ML20199G261

Insp Rept 50-416/86-03 on 860210-14.Violation Noted: Failure to Train Decontamination Workers Performing hydro-lazing & Strippable Coating,Per Tech Spec 6.8.1

ML20199G261
Person / Time
Site:	Grand Gulf
Issue date:	03/24/1986
From:	Belisle G, Caldwell J, Moore L, Moorman J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20199G235	List: ML20199G229 ML20199G243 ML20199G261
References
RTR-NUREG-0737, RTR-NUREG-737, TASK-1.C.5, TASK-TM 50-416-86-03, 50-416-86-3, NUDOCS 8604090101
Download: ML20199G261 (11)

See also: IR 05000416/1986003

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NUCLEAR HEGULATORY COMMISSION

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108 MARIETTA STREET.N.W.

ATLANT A. GEORGI A 30323

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Report No.: 50-416/86-03

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Licensee: Mississippi Power and Light Company

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-Jackson, MS 39205

Docket No.: 50-416-

License.No.: NPF-29

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Facility Name: . Grand Gulf

Inspection Conducted:

February 10-14, 1986

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Inspectors: '

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J. L. Caldwell -V-

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L. R. Moore

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G. A.'Belisle, Acfing Section Chief

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Division of Reactor Safety

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SUPARY

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-Scope: This ' routine, unannounced inspection entailed 85 inspector-hours on site

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in the areas of design changes and modifications program and audit implementa-

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tion.

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Results: One violation was identified - Failure te train decontamination workers

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-in accordance with procedures.

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REPORT DETAILS

1.

Persons Contacted

Licensee Employees

F. Adcock,' Principal Mechanical Engineer. Nuclear Plant Engineering (NPE)

C. Angle, Manager, Operational Analysis Section (OAS)

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• J. Bailey, Compliarce Coordinator

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.J.. Buller, Safety Evaluation Engineer, OAS

~D. Chieply, Quality Assurance (QA) Design P.eview Engineer

• T. Cloninger,.Vice President, Nuclear Engineering and Support

• A Cross, Site Director

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• L. Daughtery, Compliance Superintendent

• W. Edge, Manager. Nuclear Site QA

• W. Eiff, Principal Quality Engiaeer, NPE

• S.

Fieth, Director, QA'

.J. Hickman, Senior Quality Representative

• C. Hutchinson, Site General Manager

D. Johnson, Mechanical Maintenance Engineer

A. Khanifar, Electrical Engineering Supervisor

• Q. Kingsley, Vice President, Nuclear Operations

• B.-Lee, QA Audits Superviror

L.'Loboda, OAS Engineer

B. McCall,. Senior Nuclear Plant Scheduler

• R. Moomau, Acting Maintenance Manager

• J. Parrish, Chemisty/ Health Physics Superintendent

L. Patterson, Engineer

R. Patterson, Systems Engineer

• S. Tanner, Manager, Programs QA

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• F. Titus, Director, Nuclear Plant Engineering

D. Williams, Document Safety Review Coordinator

J. Wilson, Civil Engineer

M. Withrow, Instrumentation anf Controls (I&C) Supervisor

Other licensee employees contacted included office personnel.

NRC Resident Inspectors

• R. Butcher, Senior Resident Inspector

• J. Caldwell, Resident Inspector

• Attended exit interview

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Exit Interview

The inspection scope and findings were summarized on February 14, 1986, with

those persons indicated in paragraph 1 above.

The inspector described the

areas inspected and discussed in detail the inspection findings.

No

dissenting comments were received from the licensee.

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Violation, Failure to take prompt corrective action for known

conditions adverse to quality, paragraph 5.

Violation,. Failure to train decontamination workers in accordance with

procedures, paragraph 6.

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Upon management review, the violation for failure-to take prompt corrective

action for known conditions adverse to quality was determined to be

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inappropriate.

Mr. S. Feith was notified of this position during a

telephone conversation conducted on March 4, 1986.

The licensee did not identify as proprietary ar.y of. the materials provided -

-to or_ reviewed by the inspector

n'ing this inspection.

-3.

Licensee Action on Previous Enforcement Matters

This subject was not addressed in the inspection.

4.

