ML20237F117
| ML20237F117 | |
| Person / Time | |
|---|---|
| Site: | Catawba  |
| Issue date: | 12/18/1987 |
| From: | Tucker H DUKE POWER CO. |
| To: | NRC OFFICE OF ADMINISTRATION & RESOURCES MANAGEMENT (ARM) |
| References | |
| NUDOCS 8712290368 | |
| Download: ML20237F117 (9) | |
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Sub$c,t: "jatawba Nuc' lear Station' Dj
'Ikicket Nos, 50-413 and 50-414 M?
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. 'Ihe attach 6d commenbi are offered by Duke Power Company fin response to the c
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Duke power Company Comments on IE Report 50-413,414/87-23 NRC Quality Verification Audit July 13 - 24, 1987 General Comments We do not agree with the report's generalization that the " quality verification organizations, particularly Quality Assurance (QA), were not very effective in their identification and prompt resolution of problems", but we do recognize the value of this review and intend to use the information contained in the report to strive to become even more effective in our quality verification activities.
We believe our quality verification organizations, including QA, are effective in identifying problems, and line organizations are effective at resolving identified problems. We believe our philosophy and policy of emphasizing quality achievement in the line organization is correct.
The prompt resolution of identified problems is not considered to be the responsibility of the QA organization at Duke.
Me feel that involvement of the QA organization in the resolution of problems in a detailed technical manner presents a conflict of responsibilities.
It is more appropriate for the line organizations to be responsible for the resolution to the problem. This allows future auditing of the problems to be performed more objectively. The QA organization can be involved in discussions that help define the problems.
Indeed, QA reviews and approves all problem resolutions of the PIR system.
The method used to evaluate quallty verification effectiveness in this inspection seemed very subjective.
Instead of focusing on problems that had occurred, the effectiveness of the QA organization in terms of the review of, and credit for the avoidance of incidents due to QA audits and surveillance should have been considered more adequately by the inspection team.
Our QA audit reports tend to reflect the programmatic nature of audits required by regulation. This tends to drive audits of various systems and functions to the programmatic aspects instead of detailed technical evaluations of specific items. Duke has recognized this and has several initiatives in place to improve the technical capabilities in both its QA auditc and surveillance without degrading the required programmatic review. These initiatives include technical training for audit and surveillance personnel, the use of technical experts from other organizations in audits, a periodic Quality Assurance Performance Assessment (QAPA) program to provide guidance for use of audit / surveillance resources, and the implementation of a self-initiated technical audit program (SITA), all of which are described in the following paragraphs:
(1) Technical Training programs for QA Audit and Surveillance personnel:
Duke has established a training program to enhance the quality of departmental audits by providing detailed technical training to QA Audit L
Division personnel, and QA Operation Division surveillance personnel.
l The QA Audit technical training program consists of a total of (71) weeks of
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training. This includes (41) weeks of classroom instruction at the Technical Training Center and (30) weeks of On-the-Job Training. The training consists of New Engineer / professional On-the-Job Training, Task l
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l NRC Quality Verification Audit l
Page 2.
Inventory Program Training, Basic Thermodynamics and Nuclear Physics, Basic Engineer Professional Training, Health Physics and Chemistry Training, Health Physics and Chemistry Group On-the-Job Training, and Basic Nuclear Operator Training.
Site QA surveillance personnel take 46 weeks of Basic Nuclear Operator Training and 8 weeks of System Specific Training. Additional classroom instruction and On-the-Job Training is provided in the areas of their specialization, such as Chemistry, Health Physics and Nondestructive Examination.
(2) Use of Technical Experts on QA Audit Teams.
The Duke Audit group routinely obtains technical expertise from other line or staff organizations at different locations. Thus a chemistry specialist or SRO from one location can be utilized as a member of an audit team at another location. Approximately 70% of the audits conducted during the last Catawba SALP period utilized technical expertise to help identify technical deficiencies, and to evaluate the deficiencies found by others on the audit team.
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(3) Periodic QA Performance Assessment Program l
The QA organization has recently implemented a procedure entitled
" Quality Assurance Performance Assessments" (QAPA) that requires periodic performance assessments to be conducted for each department by location and functional area. The assessment looks at data produced by the QA program, including Station Incident Reports, and assigns a rating to each functional area which is then used to help determine where QA audit and surveillance resources should be allocated. The first assessment was in progress while the NRC quality verification inspection was in progress. Since then, assessments have been completed for the Nuclear Production Department and the Construction and Maintenance Departments at Catawba.
