ML14191A915
| ML14191A915 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 03/21/1988 |
| From: | Belisle G, Mellen L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14191A913 | List: |
| References | |
| 50-261-88-01, 50-261-88-1, NUDOCS 8804260114 | |
| Download: ML14191A915 (34) | |
See also: IR 05000261/1988001
Text
0% REQ 1XUNITED
STATES
NUCLEAR REGULATORY COMMISSION
-REGION
II
101 MARIETTA STREET, N.W.
ATLANTA, GEORGIA 30323
Report No.:
50-261/88-01
Licensee:
Carolina Power and Light Company
P. 0. Box 1551
Raleigh, NC
27602,
Docket No.:
50-261
License No.:
Facility Name: H. B. Robinson 2
Inspection Conducted:
January 11 -
15 and January 25 -
29, 1988
Inspector:
, 3 2.1VEff
U. Mellen, Team Leader
Date Signed
Team Members: T. Cooper
L. Moore
L. Wharton
R. Wright
Approved By:
1
WG.
Belisle,-Chief
Dat'e Stgned
Quality Assurance Programs Section
Division of Reactor Safety
SUMMARY
Scope:
This special, announced quality.verification inspection was
conducted in the areas of maintenance, design control, operations,
commercial grade.procurement, and quality assurance/ quality control.
Results:
Four violations were identified involving failure to meet
reportability requirements, failure to perform post-modification
testing, failure to maintain records, and failure to follow procedures
relating to temporary repairs, work requests, and the trend analysis
program. One unresolved item was identified related to use of
commercial grade procured items and use of commercial grade procured
items in EQ applications.
8804260114 880414
ADOCK 05000261
REPORT DETAILS
1.
Persons Contacted
Licensee Employees
R. Barnett, Maintenance Supervisor, Instrumentation and
Controls
D. Baur, Supervisor, Quality Assurance
- G. Beatty, Site Vice-President
J. Cribb, Supervisor, Quality Control
- J. Curley, .Director, Regulatory Compliance
- W. Flanagan, Manager, Design
R. Fronckowiak, Supervisor, Warehouse
W. Gainey, Supervisor, Operations
- E. Harris, Director, Onsite Nuclear Safety
- F. Lowery, Manager, Operations
- R. Morgan, Plant General Manager
M. Page, Supervisor, Technical Support
- D. Quick, Manager, Maintenance
- B. Rieck, Manager, Materials and Administration
D. Whitehead, Supervisor, Performance Evaluation Unit
L. Williams, Manager, Security
- H. Young, Director, QA/QC
Other licensee employees contacted included engineers,
technicians,
operators, mechanics, security personnel, and office personnel.
REGION II Attendees
- G. Belisle, Chief Quality Assurance Programs Section
NRC Resident Inspectors
- L. Garner, Senior Resident Inspector
R. Latta, Resident Inspector
- Attended exit interview on January 29, 1988
2,
Exit Interview
The inspection scope and findings were summarized on January 29, 1988,
with those ,persons
indicated in paragraph 1 above.
The inspectors
described the areas inspected and discussed in detail the inspection
findings.
No dissenting comments
were received from the licensee.
Proprietary information is not contained in this report.
Note: A list of abbreviations used in this report is contained
in paragraph 11.
2
Item Number
Status
Description/Reference Paragraph
261/88-01-01
Open
VIOLATION -
Failure to meet
reportability .requirements (paragraph 8.f).
261/88-01-02
Open
VIOLATION -
Failure to perform
post-modification testing (paragraph 7.c).
261/88-01-03
Open
VIOLATION -
Failure to maintain
records (paragraph 8.f).
261/88-01-04
Open
VIOLATION -
Failure to follow procedure for:
1) use of a temporary repair that results in an
FSAR change (paragraph 7.a), 2) maintaining trend
analysis program records (paragraph 6.b), 3) job
descriptions for various operations positions
(paragraph 8.e).
261/88-01-05
Open
URI -
1) Use of commercial "off-the-shelf" -items
in safety-related applications without special
quality verification testing being performed
(paragraph 9.c). 2) Lack of definite correlation
between purchased item and tested item for use of
item
in
an
EQ application
(paragraph 9.c).
3.
Licensee Actions on previous Enforcement Matters
This subject was not addressed in this inspection.
4.
Unresolved Items
Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve violations or devia
tions. One new unresolved items was identified during this inspection and
is discussed in paragraph 9.c.
5. Quality Verification (T12515/78)
The objective of this inspection
was
to assess quality assurance
effectiveness.
For this report, quality assurance effectiveness is
defined as the ability of the licensee to identify, correct, and prevent
problems. The term quality assurance effectiveness is used in this
application, but it
is not meant to be limited to the licensee's Quality
Assurance Department. It
is the total sum of all efforts to achieve
quality results.
This was a performance-based inspection.
The principal effort was to
determine whether the results that the Quality Assurance program was
designed to accomplish were actually achieved.
However, when problems
were identified, appropriate regulatory requirements were enforced.
3
The inspection effort was divided into the following area.s:
Maintenance
Design Control
Operations
Commercial Grade Procurement
Quality Assurance/Quality Control
Each area is addressed separately in this report.
6.
Maintenance
The inspector witnessed various electrical/I&C and mechanical activities
in process. The activities were completed in a highly professional manner
by
knowledgeable personnel.
The overall performance of the maintenance
activities was acceptable. The inspector noted the level of knowledge and
experience as a strength in the maintenance area.
The inspector also examined the use of Work Requests,
the Maintenance
Trend Analysis program, and the Predictive/Preventive Maintenance program.
a.
Use of Work Requests
The inspector reviewed the administrative requirements for the use of
Work Requests, conducted interviews with technicians, mechanics,
and
work planners, and reviewed documentation, including NCRs, QA
surveillances/audits, and completed work packages.
Procedure PLP-013, "Maintenance Program", Revision 2, allows work to
be performed on routine skill-of-craft activities without the use of
approved procedures, with the Maintenance Supervisor administratively
controlling the performance of the activity.
The work planners are charged with providing the work instructions to
the mechanics and technicians on the Work Requests.
Other than a
general
instruction to provide work instructions in
MMM-003,
"Maintenance Work Requests",
Revision 16, and a list of what is
considered skill-of-craft in PLP-013, there are no specific guide
lines available to the work planners.
A review of 50 recently
completed work requests by the inspector determined that there is a
wide difference in .the detail provided by the work planner.
Work instructions for similar tasks can vary greatly from simple
statements to detailed step-by-step instructions..
For example, Work
Requests 87-AQJD1 and 87-AMZQ1 were both written to repack leaking
valves.
87-AMZQ1 contains the instruction to replace valve
packing using 1/8 Chestron 1000 packing. WR 87-ADJQ1 contains six
specific steps to be performed in sequence. Both WRs are designated
as skill (i.e., skill-of-craft).
4
The lack of specific administrative control over the content of the
work instructions included on a WR is considered a weakness in the
maintenance area.
b.
Maintenance Trend Analysis
The
inspector reviewed
requirements for the maintenance
trend
analysis program,
interviewed maintenance engineers concerning the
implementation of the program, and reviewed a sample of trend reports
generated under this program.
The type of trending program utilized
at HBR,
if
used in conjunction with existing programs such as the
preventive -maintenance program,
has the potential of reducing the
amount
of. corrective maintenance
required to repair recurring
problems.
The inspector noted that a problem with the utilization of the
existing trending program was the lack of follow-up
on
items
identified during the trend reviews. Of the ten reviews conducted by
the inspector, nine of the packages did not fulfill the requirements
of MMM-011,
"Trend Analysis",
Revision 3.
Problems varied from
failure to be administratively closed out, even though corrective
action had been completed during the last refueling outage,
to
several corrective actions being past the target date without a
revision to -the schedule being approved by
the Maintenance
Supervisor.
