IR 05000400/1986068

Insp Rept 50-400/86-68 on 860820-0920.Violations Noted:Qa Personnel Failed to Identify Necessary QC Hold Points on Wr&A 86-AUAK1 & QA Personnel Failed to Provide Adequate Review of Completed Wr&As 86-ABXA1,86-ABXA2 & 86-ABXA3

ML20215K808
Person / Time
Site:	Harris
Issue date:	10/14/1986
From:	Burris S, Fredrickson P, Maxwell G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20215K773	List: IR 05000400/1986068 ML20215K771 ML20215K776
References
50-400-86-68, NUDOCS 8610280310
Download: ML20215K808 (8)

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Report No.: 50-400/86-68 Licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 5 Docket No.: 50-400 License No.: CPPR-158 Facility Name: Harris 1 Inspection Conducted: August 20 - September 20, 1986 Inspectors: ANL LW ibini /st g GJ F. Maxwell Date Signed

. f$.NLn lo lsu IQ Date Signed 9c. S\ Burpts Approved by:  % AW / d!/4/fd P. E. Fredrickson, Section Chief Date Signed Division of Reactor Projects SUMMARY Scope: This routine, announced inspection involved inspection in the areas of Licensee Action on Previous Enforcement Matters and Inspector Follow-up Items, Operations Documentation and Inspection, Preoperational Test Program Implementation Verification, and Other Activitie Results: One violation comprised of five examples was identified " Failure to Implement QA/QC Related Procedures" paragraphs 4.a.(1), (2), (3), 4.b and PDH ADOCK 00000400 0 PDR

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REPORT DETAILS 1. Persons Contacted Licensee Employees N. J. Chiangi, Manager QA/QC Harris Plant J. M. Collins, Manager, Operations G. L. Forehand, Director, QA/QC J. L. Harness, Assistant Plant General Manager, Operations C. S. Hinnant, Manager, Start-up L. I. Loflin, Manager, Harris Plant Engineering Support C. L. McLenzie, Acting Director, Operations QA/QC G. A. Myer, General Manager, Milestone Completion M. F. Thompson, Jr., Manager, Engineering Management D. L. Tibbitts, Director, Regulatory Compliance R. B. Van Metre, Manager, Harris Plant Maintenance R. A. Watson, Vice President, Harris Nuclear Project J. L. Willis, Plant General Manager, Operations Other licensee employees contacted included construction craftsmen, technicians, operators, mechanics, security force members, engineering personne'., office personne . Exit Interview The inspection scope and findings were summarized on September 19, 1986, with the Plant General Manager, Operation No written material was provided to the licensee by the resident inspectors during this reporting period. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspection. The violation identified in this report has been discussed in detail with the licensee. The licensee provided no dissenting information at the exit meetin . Licensee Action on Previous Enforcement Matters and Inspector Follow-up Items (92702, 92701) (Closed) Deviation 400/86-46-02 " Failure to Review Shif t Notes". The inspectors reviewed CP&L's letter to Region II dated August 7,1986, concerning this item and found it to be an acceptable way of addressing the conditions identified in the deviatio The inspectors evaluated the implementation of CP&L's proposed correc-tive action and corrective action to prevent further deviations, as related to this ite The inspectors reviewed all of the active 1986 shift notes and found that subsequent to the issuance of the deviation, the responsible operations supervisor has been reviewing the notes at the prescribed frequency. The yellow stick-on notes have been removed from the shift notes and those shift notes which are not applicable

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have been cancelled. The inspectors interviewed the operations super-visor who stated that he had been counseled on the administrative requirements of the applicable operations procedure, OMM-00 This item is close (Closed) Inspector Follow-up Item 400/86-55-02 " Anchor-Darling Check valves." The inspectors reviewed the licensee's evaluation and subse-quent corrective action son two Anchor-Darling check valves which were identified in Region II Potential Generic Item 85-2 The licensee previously evaluated that these valves were acceptable for use

"as is", based on a response from the vendor, Anchor-Darling. CP&L determined that the valves in question should be inspected and repaired in accordance with the original recommendations, and has performed the necessary corrective actions with the appropriate documentation. The inspectors have reviewed this item and consider this item close . Operations Documentation and Inspection (94300B, 71302, 91719)

