ML18004B620

Responds to NRC Re Violations Noted in Insp Rept 50-400/86-68.Corrective Actions:Maint Work Control Procedure Revised to Enhance Control Re Vendor Assistance & QC Personnel Received Addl Training

ML18004B620
Person / Time
Site:	Harris
Issue date:	11/15/1986
From:	Watson R CAROLINA POWER & LIGHT CO.
To:	Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
References
CON-NRC-495 HO-860366-(), HO-860366-(0), NUDOCS 8612020194
Download: ML18004B620 (27)

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@ME, Carolina Power & Light Company HARRIS NUCLEAR PROJECT P. 0.

Box 101 New Hill, North Carolina 27562 File Number.'HF/10-13510E Letter Number.'HO-860366 (0)

Dr. J. Nelson Grace United States Nuclear Regulatory Commission Region II 101 Marietta Street, Northwest (Suite 2900)

Atlanta, Georgia 30323 NRC-495

Dear Dr. Grace:

In reference to your letter of October 17, 1986, referring to RII:

50-400/86-68-01, the attached is Carolina Power

& Light Company's reply to the violation identified in Enclosure l.

It is considered that the corrective actions taken are satisfactory for resolution of the item.

Thank you for your consideration in this matter.

Yours very truly, z~

R. A. Watson Vice President Harris Nuclear Project RAW:kgo Attachment cc'.

Messrs.

G. Maxwell (NRC-SHNPP)

B. C. Buckley (NRC) 8612020194 861115 l

PDR ADOCK 05000400 G

PDR,.

MEM/8603660/1/OS2

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Dr. J. Nelson Grace Page 2

NRC-495 Attachment to CP&L Letter of Response to NRC Report RII-50-400/86-68-01 Re orted Violation.'0CFR50.55(f)(l) requires CP&L to implement the Quality Assurance Program described or referenced in the Preliminary Safety Analysis Report.

Section 1.8.5.5 of the CP&L Quality Assurance Program require that measures be established to insure that activities are conducted in accordance with documented instructions and procedures.

Maintenance Management Manual MMM-001, Sections 4.4 and 5.5.

and MMM-012, Section 5.4 and Appendix B require that maintenance be conducted in accordance with an approved WR&A.

Contrary to the above, maintenance personnel performed work on two steam generator power operated relief valves which were not identified on WR&A 86-AUAK1.

b.

Quality Assurance Procedure QAP-202, Section 7.1 requires that QA identify necessary QC hold points in WR&A's.

Contrary to the above, QA personnel failed to identify the necessary QC hold points on WR&A 86-AUAK1.

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Quality Assurance Procedure QAP-202, Sections 7.4 and 7.5 require that QA personnel review WR&A's to ensure that the documents reflected the actual work performed.

Contrary to the above, QA personnel failed to provide an adequate review of completed WR&A's 86-ABXAl, 86-ABXA2, 86-ABXA3~

d.

Quality Control Procedure QCP-302, Section 7,

and Maintenance Management Manual Procedure MMM-001, Sections 4.4 and 5.5.8, and MMM-012, Section 5.4 and Appendix B require that inspections be conducted by QC personnel at established hold points.

Contrary to the above, QA personnel failed to perform the required QC hold point inspections for WR&A's 86-AXTAl, 86-AXTBl, 86-AXTD1, 86-AXTEl, 86-AXTQ1, 86-AXTR1, 86-AXTS1, 86-AXTTl, and 86AXTUl.

e.

Section 7 requires that nonconforming conditions be documented on a Nonconformance Report.

Contrary to the above, QC supervision failed to properly document an identified nonconforming condition, an improperly controlled WR&A, (86-AUAK1).

This is a Severity Level IV violation (Supplement II)~

MEM/8603660/2/OS2

Dr. J. Nelson Grace Page 3

NRC-495 Denial or Admission and Reason for the Violations The violation is admitted as stated in parts a

& e of the Notice of Violation.

The violation is admitted with clarification for part d.

Parts b

& c are not considered to be violations of procedures as discussed below.

Maintenance personnel performed work on two spare steam generator safety valves (in lieu of two steam generator power operated relief valves as stated in the Notice of Violation) which were not specifically identified on WR&A 86-AUAK1.