The trend analysis program is not being utilized
according to procedure,
which has the potential of reducing its
effectiveness. Identified adverse trends in safety related equipment
need to be handled in a timely manner and corrective actions need to
be monitored to assure adequate completion.
Failure to maintain the Trend Analysis program requirements is
collectively combined with other examples of failure to follow
procedure in paragraphs 7.a and 8.e, and is considered an example of
violation 261/88-01-04.
c.
Preventive/Predictive Maintenance
The Preventive/Predictive Maintenance program
is designed to be
utilized to reduce the amount of corrective maintenance required on
certain safety-related and important-to-safety equipment.
The
program at HBR is presently being transferred
from Maintenance
Engineering to Technical Support. The personnel and responsibility
have already been transferred and approval of the interdepartmental
interface agreement was pending at the time of the inspection, which
would allow for the revising the.governing procedures.
According to MMM-005,
"Preventive/Predictive Maintenance Program",
Revision 9, the SPC, which consists of a list of the equipment placed
in the PM/PDM program for each system, with PM/PDM tasks for each
piece of equipment identified, is used by the maintenance planners to
5
develop the PM/PDM schedules.
The SPC will be controlled as an
instruction, requiring the Maintenance Supervisor to approve any
changes. The SPC was requested to be computerized in December 1986
in order to increase the efficiency of the utilization of the
program. The
SPC has not been updated since this request was
submitted.
The responsible engineer for the PM/PDM program demonstrated to the
inspector that the required changes to program procedural
and
computer software development are in-process, which alleviated all
concerns expressed by the inspector concerning the deviation from the
established program.
The
PM/PDM
program thoroughly addresses safety-related equipment
needs for the systems reviewed by the inspector. The components have
been evaluated and schedules developed for any components requiring
routine PM. The PM scheduling has been successfully implemented by
the work planners. The inspector determined that the PM/PDM program
adequately addresses the objectives established for it.
7.
Design Control
.Assessment
of the design control
functional area included: a design
process and interface review, justifications for continued operation and
temporary modifications review, previously identified findings
and
associated corrective actions review, and a sample design change package
review. The design process at HBR was generally adequate except for
temporary modifications and post-modification testing.
Specific problems
in these areas are discussed in later paragraphs of this section.
A
strength was identified relating to the licensee's identification of a
problem associated with an excessive number of design change notices to
approved modifications
and management's effective corrective action
initiative.
The majority of HBR modification packages are developed by NED,
the
corporate design organization. The onsite design group acts as a liaison
engineering group between onsite and offsite design activities.
The
liaison group is
separated into disciplines and. generally provides
constructability reviews, and coordination of modification implementation
and close out.
Modifications can originate via LER,
PIR,
temporary
modifications, or management initiative.
The design approval/development process typically begins with a PIR.
A
PIR can be initiated by any site personnel to propose a plant improvement
or request engineering evaluation.
There were 359 open PIRs on
January 14, 1988, which included major projects/modifications, non-routine
budget items, and non-safety-related improvements not handled by
maintenance work requests.
A review of the volume and subject of
6
modification associated PIRs did not identify any safety concerns with
respect to backlogged modification requests.
Following initiation, the
PIR receives management and discipline reviews to verify the validity of
the proposed plant improvement.
Those modification PIRs which receive
Site Vice-President approval
are further developed to establish the
detailed scope and. then modification package development is performed by
NED. Discussions with site design personnel and review of -design change
packages indicated an adequate interface between the principal design
group (NED) and the onsite implementation and coordination group.
a. Temporary Modifications and JCOs
The
inspector reviewed temporary modifications and JCOs for
conformance to programmatic requirements, longevity, and impact on
procedures and plant design basis documents. Administration of both
temporary modifications and JC0s was weak and these problems had been
previously identified by the licensee and were in the process of
being corrected.
Temporary modifications/repairs were administra
tively controlled by the maintenance group in accordance with
MMM-013,
"Temporary
Repairs",
Revision 4.
This procedure did not
require time limits on temporary repair installation nor periodic
reevaluations of temporary repairs to verify the need of continued
installation.
Due to the lack of administrative controls in these
areas, this is identified as a weakness.
The inspector reviewed the following temporary repairs/modifications:
TRP 85-07
Service Water MIC Repair
TRP 86-01
Mechanical Block of SI Mini-flow
Recirculation Valves
TRP 86-02
Commercial Grade Insert in Pressurizer
Safety Valve
TRP 86-10
Containment Penetration Bellows Repair
TRP 87-10
Jumper on SI Valve Interlock
TRP 86-01 blocked the SI
pump mini-flow
recirculation isolation valves,
SI -856A
and B, into the
open
position, to ensure a SI pump flowpath. The safety evaluation stated
that these valves were required closed only during transfer from hot
leg recirculation to cold leg recirculation and that removal of the
blocks presented no impediment to this operational transition.
The
inspector reviewed the
procedure
governing this evolution
and
verified the specific requirement for. mechanical
block removal.
Although this temporary modification involved no apparent safety
concern it
did violate the programmatic controls for temporary
modifications.
Administrative procedure, MMM-013 requires that
modifications involving FSAR changes cannot be processed via MMM-013
without the required reviews.
TRP 86-01 did involve an FSAR change
in that FSAR Figure 6.3.2.1, the flow diagram for the SI system,
identified these as fail-close valves.
The mechanical blocking open
of these valves was not identified or processed as an FSAR change.
.7
This failure to follow MMM-013 is collectively combined with other
examples of failure to follow procedure in paragraphs 6.b and 8.e,
and-is identified as an example of violation 261/88-01-04.
The inspector's review of JCOs indicated that there was no specific
programmatic controls to address this mechanism.
Due to EQ require
ments established over the past years, the JCO has assumed a focused
identity as a mechanism to document justification of plant conditions
which do not exactly conform to plant design or commitments.
The
JCOs are performed at HBR in accordance with MOD-001, "Procedure for
Preparing Engineering Evaluations",
Revision 8.
This procedure
provides a format for evaluation and requires a 10 CFR 50.59 safety
review, but does not provide administrative controls for JC~s.
It
appeared that the majority of JCOs are reviewed by at least one PNSC
member. This is due to a required review of engineering evaluations
by discipline managers. Discipline managers are also members of the
PNSC. The evaluations could be tracked via the PNSC action item list
or other plant tracking system; however,
no single mechanism exists
to ensure a consolidated control and tracking of JCOs. Additionally,
the JCO process is not specifically defined nor does any one group
have administrative responsibility for JCOs.
The
need for JCO
administrative responsibility was verified by a review of.JCOs. For
example, JCO87-101 addressed a justification for a non-EQ qualified
valve to operate in an
EQ environment.
The restriction on the
justification was to ensure the valve was deenergized one hour after
an SI actuation due to steam break or LOCA, since valve operation in
the subsequent environment could not be guaranteed after one-hour.
Although the evaluation received PNSC approval, no responsibility was
assigned to verify implementation in plant procedures. The inspector
reviewed the implementation in the impacted procedures and noted that
the valve motor-operator deenergization requirement was event
designated rather than a specific one-hour limit.
Discussions with
the cognizant engineer identified a scenario (small
break LOCA with
one SI pump running) where the one-hour limit could be exceeded.
Upon identification of this item the licensee initiated corrective
action revising the associated procedures to state the EQ precaution
as a specific time limit. - This example illustrates the need to
designate administrative responsibility for JCO implementation.
b.
Corrective Actions
The licensee has identified weaknesses in the administration of
temporary modifications and JCOs and initiated corrective action.
Procedure MMM-013 was superseded on January 29,
1988,
by MOD-018,
"Temporary Equipment Modifications", Revision 0, which provides more
specific administrative and technical
controls and transfers
administrative responsibility to operations. The JCO administrative
weakness was identified by PNSC action item 87-08 from PNSC meeting
minutes dated 5/25/87. An action completion date of 12/31/87 was not
8
met since the corrective action scope proposed to the
PNSC was
determined inadequate. An interim corrective action to revise the
Engineering Evaluation Procedure to address JCOs specifically and
require a PNSC review was committed for February 29, 1988. Long term
corrective action was to establish a program/procedure specifically
for JCO control with administrative responsibility assigned to the
onsite design group. The long term commitment date was December 31,
1988.