During this inspection period, the inspectors obtained additional information regarding the Unresolved Item 400/86-60-02, " Management Control of QA/QC Activities." This item dealt with the licensee's control and adherence to procedures during the conduct of work in accordance with the Work Request and Authorization (WR&A) program. The inspectors conducted interviews which included QA/QC inspectors, supervisors, and management personnel in the areas of issuance of Nonconforming Condition Reports (NRCs) and identifi-cation and witnessing of WR&A QC Hold points, The inspectors reviewed WR&A 86-AVAK1 which requested that maintenance provide maintenance support in assisting the Crosby representative in implementation of Field Change Request (FCR) FCR-M-1976, Rev. This FCR was being implemented to increase the reliability of the 15 installed and two spare steam generator power operated relief valves (PORVs) by adjusting the nozzle ring and guide ring settings. On July 23, 1986, the licensee approved WR&A 86-AUAK1 which identified only one relief valve to be worked (valve 218-MS line B SRV R2). However, on July 25, 1986, the vendor's representative and maintenance personnel were directed verbally by the start-up engineer to reset the two spare valves in the warehouse. The NRC inspectors were informed that the l

work was done on the spare valves to correct their settings and provide a training evolution for the maintenance personnel prior to performing the work on the valves which were identified on WR&A 86-AVAK1. While this work was in progress on the spare valves, the start-up engineer noted that Quality Control (QC) personnel were not observing the in-process work on the spare valves. The start-up engineer called QC, and when the QC inspector arrived he found that work on one of the valves had been completed and was in progress on the other spare valv The QC inspector reviewed the WR&A and found that no hold points had been assigned as required by the WR&A procedure. The QC inspector stopped work under this WR&A, wrote an NCR and submitted it to his supervision for issuance. However, his supervisor determined that this discrepancy was to be tracked under control of QC's monitoring

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i l procedure, QCP-307, Rev. O, instead of issuing a NCR, as required j by QAP-104, Section 7, to identify the nonconforming conditio Subsequently, the licensee issued 17 new WR&As. By having separate WR&As for each valve, work activities could be properly controlled r during their disassembly, resetting the nozzle and guide rings, reassembly, stamping the proper markings on the valves, and any required QC inspections. The resident inspectors reviewed all the l licensee-supplied documentation for this item and determined that the licensee failed to implement or follow procedures in several area i (1) The licensee maintenance personnel performed work, as directed by the Start-up engineer, on the two spare valves without an approved WR& Failure to perform maintenance activities in accordance with approved procedures or instructions is contrary to CP&L Corporate QA Program, Section 13, and Maintenance Management Manual MMM-012, Section 5.4 and Appendix B, and MMM-001, Sections 4.4 and 5.5, and is identified as an example of a violation, 400/86-68-01.

! (2) QC personnel reviewed WR&A 86-AUAK Their review failed to

! identify the necessary QC hold points to assure that work acti-l vities affecting quality were inspecte Failure to establish the required QC inspection hold points for maintenance activities is contrary to QA procedure QAP 202, Section 7.1, and is an additional example of violation, 400/86-68-01.

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(3) QC personnel failed to document nonconforming conditions concerning j WR&A 86-AVAK1 in accordance with the approved procedure, QAP 104, 1 Section 7. QC supervision required that the nonconforming condition be documented and controlled by utilizing QC procedure QCP-307, which was not the appropriate procedure. This failure to follow procedure QAP-104 is an additional example of violation 400/86-i 68-01.