Unresolved Items

Unresolved items were not identified during this inspection.

5.

Design Program (37702)

References:

(a)

10 CFR 50.54(a)(1), Conditions of Licenses

(b) Mississippi

Power and

Light Operational

Quality

Assurance Manual (MPL-TOP-1A), Revision 4

(c)

10 CFR 50 Appendix B, Quality Assurance Criteria for

Nuclear Power Plants and Fuel Reprocessing Plants

(d) Regulatory Guide 1.64, Quality Assurance Requirements

for the Design of Nuclear Power Plants

(e) ANSI N45.2.11 - 1974, Quality Assurance Requirements for

the Design of Nuclear Power Plants

The inspector interviewed engineers from the four disciplines of Nuclear

Plant Engineering (NPE).

Subjects discussed were educational background,

experience, training, familiarity with licensee commitments, and applica-

bility of these commitments to the individual's work related responsibility

and function. Those engineers interviewed appeared to be adequately trained

and knowledgeable of Final Safety Analysis Report (FSAR) and Technical

Specification

requirements.

The

inspector

particularly

discussed

disposition of Material Non-Conformance Reports (MNCRs),10 CFR 50.59 Safety

Evaluations, and plant staff interface. The engineers referenced applicable

procedures for disposition of MNCRs,10 CFR 50.59 Safety Evaluations, and

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appeared to employ these guidelines. The issue of escalation for resolution

of differences at the interface between plant staff and NPE was unclear in

the discussions.

This area was not proceduralized at the time of the

inspection, although the Principal Quality Engineer indicated that an

escalation procedure would be drafted as the NPE procedure manual was

reviewed and updated.

.

The licensee periodically receives documents from such organization as

Institute of Nuclear Power Operations (INPO), General Electric (GE), and NRC

concerning problems experienced by other operating plants. These documents

include CE Service Information Letters (SIL), NRC Inspection and Enforcement

(IE) Bulletins, IE Notices, INP0 Significant Operating Experience Reports,

and INPO Significant Event Reports (SER). These documents are evaluated by

NPE as to their applicability and importance to the operation of Grand Gulf

Nuclear Station. Other documents evaluated by NPE include Incident Reports,

Operation and Maintenance Reports, and Potentially Reportable Deficiencies.

Guidance for this activity is provided oy NPE AP 01-701, "Onsite and Offsite

Document Review", Revision 5.

Within NPE, document evaluations are the

responsibility of 0AS. 0AS performs the function of the Independent Safety

Engineering Group (ISEG) referred to in the

licensee's Technical

Specifications.

The inspector reviewed evaluations of IE Bulletins, SERs, and SILs received

by the licensee frem 1984 to the present. These documents are received into

NPE by OAS. They are logged in a manual tracking system and then assigned a

priority for review by the Document Safety Review Coordinator. A " Red"

priority indicates that a document has a significant impact on plant safety

or operation and requires immediate attention.

A " Yellow" oriority

indicates that the document has a potential impact on plant safety or

operatirn. A " Green" priority indicates a possible minor impact on plant

safety or operation. Also, an estimated completion date for the evaluation

is assigned. After priority assignment, the ducuments are either evaluated

internally by OAS, or distributed to other sections within NPE as may be

required for an appropriate evaluation. When documents are assigned to be

reviewed by disciplines other than the OAS, the discipline Principal

Engineer will assign a Responsible Engineer to do the evaluation according

to current workload within the discipline.

After the evaluation is

complete, recommendations are documented and appropriate action is taken to

implement

the

recommendations.

Periodically,

document

evaluations

distributed to disciplines other than 0AS will not be completed by the

assigned due date. In these cases, the Document Safety Review Coordinator

sends a memo to the Principal Engineer responsible for action on the

documents listing the late documents by title and the due date.

Currently,

the issuance of these memos is not required by an NPE orocedure, nor are the

Principal Engineers required to respond to these memos. Additionally, when

a conflict concerning evaluation timeliness or priority arises between OAS

and another discipline per'orming a document evaluation, there is no

prescribed path for escalation of the conflict in the management chain to

assure its timely resolution.

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For example, GE SIL 211, Supplement I was issued on January 14, 1985, and

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logged in the OAS tracking system on March 10, 1985. A " Yellow" priority

was assigned to this SIL.