The inspector reviewed corrective actions initiated by the licensee
for weaknesses identified with design basis documents and DCNs. Lack
of consolidated design base documents and indexed calculations had
been identified by the licensee and the NRC in previous inspections.
Programs to correct these problems are in the organizational- stage,
i.e., funds approved,
responsibilities and scope established,
and
guidelines developed for the process of compilation and evaluation of
design basis data. No actual man-hours had been expended on actual
data collection. PIR 87-038 initiated on April 1, 1987,
recommended
consolidation of design basis documents which were previously held by
various A/E or vendor groups, i.e.,
EBASCO
and Westinghouse.
The
design bases are presently available at various vendor locations
primarily due to the proprietary nature of the information and the
A/E information controls in effect during the construction period.
Design basis information is presently acquired by the design engineer
via an extensive search of specifications, FSAR, drawings, purchase
orders, etc. The DBD program will require review of post operating
license commitments with the original.design basis data retrieved
from the A/E and subtier vendors.
This updated data will then *be
entered into a consolidated controlled
system to provide for
retrieval of design base information. The projected completion date
for safety-related systems is 1991.
Closely associated to the DBD program is the calculation control
program- which will provide the collection and indexing of design
calculations.
This program was proposed on
PIR 87-141,
dated
September 8, 1987. This program is still in the proposal/approval
process although management indicated.the calculation indexing should
be under development by June 1988.
This program parallels the DB0
program in some aspects due to identical sources of information. The
DBD and Calculation control programs are long term corrective actions
to resolve a basic weakness in the HBR design control program.
A shorter term corrective action initiated by the licensee was the
DCN
reduction program.
The
licensee reviewed a sample
of 46
modifications from the period of 1982 to 1986 to determine the volume
of DCNs being used on modifications.
The evaluation identified a
problem with excessive DCNs which is illustrated by the following
table:
9
Average No.
No. of Mods
Highest
No.
Category
DCNs/Mod
Evaluated
DCNs/Mod
New Systems
26
13
100
Modified Systems 42
14
142
Modified Comps.
15
19
88
In conjunction with this evaluation, design management initiated an
assessment program and established-goals to reduce the number of DCNs
for Refueling Outage No. 11. The assessment requiredia review by the
Design Manager of each DCN to determine the reason for the DCN and if
the DCN could have been prevented.
The following are the goals
established and the results from the outage:
Category
Goal
Actual DCNs
New Systems
15
19
Modified Systems
11
5
Modified Components
6
6
The assessment of DCNs identified the two major causes of DCNs as
inadequate construction walkdowns (27 percent) and inadequate design
review (28
percent).
Additionally,
it
was identified that the
highest number of DCNs were on I&C
and electrical modifications
assigned to the contract A/E.
These were also the most complex and
extensive modifications.
The licensee was in the process of further
breakdown of root causes *and formulation of specific corrective
actions; however, the DCN reduction achieved by management focus on
the area represents a strength in the design control program.
The
licensee efforts to identify the problem scope, evaluate causes, and
provide initial improvement of the problem are commendable.
C.
Design Modification Packages
The
inspector reviewed a sample of modification packages for
documentation of design input, 10 CFR 50.59 safety evaluations, and
post-modification testing.
This review included the- following
modifications:
Modification No.
Title
M-912
Pressurizer PORV Block Valve
Replacement
M-883
Degraded Grid Bypass
Indication
M-920
AFW Control Wiring Reroute
M-890
-Upgrade
of PT Fuses on 480V
Emergency Bus
10
Documentation
of
input requirements was adequate
for those
modifications reviewed, consisting of a standard checklist and
references which more fully described the design document input.
Safety evaluations were expansive and generally comprehensive.
A
violation was identified with respect to performing post-modification
testing. Modification M-920, involving rerouting of the AFW control
wiring, stated as acceptance criteria that the AFW pumps and header
discharge valve (V2-16B) control circuits perform as designed and as
specified in FSAR section 7.3.1.1.1.
The referenced FSAR section
lists the auto start signals for the AFW pumps.
Contrary to this,.
the modification was closed out with only a circuit continuity check
performed for a post-modification test.
On June 15, 1987, the "B"
AFW pump failed to start on a loss of main feed pump auto-start
signal (LER 87-018).
The cause was a wiring error during modifica
tion implementation which would have been identified if the required
post-modification testing had been performed.
Corrective action for
this LER was implemented by Special Procedure 781, "Special Procedure
for Testing Auxiliary Feedwater Pumps A and B",
Revision C.
This
procedure tested two of the four auto-start signals.
The SL and
black out start signals were not tested at this time. Review of the
control wiring diagram, Drawing No. B-190628, illustrated that the SI
and black out circuits are physically separate from the Low-Low Steam
Generator Level and Loss of Main Feed Pump circuits and were not
impacted by this. modification.
Performance of SP-781 and'OST-201,
"Motor Driven AFW System Component Test", on June 17, 1987, provided
reasonable
assurance
of
pump operability.
However,
these
activities needed to have been performed prior to modification close
out.
An additional failure to perform specified post-maintenance testing
was identified on M-912,
"Replacement of Pressurizer
Block
Valve". The modification performance requirements stated the valves
must close in 40 seconds or less.
No verification of this closure
time was performed prior to modification close-out although a
performance test was
done
on
the valve several
months after
modification close out and the closure time was within the required
limit. Modifications M-912 and M-920 stated specific acceptance
criteria to be verified by post-modification testing.
This failure
to perform post-modification testing is identified as violation
261/88-01-02.
8. Operations
a.
Licensee Event Reports (LERs)
The inspector reviewed the licensee's preparation and handling of
LERs.
HBR
LERs are presently governed by Plant Operating Manual
Administrative Procedure AP-030, which requires compliance with 10
CFR 50.73, "Licensee Event Report System",
as well ,as NUREG-1022,
"Licensee Event Reports" and its Supplements, Nos. 1 and 2.
.
11
The
AEOD provided CP&L their second evaluation of Robinson
LER
quality in a QER dated August 6, 1987. This QER covered a sample of
15
LERs submitted by
HBR
between November
1985 and June 1987.
Robinson's overall evaluation was below the industry average and was
attributed to inattention
to detail
in completing the
LER
documentation.
Although the inspector noted similar occurrences in recently issued
LERs,
there was a marked decrease in the number of LER deficiencies
and a marked increase in the quality of the issued LERs.
The
licensee is in the process of implementing an LER quality improvement
program which will include the following:
Implementing the guidelines of NUREG-1022
Required peer evaluation of LER drafts
Improved AP-030, "Licensee Event Reports"
Improved Regulatory Compliance instructions
Development and use of an LER checklist
Obtaining an independent assessment of LER quality by
the Onsite Nuclear Safety unit
Improved -communication with other CP&L sites on
regulatory reporting matters
Developing a consistent LER format
Required Plant Nuclear Safety Committee review of LERs
prior to submittal
Preparing an LER Handbook for training and reference by
LER writers and reviewers
Developing a group instruction on LER preparation
Starting a training program for LER writers
Assessing whether prior LERs should be revised
Using an LER checklist based on NUREG-1022 and
Supplements 1 & 2
Involving more management and plant personnel in LER
review
Portions of this program have been implemented with a significant
improvement in LER quality.
b.
ISI Program
The inspector reviewed the results of various revisions of OST-151,
"Safety Injection Component Test", and determined there was an error
in the equation for.calculating SI pump suction pressure. The error
was in the constant used for suction height of the Safety Injection
pumps.
The inspector noted this method was used for calculating
suction pressure of other safety related pumps.
