ML20127N752
| ML20127N752 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 05/13/1985 |
| From: | Casey Smith, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20127N720 | List: |
| References | |
| 50-269-85-11, 50-270-85-11, 50-287-85-11, NUDOCS 8507020106 | |
| Download: ML20127N752 (9) | |
See also: IR 05000269/1985011
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARIETTA STREET,N.W.
ATLANTA, GEORGI A 30323
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Report Nos.:
50-269/85-11, 50-270/85-11, and 50-287/85-11
Licensee: Duke Power Company
422 South Church Street
Charlotte, NC 28242
Docket Nos.: 50-269, 50-270, and 50-287
License Nos.: DPR-38, DPR-47, and
Facility Name: Oconee 1, 2, and 3
Inspection Conducted: April 22-26, 1985
Inspector: [M
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C. F. Smith
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Djfte Signed
Accompanying Personnel:
R. M. Latta, Region II
L. R. Moore, RII
Approved by: MM
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C. M. Upright, J'
ion A ief
Dage S14ned
Division of Rea tor Ssfety
SUMMARY
Scope: This routine, unannounced inspection entailed 92 inspector-hours on site
in the areas of design control and tests and experiments.
Results: One violation was identified - Failure to submit an Annual Report of
Nuclear Station Modifications Within Required Time Frame.
8507020106 850520
ADOCK 05000269
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REPORT DETAILS
1.
Persons Contacted
Licensee Employees
S. Baldwin, Associate Engineer - Projects Services
- R. Bond, Compliance Engineer
C. Cooper, Assistant Engineer - Project Services
- G. Davenport, Performance
B. Davis, Associate Engineer
- W. Foster, Maintenance
- T. Glen, Maintenance
R. Haynes, Corporate Licensing Engineer
- R. Knoerr, Project Sgrvices - Engineering Manager
- T. Mathews, Compliance - Technical Specialist
J. McCool, QA Surveillance Superintendent
- J. McIntosh, Superintendent Station Services
- T. Owen, Superintendent of Maintenance
R. Ridings, SRO
C. Tomkins, Engineering Manager, SSD
- M. Tucker, Station Manager
E. White, Project Support Engineer
NRC Resident Inspector
- J. C. Bryant, Senior Resident Inspector
- Attended exit interview
2.
Exit Interview
The inspection scope and findings were summsrized on April 26, 1985, with
those persons indicated in paragraph 1 above. The inspector described the
areas inspected and discussed in detail the inspection findings listed
below.
The licensee did not identify as proprietary any of the materials
provided to or reviewed by the inspector during this inspection.
Violation, Failure to Submit an Annual Report of Nuclear Station
Modifications Within Required Time Frame, Paragraph 4.a.
Inspector Followup Item, Working Level Procedures for Project Services
Group, paragraph 4.b.
Inspector Followup Item, Correction of Design Deficiency in Nuclear
Station Modification ON-1826 Part A, paragraph 4.c.
3.
Licensee Action on Previous Enforcement Matters
This subject was not addressed in the inspection.
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4.
Design Program (37702)
References:
(a)
10 CFR 50, Appendix B, Quality Assurance Criteria
for Nuclear Power Plants and Fuel Reprocessing
Plants, Criterion III
_(b) Regulatory Guide 1.64, Quality Assurance Require-
ments for the Design of Nuclear Power Plants,
Revision 2
(c) ANSI N45.2.11-1974, Quality Assurance Requirements
for the Design of Nuclear Power Plants
(d) Regulatory Guide 1.33, Quality Assurance Require-
ments (Operations) November 1972
(e) ANSI N18.7-1976, Administrtive Controls and Quality
Assurance for the Operational Phase of Nuclear
Power Plants
(f)
10 CFR Part 50.59, Changes, Tests and Experiments
(g) Technical Specifications Section 6.1.2, Technical
Review and Control
-The inspector reviewed the license design change program required by
references (a) through (g) to verify that these activities were conducted in
accordance with regulatory requirements, industry guides and standards, and
Technical Specifications.
