ML20054C498
| ML20054C498 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 08/18/1981 |
| From: | Moseley N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | Utley E CAROLINA POWER & LIGHT CO. |
| Shared Package | |
| ML20054C499 | List: |
| References | |
| NUDOCS 8204210202 | |
| Download: ML20054C498 (6) | |
See also: IR 05000261/1981005
Text
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NUCLEAR REGULATORY COMMISSION \\ ',.(J!llhh ( 6- [\\
WASHING T ON, D C. 20555
- y'f %, .....f AUG 1 : E01 E 70 Docket No. 50-261 - . f[CN'( Carolina Power and Light Company d')r ATTN: Mr. E. E. Utley Executive Vice President '- 2 , /J,"in Power Supply and Engineering lif , s- and Construction 7 o .W ; - , ~G y -O 411-Fayetteville Street - f. -," Raleigh, North Carolina 27602
o ' Gentlemen: %. x 50-261/81-05 (PAS) ' Q 'y ::i , Subject: Performance Appraisal Inspection -- This refers to the Performance Appraisal Inspection conducted by Mr. A. T. Gody l and members of the Performance Appraisal Section Office of Inspection and , ' Enforcement, on June 22-July 2 and July 13-17, 1981, of activities authorized i by NRC Operating License No. DPR-23 for the H. B. Robinson Nui:lcar Plant. This also refers to the observations discussed with you and other members of ' your staff on June 26, July 2, and July 17, 1981, at the H. B. Robinson Nuclear Plant and the Carolina Power and Light Company corporate office. This inspection is one of a series of Performance Appraisal inspections 'being l conducted by the Office of Inspection and Enforcement. The.results of these inspections are used to evaluate, from a national perspective, the performance of your management control programs in support of Nuclear Safety. The enclosed report 50-261/81-05 (PAS) identifies the areas examined during the inspection. Within these areas, the review consisted of a comprehensive examination of your management controls over licensed activities, including an examination of procedures and records, observations of work activities and interviews with management and other personnel. i While the enclosed report includes observations which may result in enforcement dCtions, these matters will be addressed by the IE Regional Office. The enclosed report also addresses other observations and the conclusions made by the team for this inspection. Section 1 of the report provides further information regarding the observations and how they will be utilized. Appendix A to this letter is an Executive Summary of the conclusions drawn for the eight functional areas inspected. l l 8204210202 010818 PDR ADOCK 05000261 G PDR . ._ _ ._ - ._- - _ _ . -___
. . t O Carolina Power and Light Company 2 AUG 181991 Of the eight areas inspected.and evaluated, seven areas were considered Average while one area, the Corrective Action System, was considered Below Average. As a result of the significant weaknesses identified in the one area considered Below Average, you are requested to inform this office within 30 days of receipt of this letter of the actions you have taken or plan to take to improve the management controls in this area. Your response to this office concerning the area identified as Below Average will be followed by the IE Regional Office. l l In accordance with 10 CFR 2.790 of the Commission's regulations, a copy of this letter, its enclosures and your response will be placed in the NRC's If this report contains any information.that you (or ' Public Document Room. your contractors) believe to be exempt from disclosure under 10 CFR 9.5(a)(4), l it is necessary that you (a) notify this office by telephone within seven (7) l l days from the date'of this letter of your intention to file a request for ' withholding; and (b) submit within twenty-five (25) days from the date of l this letter a written application to this office to withhold such information. If your receipt of this letter.has been delayed so that less than seven (7) ! days are available for your review, please notify this office promptly so that l Consistent with Section 2.790(b)(1), any such l a new date may be established. application must be accompanied by an affidavit executed by the owner of the l information which identifies the document or part sought to be withheld, and which contains a full statement identifying the basis upon which it is claimed This section that the information should be withheld from public disclosure. further requires the statement to address.with specificity the considerations I listed in 10 CFR 2.790(b)(4). The information sought to be withheld shall be If.we incorporated as far as possible into a separate part of the affidavit. do not hear from you in.this regard within the specified periods noted above, t the report, its enclosures and your response will be placed in the Public ' Document Room. If you have any questions concerning this inspection, we will be glad to discuss them with you. ' Sincerely, l Y
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, c:~,. forman C. Moseley, Director Division of Program Development and Appraisal l Office of Inspection and Enforcement Enclosures: . 1. Appendix A - Executive.Sumary 2. IE Appraisal Report No. 50-261/81-05(PAS)
. , , . Distribution: (w/ Appendix A) Chairman Palladino Commissioner Gilinsky Commissioner Bradford Commissioner Ahearne Commissioner Roberts SECY OCA (3 ) W. J. Dircks, EDO (10) H. R. Denton, NRR W. Haass , NRR S. H. Hanauer, NRR B. Burnett, NMSS C. Michelson, AE00 H. Boulden, DIA. SALP Chairman S. Weise, NRC Resident Inspector J. H. Sniezek, RRRI V. Stallo, IE H. D. Thornburg, IE N. C. Moseley, IE J. M. Taylor, IE PAS Files Regional Directors , Central Files NRR Project Managers . _ _ ' PDR LPDR NSIC TIC RII Reading Room All Licensees E. P. Wilkinson, INPO , i D. Goddard, Oregon DOE i State of North Carolina ^ 1 l , 1 . l l l l ' _