The licensee
assigned a team of two people to resolve the question immediately..
One individual measured the piping locally to determine the height of
the eye of the pump suction from the base elevation.
The othe'
researched the plant drawing file and procedure files to determine
12
the basis for the original height.
As a result, the listed height
correction was determined to be inaccurate in the round off to the
nearest foot. The measured height was determined to be 29 inches and
should have been rounded off to 2 feet instead of 3 feet.
The root
cause was not determined, but was speculated to involve the use of
the top of the piping as reference instead of the centerline of the
piping (eye of the pump).
The licensee agreed that the eye of the
pump would have been the correct reference for establishing the pump
suction pressure. To determine the effect of the one foot error, it
was evaluated against the current pump operating conditions.
One
foot of suction error would introduce a maximum error of 0.43 psig,
or 0.03% of the operating delta pressure of approximately 1450 psid.
The actual effect was insignificant since the accuracy was set by the
maximum reading error of the instrumentation.
This was set at the
resolution of the discharge pressure gauge (2000 psig) which was 10
psig minimum.
Although the error was insignificant, the licensee
stated that a change would be made to the OST to correctly indicate
the suction pressure.
The licensee is
also investigating the
likelihood of a similar condition existing on the other pumps tested
by the ISI program.
While the investigation was proceeding,
the
licensee reviewed the effect of another potential error on low
pressure pumps.
Due to the piping sizes involved, the error will
still most likely be one foot or less (0.43 psig). The RHR pumps.are
the most sensitive, but due to their elevation being lower than the
RWST the error would be conservative. It would represent an error of
approximately 0.3%, still below the resolution of the gauges.
The
licensee stated that they would complete the review to ensure no
other similar errors existed and initiate procedure changes where
applicable.
The licensee's prompt attention and immediate corrective actions are
considered an example of responsiveness and management concern in the
ISI program.
c.
OST Scheduling
The inspector reviewed the licensee's methods used for scheduling
OSTs and noted the scheduling appeared to be complete and accurate.
All OSTs reviewed were accomplished within the required interval.
d.
Conduct of Operations
The inspector reviewed the conduct of on-shift operators and the
conduct of operators during plant events. The inspector concluded
the .operators were knowledgeable of plant conditions, their assigned
duties, and events that significantly effected plant operations. All
operational activities witnessed by the inspector were completed in a
highly professional manner. The overall conduct of operations was
satisfactory.
13
e.
Procedure OMM-001
The inspector reviewed OMM-001, "Operations -
Conduct of Operations",
Revision
12.
The
inspector noted that job descriptions for
operations personnel were not consistent with lower tier documents or
actual work performed. An example of this practice is the require
ment of section 3.10, Shift Technical Advisor, delineating an STA
duty as "Review plant LERs for completeness,- applicability, and
compliance with reporting requirements."
The STA is not in the
review cycle for all
LERs.
This duty is
performed by Senior
Specialists in Regulatory Compliance.
This example of failure to follow procedure is collectively combined
with other examples in paragraphs 6.b and 7.a, and is identified as
an example of violation 261/88-01-04.
f.
Diesel Generators (D/G)
The inspector reviewed operation of the diesel generators. During
the attempt to reconstruct
the
events of August
26,
1987,
September 8, 1987,
November 4, 1987,
and November. 5,
1987,
the
inspector noted the Shift Foreman's log and the Control Operator's
log did not contain appropriate log entries as required by OMM-001.
OMM-001,
Section 5.7.3, "Shift Logs",
paragraph 1, requires the
Control Operators log to record the plant status and events in
chronological order.
Log entries include the following:
Date
Plant Status
Changes in Generator Output
Changes in Reactor Power Level
Starting and stopping of major equipment
Change of Auxiliary System and Configuration
Changes in Reactor Control Rod group positions
Performance of surveillance tests
Instrument or equipment.malfunctions or failures
Unusual trends or conditions observed
Major in-plant electrical switching
Starting and stopping of gaseous or liquid waste releases
Setpoint changes
Performance of AOPs both immediate and subsequent actions
Performance of EOPs both immediate and subsequent actions
OMM-001, Paragraph 2, requires the Shift Foreman's log book to record
the following events:
Change in status.of equipment
Reportable occurrences
Unusual occurrences
14
Set point changes
Liquid or gas releases
Changes of major auxiliary equipment service
Significant events
Entering the emergency plan
Changes of emergency classification
Additionally, 10
CFR
50,
Appendix
B, Criterion XVII,
Quality
Assurance Records, required that sufficient records be maintained to
furnish evidence of activities affecting quality. The records shall
include at least the following:
operating logs.
Contrary to the requirements,
log entries were not adequately
.maintained on multiple occurrences during the diesel generator events
between August 26,
1987 and
September 8,
1987,
as shown in the
following chart. These examples are not all inclusive and are used
to illustrate operator log problems.
Date
Time
Missing log entry
8/26/87
0145
Both D/Gs inoperable, did not record
entry into TS 3.0 in Shift foreman's or
Control operator's log.
8/26/87
0145 -
0157
Did
not
record
D/G
investigation
.performed by Shift Foreman
in shift
foreman's log.
Two additional D/G
starts and one additional D/G trip were
not recorded in the control operator's
log.
8/26/87
1400
Seven day LCO for "A" diesel generator
inoperability not recorded in shift
foreman's or control operator's log.
8/27/87
1349 -
2330
No records of testing of "A" Diesel
generator, or, diesel generator trip in
control operator's log.
9/8/87
0545
Seven day LCO for "B" diesel generator
inoperability not recorded in shift
foreman's or control operator's log.
9/8/87
2230
Both D/Gs inoperable, did not record
entry into TS 3.0 in shift foreman's or
control operator's log.
Failure to make appropriate log entries as required by 10 CFR 50
Appendix B, Criterion XVIII and OMM-001 is considered to be violation
261/88-01-03.
15
As a result of the incomplete and conflicting information available,
the inspector requested that the licensee reconstruct a sequence of
events for 4 diesel generator events and the activities concerning
the diesel generators between the related events of August 26, 1987,
and September 8, 1987,
and the events of November 4, 1987,
and
November 5, 1987.
Although some inconsistencies exist between these
sequences of events
and existing records
and interviews,
the
inspector evaluated the sequences of events to determine procedural
and regulatory adherence during the events.
SII
SII
DIESEL GENERATOR SEQUENCE OF EVENTS
8/25/87 -
9/17/87
Date/Time
Event
8/25 0205
"A" Diesel Generator was tested in order to take "B" Diesel
Generator out of service for preventative maintenance, standby
jacket water cooling system maintenance, and other miscellaneous
work.
0348
OST-401 was successfully completed for "A" Diesel
0800 "B" Diesel Generator was removed from service under a 7-day LCO for
preventative maintenance.
8/26
-
0130
Licensed operator was sent to perform the OST-401 operability
check on "A" Diesel Generator (D/G).
0145 "A" D/G tripped on overspeed during the initial start and was
declared inoperable resulting an 8-hour LCO (T.S. 3.0).
The Shift Foreman investigated the problems with "A" D/G:
o
Governor linkage was inspected.
o
Injection
pump
inspection
covers
were
removed
for
inspection.
No apparent problems were revealed during this investigation.
"A" D/G was started again.
o
Shift Foreman observed engine governor linkage:
-
Governor appeared to be controlling engine speed
(speed indicator not provided).
-
Engine again tripped.
"A" D/G was started again.
o
This start appeared normal, and the engine was shut down by
the operator.
The Operations Manager was notified (On-Call Manager):
0
Both D/Gs were out of service.
0
No apparent cause of trips had been found.
o
The last start was successful.
0
Engine operation appeared normal.
0
There was no known history of overspeed tripproblems.
Overspeed trips were believed to have been spurious.
Date/Time
Event
17
o
The decision was then made to perform OST-401
(Normal
Operability Surveillance Test).
o
Maintenance was directed to expedite reassembly of "B" D/G.