The following criteria were used during the
review to assess the overall acceptability of the established program:
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Procedures have been established to control design changes which
include assurance that a proposed change does not involve an unreviewed
safety question or a change in technical specifications as required by
Procedures and responsibilities for design control have been esta-
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blished including responsibilities and methods for conducting safety
evaluations.
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Administrative controls for design document control have been esta-
blished for the following:
Controlling changes to approved design change documents
Controlling or recalling obsolete design change documents such as
revised drawings and modification procedures
Release distribution of approved design change documents
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Administrative controls and responsibilities have been established
commensurate with the time frame for implementation to assure that
design changes will be incorporated into:
Plant procedures
Operator training programs
Plant drawings to reflect implemented design changes and modifica-
tions
Design controls require that implementation will be in accordance with
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approved procedures.
Design controls require assigning responsibility for identifying
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post-modification testing requirements and acceptance criteria in
approved test procedures and for evaluation of test results.
Procedures assign responsibility and delineate the method for reporting
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design changes to the NRC in accordance with 10 CFR 50.59.
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Controls require review and approval of temporary modifications in
accordance with . Section 6 of the Technical Specifications and
The documents listed below were reviewed to verify that these criteria had
been incorporated into the licensee design program:
Duke Power Company Topical Report, Quality Assurance Program, Duke-1
Section 17.2.3, Revision 8
Nuclear Station Modification Manual
Section 3.0 Responsibilities, Revision 0
Section 4.2, Design Engineering Designed Modifications, Revision 0
Section 4.3, Station Designed Modifications, Revision 0
Section 4.4, Exempt Changes, Revision 0
Section 7.0, Administration of Nuclear Station Modifications,
Revision 0
Section 7.6, Design, Revision 0
Section 7.7, Drawing Control, Revision 0
Section 8.0, Administration of Major Construction Projects,
Revision 0
Section 9.0, Administrative of Exempt and Temporary Changes,
Revision 0
Oconee Nuclear Station Directive
Section 2.2.2 (TS) Independent Verification, dated 12/1/84
Section 2.3.4 (TS), Nuclear Station Modification Program, dated
12/1/84
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Section 2.3.5 (TS), Control of Temporary Modifications, dated
12/1/84
Section 4.4.3(M), Qualification of Interfacing Individuals, dated
12/1/84
Section 4.5.3, Qualified Reviewer, dated 12/1/84
Administrative Policy Manual for Nuclear Stations, Revision 21
Section 2.5, Qualification and Training of Personnel
Section 4.8, Safety Related Analyses
Quality Assurance Procedure
QA-506, QA/QC Requirements for Nuclear Station Modifications
(NSMs)
The inspector 1nterviewed licensee onsite QA staff to determine the
degree of involvement of QA staff members in the performance of
surveillance in the functional area of plant modifications.
The
following surveillance reports were reviewed by the inspector.
Report No. 0-S84/17, Station Modification Implementation,
performed March 12-22, 1984
Report No. 0-S84/32, Station Modification Documentation and
Approval, performed May-10-21, 1984
Report
No.
0-S84/44,
Station Modification
Implementation,
performed June 21 - July 3,1984
Report No. 0-S84/59, Station Modification Documentation and
Approval, performed Sepu ber 11 - October 1, 1984
Report
No.
0-S84/80,
Station
Modification
Implementation,
performed December 21 - January 3,1985.
The inspector selectively verified that appropriate corrective actions
were taken by the responsible organizations for identified deficiencies
documented in surveillance reports.
The licensee has established a Modification Management System (MMS)
intended to support the station needs and the efficient scheduling of
associated engineering activities.
A quota of 100 active Station
Problem Reports (SPRs) and Nuclear Station Modifications (NSMs) has
been assigned to this system. The Project Services group administers
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the MMS by performing evaluations of SPRs and subsequently initiating
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request for modifications.
An Accountable Engineer from Project
Services is assigned to each NSM to ensure proper implementation of
the NSM program.
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The inspector interviewed licensee staff members within Project
Services to ascertain their understanding of, and the degree of their
involvement in, the nuclear station modification program.
