data indicates 30 days past due open Muing Ave ey, comitments and unconfirmed closed comeltaents 80 - based on LCTS status of all hRC coneitsent Consiteente Open 50 -
N 50 -
46 47
~ 45 45
~
l 40 -
30 -
-
- - o l lku - # - - - e. s -
A licensing commitment le en action l@GL has Month
E Cgased to perform or le required to perfore to satiety a regulatory requireacn . . . . .
. . _ .
_ _ -
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- - ENCLOSURE (Page 6)
INDICATOR #23
-
Core Burnup v Time
_
311.7
[ . Cycle-to-Date includes 15 ETPD produced prior gyg3,_gn_9,g,
_ to January 198 ~
Six-Month
-
~
-
Moving Averagt 200 -
l _ Monthly EFPO
I 140 120 100
-
-
-
$$$
I 80
-
-
, j 12.4 1 .3 16 2 .___} .2 g
O
. . . - -m m a o __m_-mm ne*s e n n o n I Core burnup vs. time indicates reactor core de-d ned o e 43 .
Month I DOICATOR #24 Maintenance Work Order Status I 1986 Plant Goal = 800 Backlog I 2500 2400 -
2387 Six-Month Moving Averag I 2200 2100
-
. 2075 N
'"
Number of MW0s 2000 -
<<MN 1900 -
1800 1724
'
1700 -
1600 -
1 1500 -
'
' 1500 1400 -
1300 -
l 1238 1255 1231
"O ER11 eel i snnnsnn A Maintenance Work Order Octo) to required to Month a my esintenance work on plant I
-
_- .
-
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __ _ .______
' ' *
ENCLOSUP,E (Page 7)
l Temporary M fi?ation Status 1986 Plant Goal = 40 l Nueer Outstanding 74 74 70 -
Moving Average
'
""
"
" ~
so -
outstanaing 50 .
- h'
40 - l 30 -
20 -
10 -
o o e*** n n n n
!!5.!E$nEf!!!!!!!!$IE'I'"III
'
I IICICATOR #26 Spare Parts Availability l 1986 Plant Goal = 95%
Percent ,
- "-""
- - ,,., ... ,,., ,, ... 2 - " - >
'
"
s i s s h. u s u
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.! ge
- _ III
"
EEEEE EE
~ . * ~ ~ ~ , * ~
3 ;;.ltill/;l'l:$1l'.L""' ""
ENCLOSURE (Page 8)
. .. .
INDICATOR #27 E
.
Design Change Status i
Number of DCPs 120 110 -
'"
E 100
-
- Issued for Construction 80 -
70 -
DCPs identified
,
this scnt ....-'..,
,,,,..-
E gn .
~,
,, .. ...
-
_....-
10 -
.<'
u' e* n' zu' m'w' *
....,,,,,.... -
' '
0 ' ' ' ' '
A design change package gives instruction Month I esterial requirements. stress analysis, wiring disgrees etc. for design changes at 66N I IICICATOR #28 l Material Non-Conformance Report Ststus Number of M 700 wpg 850 .
Open MCR?
600 -
!El0 -
Plant Staff 500 -
'-- - ....
-
Open MNCRs
,
.........
6 -
M 350 -
Open HNCRs 300 -
250 -
Total
,
Monthly Open 150 - ammmmmes R 100 -
Total
,
, _ ' ... q
,,,,,
.-.--
Monthly Issued
- - _ .
Y 4 Hantt los ( An MNCR documents deficiencies which render the Month I safe use able of Safety Rslated materials una: cept-or indeterminat I
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_ _ _ _ _ _ _ _ _ . _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ __ _ _ _ _ _ .
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- ENCLOSURE (Page 9)
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IE ICATOR #29 GA Nonconformance Performance Indicators Number of CARS 80 Open
"
50 - I?*ued
.........
C1cscd 40 .
a reflects CARS originated in the AP _
,'. *
,, , *. , '
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E
'
10 .,,,,, ',N ,, ,- N,,
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,
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, ,
,
,
, ,
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,
,
-
',,,
'
~ ,
, ., ,
., ~ *
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E AU685 SEP85 OCT85 N0Y85 DEC85 JAN86 FEB86 MARS 6 APRS6 MAYB6 JUN86 JUL86 Month I A corrective acticnform and procedJ"e nonCo9 request 89Ces and progaess in corre: ting any deviation identifie identifies monitors the progasm l
E IEICATOR #30 Design Document As-Bui1t Status l
Nu3er of Drawings 900 pgn ggic, 800 -
Re:eivcd E 700 .........
-
600 - Closed 500 -
400 -
300 -
200 -
- ~ '
........,,, , , ' ... xh - _+_ -= , - - ,
- @# ## &# ad f@# *M M ## M ##
This plot indicates the status of all drawings Month that have to be chan2ed to reflect current plant condition?.
_ -
____- . _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
l L
- ** - ENCLOSURE (Page 10)
IEICATOR #33 Personne1 Error Incident Reports
[
1986 Plant Goal = <9
!
Incident Reports 20 p g g ,3 Data is based upon LERs considered to be caused by human error G personnel incidents that are " " " " "
unreportable as LER Year-to-Lat " ,
Six-Manth I Having Ave.aag ,
=
Menthly Ficpcat9
-
E 5 -
'
2 2 2 2
. iv
- # c* #* # # # # # #* # #
Nonth -
IPersonnelerrorincidentreportsarecausedwhenwritten procedures are not followed ce accepted /
approved practices saa not peaforme .
IEICATOR #34 Number of Contract Employees i 1986 NPD Goal = 50 Number of Contract Employees 139 Nnicaa Sarrc"t I ,
Licencing & Safcty E 110
~
I NPE 100 -
80 -
01 ant Staff 60 -
40 -
l
'
30 -
0 .
N N N i All exempt G non-exempt contract personnel ame Month included excect construction.secuaiti, and personnel under bechtel maintenance contract _ _ _ _ _ _ _ _ .