(4) Self Initiated Technical Audits A recently implemented QA Procedure entitled "Self-Initiated Technical Audits" (SITA) provides for a vertical slice technical audit on selected i
systems at Duke nuclear plants. This procedure incorporates many of the features of the NRC SSFI inspections. The audit team is composed entirely of eight to twelve senior technical experts led by a QA certified lead auditor. Team members and the system to be analyzed are selected by upper levels of management in the affected departments. The audit, including the development process, lasts about ten weeks, and for this reason only a few of these type audits are expected to be completed each year. The first such audit was completed at the Oconee Nuclear Station in August 1987 to evaluate the adequacy of the design, construction, testing, operation and maintenance of the Low Pressure Service Water System.
While this approach is an intensive look at a given system, weaknesses identified are evaluated for their applicability to other stations, systems and components.
With the initiatives described above, it is not the intent of Duke to totally staff the QA Audit and Surveillance organizations with personnel that have the same technical skill level as those in the line (including Design Engineering) departments. The reasons for this are two-fold. First, Duke believes that this approach is not necessary to obtain meaningful w_____-_--_
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NRC_guality Verification Audit page 3 l
audits and surveillance.
Training in auditing skills such as sampling techniques and root cause analyses can be used.by.an auditor who is not technically equal to the-audited group to spot problems.
Second, the ability to obtain qualified technical Duke personnel by borrowing them from the various line organizations for specific audits reduces the necessity for staffing QA with that expertise.
It might also be difficult for a true technical expert to maintain that expertise very long if he or she were removed from the actual line responsibility and placed in. an auditing function. Our capability to borrow technical expertise internally while still maintaining auditor independence is enhanced because of having seven operating units and our own Design Engineering Department as well as a Construction and Maintenance Department.
l A total of (16) technical issues were identified by departmental audits conducted at the Catawba Nuclear Station during the period of January 1, 1986 through July 1, 1987 in such areas as Health Physice, Chemistry, Independent Verification Activities, and Surveillance Testing. The number of technical issues raised constitute approximately 35% of all items identified at Catawba during this period. These figures indicate that a significant number of technical issues were identified by departmental audits.
Comments on specific points in the report are given below in the same order in-l which they appear in the report.
I.
Plant Operations The third paragraph on the cover letter incorrectly states that the plant was in an unanalyzed condition during certain periods since two RN pumps would not have been available under certain postulated scenarios.
It is implied that the FSAR requires two RN pumps to be available at all times for the removal of deccy heat. To the contrary, the FSAR does not describe the number of pumps required under these conditions. The FSAR states that two RN pumps are sufficient for worst case conditions, and later states that two pumps are required to meet the post-LCOA requirements of one unit while taking the unaffected unit from power operations to cold shutdown with a loss of offsite power.
During all periods of time during which the inspection team's postulated scenario applies, one unit had already been placed in cold shutdown. The FSAR states that the RN System is capable of supporting a plant shutdown assuming a LOCA, seismic event blackout, and single failure when a diesel generator is down for maintenance. At all times that a diesel generator was removed from service and single failure criteria applied, one pump was sufficient to meet this requirement.
Safety evaluations performed in accordance with 10 CPR 50.59 have consistently determined that an unreviewed safety question does not exist.
NRC Region 11 personnel have been kept informed of these evaluations since Unit 2 licensing.
NRC Quality Verification Audit Page 4 1
I A. Problem Identification Reports 1
On page 3 of the Inspection' Report it is stated that "In response to NRC' concerns, the licensee committed to review for revision Operating Procedure OP/0/A/6400/06, " Nuclear Service Water System" to require realignment of the pump suction to the Station Nuclear Service Water Pond when a pump of diesel' generator is out of service. The licensee also committed to review
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CP/0/A/6400/06 to assure RN System operability under any scenario described j
in the proposed revision."
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It is stated that these commitments occurred at a meeting with NRC Region II inspectors on August 25, 1986. No evidence can be found to support these statements, either in documentation or in the memories of station personnel or the NRC Inspectors present at the meeting.