Addi-
tionally, the following nuclear station modification packages were
reviewed by the inspector:
NSM # ON-1550, Revision 1, Remove existing non-code valves 2, 3,
Dwg-275 and 276, and replace with valves which are qualified to
ANSI B31.1, Renumber to 2, 3, Dwg 262 and 263
NSM # ON-1762, Revision 0, Replace existing Limitorque Motor
Operator with environmentally qualified substitute
NSM # ON-1240, Revision 0,1, 2, Modify device lead terminations
and bypass / seal personnel hatch electrical penetrations with
materials and procedures that are qualified to function in post-
accident environment (NRC Bulletin 79-01)
NSM # ON-1826/0A+0B Revision 0, Motor driven emergency feedwater
pump automatic initiation pressure switches test circuits
Station Support Division (SSD) performs the implementation of NSMs
assigned to them by Nuclear Production. An informal training program
for SSD staff members is presently being implemented, in that SSD
engineering personnel are assigned to Project Services to acquire the
training and experience commensurate with their responsibilities as
Accountable Engineers.
The training required to meet the minimum
qualification delineated in Station Directive 4.4.3 is in the initial
stage of implementation for SSD staff members.
Within this area, one violation and two inspector followup items were
identified and are discussed in the following paragraphs.
a.
Failure to Submit an Annual Report of Nuclear Station Modifica-
tions within required time frame.
10 CFR 50.59 paragraph b requires the licensee to submit an
annual report of facility changes to the NRC. The licensee in a
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letter from Hal B. Tucker to Dr. J. Nelson Grace, Regional Admini-
strator, dated March 7, 1985, submitted a description of '.he
nuclear station modifications completed during 1983. The licensee
normally submits this annual report during July to August of the
succeeding year. Failure to submit an annual report of facility
changes in accordance with the requirements of 10 CFR 50.59 is
identified as violation 269, 270, 287/85-11-01.
b.
Working Level Procedures for Project Services Group.
The licensee has identified a need for working level instructions
for staff members within the Project Services Group.
The
inspector reviewed an incomplete ccpy of the Project Services
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Manual. Additionally, the status of the manual was discussed with
licensee management. Sections 4 and 5 which address activities
performed by this group in the functional area of station modift-
cation are still being developed.
Until the licensee develops
working level instructions for activities performed by the Project
Services Group in the modification program, this is identified as
Inspector Followup Item 269, 270, 287/85-11-02.
c.
Correction of Design Deficiency in Nuclear Station Modification
ON-1826 Part A.
Nuclear Station Modification ON-1826 Part A was prepared and
implemented in response to a licensee commitment contained in
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It involved the addition of test circuitry to
facilitate Technical Specification (TS) required periodic testing
of the control oil pressure switches on both the motor-driven and
turbine-driven emergenc', feedwater pumps (EFWPs).
Subsequent to the implementation of the modification, a design
deficiency was identified. This deficiency concerned the contact
development of the test switch in that a jumper is required to be
installed across contacts 9 and 10 of the test switch each time
the functional test is performed of the motor-driven emergency
feedwater pumps (MDEFWPs) initiation pressure switches.
Uninten-
tional start of the MDEFWP results if the jumper is not used. The
switches presently in use were installed in June 1982 for Unit 2,
September 1982 for Unit 3, and July 1983 for Unit 1.
The inspector interviewed licensee management concerning the
status of the corrective actions taken and reviewed the following
documents in connection with the resolution of this deficiency.
Procedure
I.D.
No: TN/1/A/1826/0/A, Procedure for Imple-
mentation and Verification of NSM ON-1826 Revision 0, Part A.
Drawing # OEE-117-90, Elementary Diagram, 4160 Volts Switch-
gear ITE Unit 0, Motor Driven Emergency Feedwater Pump Motor
1A.
Drawing # OEE-117-91, Elementary Diagram, 4160 Volts Switch-
gear ITE Unit 0, Motor Driven Emergency Feedwater Pump Motor
18.
Procedure ID No: IP/0/A/275/6C, Safety Related Functional
Test of the MDEFWP Initiation Pressure Switches.
