ML18019A797
| ML18019A797 | |
| Person / Time | |
|---|---|
| Site: | Harris  |
| Issue date: | 04/25/1986 |
| From: | Joseph Willis CAROLINA POWER & LIGHT CO. |
| To: | Grace J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| CON-NRC-441 HO-XXXX(O), NUDOCS 8605050338 | |
| Download: ML18019A797 (10) | |
Text
Carolina Power & Light Company OS gpss'g
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'HEARON HARRIS NUCLEAR PROJECT APR 2 5 1988 File Number:
SHF/10-13510E Letter Number.'O-XXXX (0)
NRC-441 Dr. J. Nelson Grace United States Nuclear Regulatory. Commission Region II 101 Marietta Street, Northwest (Suite 2900)
Atlanta, Georgia 30323
Dear Dr. Grace:
In discussions with members of your staff during the week of April 14, 1986 and in a telephone conversation on April 22, 1986, it has become apparent to us that the actions that we had taken to resolve the violation identified in Enclosure 1
(RII:
PAT 50-400/85-47-04) were not adequate and require extra action on our part.
The purpose of this letter is to provide a
description of the expanded actions we have underway to resolve this violation and provide scheduled completion dates for these actions.
Please find attached our revised response to the violation. It is considered that the corrective actions taken/planned are satisfactory for resolution of the item.
Thank you for your consideration in this matter.
Yours very truly, J. L. Willis Plant General Manager Harris Nuclear Project JLW/CSH/cwj Attachment cc.'Messrs.
G. Maxwell (NRC-SHNPP)
B. C. Buckley (NRC) 8605050338 860025 PDR ADOCN 05000400 G
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Attachment to CP&L Letter of Response to NRC Report RII:
PAT 50-400/85-47-04 Re orted Violation.'0 CFR 50, Appendix B, Criterion V as implemented by CP&L accepted QA program (FSAR Chapter 17.2) requires that instructions, procedures, or drawings shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
10 CFR 50, Appendix B, Criterion XVII as implemented by CP&L accepted QA program (FSAR Chapter 17.2) requires that test records shall as a
minimum, identify the inspector or data recorder, the type of observation, the results, the acceptability, and the action taken in connection with any deficiencies noted.
Contrary to these requirements, test procedure 1-2005-P-01, Revision 0, Hot Functional Test, approved December ll, 1985, provided acceptance criteria 7.1 and 7.2, which are vague and imprecise as follows:
7.1 Reactor Coolant System heat-up has been satisfactorily demonstrated within limitations listed or referenced in the steps of this procedure (Section 6.1).
7.2 Supporting Systems and Components have demonstrated satisfactory operation as described in the steps of this procedure.
Furthermore, as of December 20,
- 1985, the procedure steps and data sheets listed below did not prescribe quantitative, or qualitative acceptance criteria, normal operating ranges or limitations to evaluate the test results and the acceptability of the test data.
10.2 10.4 10.5 10.8 10.9 10.18 Reactor Coolant Pump Data Incore Cooling (ICC) Monitor gl Seal Data w/RCP's Secured gl Seal Data w/RCP's Energized Containment Ventilation CRDM Cooling Fan Temperature In addition, the following sets of data do not have have a
verification signature and data to identify the data recorder for data sheets:
10.2, 10.4, 10.9, 10.10, 10.11, 10.12, 10.13, 10.14, 10.16, 10.18, 10.19, 10.20, 10.21, 10.22, and 10.23.
This is a Severity Level IV violation (Supplement II).
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Denial or Admission and Reason for the Violation:
The violation is correct as stated.
In the first part of the violation the acceptance criteria in Section 7.1 and 7.2 of 2005-P-01 was vague in that it referenced steps in the procedure in general (i.e., referred to 6.1 and "steps in this procedure" respectively) and should have been worded in a more precise manner.
Procedure 2005-P-01 data sheets 10.2,, 10.4, 10.5, 10.8, 10.9, and 10.18 listed data to be recorded without either providing definite acceptance criteria or indicating that the data was being recorded for "baseline data" or "for information only".
There was no method described to evaluate for acceptability of the data that was "for information only" but which did not have definitive acceptance criteria defined in the procedure.
The second part of the violation was due to CP&L's misinterpretation of the requirements for having a "data recorded by" signature or initials on each Data Sheet within a preoperational test procedure.