The discussions at this meeting were a part of the ongoing communications between the station and NRC concerning Tech Spec compliance while operating under a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> action statement with a diesel generator out of service. No concerns were identified involving SNSWP alignment until January 1987.
These statements are contrary to information supplied to the Inspection Team.
An excessive amount of attention is given to the handling of SPR CNPR-02350.
This problem report proposed a plant modification with the justification being that a potentially unacceptable sequence of events could occur with a diesel generator out of service. Under subsequent evaluation, this sequence of events was determined to be invalid since it failed to recognize that existing operating procedures require the isolation of the redundant flow channel and throttling of flows on the affected channel. However, the subsequent review of the proposed modification concluded that it wculd enhance overall plant safety and was therefore implemented.
I B. Reactor Trips This is an example where groups other than QA identify problems and proceed with their resolutions.
Except for subsequent audits, involvement of the QA organization in this case was not necessary.
I C. Procedures We disagree with the statement that QA has not been effective in identifying sit.ficant problems with procedures or evaluating changes implemented by
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the Operations Group. During the course of audits performed at the Catawba Nuclear Station during the period of January 1, 1986 through July 1, 1987, (eleven) technical implementation problems were identified to station management. Some examples are listed below:
Audit Item Description NP-86-08(CN)(03)
The acceptance criteria for energy calculation in Procedure HP/0/B/1001/16 appears to be too liberal, which could lead to isotopic identification problems.
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NRC Quality Verification Audit Page 5 NP-86-06 (CN) (08)
Procedure OMP 2-19 does not contain the requirement to check the operation and l
lubricating oil levels of the diesel generator I
pedestal bearing, as required by TDI Owners l'
Group recommendations and Catawba licensing requirements.
NP-86-18(CN)(03)
Pump Test Procedures PT/1/A/4200/05A, l
05B, 10A, and 10B; and Procedures PT/1/A/4400/07A and 07B do not require the monitoring of flow as required by ASME Section XI, Subsection IWP-3100, requirements.
NP-86-04(CN)(05)
Procedure OP/0/A/6200/11 does not require the opening of valve 1NM420. The valve is required to be closed the step before and closed the step after with no command to open the valve in between.
NP-86-23(CM)(07)
Procedure PT/0/B/4600/06 does not require the collection of water, soil, and vegetation samples as required by NUREG 0654, Section N.2.E.1.
The occurrence of technical implementation inadequacies constitutes 24% of all findings identified at Catawba during this period.
In all cases, these audit reports were provided to line management. Additionally, the Periodic Assessment of Departmental Audit Report, dated November 4, 1986, identified to upper management this type of inadequacy as the predominant area of concern at Catawba. These examples illustrate that technical implementation inadequacies had been identified by QA audits at Catawba.
I D. Personnel Errors An in-depth evaluation of approximately (177) incidents involving personnel errors occurring at the Catawba and McGuire Nuclear Stations was conducted during the course of Departmental Audit PS-87-01(PS), June 8 through July 17, 1987.
The evaluation was performed in an.# fort to determine weaknesses in systems training or a failure to effectively apply lessons learned from McGuire's experience to the Catawba Operator Training Program.
It was found that the particular circumstances involved in the Incident Reports were so varied that no common training weakness could be identified.
As a result of further reviews and observation of simulator exercises, the audit team recommended that additional scenarios be incorporated into existing simulator exercises in order to reinforce Licensed Operator ability to recognize and cope with LCO (Limiting Conditions for Operation) conditions. A " draft" copy of the appropriate section of report PS-87-01(PS) was presented to the NRC inspector during the course of the Quality Systems Verification Inspection, but no reference is made to it in the Inspection Report.
In an effort to identify the existence of personnel errors in "real time",
each audit of each Operations Group requires the independent verification of
NRC Quality Verification Audit Page 6 the position of 30-50 valves, the review of Red Tag Logs, Control Room Operator Logs, and the Tech Spec Action Log to verify conformance with the technical specification requirements for unit operation. Additionally, licensed.and non-licensed personnel are interviewed to determine their-knowledge of' unit operating procedures. These activities are conducted with the assistance of an SRO serving as a borrowed technical expert member of' the audit team. This process was explained to the inspector during the course of the inspection, but again, no credit is given in the Inspection Report.