This SIL concerned possible drive mechanism

malfunctions for the Traversing Incore Probe (TIP) which causes the detector

to be withdrawn beyond the shielded position into the drive housing.

If

this occurs, general area radiation levels become excessively high around

the drive housing.

Supplement 1 to SIL 211 was sent to the Mechanical

Section for evaluation. The Mechanical Section sent a memo to 0AS stating

that corrective action had already been taken by issuing DCP 82/4154 on

November 11, 1982, which provided corrective action for SIL 211. The memo

also stated that actions suggested by SIL 211 and SIL 211, Supplement 1,

were similar and that no further corrective action was required.

The

licensee had access to information that indicated that corrective action for

SIL 211 might not be adequate to completely cc rrect th problem and that

action suggested by SIL 211, Supplement I would.

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SIL 211 and its supplement were discussed with the Principal Mechanical

Engineer and the Mechanical I&C Engineering Supervisor and they stated that

they were still in the process of determining the Supplement's applicability

to Grand Galf.

The evaluation for SIL 211, Supplement 1, was still

outstanding at the time of this inspection.

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The inspectors' offsite document review also identified a failure of the

tracking system which caused the evaluation for SER 2-84 not being completed

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in a prompt manner.

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INPO SER 2-84 described a reaction of the zinc primer and/or phenolic liner

of diesel fuel oil storage tanks and naphenate base fuel oil with potential

application to licensee safety-related equipment. The reaction resulted in

the formation of a gel which could plate out on the ejector nozzles and

possibly cause the clogging of in-line strainers.

This condition could

eventually result in compromising the ability of the diesels to perform at

design capacity.

It is noted on the SER that this is a long term

degeneration effect on the diesel as opposed to a sudden catastrophic

failure.

The SER was received January 6,

1984.

A memo from the OAS

Principal Engineer to the NPE Mechanical Principal Engineer, dated

October 31, 1984, requested verification of the applicability of the zinc

primer-fuel oil reaction at Grand Gulf. On February 22, 1985, a memo from

the OAS Principal Engineer informed the Plant Manager of the zinc primer

applicability and recommended verification of onsite fuel oil as naphthenate

based. The response priority given on this memo was " Green". The fuel oil

was determined compatible with the zinc reaction and the Plant Manager

requested NPE to evaluate continued operation of the diesel generators until

the fall outage in 1985. A memo dated July 31, 1985, from NPE to the Plant

Manager listed potential courses of action for evaluation and endorsed

normal use and operation of diesel generators at least until the fall

outage. The memo also stated that NPE would evaluate potential courses of

action and advise plant staff at this time. Documentation was not available

to verify that corrective actions or further evaluations were performed.

Two years af ter initial receipt of the SER relating to safety related

equipment, the licensee had not completed evaluation and corrective action

to close out the issue.

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NUREG-0737, Clarification of TMI Action Plan Requirements,Section I.C.5, _

Procedures for Feedback of Operating Experience to Plant Staff.. requires

that procedures be prepared to assure that operating information pertinent

to plant safety originating both within and outside the utility organization

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is continually supplied to operators and other personnel. Procedure NPE AP

'01-701 provides administrative guidance for reviewing operational feedback

to plant personnel. The two examples previously discussed relating to GE

SIL 211, Supplement 1, and INPO SER 2-84 are indic'ative that additional

management attention is needed in this area to :ssure that evaluations arel

performed and recommendations resulting from these evaluations are

implemented in a timely manner.

The inspector reviewed onsite generated documents, MNCRs, and Design Change

Packages (DCPs) evaluated by.NPE. DCPs were reviewed for a period from 1982

until the present.

Significant improvement was noted by the inspector in

the quality of 10 CFR 50.59 safety reviews and safety review appli ability

checklists performed over the last year. This improvement can be credited,

in part, to the addition of a procedure providing guidance for reviews which

was implemented in August 1985.

The remaining credit would be on the

increased emphasis on personnel to provide a more thorough basis for

statements on safety reviews and safety review applicability checklists.