CP&L's interpretation had been that when data was recorded on a Data Sheet at the direction of a procedural step within the body of the procedure which had an initial/date blank (
/
), that another signature on the Data Sheet was not required.
Corrective Ste s Taken and Results Achieved:
In response to the violation that the acceptance criteria of 7.1 and 7.2 were vague and imprecise, these criteria were modified in Revision 1 to 1-2005-P-01.
Specifically, the changes were as follows:
7.1 of Revision 0 which read as follows.
7.1 Reactor Coolant System heat-up has been satisfactorily demonstrated within limitations listed or referenced in the steps of this procedure (Section 6.1).
was changed in Revision 1 to read as follows'.
7.12 Reactor Coolant System heatup has been satisfactorily demonstrated within the limitations listed or referenced in the steps of this procedure (Section 6.1).
7.12.1 RCP baseline vibration data has been recorded (6.1.6 and Data Sheet 10.2).
7.12.2 RCP's have operated to obtain baseline Mims data (through 1-1095-P-Ol).
7.12.3 Preliminary pressurizer spray valves settings have been made (Data Sheet 10.10).
7.12.4 The reactor coolant loop flow trip and alarm operation has been verified at the setpoints specified in Reference 4.2.2 (Step 6.2.5 and Data Sheet 10.11).
7.2 of Revision 0 which read as follows:
7.2 Supporting Systems and Components have demonstrated satisfactory operation as described in the steps of this procedure.
was changed in Revision 1 to read as follows.'.9 Supporting Systems and components have demonstrated satisfactory operation as described in the steps of this procedure.
(Sections 6.1, 6.2 and 6.3 and Data Sheets 10.5, 10.6, 10.7 and 10.8).
7.9.1 CVCS System responds to pressure changes when the RCS is in a water solid condition (6.1.5 and Data Sheet 10.7).
The above corrective action was taken in response to the original violation.
In retrospect, and after additional discussions with members of your staff it was evident that our corrective actions were not totally adequate and the following additional actions have been taken.
A memorandum to file (File No. SHF/10-16050, Letter No. MS-862272 (0) has been written to provide further clarification of how the procedure steps and collected data supports these acceptance criteria.
In order to support the acceptance criteria of 7.12 (Revision 1 to 1-2005-P-01) specific procedural steps as well as the Plant Operating Manual General Procedures (GP-001 and GP-002) have been listed.
This memorandum to file will be submitted to the Joint Test Group review group (discussed in New Corrective Action section) for their evaluation and inclusion in an addendum test report.
In the case of 7.9 (Revision 1 to 1-2005-P-01),
additional clarification has also been provided.
A listing has been made of those preoperational and functional test procedures performed during Hot Functional Testing that demonstrated satisfactory operation of various systems and plant components.
Violation PAT 50-400/85-47-04 also listed several data sheets that did not have a verification signature and date to identify the data recorder.
Corrective action was reported in our letters HO-860239 (0), MS-862027 (0).
A subsequent review has shown that one of the data sheets, Data Sheet 10.18, CRDM Cooling Fan Temperature, at the time of test performance did not have verification signatures and dates to identify the data recorder.
Memorandum to file (File No.
SHF 10-16050, Letter No. MS-862272 (0) identifies the persons by signature who recorded the data on Data Sheet 10.18.
Corrective Ste s Taken To Avoid Further Nonconformance:
The actions previously planned and taken to correct the identified violation and prevent reoccurence were provided in our original letter HO-860239(0) and supplemental letter MS-862027 (0).
The actions taken by us were to identify by written memorandum to Start-Up Personnel that preoperational test procedures must have definitive acceptance criteria for data recorded for the purpose of determining that equipmentlsystems meet design performance requirements or regulatory commitments.
The guidance further stated that any data recorded in the procedure for comparison to future operating conditions without clear acceptance criteria must be identified as "baseline" or "for information only" data.
We required our Engineers to review completed and approved (but not run) test procedures for definitive acceptance criteria, baseline
- data, and missing signature blanks from data sheets as addressed in the violation.
Procedures in review cycle or being written were to be corrected before approval.
After further discussions with your personnel during the week of April 14, 1986, it became apparent that our corrective action was not correctly focused and had not adequately resolved the issue.
