IR 05000416/1988004

Insp Rept 50-416/88-04 on 880307-11.No Violations or Deviations Noted.Major Areas Inspected:Operations,Design Control & Licensee Action on Previously Identified Insp Findings

ML20153F297
Person / Time
Site:	Grand Gulf
Issue date:	04/21/1988
From:	Belisle G, Moore R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20153F290	List: IR 05000416/1988004 ML20153F287
References
50-416-88-04, 50-416-88-4, NUDOCS 8805100294
Download: ML20153F297 (9)

Text

_ _ . - - -_

._ .- _

____

,

t

' '

s ou cy

3 k UNITED STATES -

g ,g NUCLEAR REGULATORY COMMISSION j o '* REGION 11 l 101 MARIETTA ST., Yg ATLANTA, GEORGIA 30323 l

,,,,,

j Report No.: 50-416/88-04

!

Licensee: System Energy Resources, In Jackson, MS 39205 l

'

Docket No.: 50-416 License No.: 'NPF-29-l Facility Name: Grand Gulf  !

Inspection Conducted: March 7-11, 1988 Inspector H R h - I /S@

R Moo're, Team Leader Gate' Signed Accompanying Personnel: E. Lea Approved by: 7 G. Belisle, Chi F

/' / [

/D' ate 61gned

l Quality Assurance Programs Section  !

Division of Reactor Safety SUMMARY l

Scope: This routine, announced inspection was conducted in selected aspects of operations, design control and licensee action on previously identified inspection finding Results: No violations / deviations were identified, l

l gDR805100294 880429 g ADOCK 05000416 DCD ,

.

.

.

.

.

. .

.

.

REPORT DETAILS ,

i Persons Contacted Licensee Employees C. Burgess, Manager of Methods and Procedures

• Cross, Site Director

• D. Cupstid, Technical Support Superintendent

• L. Daughtery, Compliance Supervisor

• J. Dinnette, Jr., Manager, Plant Maintenance >

• C. Dutchin, General Manager

• Eiff, Principal Quality Engineer

• C. Ellsaesser, Operations Coordinator

• S. Feith, Director Quality Program

• C. Hicks, Operations Assistant

• McAnulty, Electrical Superintendent l

• A. McCurdy, Manager, Plant Operations f

'

• R. Moomaw, Technical Assistant to Manager Maintenance

• J. Summers, Compliance Coordinator

• S. Tanner, Manager, Quality Services

• M. Wright, Manager, Plant Support

J. Yelverton, Technical Assistant Other licensee employees contacted included engineers, technicians, aperators, mechanics, and office personne NRC Resident Inspectors

• R. Butcher, Senior Resident Inspector

• J. Mathis, Resident Inspector

• Attended exit interview Exit Interview The inspection scope and findings were summarized on March 11,1988, with those persons indicated in paragraph 1 above. -The inspector described the areas inspected and discussed -in detail the inspection findings. No dissenting comments were received from the licensee. The licensee did not identify as proprietary any of the materisis provided to or reviewed by the inspector during this inspectio Note: A list of abbreviations used in this report is located in the last paragraph of the report.

f

. . _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _

.

. .

.

.

Item Numbe Status Description / Reference Paragraph 416/86-18-1 Closed IFI- Publication of nuclear production division procedures and correction to lower tier procedures (paragraph 9)

416/d6-22-1 Closed URI- Timeliness of correction actions (paragraph 8)

~ Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio . Unresolved Items Unresolved items were not identified during this inspectio ;

i General l The purpose of this inspection was to review the effectiveness of licensee actions to correct weaknesses identified in the September 1986 QA Opera-tional Assessment Inspection, NRC Inspection Report No. 50-416/86-25. The Operational Assessmer.t Inspection reviewed quality assurance effective-ness in selected functional areas; i.e. operations, maintenance, design control and QA/QC via various plant operational performance indicator The operational assessment inspection team examined 15 performance indicators associated with these functional areas for absolute value, significant trends, and management response to these trend That inspection identified weaknesses in the operations and design control functional areas. This inspection, reviewed the licensee's corrective action effectiveness for the Operational Assessment identified weaknesses and additional'y reviewed licensee closure action on previously opened item l Operations An operations functional area weakness identified by the assessment team was the number of reactor scrams attributed to procedural inadequacies and personnel error. The inspector reviewed the licensee's mechanisms to resolve operational problems and the effectiveness of these mechanisms by reviewing i censee's analyses performed of subsequent reactor scrams /

trip Eight trips had occurred since the last QA inspection report was issue Four were at power trips. Each at power trip occurred due to mechanical

. or electrical malfunctions. The remaining four trips occurred during

'

subcritical conditions. Two of the trips, which occurred while the 1 reactor was suberitical, were due to personnel error. The cause of the

!

two trips and their corrective actions were identified in the following LERs:

- - - - . _ . - . _ _ . . _, ,,._, , .

, _

__ _ -

.

..

. .

. .LER 87-25 RPS fase improperly replaced while performing "Main Steam Line Isolation Valve Closure Calibration".

Corrective Actions: The responsible individuals were reprimanded for their failure to correctly install the fuse. .The incident was brought to the attention of others by placing the LER in the required reading'

progra LER 88-01 Use .of a nonconducting tool, in an Upper Cable Spreading Room panel, resulted in a ground between a

_

power supply and cabine Corrective Actions: Procurement of nonconducting tools is being pursued. Protective guards will be installed on the heat sinks of the two power supplies. SERI will evaluate the feasibility of installing a time delay in the logic. The individuals involved were reprimande A somewhat similar event, such as the one identified in LER 88-01 was reported in LER 86-34. The corrective actions stated in LER 86-34 was that edge guards were installed on the rectifier fins and on three similar units to preclude recurrence of grounding rectifier circuit This event occurred in a control room pane No other grounding problems have occurred in the control room panels since the edge guards were installe The licensee attempted to locate documentation on the installment of edge guards, but were unable to do so. The inspector expressed a need for improved documentatio Based on the inspector's review of post trip analysis and LERs, it appears that operator error and procedural inadequacies have been significantly reduced as a source of reactor trip Within this area, no violations or deviations were identifie . Design Control The inspector reviewed licensee corrective actions on design control weaknesses identified in the Quality Assurance Effectiveness Inspection, in September 1986. Problems identified included; the volume of CNs on approved DCPs, identified deficiencies in configuration control, lack of I adequate documentation to substantiate performance of engineering evalua-tions and equipment qualification, quality of contractor engineering design services, and the sequencing of activities - during the design process. Corrective actions were incorporated into various long term i

'

programs and actions to resolve associated CARS. Additionally, the inspector examined a sample of safety related DCPs to assay the effective- I ness of the licensee's corrective action l

. _ _ - - _ _ _ _ _ - -

. .

,

. .

.

.

4 .

i A pilot program was initiated following.CN problem identification by the licensee previous to the September 1986 NRC inspection. The pilot program was to evaluate CNs generated during RF01, determine the cause, and assess if the CNs were avoidable and. indicative of weaknesses in the design process. The pilot program appeared to be ineffective in reducing the v31ume of CNs as evidenced by only a slight reduction between RF0 1, 389 CNS, and RF0 2, 360 CNS. The licensee methodology for CN evaluation appeared inadequate because the reviewers were often the responsible-engineers evaluating their own activity. They were originators of the DCPs and the CNs. Additionally, there were a relatively large number of personnel evaluating the CNs thereby resulting in an inconsistency in cause code interpretation. The lack of both CN evaluator independence and consistent cause code interpretation limited the effectiveness of the CN pilot progra To achieve a more accurate assessment of CN generation, the NPE group reviewed all CNs produced during RF0 2. These CNs were catergorized into 17 different cause codes and discipline responsibility assigned. This evaluation appeared to provide justification for the volume of CNs rather than a noncompromising effort to identify methods to improve the front end design change process and reduce field modifications to approved design change package A portion of RF0 2 CNs were field enhancements and other CNs were unavoidable due to various plant conditions. Some CNs, however, were avoidable and indicated a lack of attention to detail at some level in the design development or implementation process. Although utilization of the CN process does not necessarily indicate a failure in the licensee design process, it does represent an aspect of design process quality. It appeared that the CN condition at the present is relatively l unchanged from that condition identified in the 1986 QA operational