0157 "A" Diesel was started to run OST-401 operability check.
0202 "A" Diesel paralleled to the grid.
While OST-401
was in progress, Operations Manager discussed
operability and reportability with the Director
-
Regulatory
Compliance:
0
It was determined that this event constituted a 4-hour
report.
0
It was decided that if the OST-401 testing was successful,.
"A" D/G would be declared operable.
0
It
was decided that if
the OST-401 testing was
not
successful,
Unit No. 2 would be shutdown since "B"- D/G
could not be returned to service within 8 hours9.259259e-5 days <br />0.00222 hours <br />1.322751e-5 weeks <br />3.044e-6 months <br />.
The Operations Manager directed the Shift Foreman to:
0
Complete OST-401 to return "A" D/G to service.
0
o
Perform an additional start approximately one hour after
the D/G was shutdown to increase confidence that the D/G
was operable under relatively cold start conditions.
0340 "A" Diesel separated from the grid.
0343 "A" Diesel stopped.
0350
OST-401 was completed satisfactorily. (Exit TS 3.0)
0400 "A" Diesel declared back in service.
0404
NRC Resident notified that both-diesels had been out of service.
0408
Red Phone call made to notify that both diesels had been out of
service. (10 CFR 50.72 B.2.iii)
0501 "A" Diesel restarted
successfully as directed earlier. by the
Operations Manag.er.
0506 "A" Diesel stopped. No operability problems had been noted.
0730
At the daily Unit Managers'
meeting, this event was discussed,
Although "A" D/G had started successfully the last three times,
it was decided to further investigate the overspeed trip on "A"
D/G. A technical representative from Fairbanks Morse was called
in to help investigate the trips.
Date/Time
Event
18
1118 "B" Diesel was started for an operability check to place it back in
service.
1121 "B" Diesel was paralleled to the grid.
1259 "B" Diesel was -separated from the grid.
1315
OST-401
was satisfactorily completed,
and
"B" Diesel
was
declared back in service.
1400
"A" Diesel
taken out of service under a 7-day
LCO for
preventative maintenance
and to investigate the previous
overspeed trips which had occurred at 0145 hours0.00168 days <br />0.0403 hours <br />2.397487e-4 weeks <br />5.51725e-5 months <br />.
(WR87-AMER1)
Later in the day, the technical representative arrived and found
that one fuel injection pump control rod was hanging in the open
position.
It
was believed that the trips were caused by
excessive fuel being pumped into the engine.
The pump was
replaced early the next morning.
8/27 1349
-
"A" Diesel Generator testing was conducted.
2330
1631
Unit No. 2 was shutdown due to an E-H Oil leak.
1957 "B"
Diesel was started for operability testing because "A" Diesel
remained out of service.
2145
OST-401 was satisfactorily completed for "B" Diesel.
2330 "A" Diesel was started to run the operability check.
8/28 0130
"A" Diesel declared back in service per the satisfactory
completion of OST-401.
0250
Unit 2 was returned on line due to successful E-H Oil leak
repair.
8/31 2143
"B" Diesel was started to run an operability check. "A" Diesel
was to be taken out of service to replace exhaust manifold heat
shields.
2340
"B" Diesel
was stopped and operability performance declared
satisfactory due to the completion of OST-401.
9/1
0830
"A" Diesel was taken out of service to install exhaust manifold
heat shields.
1345
"A" Diesel was declared back in service due to the successful
.completion of OST-401.
Date/Time
Event
19
9/7
2240
"A" Diesel started for operability check to remove "B" Diesel
from service for maintenance not previously completed on 8/26.
NOTE:
At this time, "A" D/G had been successfully cold started
on 2 separate occasions since 8/28/87.
9/8 0028
"A" Diesel was stopped and OST-401 was satisfactorily completed.
0545
"B" Diesel was taken out of service for maintenance under a
7-day LCO.
2236
"A" Diesel was started to perform an operability check.
o
"A" Diesel tripped on overspeed.
-
Declared out-of-service resulting in an 8-hour LCO.
2238
"A"Diesel was again started, and again tripped on overspeed.
0
Shift Foreman notified the Operations Supervisor.
O
Conference call was set up between the Shift Foreman,
Operations Supervisor, and the Operations Manager.
-
No
confidence
in "A" -diesel operability due
to
overspeed trips (apparent repeat of the 8/26 event).
-
"B" D/G could be returned to service within the Tech.
Spec. 3.0 LCO.
-
Start Plant shutdown if the "B" D/G OST is not started
within five hours.
-
If
OST-401
was
not satisfactory,
proceed to -hot
shutdown within the T.S. LCO.
P ~
On-Call Manager and the Director-Regulatory Compliance were
involved in the discussion and concurred with the
decisions.
2350
The
NRC Resident was notified of a 4-hour immediate
notification.
9/9 0208 "B" Diesel was started.for. an operability.check because "A"
Diesel
was currently out of service.
0219
Red Phone call was made to the NRC for a 4-hour significant
event.
0406
OST-401 was completed,
and "B" Diesel was declared back in
service.
0419
NRC was notified, when they called for a Daily Plant Status
Check, that "B" Diesel was operable at 0406 and that "A" Diesel
was out of service. under a 7-day LCO.
Date/Time
Event
20
1300
A PNSC was conducted to review the "A" D/G concerns.
The PNSC
appointed a project team consisting of Tech.
Support,
Mech.
Maint., ONS, and Operations personnel. The task team took steps
to obtain technical assistance representatives from Fairbanks
Morse, Woodward Governor, and independent engineering consulting
services from Trident Engineering.
9/10 0136
"B" Diesel started for operability testing because "A" Diesel
was still out of service.
0404
OST-401 was satisfactorily completed.
2015
Unit 2 was taken off-line due to a turbine generator hydrogen
cooler leak.
2046
Reactor was shut down. Redundant diesel testing is no longer
required by Technical Specifications.
9/14 0633
"A" Diesel
was
started for testing after injection pump
replacement.
1351
"A" Diesel was stopped.
1451
OST-401 was unsatisfactorily completed.
When speed droop was
reset to zero the engine speed drifted badly.
2108 "A" Diesel was run to allow governor compensation adjustment.
2239 "B" Diesel was started for operability check.
9/15 0045
OST-401 operability check for "B" Diesel was satisfactorily
completed.
-
0200
Test run of "A" D/G to test governor operation.
0615
-
"A" Diesel was run to test the governor operation per
0747
OP-604 in order to gather load indicator vs. load data.
1010
-
"B" Diesel was run to gather data for Engineering so that
1051
the maximum starting RPM's for "B" D/G could be compared to "A"
D/G.
1640
-
"A" Diesel was run for testing after the governor oil
1707
was changed.
9/16 2100
"A" Diesel was started. This run was to perform an overspeed
trip test after the trip mechanism was adjusted to give a higher
trip point. This test was satisfactory.
2102 "A" Diesel was paralleled to the grid.
Date/Time
Event
21
2212 "A" Diesel was separated from the grid and subsequently stopped.
OST-401 was completed.
Evaluation of data revealed that
improvement could be made in the balance between cylinder
temperatures.
9/17 1400
-
"A" Diesel was run for an operability check following
1541
maintenance work to balance the cylinder temperatures.
2140
OST-401 was satisfactorily completed,
and
"A" diesel
was
returned to service.
11/3/87
0401 -
"B" Diesel Generator (D/G)
was tested for operability
0545
per OST-401 (using the inboard solenoid) to take "A" D/G
out of service to perform work on its service water system.
0600 "A" D/G was taken out-of-service.
11/4/87
0505 "B" D/G was tested for operability per OST-401 (using the
outboard solenoid) because "A". D/G was still out of service.
11/5/87
0250-"B" D/G local start was attempted by a licensed operator (using
the inboard solenoid).