__ i . ' APPENDIX A , 1 EXECUTIVE SUMMARY A team of five NRC Inspection Specialists from the Performance Appraisal Section conducted an announced inspection at the H. B. Robinson Nuclear Plant _ site and Carolina Power and Light Company corporate office during the period June 22 - Seven areas July 17, 1981. Management controls in eight areas were evaluated. were considered Average and one area was considered Below Average. The licensee had established effective programs to provide management controls over the functional areas inspected and evaluated except in the area of Corrective Action Systems. ' During the inspection, the team was generally impressed with the knowledge, qualifications, and awareness of responsibilities displayed by the licensee's However, there were weaknesses in personnel awareness and under- personnel. standing of certain portions of the programs relating to Operations, Corrective Action Systems, and Training. Non-licensed training in certain areas appeared to require additional management attention. In the Generally it appeared that the programs were adequately implemented. areas of Design Changes and Maintenance, which are currently undergoing revision, l management attention should be directed toward monitoring the implementation of Additionally, the implementation of the new Quality j these revised programs. l Assurance Audit, Corrective Action, Training, and Independent Review programs needs continuing management involvement. Management oversight and involvement was extensive in most areas inspected. This was demonstrated by the program changes recently implemented or in progress. An These changes appeared to increase management effectiveness in these areas. exception was the Corrective Action System, one critical input utilized.to measure the effectiveness of a quality program, which can provide an important l tool to measure the adequacy of established management controls. i The following information is a summary of the inspection results of the individual areas. _ Review of Licensed Activities (Ocerations): Average (Section 2). The licensee had established an ef fective organizational structure and corporate and administrative policies in the area of operations. Responsibilities were The company had established through job descriptions and written procedures. established a strong, experienced staff and the turnover rate appeared to be low. . The operations program appeared to be adequate with the exception of the weaknesses which appear to be related to a need for better understanding of the The new QA program commitments which quality assurance program by the staff. l require review and changes to the implementing procedures further emphasizes i the need for additional training of the entire staff regarding the QA program requirements. . g - , - - - - - - e,r,-, ,, -- -- ,<,,,w nr,- n- - - - , ,v.. .- y - , ,-.-.---n,n - -.:.----, -
i . 2- Committee Activities: Average (Section 3). The licensee had established an effective organizational structure and adequate administrative procedures in the areas of onsite comittee and offsite review functions. Responsibilities for review activities were delineated in job descriptions and written procedures, although the general responsibilities of the Nuclear Safety and Research Depart- ment were not adequately addressed in the Corporate Quality Assurance Program (CQAP). The company had established a strong, experienced review staff and the turnover rate appeared to be low. The licensee was in the process of staffing the onsite review function of the Corporate Nuclear Safety Section (CNSS) to meet the proposed TS organization requirements. Design Changes and Modifications: Average (Sectidn4). The licensee had established a program to control safety related design changes and modifications. The program appeared to have been adequately implemented. The corporate program apoeared to be well founded and based on sound engineering practices. However, the plant procedure used for changes contained some administrative deficiencies. Corporate and plant personnel involved in design changes appeared to be well qualified and aware of the program and its requirements. The most significant weaknesses involved a lack of timeliness in updating plant drawings and providing training on modified systems. . The licensee was in the process of upgrading the design change program. The current corporate program procedures had been issued in February and revised in April of this year. The current plant program procedures had been issued in late 1980 and early 1981. The licensee had determined that there were deficiencies in his program and had contracted with a vendor to prepare new program procedures. Maintenance: Average (Section 5). The licensee had established a program to centrol safety-related maintenance activities. The most significant weakness involved the lack of an independent review of removal and return to service of , equipment for maintenance and testing. Personnel involved in the maintenance program appeared to be well qualified and knowledgeable of procedures and the ] work request system. ' The licensee had expended considerable effort upgrading the maintenance program during the past 18 months. Most of the program procedures had either been revised or newly issued during this time. The licensee had recently implemented an integrated maintenance program. The purpose of this program was to provide increased planning of maintenance activities, to utilize maintenance personnel more effectively, and to establish a means of collecting statistical data to accomplish these goals. As indicated above, there were still procedural weak- nesses in the program. The licensee had recognized a number of these weaknesses and was in the process of upgrading the program procedures. Quality Assurance Audits: Average (Section 6). The QA audit program appeared fundamentally sound, however, several weaknesses were identified. The Site Surveillance function was limited in size and the program should be more effectively utilized in verifying corrective actions. The new QA audit program The implementation had not progressed sufficiently for objective coment. review of past audits and the well qualified staff indicated potential for a continuing viable QA audit and surveillance program. ._.