Material Nonconformance Reports (MNCRs) may be generated at any plant

organization level. After generation, the MNCR is directed to the QA Senior

Quality Representative where the report is logged and tracking begins. The

MNCR is then directed to the operations plant staff for initial evaluation.

Following this evaluation, the MNCR is either returned to QA for

implementation, tracking, and closure or to NPE for further evaluation.

After NPE evaluation, the MNCR returns to QA for distribution and tracking.

MNCRs concerning safety-related or important to safety issues received an

additional Design Quality Review by the QA Review Group.

This group

utilized QA Procedure 3.10, " Review of Design Documents Generated or

Approved by NPE", Revision 6, to provide guidance for this review.

The

majority of errors identified by this design quality review were

administrative in nature,

i.e.,

drawing revision discrepancies, signatures

missing from 50.59 reviews, or incomplete MNCR forms. QA was responsible

for verification and final closecut of the MNCR.

During the MNCR review, the inspector noted a discrepancy with MNCR 0142-85.

This MNCR dealt with marginally acceptable results of a Technical

Specification required surveillance of heaters in the Standby Gas Treatment

System (SGTS).

Electrical surveillance 06-EL-1T48-R-0001, Standby Gr.s

Treatment Heater Test, was being performed as a retest for DCP 84/3109.

This DCP removed the 50 Kilowatt (kw) heaters originally installed in the

SGTS and replaced them with 48 kw heaters which met 10 CFR 50.49 require-

ments. Technical Specifications require these heaters to dissipatt 5015 kw

for operability requirements.

The electrical surveillance performed on

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Train A of the SGTS on March 7, 1985, was performed twice before acceptable

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results were recorded. The first test was performed using a TIF digital

clamp-on ammeter (r; accuracy) with the measured capacity at 44.02 kw.

An

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Amprobe RS3A clamp-on ammeter (3*a accuracy), listed as a required test

equipment in the surveillance procedure, resulted in a capacity of 45.6 kw.

Based on these marginally acceptable results, MNCR 0142-85 was generated.

An attachment to the MNCR stated that acceptable readings were obtained only

after the heaters were energized for one hour.

El.ctrical maintenance

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personnel stated it was not unusual to employ additional test equipment in

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such situations and, cue to satisfactory readings obtained with surveillance

procedure suggested equipment, a violation of Technical Specifications did

not occur.

Electrical maintenance personnel also stated that energizing

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heaters for one hour would have a tandency to reduce, rather than increase,

heater output. NPE disrositioned this MNCR by stating that a nonconformance

did not exist and justified this statement with calculations generated by an

NPE engineer, demonstrating that the heaters could perform their intended

function with only 21.5 kw generated.

The disposition further stated that

50 5 kw value was based on the size of the originally installed heaters, not

supported by calculations, and that NPE would process a TS change based on

their calculations.

The current TS did not reflect this proposed change.

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Investigation of the change processing revealed a March 14, 1985, memo

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transmitting the change from NPE to the Director of Licensing and Safety.

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The inspector verified the memo was transmitted but could not locate any

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evidence to verify the change had been made or was still being processed.

Since a violation of TS has not occurred, this issue was not deemed a

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violation; however, the inspector was concerned with the interface weakness

which permitted this proposed TS change to remain unprocessed.

After

investigation, the deficiency appeared to be the result ~ of a low priority

assignment and/or a failure of the tracking mechanism to verify corrective

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action completion on an MNCR.

Investigation of the TS change issue demonstrated an inconsistency between

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the Licensing Group for TS changes and the procedure employed by NPE.

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Nuclear

Licensing

and Safety procedure 3.5,

" Control

of Technical

Specifications", Revision 0, described the detailed method by which TS

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changes are submitted to the Licensing Section and how these submittals were

to be acknowledged and processed.

The NPE procedure,01-319, " Changes to

GGNS Technical Specifications", Revision 2, did not provide a method for

receiving an acknowledgement from licensing and provided o r.1v general

guidelines for processing and submittal.

This inconsistency provides a

basis for discrepancies in the processing of TS changes by NPE. This issue

was discussed with the Principal Quality Engineer and will be reviewed in

conjunction with the NPE procedures enhancement program recently instigated

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by the Quality Engineering Group.