The
start sequence was stopped
(pushbutton released) due to audible evidence of air leaking to
atmosphere in the vicinity of the
starting air solenoid
The
operator notified the Shift
Foreman,
who
proceeded to the Diesel Generator Room.
The Shift Foreman
0
Inspected air system
O
Instructed the operator repeat start sequence, while he watched
the air start system,
in the exact manner as was previously
performed.
11/5/87
0256 A second attempt to local start "B" D/G resulted in a successful
start.. At that time, the Shift Foreman notified the operating
supervisor and was instructed to start the diesel a third time.
11/5/87
0310 A third attempt to local start "B" diesel resulted in a
successful start using the inboard solenoid.
Shift Foreman was directed to set up a conference call between
Operations Supervisor, Operations Manager,
and the Director
Regulatory Compliance.
The following is a summation of the
conference call.
0
Reviewed sequence
O
Decided on-2 potential causes
(1) Sticking check valve (non-tested side)
(2) Sticking.solenoid valve (tested side)
Date/Time
Event
22
11/5/87
0
After the successful starts:
-
It
was determined that the most probable cause was a
sticking check valve
1. Check valve flow path was used in the previous day's test.
2. The check valve apparently became unstuck during -or after
the aborted start attempt as a result of reverse airflow or
mechanical vibration.
It was recognized that, had both solenoids been lined up for
normal operation (not in the test configuration), the D/G would
have auto-started as required.
o
The D/G was considered to be operable because it
was the
local start test configuration that caused the failure to
start.
(Later,
the PNSC
recognized that the D/G should
have been considered technically inoperable prior to its
successfully starting).
o
The Shift Foreman was instructed to complete the OST.
0507
OST-401 on "B" D/G was successfully completed.
0730
The event.was discussed during the Daily Unit Managers' Meeting.
(Managers
of Operations and Maintenance later discussed the
event with Project Vice President).
It was decided to gather
pertinent information for review by PNSC.
11/5/87
1330 The
PNSC
was convened to review the EDG testing concerns,
discuss reportability issues, and recommend follow-up actions.
The PNSC directed that the following actions be taken:
0
Inspect check valves on "B" D/G.
0
Check strainers for debris.
0
If no problems found, check solenoid valves.
o
Operations to write an NCR to track resolution.
0
"B" D/G should be considered technically inoperable for the
six minutes until the
successful
start, and that a
four-hour report be issued.
Declared reportable at 1500
hours.
11/5/87
1500 The NRC Resident was notified of this event.
1847 A four-hour immediate notification was made to the NRC via the ENS.
11/5/87
1500 -
The following work was performed:
11/6/87
0525 0
A starting air solenoid from stock was set up in the I&C
Shop to give the I&C Technicians a feel for a properly
operating solenoid.
Date/Time
Event
23
o
Since "A" D/G was out of service, its strainers and check
valves were
disassembled
and
inspected.
No debris,
discoloration, or freedom of movement problems were found.
o
"B"
D/G
was
started (using
the outboard solenoid),
synchronized to the grid,
separated from the grid, and
stopped. It was verified to be operable per OST-401.
0525-0542 "A" D/G was test operated prior to installing heat shields.
0828-1030 "A" D/G was test operated per OST-401 and returned to service.
1135-1510 (The following is a summary of actions taken as directed by the
PNSC):
O
The "B" D/G
outboard strainers and check valves were
disassembled and inspected. No debris, discoloration, or
freedom of a movement problems were found.
The outboard solenoid valve was disassembled and inspected
for signs of trash or other material.
The solenoid main
plunger was checked for free operation and any signs of
sticking.
Condition of components
appeared
to
be
satisfactory.
0
"B"
D/G
was then satisfactorily started for outboard
solenoid valve testing.
1515-1643 o
The "B" D/G
inboard strainers and check valves were
disassembled and inspected. No debris, discoloration, or
freedom of a movement problem were found.
o
The inboard solenoid valve was disassembled and inspected
for signs of trash or other material.
The solenoid main
plunger was checked for free operation and any signs of
sticking.
Condition
of
components
appeared to be
satisfactory.
o
"B" D/G was then satisfactory started for inboard solenoid
valve testing.
The NCR remains open at this time.
NOTE: The licensee omitted a November 4, 1987, diesel generator
event from the sequence of events. This event involved the
inoperability of both diesel generators for less than one minute
after a motor control center was inadvertantly disabled.
24
Following the event of August 26,
1987, the licensee's cursory
corrective actions appeared inadequate to preclude repetition.
This is identified as a management weakness.
Following an
identical
failure
on
September 8, 1987,
the
licensee
aggressively began troubleshooting diesel generator problems.
Several days later the licensee found that the problem was a
defective overspeed trip mechanism and performed corrective
action.
During the Diesel Generator events of August 26, 1987,
September 8, 1987,
November
4,
1987,
and November 5,
1987
the licensee determined that these events were reportable as
four-hour events and notified the NRC as required by 10 CFR
50.72.b.2.iii.
This requires the licensee to notify the NRC
as soon as practical and in all cases within four hours of the
occurrence of any of the following;
-
Any event or condition that alone could have prevented the
fulfillment of the safety function of structures or systems
that are needed to:
o
Shutdown the reactor and maintain it
in a safe
shutdown condition,
So
Remove residual heat,
o
Control the release of radioactive material, or
0
Mitigate the consequences of an accident.
For the events of November 4, 1987,
and November 5, 1987, the
reporting requirements for 10 CFR 50.72.b.2.iii were not met in
that they were not reported within four hours as required.
Date
Report Time (following event)
8/26/87.
2 hours2.314815e-5 days <br />5.555556e-4 hours <br />3.306878e-6 weeks <br />7.61e-7 months <br /> 38 minutes
9/8/87
3 hours3.472222e-5 days <br />8.333333e-4 hours <br />4.960317e-6 weeks <br />1.1415e-6 months <br /> 41 minutes
11/4/87
21 days
11/5/87
approximately 16 hours1.851852e-4 days <br />0.00444 hours <br />2.645503e-5 weeks <br />6.088e-6 months <br />
In reviewing these events, it was determined that the
requirements of 10 CFR 50.72.b.2.iii are not. applicable.
The
requirements of 10
CFR 50.72.b.1.ii
are applicable.. This
requires that the licensee notify the NRC as soon as practical
and in-all cases within one hour of the.occurrence of any of the
following:
-
Any event or condition during operation that results in the
condition of the
nuclear powerplant,
including* its
principal safety barriers, being seriously degraded; or
results in the nuclear power plant being:
o
In
an
that
significantly
compromises plant safety;
25
o
In a condition that is outside the design basis of the
plant; or
o
In a condition not covered by the plant's operating
and emergency procedures.
The failure to follow reporting requirements of 10 CFR 50.72 is
identified as violation 261/88-01-01..
g. Technical Specification Interpretation
TS 3.3.2.2.b requires that "If
one containment spray pump becomes
inoperable during normal reactor operations, the reactor may remain
in operation for a period not to exceed 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> provided the four
fan cooler *units are operable and the remaining containment spray
pump is demonstrated to. be operable prior to initiating repairs."
The normal operating practice at HBR is not to retest the remaining
containment spray pump if it has been demonstrated operable prior.to
entering the TS action statement. This practice appears to conflict
with the literal interpretation of the TS action statement. -The
inspector did not view this as a significant safety-related problem
although this does not appear to comply with the current wording of
the TS. This issue is being referred to NRR requesting an inter
pretation of the TS.
26
9.
Commercial Grade Procurement
The licensee's nuclear procurement program was inspected with the major
focus
on
the procurement of commercial
"off-the-shelf"
items.
The
inspection was accomplished by reviewing procurement records, engineering
evaluations, and interviewing plant personnel.
a. Program Controls
The nuclear procurement program requires engineering and quality
assurance reviews for all purchase orders prior to the order being
placed. The planning staff initiates the material requisition.