. . -3- Corrective Action Systems: Below Average (Section 7). The corrective action Awareness and training were program appeared fragmented and not well defined. There was no overall program for identifying and tracking problems to weak. The corrective action system consisted primarily ensure evaluation and closure. Another weakness of the use of nonconformance reports within the QA organization. The human was the failure to develop a comprehensive trend analysis system. factors screening and evaluation system should prove to be one significant component of the corrective action system when fully implemented. Training: Average (Section 8). The portions of the training program that were the respon- Non-Licensed: sibility of the Training Center were well defined in written procedures. a. The courses and lesson plans that had been developed were above average The instructors and managers of and the physical facilities were good. the program were aware of their responsibilities, displayed a knowledge of The implemented governing procedures, and appeared well qualified. portions of the program were monitored by various levels of management. The status of implementation was the only deficiency that detracted from the program established at the Training Center. The goals, objectives, and schedules concerning training for corporate individuals had not been established. The corporate office training Periodic retraining for programs were not under centralized management. operators remaining in non-licensed positions was not well defined in Plant craft supervisors' understanding of the training procedures. program required improvement. The licensee had established a strong written program to provide Licensed: b. initial training for license candidates, although the eight week simulator The written training for license candidates had not been implemented. retraining program for licensed operators was established, implemented, and The seven weeks of technical training for SR0s by considered adequate. an outside consultant had not been implemented. The lack of full imple- mentation of planned training detracted from an otherwise above average program. Average (Section 9). The licensee had established a written Procurement: These program and implementing procedures to control procureme Personnel appeared knowledgeable, qualified, committed overall requirements. to the QA Program, and had a positive attitude toward their work. A significant weakness was that the storage of material was not consistent with The licensee's certain ANSI N45.2.2 and licensee QA Program requirements. responsiveness to the inspector's observations provided emphasis to the apparent commitment management and employees displayed toward the QA Program. . -, , - - - , , , -- . . - - ~ ~ , r- - -
. . U.S. NUCLEAR REGULATORY COMMISSION , OFFICE OF INSPECTION AND ENFORCEMENT (OIE) l DIVISION OF PROGRAM OEVELOPMENT AND APPRAISAL ' PERFORMANCE APPRAISAL SECTION (PAS) I . Report No. 50-261/81-05(PAS) l License No. OPR-23 Occket No. 50-261 l Licensee: Carolina Power and Light Company 411'Fayetteville Street j Raleigh, North Carolina 27602 Facility Name: H. B. Robinson H. B. Robinson Nuclear Plant, Hartsville, South Carolina, and l Inspection At: Carolina Power and Light Company, Raleigh, North Carolina ' Inspection Conducted: June 22-July 2 and July 13-17, 1981 G 181981 C4 / Inspectors: A. T. Gody,~ Inspec* Specialist (Team Leader) date signec 1 AUG 181981 /)[ d , M . g # N. C. Choules, tion Specialist date signed AUG 181981 ( f j 4f , date signed 0'. T. ' Hunter I spection S ecialist AUG 181981 [[ g F. J. Jablonsk nspection Specialist date signed ' AUG 181981 M date signed G./Napuda, Inspection Specialist Accompanying Personnel: " 5. Weise, Resident Inspector, RII " J. M. Taylor, Deputy Director, Division of Program Development and Appraisal, IE:HQ i f
- J. G. Partlow, Chief, Program Appraisal Branch, IE:HQ
- P. J. Kellogg, Acting Director, RRPI Division, RII
l ' +# C. F. Holden, Inspection Specialist, PAS, IE:HQ " Present during the exit meeting on July 17, 1981 - Present during the meetings on July 2 and June 26, 1981
- i Present during t e
eks c ~ June 22 and 29, 1981 -- 8d Approved by: J. G. Partlow, Chief, Performance Appraisal date signed Branch }}