'

Assessment Inspection and that licensee action has been ineffective in improving their self-imposed goal to reduce the number of CNs issue A previously identified weakness which appeared to have improved, was in the configuration control are Initially identified by the licensee in CAR 2232 for specifically identified deficiencies, this item was tracked via CARS 2244 and 2245 for resolution of the generic problem. Corrective !

actions included reviewing DCPs, drawing walkdown and reverification by NPE and PM&C, procedure changes, and personnel training. CAR 2245, which l addressed training, remains open due to a priority shift during RF0 2 but CAR 2244, which addressed the reverification and programatic problem, was closed on January 7,1988, based on completed corrective action The effectiveness of the corrective actions was determined via audit QSA 88/0012, Document Control and CARS 2244 and 2245, which was completed recently. The audit report had not been officially released but discus-sions with the audit group indicated that plant performance in the configuration control area had improved. The inspectors' review of the audit data supported this conclusio , . _. _ ._ _ - _ _ - - _ . _ - . _ _ ~

.

.

. .

.

.

An identified weakness relating to missing or inadequate documentation to qualify equipment and evaluations has been in the resolution process for the last two year The-item has been tracked via CAR 220 The longevity of this open item appeared to be primarily due to priority shifts from refueling outage Corrective action has continued and tracking by the QA group appeared adequat An initial review in 1986 identified 109 piping drawings for detailed review and analysis to verify qualification Performance of stress analysis on 41 piping runs identified 36' stress problems of which 15 have been resolved and the remaining committed to resolution by December 30, 198 In 1986, the licensee identified that engineering design vendor services had inconsistent qualit This item was assessed as a weakness in the !

September 1986 inspection. Corrective action for this problem was to reduce the volume of design vendor services, upgrade vendor performance, and improve vendor interface by requiring the vendor to utilize licensee procedure Previously, the bulk of design activity was performed by vendors, supplemented by the in-house design organization. Discussions ;

with design management indicated a policy of the licensee acquiring a j greater responsibility for design activity. Design activity for RF0 3 will primarily be the responsibility of the in-house design organization !

with vendor supplementatio Associated with this increased site design I responsibility, the licensee was in the process of developing safety- ,

related system design criteria which will reduce the dependency on the A/E )

(Bechtel Eastern Power Company) or other vendors for design basis informa- )

tion. Vendor design service's quality has been enhanced by including a '

performance factor in the vendor contract. A grading system was used to measure performanc A letter from the Bechtel Project Engineer to the licensee's NPE organization dated January 28, 1988, stated that the quality and productivity of Bechtel services had improved due to specific Bechtel initiatives to improve performance. The design process interface improvement was achieved by requiring Bechtel to utilize SERI design procedures thus reducing the interface discontinuity from attempting to convert the Bechtel design format into the SERI format. Use of SERI procedures provides greater assurance that SERI commitments are me The discrepancy associated with design activity sequencing was tracked and closed via CAR 2236. The finding stated that design input and design verification documentation were not always clear or complet For example, there were DCPs in which the design verification was signed off before the design preparation or the design input completion after the design preparation. This CAR was closed on March 3,1987. The inspector's review of sample DCPs from 1987 did not identify any discrep-ancies in the design process sequence; however, the reiterations inv-1ved in the review process resulted in a number of signatures arrayed on the verification documentation in a disorganized manne .