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.The Quality Engineering Section of NPE currently performs Quality

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Evaluations (internal audits) of NPE functions. The following evaluations

were reviewed by the inspector:

QE 86/001

Specifications

QE 85/005

Certification of Information

QE 85/004

Document Control

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QE 85/002

Design Change Control

QE 85/001

Performance of Design and Preparation of DCPs

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The Principal Quality Engineer (PQE) establishes a schedule for conducting

the evaluation and performs them accordingly. Evaluations ar: issued to the

Cognizant Principal Engineer (CPE) containing audit findings and recommended

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correr+.ive actions after the evaluation and corrective actions, if any, have

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been discussed between the PQE and CPE. Corrective action, if any, is then

taken by the CPE. Implementation of corrective action is then verified by

QE.

Procedure NPEAP 01-203, " Evaluation of NPE Activities", was first issued on

August 21, 1985, to assist NPE managers in finding problems and assessing

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root causes. All of the evaluations listed above, except 85/005, identified

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discrepancies.

Discrepancies were generally for failure to include the

proper drawing and procedure rei:1sions in DCPs, failure to include Equipment

Qualification Control File change review questionnaires in Change Notice

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packages, failure to provide complete control of design drawings, and

failure to re-file items properly.

It appears that the evaluations will

provide NPE with a method of finding problems and assessing root causes in

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dddition to that already provided by the plant Quality Assurance Department

audits.

Due to previous SALP ratings in the design control area, the inspector

reviewed changes in the NPE program and organization with potential for

improvement of licensee performance.

Personnel changes provide one

potential for improvement.

The Principal Quality Engineer position was

filled by an apparently quality conscious individual actively attempting to

locate and correct problem areas.

The organization has raduced the number

of contractor personnel, replacing these with company personnel better

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motivated to quality work and company goals. All professional staff members

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are participating in formal Engineering Analysis Training.

In addition, the

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Quality Engineering Group has initiated proceduralized internal evaluations

i to identify problems within NPE and provide corrective action. Due to the

short time these changes have been in effect, a determination cannot be made

as to the effectiveness of these measures.

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Within this area, no violations or deviations were identified.

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Audit Implementation (40704)

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10 CFR 50.54(a)(1), Conditions of License

References:

(4)

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(b) Mississippi

Power. and. Light Operational

Quality

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Assurance Manual (MPL-10P-1A), Revisian 4

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(c) 10 CFR 50 Appendix B, . Quality Assurance Criteria for

Nuclear Power Plants and Fuel Processing Plants

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(d) Regulatory Guide 1.144, Auditing of Quality Assurance

Programs for Nuclear Power Plants

(e) ANSI N45.2.12-1977, Requirements for Auditing of Quality

Assurance Programs for Nuclear Power Plants

(f) Technical: Specifications, Section 6

Several aspects of the QA audit program were inspected, especially in the

area of training audits. There were 15 training related audits and several

other, audits which included ' training activities performed by QA . audit

personnel in 1985. The. inspector reviewed the below listed eight training

related audits, three miscellaneous audits, and a Corrective Action Request

(CAR) which resulted from a 1 finding that was ' identified in one of the

audits.

These audits for. the most part were record and program reviews to

verify that training and other activities were being conducted in accordance

with - Mi ssi ssippi Power and Light (MP&L) procedures and other applicable

requirements. A few audits included classroom participation =but very few

. included. interviews with personnel to -determine their understanding of the

material and views on the adequacy of the training.

Audit Report No. 85/0009

Maintenance Training and Qualification

Program

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Audit Report No. 85/0037

Shift Technical Advisor Training

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Audit Report'No. 85/0045

Operator License Instructor Qualification

Audit Report No. 85/0073

Radiation Worker Training Program

Audit Report No. 85/0127

Contractor Process Control

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Audit Report No. 85/0153

Qualification of Contract Personnel

-Audit Report No. 85/0032

Fire Protection Implementation Procedures

Audit Report No.-85/0018

Fire Brigade Training

Audit Report No. 85/0144

Environmental Qualification of Electrical

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Equipment

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Audit Report No. 85/0166

Transamerican Delaval Incorporated (TDI)

Diesel

Generator DQ/QR Reports and

Summary of TDI Owners Group Recommenda-

tions and MP&L Actions

Audit Report No. 85/0064

Feedback of Operational Information

Several observations were discussed with QA management dealing with training

and miscellaneous other audits. One particular observation dealt with Audit

No. 85-0166. This audit reviewed 96 of 200 line item commitments to the NRC

to perform recommended activities on TDI diesel generators to ensure

operability. Of these 96 items, 2 were found to be deficient in that one

had not been incorporated into the surveillance activities and therefore was

not being performed, and the other involved the actual surveillance

periodicity being greater than that committed to in the letter to the NRC.