The
technical support group and qualit'y assurance group then review the
material requisition to determine' the need for any technical and
quality requirements. The reordering of spare and replacement items
is generated through a computerized material management system.
b.
Implementation and Program Review
The nuclear procurement program as it relates to commercial "off-the
shelf" items has administrative controls which
are
implemented
-through the corporate material management system.
This system is
programmed to require engineering and QA approvals if any .changes are
entered. Commensurate approvals are required for the purchase of any
new item.
c.
Review of Commercial Grade Procurement
The inspector performed detailed reviews of various engineering
documents related to upgrades, re'lacements-in-kinds, and classifica
tion changes. The EEs that were written as justification for these
actions were detailed, in-depth, and adequately addressed all
concerns.
The inspector reviewed commercial1
"off-the-shelf" procurements for
selected electrical and mechanical
spare
and replacement parts.
Purchase requests for replaceme nt .items are reviewed by the
engineering technical
support group to verify that the original
specification identified the item as commercial
grade.
For items
where additional controls were or ginally required, similar controls
are again delineated.
The eng neering evaluation sufficiently
identified originally procured commercial grade items for the
procurements. reviewed.
However,
since items were originally purchased as commercial grade,
there is no way of assuring tha
later items purchased by the same
procurement
process
meet
the
original
item's
critical
characteristics.
Critical characteristics are the
identifiable
and/or measurable attributes of commercial grade items.
Commercial
27
grade vendors are not audited by the licensee; therefore,
some
special verification requirements need to be established for the
procurement of commercial grade items.
Several
mechanisms are
available to verify critical characteristics; however,
they are not
being performed.
The licensee's interpretation is that a receipt
inspection verifies an item's critical characteristics.
A receipt
inspection; however, only verifies the item's unique identification,
cleanliness, physical state, and workmanship.
FSAR Section 17.2.7 requires that for the purchase of commercial
"off-the-shelf" items where spedific quality assurance controls
appropriate for nuclear applications cannot be practically imposed,
special quality verification requirements shall be established and
described, if required, to provide the necessary assurance to CP&L of
the acceptability of the item.
CP&L Corporate Quality Assurance! Program,
Revision 10,
Part 5
Material and Equipment Control,
Section 5.5, "Off-the-Shelf Items",
requires that an engineering evaluation be performed prior to an
"off-the-shelf" item being used
n a safety-rel.ated application to
establish the suitability of the item for its intended use.
The use of commercial "off-the-shelf" items in safety-related
applications without special quality verification requirements to
0provide
assurance of the item'I acceptability is considered an
example of unresolved item 261/88-01-05 and will be forwarded to NRR
for resolution.
The inspector reviewed approximately two years of engineering
evaluations and identified that one (87171)
justified the use of
Scotch 70 tape, which was purchased as non-Q, for EQ applications.
This was justified based on an upgrade of the tape to commercial
grade.
The evaluation documented that only a visual inspection of
the tape was performed. The basis of the upgrade was a seven year
old EQ test report for Scotch 70 tape.
The use of commercial grade
items in EQ applications is acceptable only if a definite correlation
can be made between the item plurchased and the item originally
tested. This is considered to be a- further example of unresolved
item 261/88-01-05 and will be forwarded to NRR for resolution.
10.
Quality Assurance/Quality Control
Reviews of the _HBR
QA organization
effectiveness consisted of an
evaluating both the site's QA/QC organization and the co.rporate
PEU.
Assessment of each unit's activities was conducted by interviews with each
Unit Supervisor.
The inspector also conducted a detailed review of
audit/surveillance schedules,
schedulling compliance, audit/surveillance
findings, nonconformance reports, adequacy and timeliness of corrective
actions,
and the project's trend analysis programs.
The evaluation
28
concluded that the HBR
QA program
was adequately accomplishing
its
assigned function of identifying, correcting and preventing problem
recurrence. This conclusion is based on observations, discussions with
responsible management personnel and documentation reviews.
The audit/surveillance unit size and experience level is adequate.
The
inspector examined the experience, training, and qualification records for
the HBR Director of QA/QC and 22 site CP&L QA/QC personnel and determined
they were qualified in their respective areas of engineering,
surveillance, or inspection responsibilities.
Examination of the above
records and discussions with several site QA/QC personnel confirmed that
this organization has a good blend of experience (multidisciplined
backgrounds), large number of years in the nuclear (15.6 years average)/QA
(10.5
years average)
industry,
has
been rather stable with minimal
turnover of personnel,
and maintained its independence while keeping
excellent rapport with plant craft and management personnel.
These
characteristics were identified as a noteworthy strength of the QA/QC
organization.
The NRC inspector accompanied a QA/QC technician during the performance of
the surveillance of MST-021,
"Reactor Protection Train 'B' At Power",
Revision 1. Discussions with this individual concerning the subject test
procedure and systems 'involved indicated that he was well qualified to
monitor
the test and was
knowledgeable of good audit/surveillance
principles.
NCR 88-033 was generated by the I&C group to identify a
control room status light (LC-475B1)
which did not light as required
during step 31 of MST-021.
The NRC inspector witnessed the trouble
shooting of the problem authorized by WR 88-ABB11.
The relay contacts
that feed the status light were spray cleaned and subsequently tested
satisfactory.
The
in-process
QA/QC
surveillance test checklist and
MST-021 documentation recorded by I&C and control room personnel were
examined and found satisfactory.
The qualifications of six PEU audit
personnel were recently reviewed and the results were documented in NRC
Inspection Report No. 50-400/87-38 by this inspector-and determined to be
appropriate.
A formalized audit/surveillance system was in place and adherence to
schedules was
adequate.
Operations QA/QC Section Procedure 0QA-201,
"Surveillance Program", Revision 1, and Corporate QA Departmental
Procedure CQAD 80-1,
"Procedure for Corporate QA Audits", Revision 13,
require formalized systems.
The
inspector examined the HBR audit/
surveillance planning and scheduling matrices for 1986 -
1987,
the
approved first quarter
1988
schedules,
and the tentative audit/
surveillance schedule for the remainder of year 1988.
The inspector
determined that the subject audit/surveillance schedules
contained
satisfactory coverage of quality related activities and commitments
contained in the FSAR and Technical Specifications.
Adherence to these
schedules was adequate.
29
Audits/surveillances conducted appeared to be satisfactory in depth and
scope and identify some relatively significant problems for management
corrective action.
The inspector reviewed the following audits/
surveillances and their respective checklists that were performed at HBR
during 1986 -
1987:
Audit/Surveillance No.
Activity Examined
QAA/0020-86-01
HBR Operations
QAA/0020-87-01
HBR Operations
QAA/0020-87-06
Modification Process - All
Aspects
QAA/0020-87-07
HBR Activities
QAA/0104-86-01
HBR Design Engineering
Section
QAA/0127-86-01
HBR QA/QC Unit
QAA/0127-86-02
HBR QA/QC Unit
QAA/0127-87-01
Operations QA Unit
QASR/86-012
QC Activities
QASR/86-015
Procurement Control
QASR/86-057
Locked Valve List
QASR/86-081
Material and Equipment Control,
Storage and Shipping
JQASR/86-097
Personnel Training and Records
QASR/86-114
Safety Reviewer Qualifications
QASR/86-136
Control of Special Processes
QASR/86-137
Spare Parts Evaluation
QASR/87-003
Construction Activities
QASR/87-036
Outage Activities 4/5 - 4/11/87
QASR/87-056
Maintenance Work Request Program
QASR/87-063
Control of Measuring and Test
Equipment
QASR/87-099
Procurement Control
QASR/87-106
QA/QC Activities
In general, the inspector noted that the audit/surveillance reports and
related checklist items examined were verified to the depth and scope
necessary to ascertain the activities' compliance or noncompliance with
the accepted QA program. However,
comments and responses to some audit/
surveillance checklist items were very brief to the point that reconstruc
tion of the audit data would be difficult. The specifics as to what was
examined,
how examined,
sample size considered, accept/reject criteria
used, and the acceptability of the audited item were often not documented..