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b. The inspectors evaluated WR&As 86-AXTA1, 86-AXTB1, 86-AXTD1, 86-AXTEl, 86-AXTQ1, 86-AXTR1, 86-AXTS1, 86-AXTT1 and 86-AXTV1 and found that the required QC hold points and necessary work directives had not

been properly assigned or witnessed. These WR&As were generated to j incorporate FCR 1-3404 to climinate the use of terminal blocks in nine Barton Model 752 transmitters. The terminal blocks connected the i transmitter leads to the class 1E control cables. The terminal blocks were only qualified for 11 years and therefore the licensee decided to replace them with butt splices using EBASCO electrical specification 2166-B060. Further investigation into this area led the inspectors to

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determine that the licensee failed to comply with the requirements of

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the operations maintenance progra The above referenced FCR package required that the operations group

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generate the appropriate WR&As to cover all of the necessary work and l

documentation. The licensee issued the above identified nine WR&As requiring the QC group to witness the proper implementation of this <

FC However, when the work was performed during second shift on

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i August 8, 1986, an electrical QC inspector was not on sit NRC inspectors were told by the responsible QC supervisor that the main-tenance group called him at home. He informed maintenance to go ahead and pass the QC inspection hold points, that he would take care of the hold points during the final review process of the WR& The NRC i inspectors questioned the method that was to be used to verify proper implementation of the FCR since the QC hold point required witnessing termination of leads, butt splicing and installation of Raychem sealan After making the necessary butt solices, maintenance installed the Raychem sealant and heat shrink tuoing over these connectors. The NRC inspectors verified that inspection, after installation of the Raychem

seal and shrink tubing would not be an acceptable method of inspecting the butt splice Prior to the end of the reporting period, the licensee required that the previously installed splices be determined

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and reinstalled and properly inspecte The inspectors reviewed these in plant field modifications, and informed the licensee that failure to witness the required in process QC hold points was contrary to MMM-001, Rev. 2, Section 4.4 and 5.5.8, MMM-012, Rev. 4, Sections 5.4, and the Appendix B and is an additional example of violation 400/86-68-0 The inspectors obtained and reviewed a copy of WR&A 86-ABXA1, 86-ABXA2, and 86-ABXA3 from the completed records vault. The WR&A requested that licensee maintenance and instrumentation and control personnel determinate, repack and reterminate motor valve operator 2CT-V758 in accordance with instructions in EBASCO electrical specification 2166-B060 and operations maintenance procedures. AS required by site procedures, the QA/QC organization performed an initial and final review of the WR&A to assure that proper procedural controls were use The inspectors noted that the WR&As identified two separate valves, when only one valve required maintenanc Under the equipment identification section, the WR&A stated that the valve to be worked was

"HAN-CNMT SUMP TO CNMT SPRAY PUMP 1B-SB VLV ID CT-758," however, under the section entitled " Nature of Trouble, How Found, Location:", the valve was identified as "2CT-V75A." Even though the WR&A contained conflicting information, the work was conducted on the correct valv The inspectors informed the licensee management that none of the QA/QC reviews of the WR&A documentation identified that two

separate valves were listed on the WR&A, whereas only one of the i

valves shown on the WR&A was required to have maintenance performed on it. The inspectors informed the licensee that this is contrary to QAP-202, Review of Work Request & Authorization, Rev. 1, Sections 7.4 and 7.5 and is an additional example of violation 400/86-68-0 The previously identified Unresolved Item 400/86-60-02, " Management Controls of QA/QC Activities " is closed, but the above discussed five items are collectively identified as a violation 400/86-68-01,

" Failure to Implement QA/QC Related Procedures." . - .- . - _ _ - - _ _ _ _ _ _ _ - - - - - _ _ - _. .-

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d. During routing reviews of NCRs affecting safety-related equipment for June - August 1986, the inspectors observed several problem area (1) NCR 86-0042 identified that ANSI N45.2.2-1972, paragraph 6.4. and SHNPP FSAR Exception to 6.4.2.7 state that prior to being placed in storage, rotating equipment weighing over approximately 50 pounds shall be evaluated by engineering personnel to determine if shaft rotation in storage is required and these evaluations shall be documented. The NCR further states that contrary to this, there were no operation procedures which addressed the above requirements. This NCR was assigned to the maintenance group for response. The maintenance manager submitted a memorandum on June 19, 1986, which stated, "The subject NCR should not be assigned to the maintenance group for responsibility and correc-tive action." The NCR was identified on June 13, 1986, as a significant generic condition, requiring a documented corrective I action within 30 day However, the inspectors noted that on August 28, 1986, there were not corrective actions or extensions granted within the required 30 days. As a result of inquiry by the resident inspectors, the licensee issued another NCR again identifying the same nonconforming conditio (2) NCR 86-0055, dated July 23, 1986, and NCR 86-0069, dated August 21, 1986, identified similar instances where maintenance activities were performed under control of WR&As which changed the scope of the work from a maintenance activity to a modification activit MMM-001, Rev. 2, Section 5.2.4 states "When instructions are included on a Work Renuest or checklist, or if approved procedures are identified, personnel are required to adhere to those proce-dures and/or instructions...or if there is a change in the scope of a prccedure or Work Request, the Mechanic / Technician must stop work and notify their Foreman."