Duke Power Company, Oconee Nuclear Station, Transfer of
Completed or Partially Completed Modifications Forms for
Units 1, 2, and 3 NSM No. 1826, Revision 0, Part A.
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The licensee stated in Hal B. Tucker's letter to Dr. J. Nelson
Grace dated March 7, 1985, that NSM ON-1826 was completed for Unit
I and partially completed for Units 2 and 3.
The inspector
determined that this modification is presently incomplete for all
three units. The documentation for Unit #1 modification package
was reviewed and signed off by the responsible organizations as
being completed prior to identification of the design deficiency.
Additionally, the inspector inquired as to the status of the TS
required periodic tests, and licensee management confirmed that
the tests are conducted on a monthly basis by use of the jumper
between contacts 9 and 10 of the test switch.
The inspector
verified that provisions have been made for independent verifica-
tion of the addition and removal of the jumper in procedure ID No.
IP/0/A/275/6C. In addition, the inspector verified that a nuclear
station evaluation was performed and documented in connection with
the development and use of procedure ID No. IP/0/A/275/6C.
Until the licensee has developed and implemented corrective
actions for elimination of the design deficiency in NSM ON-1826
Part A, this is identified as Inspector Followup Item 269, 270,
287/85-11-03.
5.
Tests and Experiments (37703)
References:
(a) Appendix B to 10 CFR 50 - Quality Assurance
Criteria for Nuclear Power Plants and Fuel
Reprocessing Plants
(b) 10 CFR 50.59 - Changes, Tests and Experiments
(c) Duke
Power Company Topical
Report,
Quality
Assurance
Program,
Duke-1,
Section
17.2.11,
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Revision 8
(d) Technical Specification Section 6.1.2, Technical
Review and Control
(e) Regulatory Guide 1.33, Quality Assurance Require-
ments (Operations) November 1972
(f) ANSI
N18.7-1976Property "ANSI code" (as page type) with input value "ANSI</br></br>N18.7-1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.,
Administrative Controls and
Quality Assurance for the Operational Phase of
Nuclear Power Plants
The inspector reviewed the licensee's test and experiment program required
by references (a) through (f) to verify that the program was in conformance
with regulatory requirements, commitments in the application, and industry
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guides and standards. The following criteria were used during this review
to assess the overall acceptability of the established program:
A formal method has been established to handle all requests or
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proposals for conducting plant tests involving safety related
components.
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Provisions have been made to assure that all tests will be performed in
accordance with approved written procedures.
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Responsibilities have been assigned for reviewing and approving test
procedures.
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A formal system, including assignment of responsibility, has been
established to assure that all proposed tests will be reviewed to
detprmine whether they are as described in the FSAR.
Responsibilities have been assigned to assure that a written safety
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evaluation required by 10 CFR 50.59 will be developed for each test to
assure that it does not involve an unreviewed safety question or a
change in Technical Specifications (TS).
The documents listed below were reviewed to verify that the previously
listed criteria had been incorporated into the licensee's tests and experi-
ments program.
Administrative Policy Manual for Nuclear Power Station
Section 3.2.3, Special Testing, Revision 21
Section 4.8, Safety Related Analyses, Revision 21
Section 4.8, Administrative Instructions for Temporary Station
Procedures, Revision 21
The inspector reviewed licensee test and experiments program documents and
determined that a test program had been established to assure that all
testing required to demonstrate satisfactory operation in service of
structures, systems, and components has been identified. Additionally, all
testing is performed in accordance with approved written procedures. The
inspector verified that provisions had been established for written safety
evaluations required by 10 CFR 50.59 for special tests to assure that
unreviewed safety questions or changes to the TS do not exist.
The inspector conducted a review of plant QA surveillance reports for plant
tests conducteu over the past 12 months and determined that surveillances
were not performed on special tests.
In subsequent discussions with
licensee management, the inspector was informed that special tests as
defined in 10 CFR 50.59 were not performed by plant personnel within this
time frame.
Within this area, no violations or deviatigas were identified.
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