The comment was made that QA did not vary their surveillance and audit schedules to address problem areas unless specifically requested by plant management. Although audit schedules were not revised, the scope of audits were changed to address problem areas.
The QA Audit Division established a data base in November 1986, containing items identified during NRC, INPO, departmental audits, and Station Incident Reports which is used to identify areas which require in-depth evaluations during the course of departmental audits. Areas identified include such items as:
- 1) the technical adequacy of procedures, 2) conformance to limiting conditions for operation, 3) Technical Specification surveillance testing, and 4) corrective maintenance activities. The NRC Inspector was informed of this effort during the Inspection. This program will be further enhanced by the efforts of a study group formed to recommend ways in which the information contained within the plant data system may be more effectively utilized by-the QA Department in the planning and execution of audits.
Additionally, the QA Audit Division reviews all station Incident Investigation Reports, NRC Inspection Reports, and INPO Evaluation Reports.
Significant incidents are designated as requiring in-depth evaluations during the course of audits conducted. These evaluations, and the source document, are specifically addressed in the audit report. The following examples are listed below:
Audit Report Source Document NP-86-18(CN)
Information Notice 85-84 NP-87-06(CN)
Information Notice 87-03 NP-87-06(CN)
IIRC87-006-1 NP-87-12(CN)
Information Notice 87-07 NP-87-06(CN)
Information Notice 85-92 NP-87-06(CN)
IE Inspection 50-369/86-31 NP-87-01(CN)
IE Bulletin 85-03 The use of this system was explained to the NRC inspector during the course of the Quality System Verification Inspection.
l An initiative taken by the QA organization in this area is the development l
of the Quality Assurance Performance Assessment (QAPA) Program. This program provides input for scheduling of audit and surveillance resources.
While not completed for Catawba at the time of this inspection, this assessment has now been completed.
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NRC Quality Verification Audit Page-7 II C. Post-Modification Testing Conclusions in this section were based on written reports which were incomplete at the time of the inspection..The statement is made that significant problems were identified which should have been documented on PIR's.
"The fact that these significant problems were not documented in PIR's-illustrates a weakness in the PIR program." (first sentence Page 20)
Upon conclusion of the written reports by the Testing Review Committee it was documented that no significant problems remained which had not already been promptly identified and reported on PIR's.
While documentation errors had complicated the task of re-constructing how and when post-mod testing had taken place, no components or systems were ever inoperable under Technical Specifications.
Interviews with the Testing Review Committee Chairman revealed that this conclusion was discussed with the NRC Inspection Team at the time of the inspection. This being the case, it should have been included by the team in the Inspection Report.
III B. Surveillance Reports See General Comments.
III C. QA audits l
See General Comments.
IV.
Conclusion It is asserted that we segregate regulatory compliance and quality verification into two distinct activities with QA monitoring compliance and line management verifying quality. We do not feel this correctly reflects either the intention or practice of our program. Both the QA organization and line management share the responsibilities for compliance and quality verification activities. Line management includes organizations not called QA that aid in the quality verification and conpliance functions. To say that both those functions, or only one, should be exclusively in the QA organization is not at all in line with our philosophy or practice.
Other organizations separate from line management also perform quality monitoring and verification. The Nuclear Safety Review Board (NSRB) serves as a safety review and audit backup to the normal operating organization.
l The Nuclear Safety Assurance Group maintains on-site and off-site groups that review safety related activities associated with plant startup and operation. They investigate abnormal plant incidents to determine causes and corrective actions. =They also provide trend analysis of incidents to identify negative trends and provide recommendations to management for improvement. All these organizations in addition to the QA organization provide quality verification activities.
In addition to these organizations, line management is encouraged to monitor the achievement of quality, to identify problems, and take corrective action without having to involve the QA organization.
This may result in problem solving groups existing without formal QA department involvement. For
NRC Quality Verification Audit Page 8 example, the Testing Review Committee was formed to investigate and resolve a problem identified by line management. QA will'be involved through their periodic audits and assessments. There is no intention to exclude QA from any function; but, rather to involve appropriate technical expertise in solving problems to achieve quality.
A substantial staff'of technical expertise is available to QA and other quality verification organizations from within the company. The technical training programs described for QA audit and surveillance personnel, will enhance their ability to detect technical problems and allow them to communicate more effectively with technical experts that are borrowed for audits and surveillance.
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