Also, occasionally, the response given for an audit/surveillance checklist
item either did not verify the acceptability of that item or was not
relevant to the checklist item being examined.
A few examples that
illustrate the above identified audit/surveillance weaknesses are:
30
QAA/0104-86-01
Checklist Items 2.2.24 thru 2.2.28
QAA/0127-86-01
Checklist Items 4.3, 5.1.2.5 thru
5.1.2.8
QAA/0127-86-02- Checklist Items 6.4, 6.8
QASR/86-015
Checklist Items -
Most
QASR/86-114
Checklist Items -
Most
QASR/86-136
Checklist Items -
Most
QASR/86-137
Checklist Items -
Most
QASR/87-003
Checklist Items -
Most
The inspector observed that audit/surveillance reports and related
checklist content appeared to have continually improved since January
1987. Discussions with the Project QA/QC Surveillance Specialist and the
HBR Lead PEU
QA Specialist identified that increased emphasis had been
placed in this area.
The inspector noted that checklist line items,
cancelled or not inspected on an audit/surveillance, were being conscien
tiously
examined
on
subsequent
audits/surveillances
as
stated.
Discussions conducted with the
PEU
Supervisor (Region
II
Inspection
50-400/87-38) and with the HBR QA Supervisor identified CP&L's new audit/
surveillance philosophy is changing to a more performance based concept.
A good example of this transformation at HBR is performance based audit
QAA/0020-87-06,
which examined three safety significant modification
packages-from their conception in design through installation, inspection,
turnover and filing of the record packages.
This comprehensive audit
resulted in 11 adverse findings being identified.
The fact that HBR
audits/surveillances are
becoming
more
performance
based
versus
documentation oriented was identified as another strength of the QA
organization.
A potential violation in the audit area relating to the protection of
safeguards information was identified to appropriate licensee personnel
and will be examined further by Region II Security Inspectors during their
next routine inspection.
Discrepancies identified by either site QA/QC,
Corporate audits or plant
personnel receive timely, appropriate corrective action.
The inspector
reviewed the following NCRs and ADRs for the above attributes:
ADR/NCR No.
Title
ADR/0020-87-06-F2
No Structural/Seismic Safety
Review
Conducted for Modification 908
ADR/0020-87-06-F4*
No Documented Evidence in
Modification
Package 908 of an ALARA Review
ADR/0104-86-01-C1
Training Program and Schedule Had
Not Been.Formally Established
ADR/0127-87-01-C1
"Comment Due Date" Change Did Not
Require Approval
31
NCR/86-110
RPC Craft Personnel Not Required to
Read Procedures
NCR/86-154
Quarterly Calibration Checks Not Performed
as Required
NCR/86-155
Welding and Brazing Material Control Record
Filled Out Improperly .
NCR/86-178
QA Records Not Filed in Fireproof Cabinet
NCR/87-012
Personnel Certified to Operate Forklift
Before Demonstrating Their Ability
NCR/87-013
Gripper Not Listed on Material Control Tool
List as Required
ADR/NCR No.
Title
(cont'd)
NCR/87-056
OP-305, Step 6.14.4.3 Revised Without
Temporary Change
NCR/87-069
Inspections Not Performed as Required
NCR/87-118
Indeterminate QC Witness of EQ Splice Kits
NCR/87-128
OST-10 Not Performed Within Grace Period
NCR/87-138
Engineering Evaluation Not Performed on
Torque Wrench Found Out of Tolerance.
NCR/87-155
Valve V2-26 Failed to Operate During OST-206
NCR/87-184
Reports.Not Completed for Inspections
Performed
NCR/87-185
EE 86-145 Was Not Performed Prior to
Performance of Work
NCR/87-191
QA/QC Does Not Review Work Request for
Maintenance Performed on EQE
NCR/87-222
EE 87-103 Did Not Address FSAR
Section 3.5.1.2 Requirement
Examination of the above ADR/NCR discrepancies identified that they were
properly handled. Satisfactory corrective actions were specified and the
close out of the subject discrepancies was accomplished by reinspection/
verification
of details
as
necessary.
The
PEU
has performed
satisfactorily in follow up and closing out ADRs.. A total of 14 ADRs were
identified in 1986 and 22 during 1987.
Currently, there are eight ADRs
(all issued in 1987)
open;
seven of which are pending completion of
corrective actions and are progressing satisfactorily.
The eighth ADR
(20-87-06-F5)
has been granted an extension to March
15,
1988,
for
submittal of a new response.
There were 174 NCRs issued in 1986 and 264
in 1987.
As of December 31,
1987, there were 31 "Q" and 9 "Non-Q"
type,
or a total of 40 NCRs outstanding.
The majority of these 40 open NCRs
were issued during November -
December 1987 and corrective actions are
still ongoing. Only 5 of the 40 outstanding NCRs are older than 6 months.
The oldest NCR (86-110, issued August 11, 1986) remains open deliberately
by .QA/QC to verify that the training of RPC crafts on new procedures was
being implemented properly.
NCR 87-037,
issued March
16,
1987,
has
32
generic implications affecting other plants and resolution required
extensions and escalation which has resulted in approved corrective
actions to be implemented by April 1, 1988.
Review of the remaining 3
NCRs (87-003,87-030, 87-123) determined that these items were in the
process for resolution and their long term resolution was not due to
inattention by management.
Based on the above current statistics and
discussions with responsible PEU/QA/QC personnel, the inspector concluded
that the ADR/NCR corrective action systems have been responsive and well
controlled. A strength was identified in that HBR management has placed
increased emphasis on plant personnel's use of the NCR system to identify
and correct deficiencies. This has resulted in a substantial increase in
the number of NCRs being identified during the latter half of 1987 which
were subsequently corrected.
Mechanisms were in place to recognize and prevent recurring or repetitive
discrepant conditions and upper management was made aware of these trends.
The Senior Executive Vice-President reviews and signs each corporate audit
report issued. The QA Department used several excellent nonconforming
trending/status programs that help identify adverse trends and recurring
discrepant conditions.
The inspector examined the following
HBR
and
Corporate QA discrepancy trend/status reports that are routinely presented
to CP&L's upper level management and found them satisfactory for their
intended purpose:
Corporate Quarterly Nonconformance Trend Reports (4th Quarter 1985
through 3rd Quarter 1987)
HBR QA/QC.Monthly Reports (November and December 1987)
HBR QA/QC Quarterly Surveillance Program Status Reports (1st Quarter
1986 through 3rd Quarter 1987)
11.
List of Abbreviations
Audit Deficiency Report
Office of the Analysis and Evaluation of Operational Data
Auxiliary Feedwater System
A/E
Architect/Engineer
Carolina Power and Light Company
Design Basis Document
DCN
Design Change Notice
EE
Engineering Evaluation
Environmental Qualification
EQE
Environmentally Qualified Equipment
Final Safety Analysis Report
HBR
H.B. Robinson Nuclear Plant
Instrumentation and Controls
Inservice Inspection
JCO
Justification for Continued Operation
33
LER
Licensee Event Report
Loss of Coolant Accident
Microbiologically Induced-Corrosion
Maintenance Surveillance Test Procedure
Nonconformance Report
NED
Nuclear Engineering Department
NRC
Nuclear Regulatory Commission
OST
Operations Surveillance Test Procedure
POM
Predictive Maintenance
PEU
Performance Evaluation Unit
Plant Improvement Report
Preventive Maintenance
PNSC -
Plant Nuclear Safety Committee
Power Operated Relief Valve
Potential Transformer
Quality Assurance
QAA
Quality Assurance Audit
QASR
Quality Assurance Surveillance Report
Quality Control
QER
Quality Evaluation Report
RPC
Robinson Plant Construction
Safety Injection System
System Program Chart
TRP
Temporary Repair Procedure
.
TS
Technical Specifications
Unresolved Item
Work Request