WR&A 86-AUAKl was initiated as an assist work request to provide general labor in assisting the start-up engineer and vendor representative in performing adjustments on the steam generator safety valves.

Since the work request was initiated and planned as an assist ticket only, it did not address all valves.

Only one valve was mentioned to get the work request into AMMS (Automated Maintenance Management System) with a specific I.D. It was assumed it would not be necessary to mention all 17 valves since only labor was planned and traceability to specific valves by specific I.D.

was not considered necessary.

b.

Investigation shows that the requirements of QAP-202 were met in the initial review of WR&A 86-AUAK1.

At the time of QA initial review, no QC hold points were indicated or required by the QC Hold Points list in procedure MMM-01.

The repair instructions, did not specify any work that would warrant application of QC hold points.

When QC personnel observed that actual work involved a different valve than that identified on the WR&A, the work was stopped and WR&A's were written to cover'he actual work to be done.

The new WR&A's issued for work on installed valves contained appropriate QC hold points.

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Investigation shows that reviews of WR&A's 86-ABXA1, 86-ABXA2

& 86-ABXA3 were adequate.

Initial QA reviews of the WR&A's in question were performed in accordance with QCI-25.1, Maintenance WR&A Initial and Final Review, which was in effect at the time 1 30 86).

This instruction, which was designed to limit QA reviews to portions of the form which affect quality, did not require review of the "Nature of Trouble" block.

Information in this block is not used in accomplishing work and is not the block used to identify the equipment to be worked on.

The planner does not correct errors in the "Nature of Trouble" block, but ensures that the "Repair Instructions" are appropriate and adequate based on his investigation of the problem.

Final QA reviews of the WR&A's in question, which were completed in April, 1986, were performed in accordance with Operation A/

C Unit procedure QAP-202, Review of WR&A's.

The reviews verified that the work performed was consistent with the repair instructions given for the work.

MEM/8603660/3/OS2

Dr. J. Nelson Grace Page 4

NRC-495 d.

On review of the WR&A and associated FCR, the QC Specialist determined, that the required verifications could be satisfactorily performed after the work was complete through inspections performed at final walkdown.

In the judgement of the QC Specialist, verification of the use of proper materials and crimping tools followed by post maintenance testing would provide adequate assurance that the splices would perform satisfactorily in service.

While supervisory judgment is provided for in procedure MMM-001, the intent is to have inspection hold points, at least equivalent to those required at initial installation, during modification work.

This would have included witnessing the splicing operations for the WR&A in question.

e.

The QC Supervisor, having discussed the situation with inspection and maintenance personnel, decided to describe the incident in a QC Monitoring Report rather than a

Nonconformance Report.

This decision= was based on his knowledge that the work performed was in accordance with an approved Field Change Request and that the deficiencies related to the Work Request

& Authorization (WR&A) Form had been corrected.

Corrective Ste s Taken and Results Achieved:

WR&A's AUAK (2 through 9) and AUAK (A through I) were initiated on July 24, 1986 to control and document work on each of the referenced valves.

b.

Not applicable.

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Not applicable.

d.

All nine of the splices were removed and reworked, with hold points for QC inspector witnessing the crimpi'ng and application of heat shrink insulation sleeves.

This was done before a final QC walkdown of the original work was performed.

e.

NCR OP-86"0064 was issued to identify that "QC identified a nonconforming condition concerning Main Steam safety valves and a nonconformance report was not issued."

NCR's OP 0061 and OP-86-0065 were issued to Start-up and Maintenance, respectively, to identify specific nonconformances associated with work on the Main Steam relief valves.

These three NCR's have been closed and the work on the relief valves has been completed.

MEM/8603660/4/OS2

Dr. J. Nelson Grace Page 5

NRC-495 Corrective Ste s Taken to Avoid Further Noncom liance'.

MMM-012 "Maintenance Work Control Procedure" has been revised to enhance control concerning vendor assistance WRSAs.

MMM-012 now states that generic assist type work requests will not be processed for vendor assists.

In addition, MMM-012 specifically states that vendor work being done on more than one component will have individual work requests for each tag number or specific I.D.

Training for applicable maintenance personnel regarding the subject changes to MMM-012 has been accomplished.

b.

Not applicable.