The discrepancies were corrected and verified by the auditor during the

course of the audit. The inspector questioned QA supervision on why the

remaining 104 line items were not audited following the discovery of the two

discrepancies and was told that a much greater percentage of deficiencies

must be found to warrant a 100% audit even considering the significance of

the TDI diesel generator operability question.

Another observation involved Audit 85-0037.

During the course of this

audit, the QA auditor identified a new requirement to have STA's fill out

qualification cards. But since the requirement for the qualification cards

was not in effect during the period being audited, the cards were not

reviewed. The qualification card requirement became effective December 1,

1985. The audit was conducted February 1985, but audited a period in late

1984. The inspector asked QA supervisicn if this new requirements for STA

qualification cards had now been audited in light of past training

qualification card problems, the inspector was told that the next STA

training audit was not scheduled until March 1986.

The final observation deals with Audit 85/0144 which looked at the

Environmental Qualification (EQ) of electrical equipment.

The audit

provided some very good recommendations to the EQ program.

These

recommendations consisted of NPE reviewing and revising ES-19, " Engineering

Standard for Environmental Equipment Qualification Maintenance," due to its

lack of adequate detail and minor inconsistencies.

More important, the

audit recommended that NPE perform plant walkdowns to support the

development of this new revision.

Finally, the audit recommended that

personnel associated with environmentally- qualified equipment should receive

training in order to understand the significance of the EQ program.

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Within this area, one violation was identified.

The training audits

reviewed did not identify any major deficiencies with the exception of one

that was identified in Audit 85/0073. This deficiency involved the training

of decontamination workers. The QA auditor identified that decontamination

training had nnt been received by any MP&L permanent or contract employees.

Through discussions with plant maintenance supervision, the QA auditor was

informed that decontamination work was being performed even though the

decontamination training had not been completed. QA initiated CAR 2157,

documenting the findings and requesting resolution. The plant and training

department responded by providing decontamination training to the

Labor /Decon Section.

During the CAR review and discussions with the

training department, the Labor /Decon Section supervisor, and the painters

supervisor, the inspector was informed that decontamination work such as

hydrolazing and use of strippable coatings was being performed by Bechtel

contract employees and MP&L painters, respectively. These workers did not

fall under the Labor /Decon Section that had received decontamination

training and therefore, were performing specific decontamination activities

without the required training.

The inspector discussed this apparent

discrepancy with the Chemical / Radiation Superintendent, Manager of Plant

Maintenance, and the painters' supervisor and was assured the decontamination

activities, even though performed by workers without the benefit of

decontamination training, were performed under the monitoring of Health

Physics (HP) personnel. The inspector was informed that these workers had

also received radiation training such as Rad Worker I and Rad Worker II

prior to the performance of decontamination work. The reason given as to

why decontamination training had not been provided to the Bechtel

hydro-lazers or the MP&L painters was because they were not in the

Labor /Decon Section and plant personnel failed to recognize that the work

performed by these personnel required them, by procedure, to have completed

the decontamination training.

QA also closed out CAR 2157 with the

completion of training of the Labor /Decon Section, failing to followup to

ensure that all personnel who performed specific decontamination activities

had received the required training.

Technical Specification 6.8.1

requires that written procedures be

established, implemented, and maintained covering activities in Appendix A

of Regulatory Guide 1.33, Revision 2, February 1978.

Section 7.e(6) requires,

radiation protection procedures.

Administrative Procedure 01-S-04-25,

" Decontamination Training Program", requires that all personnel performing

decontamination work receive decontamination training.

The failure to

ensure that personnel performing hydro-lazing and strippable coating

decontamination activities had received required training is identified as

Violation 50-416/86-03-01.

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