.

.

. .

.

.

l The inspector reviewed a sample of safety-related design change packages  :

implemented in 198 Selected aspects of the design process review i

'

included: documentation of design input requirements, 10 CFR 50.59 evaluations, post modification testing and effectiveness of licensee corrective actions for those weaknesses previously discussed. The sample of DCPs included the following:  :

l 82 0252 84 0016 84 3221 85 4053 87 0017 87 0091 The design process aspects reviewed were adequately performed and docu-mente Corrective actions initiated by the licensee to address the ,

identified design control process weakness identified during the  !

September 1986 inspection appeared to be of.a magnitude and effectiveness to resolve those program deficiencies, j

!

Within this area, no violations or deviation were identifie I License Action on Previously Identified Enforcement Action (92701) .l

'

Timeliness of Corrective Actions

'

(Closed) Unresolved Item 416/86-22-01:

A previous inspection conducted in July 1986, identified a weakness in the licensee's ability to effectively implement corrective actions for material nonconformance reports (fiNCRs) in a timely manne The report 1 also stated that the licensee had established a task force to reduce the i number of outstanding MNCR !

The inspector reviewed 30 open and 30 closed MNCRs to determine corrective i action timeliness. The open MNCR volume has been significantly reduced I since the last review. On July 21, 1986, there were 657 open MNCRs, of

'

which 254 were open for more than a year. As of March 4,1988, there were only 159 MNCRs open, of which 83 were open for more than one yea I Additionally, the inspector reviewed Administrative Procedure 01-S-03-3, Rev. 21, Material Nonconformance Report, and SERI Policy No. 8.510 Rev. O, Condition Identification and Evaluation. Measures taken by the task force to correct programmatic deficiencies were adequate. Based on the above information, the task force has effectively reduced the outstanding MNCR ,

numbe j i Licensee Action on Previous Inspection Findings (92702) l

!

(Closed) Inspector Followup Item 416/86-18-01. Publication of Nuclear Production Division Procedures and Corrections to Lower Tier Procedure A previous inspection identified discrepancies in paragraph numbers referenced in lower-tier quality implementing program documents for commitments delineated in the NPD Policy and Organization Manua These i

, , - - ,. _

._ .. , . . - - . . - . ., , -, -- .---.

_ _ _ _ _ _ _ _ - _

_ .

.

.. .

. . . . . . . . . . .

=

.

. . l

'

.

7 discrepancies were caused by replacing the NPD Policy and Organization Manual with the NPD Policy Manual and the NPD Procedures Manual. At that time, correction of the discrepancies required completing the phase-out of the NPD Policy and Organization Manual and editorial corrections of the lower-tier quality implementing procedure The inspector reviewed the SERI Operating Manual and interviewed SERI personnel in response to this item. The SERI Operating Manual resulted from reorganization within Mississippi Power and Light and replaces the NPD Policy and Organization Manual, NPD Policy Manual, and NPD Procedures Manua One additional section, Master Issue List, was in draft and awaiting final management approval. This section is not an NRC commit-ment. Those sections that contain NRC ccmmitments were complete. Cross references to previous plant documents were provided and training sessions are planned for SERI snployees on the new manual and procedure .. _ _ _ _

.

.

. .

.

.

10. Abbreviations A/E Architect Engineer CAR Corrective Action Request CN Change Notices DCP Design Change Package IFI Inspector Follow-Up Item INP0 Institute of Nuclear Power Operations MNCRs Material Nonconformance Report MWO Maintenance Work Orders N Number NPRDS Nuclear Plant Reliability Data System NPD Nuclear Production Department NRC Nuclear Regulatory Commission PM&C Plant Maintenance and Construction Group QA Quality Assurance QC Quality Control RF0 Refueling Outage RPS Reactor Protection System SERI System Energy Resources, In URI Unresolved Item l

i I