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Not applicable.

d.

QC supervisory personnel have been instructed to take the more conservative approach to assigning inspection hold points whenever the WR&A is not specific or is unclear.

Basing decisions on actions needed to assure quality without yielding to pressures of convenience and expediency was emphasized.

Process control procedures under development for future modification work will include'andatory inspection hold points.

e.

QC personnel have received additional training on appropriate procedures and the Section policy on the timely issue of nonconformances.

QC supervision have been counseled on procedure interpretation and the nonconformance control policy to be followed.

Date When Full Com liance Was Achieved:

Full compliance was achieved on October 2, 1986.

MEM/8603660/5/OS2

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September 25, 1986 Docket No. 50-400 License No.

CPPR-158 Carolin~Power and Light Company ATTN:v Nr. E.

E. Utley Senior Executive Vice President Power Supply and Engineering and Construction P. 0.

Box 1551

Raleigh, NC 27602 Gentlemen:

SUBJECT:

NRC INSPECTION REPORT NO. 50-400/86-67 This refers to the Nuclear Regulatory Commission (NRC) inspection conducted by N. A. Scott on September 2-5, 1986.

The inspection included a

review of activities authorized for your Shearon Harris facility.

At the conclusion of the inspection, the findings were discussed with those members of your staff identi-fied in the enclosed inspection report.

Within the scope of the inspection, no violations or deviations were identified.

In accordance with Section 2.790 of the NRC's "Rules of Practice,"

Part 2, Title 10, Code of Federal Regulations, a copy of this letter and its enclosure will be placed in the NRC Public Document Room.

Should you have any questions concerning this letter, please contact us.

Sincerely,

Enclosure:

NRC Inspection Report

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R. A. Watson, Vice President

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Harris Nuclear Project D. L. Tibbitts, Director of Regulatory

/ Compliance

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L. Willis, Plant General Hanager bcc w/encl:

(See page 2)

(original signed by )

David N. Verrelli, Chief Reactor Projects Branch 2

Division of Reactor Projects

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Carolina Power and Light Company September 25, 1986

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C. Barth, OGC v J.

Moore, OGC MRC Resident Inspector Document Control Desk State of North Carolina RII RII MSco4t: cdg ABe 1 is 1 e 09 /f/86 09/ P/86 Rii t

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+**pe Report No.:

50-400/86-67 1

UNITED STATES NUCLEAR'REGULATORYCOMMISSION REGION II 101 MARIETTASTREET, N.W.

ATLANTA,GEORGIA 30323 L l Licensee:

Carolina Power and Light Company P. 0.

Box 1551

Raleigh, NC 27602 Docket No.:

50-400 Facility Name:

Harris 1

Inspection Conducted:

September 2-5, 1986 Inspector:

cott Approved by:

G.

Be s e, c

ng ection Operations Branch Division of Reactor Safety 1

t bt ref License No.:

CPPR-158 7-zZ -4, Date Soigne ate sgne

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SUMMARY

Scope:

This routine, unannounced inspection was conducted in the area of licensee action on previously identified inspection findings.

Results:

No violations or deviations were identified.

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REPORT DETAILS Persons Contacted Licensee Employees G. Campbell, Maintenance Manager L. Capps, Technical Support, Materials

• N. Chiangi, Quality Assurance/Quality Control (QA/QC) Manager

• J. Collins, Operations Manager J. Corey, Construction Project Manager

• C. Gibson, Assistant to Plant Manager

• K. Hate', Principal QA Engineer

• B. Herring, Technical Support, Materials M. Jackson, Maintenance Project Engineer

• R. Lamb, Harris Plant Engineering Section (HPES) Engineer

• T. Lentz, Technical Support Manager

• L. Loflin, HPES Manager

• L. Ollivier, Technical Assistant L. Olsen, Technical Support Project Specialist

• S. Rea, Technical Support Engineer

• D. Tibbits, Regulatory Compliance Manager

• M. Thompson, HPES Engineer

• R. Van Metre, Technical Support Manager

• M. Wallace, Compliance Engineer

• D. Whitehead, QA/QC Manager Other licensee employees contacted included engineers, technicians, and office personnel.

NRC Resident Inspectors

• G. Maxwell S. Burris

• Attended exit interview 2.