This was, in our opinion, caused in part by the fact that our procedure reviews were performed by the same Engineers and supervisors in the Start-Up Group that have been intimately involved with researching requirements, writing, and performing the test procedures being reviewed.
In addition, our efforts to develop a clear and uniform understanding among the 60 Start-Up Engineers of what constitutes appropriate acceptance criteria and what delineates baseline data were not fully effective.
Thus in retrospect, reviews by a large number of Engineers without consistent understanding of all of the issues involved resulted in the reviews being focused on missing signature blanks on data sheets and looking for baseline data rather than making the Section 7 criteria clear, definitive, and user friendly.
Another factor was the fact that the SUM Section 11 (Page 11 - 10) requires each step in Section 6.0 of the procedure to have acceptance criteria, and therefore the Engineers considered more general Section 7 acceptance criteria statements to be acceptable.
Therefore, the Section 7 statements did not receive the attention necessary to resolve the valid concern expressed in your violation.
Additionally, the Startup Manual gives good examples of clear acceptance criteria but did not provide examples of ambiguous and thus un-acceptable statements to bound the acceptance criteria.
Several general and thus un-acceptable statements will be added to the SUM as examples.
New Corrective Action:
Having analyzed what we consider our earlier weaknesses to have been in resolving this issue, we are taking the following. actions in addition to those identified in our earlier responses',
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A Task Force of qualified personnel has been established to review preoperational tests in progress and those not started to ensure that acceptance criteria in Section 7
is unambiguous and user friendly, detailed, (i.e.
contains specific values or references specific Section 6 procedure steps or subsections),
and that baseline data is clearly identified in the procedure.
This Task Force consists of three Start-Up Personnel, representatives of Operations QA, On-Site Nuclear Safety Review Group, and Contract Westinghouse Engineers.
The Westinghouse Engineers have been brought on site solely for this purpose and provide additional experience from other sites.
The Task Force works to a w'ritten charter and written review checklist to ensure that the correct areas are covered.
The procedure being reviewed by a single body of trained and experienced personnel ensures.
consistent reviews, detailed reviews, and fresh, independent scrutiny by people both on and off site who are not intimately involved with the program.
This fresh talent is complemented by the assigned Start-Up Engineer for each procedure and other members of the Task Force from Start Up who are familiar with our administrative requirements and commitments.
Preoperational testing was delayed until applicable test procedures could be reviewed.
Before any additional preoperational tests are run, they will be reviewed by the Task Force and any concerns resolved through revision or TCN and the Task Force re-reviewing the changes to ensure that they are correctly incorporated.
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To make the procedure more user and audit friendly, sign-off steps are being added for each acceptance criteria subsection in Section 7,
and the test objectives, test steps in Section 6.0, and acceptance criteria in Section 7.0 grouped and correlated where practical to make verification of acceptance easier.
The Section 7.0 is also being typed on a separate page in the procedure so that it can be easily pulled out during reviews and compared to test steps in Section 6.0.
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A training outline covering items in this violation, stressing good test preparation, and concentrating on all aspects of the acceptance criteria concerns has been developed.
All Start-Up Engineers as well as representatives of QA, Operations,
- HPES, and the JTG Members who review procedures will be trained.
Training for Start-Up Engineers will be completed before any additional preoperational tests are performed.
The JTG and review staff personnel will be trained by May 2, 1986.
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In light of our new sensitivity to the issues outlined in this violation, we do not feel that our earlier JTG reviews of completed test procedures may have been detailed enough.
Therefore, a Non-Conformance Report (NCR) has been written against the JTG Review process and identifies all JTG accepted preoperational test
- procedures.
To close this NCR a permanent review group of experienced contract personnel with experience in reviewing test results and procedures for other nuclear power plants will be formed as the JTG STAFF to review all JTG accepted preoperational tests.
They will evaluate the accepted test results using a checklist similar to the one described above for procedures that have not been tested.
The Staff review results will be evaluated and any clarifications needed for the completed procedures including any previous memoranda to file, consolidated in a test report addendum.
This addendum, along with the procedure, will be re-reviewed and approved by the JTG.
The review will also identify whether any tests need to be re-run.
This review will be completed by May 23, 1986.
Date When Full Com liance Was or Will Be Achieved:
Full compliance is pending completion of "Corrective Steps Taken to Avoid Further Nonconformance" as stated above.
It is projected that full compliance will be achieved by May 23, 1986.
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