Exit Interview 3.

The inspection scope and findings were summarized on September 5, 1986, with those persons indicated in paragraph I above.

The inspector described the areas inspected and discussed in detail the inspection findings listed below.

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 inspector during this inspection.

Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.

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4.

Unresolved Items Unresolved items were not identified during this inspection.

5.

General This inspection was performed to close out inspector followup items

( IFI) available for closure prior to operational licensing of the plant.

The items were previously identified during NRC inspections that reviewed programmatic licensee activities prior to operation.

Future inspections will close the remaining IFIs when the licensee has taken the necessary corrective action.

Section 6 of this report addresses the IFIs reviewed during this inspection.

This section also indicates the reason for closure or nonclosure of the item.

Additionally, the section provides comments regarding areas of interest surrounding the IFIs.

The inspector reviewed the following additional or altered (since the previous inspections) procedures Nuclear Engineering and Licensing Department Procedures, Revision 19 3.0 Engineering Procedures Harris Plant Engineering Section Manual of Instructions, Revision 44 2.0 Administrative Instructions 3.0 Engineering Instruction MMM-012 HPES 3.22 HPES 3.25 AP-24 Maintenance Work Control Procedure, Revision 5 (Draft)

Process, Control, and Resolution of PCRs, Revision 46 (Draft)

Process, Control and Resolution of FRs, Revision 46 (Draft)

Temporary Bypass and Wire Removal Control, Revision 0, A/C 0/3 AP-102 AP 600 AP-IX-09 AP-IX-34 Authorization for HPCS Work, Revision 0, Change 2

Plant Change Request Initiation, Revision 2

Field Contract Administration, Revision 4

Control of Construction Work on Operational

Systems, Revision 0

PLP-601 MOD-103 Plant Confirguration Control

Program, Revision 2

Engineering Evaluations, Revision 6

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MOD-200 Review and Approval of Modifications, Revision 3

MOD-201 Technical

Reviews, Revision 2

MOD-202 Modification Implementation, Revision 1

MOD-206 Temporary Modifications, Revision 0

6.

Licensee Actions on Previously Identified Inspection Findings (92701) a ~

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(Closed)

Inspector Followup Item (86-33-03):

Transfer of Construction Records to Operations Based on a Carolina Power and Light memorandum (dated July 2, 1986) from the gA/gC Director, a

completion of transfer date has been established.

The memo, titled "Response to IFI 86-33-03", indicates, in part, that "a target date of December 31, 1987 was established for completion of the records transfer.

This date is based on commercial operations commencing in December 1986."

(Closed)

Inspector Followup Item (86-33-05):

Expiration of Temporary Changes to Procedures The inspector reviewed a procedure change which limited the time span of a temporary change.

Revision 4 to AP-007 limited active life of a temporary change to any procedure to 21 days and the change itself must be reviewed by a

manager in 14 days of issue.

Further, temporary changes issued during outages did not expire until 21 days after the end of the outage.

Sections 5.2.14 and 5.2. 15 of AP-007, which dealt with actions after a

temporary change implementation and after the change was found to be unacceptable, contained "should" statements that were more appropri-ately imperative in nature.

The licensee issued a change during the inspection period which was reviewed by the inspector that replaced the conditional statements.

(Closed)

Inspector Followup Item (86-33-07):

Control of Shaft Keys The inspector reviewed licensee actions concerning shaft key controls.

The licensee stated that the materials group of the technical support sections identified all motor shaft keys in storage and those motor shafts on safety related equipment which would require keys.

The keys that had been attached to motors in storage were stated by the licensee to have been assigned unique identifiers and stored separately.

Shaft keys procured or yet to be procured were stated by the licensee to have been entered into the equipment data base computer program as repair parts.

The end use process for repair parts is administratively controlled by procedure MMM-012.

The licensee stated that the motor vendors were being contacted for additional key specification infor-mation.

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Procedure MMM-012 generally required that repair parts be obtained via this instruction.

Repair parts were required to be drawn from stores under unique identifiers.

Repair parts not identified in the equipment data base (i.e., uniquely identified for safety related applications) must be procured or obtained via an engineering evaluation process described procedurally in a technical support section instruction.

As the operational procedures become effective, older instructions are being phased out.

Engineering Work Requests (EWR) used to obtain engineering evaluations were still in existence as those evaluations proceed.

MOD-103, which utilizes Plant Change Requests (PCR) for evaluations, will replace EWR procedures.

Regulatory Compliance was responsible for cancellation of EWR procedures at the time of this inspection.

(Closed)

Inspector Followup Item (86-33-08):

Inconsistent Designation of Procurement Requisition Forms The inspector reviewed PMC-001 (AC 2/2 of May 29, 1986),

Procurement and Cataloging of Parts,

Material, Equipment and Ser vices.

This procedure was consistent in its terminology with regard to procurement forms.

(Closed)

Inspector Followup Item (86-53-01):

HPES Procedures The inspector reviewed selected HPES procedures as stated in paragraph 5.

Procedure HPES 3.24 which was listed in NRC Inspection Report No.

50-400/86-53 was issued by the licensee as HPES 3.25.

(Open)

Inspector Followup Item (86-53-02):

Changes to Design Modification This item remains open based on the need for further licensee action.

MOD-202 was revised to reference Field Revision (FR) review per HPES 3.25.

HPES 3.25 was issued containing some wording problems with regard to ANSI N45.2.11; the procedure did not assure that the FR would be subject to the same design control measures that were applied to the original design.

This was discussed with the licensee and the licensee showed the inspector an unapproved draft potentially correcting the problem.

Based on the draft status of the procedure and the fact that the licensee wanted to consider expanding the pertinent segment of the instruction after an impending engineering training session, the item was left open.

(Closed)

Inspector Followup Item (86-53-03):

Temporary Modifications The inspector reviewed MOD-206.

This procedure addressed temporary modifications on operable equipment.

(Closed)

Inspector Followup Item (86-53-04):

Independent Review and Corrective Action

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The inspector reviewed a revision of procedures dealing with evalua-tions.

AP-600 was revised to assess operability requirements that a

Plant Change Request (PCR) may alter.

NOD-103 was changed to assess PCR reportability potential.

(Closed)

Inspector Followup Item (86-53-05):

Option or Recoranendation Statements in Design Procedures The inspector reviewed selected Technical Support and HPES procedures for conditionality statements.

Conditionality statements had been deleted.

Again, due to the out of place "should" statements found in AP-007 (see subparagraph "b" above),

the licensee's attention is directed to any other option or recommendation statements to be found within site procedures.

(Closed)

Inspector Followup Item (86-53-06):

Procedural Completion for Groups Involved in Design Control The inspector performed a comparison of selected standard requirements to actual site programmatic requirements.

Standards such as ANSI N45.2.11 and N18.7-1976 reflect general, minimal requirements which the licensee has adopted via their accepted quality assurance program.

The inspector verified that programmatic attributes of the standards have been incorporated into site applicable procedures.

During the preoperational

phase, procedures have developed at the site as requirements have been identified, as site groups have determined their interface

points, and as perceived needs have arisen.

Engineering aspects of design control have been given the greatest programmatic effort.

The engineering procedures require that all groups utilize the PCR administrative method in the modification process; other site applicable procedures minimally evoke the engineering procedures.

A loose framework of contractural controls was present to bind outside contractors to site requirements.

Although the framework is present, construction project engineering was preparing an additional administrative instruction (tentatively identified as AP-33) which should solidify the contractural procedural framework.

At the time of the inspection, quality assurance was the final reviewer in the PCR and contract process.

(Closed)

Inspector Followup Item (86-53-07):

Design Bases Packages The inspector reviewed the procedural control of design input on site.

The initial architect-engineer has turned over the design input, which contains the Plant design bases to HPES.

Administrative procedures are present to control use of the original design input.

As stated by the licensee, the original architect was hired to develop design bases packages from the aggregate corpus of the input to facilitate use and summarize information on a

system level.

The

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s sk licensee stated that the design bases were retrievable for design use and general plant application.

The packages were stated as not being required for the design process.

The inspector did not examine the implementation aspects of the process.

Previously when the IFI was written, the licensee had indicated that the design bases packages would be completed by August 1986.

Since that time, review personnel had been reallocated to other projects of higher priority.

The target date for completion of the design bases packages has slipped to approximately December 1986.

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