Contrary to this, the maintenance group failed to identify that the work scope was changed as described in the repair instructions. The work performed changed the WR&A from a maintenance activity to a modification. Maintenance personnel failed to identify to QA/QC and/or In Service Inspection (ISI) that a review was required under the new activity. NCR 86-0055 was identified and corrective action implemented on August 22, 1986, which involved training maintenance personnel as to the above specified requirement However, on August 21, 1986, QC personnel identified a similar instance on NCR 86-0069 which occurred as noted on NCR 86-0055. The inspectors questioned QC management to determine if this condition was indicative of inadequate corrective actio The inspectors will evaluate CP&L's corrective actions for NCR 86-0055 and NCR 86-0069 and the apparent lack of prompt action on NCR 86-0042 during subsequent routine inspections.

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6 Preoperational Test Program Implementation Verification (71302) The inspectors conducted routine tours of the facility to make an independent assessment of equipment conditions, plant conditions, security, and adherence to regulatory requirements. The tours included a general observation of plant areas to determine if fire hazards existed; observation of activities in progress (e.g., maintenance, preoperational testing, etc.) to determine if they were being conducted in accordance with approved procedures; and observation of activities which could damage installed equipment or instrumentation. The tours also included evaluation of system cleanness controls and a review of logs maintained by test groups to identify problems that may be appro-priate for additional follow-u During the weeks of September 8 and September 15, 1986, testing was in progress on the engineered safety feature These tests were being conducted to assure that the overall safe shutdown features would function as designed. The tests described in the procedure which controlled the testing " Engineered Safety Features Integrated Test" 1-090-P03 were completed on September 18, 1986. As a result of the test no major equipment problems were identified. The resulting test data which was taken by the licensee has not yet been assembled and evaluated to determine its acceptabilit No violations or deviations were identified in the areas inspecte . OtherActivities(94300B) On September 9, 1986, management representing Region II and the Offices of Nuclear Reactor Regulation and Inspection and Enforcement met with CP&L corporate and site management. The agenda included a briefing by CP&L concerning the status of operational readiness, construction, preoperational testing, and start-up. During the meeting, information was exchanged in the areas of: the proposed operations staffing, operations training program, CP&L's application of lessons learned from other near term operating license plants, maintenance programs practices implemented by other utilities, the status of plant proce-dures and Technical Specifications, emergency preparedness, evaluations and recommendations by INPO concerning operations and maintenance, start-up organization and the role of the on-site nuclear safety grou After the meeting there was a tour of the power block. The tour ended by a visit to the Harris Plant simalator where a plant accident condition was simulated and observed by the tour group. Upon completion of the simulator tour an exit meeting was held between NRC and CP&L managemen On September 15, 1986, the Chairman of the Nuclear Regulatory Commission visited the Harris site. The visit began with the Chairman having a brief meeting with the resident inspectors following by a CP&L presenta-tion wherein the status of operations staf fing, start-up, operations maintenance, operating Technical Specifications and procedures were discussed. Several members representing parties to the license hearings

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attended the CP&L presentation and accompanied the Chairman for the duration of his visi After the presentation, a site tour was conducted. The party toured the control room and the Chairman inter-viewed on shift operators. He then held a meeting with a large number of additional NRC-licensed CP&L operator The party toured the on-site emergency response technical support center (TSC) and was briefed by responsible CP&L supervision concerning the TSC, the display system which is to be utilized during emergency response conditions and the guidelines which CP&L plans to follow when implementing plant emergency operating procedures. The tour then proceeded through the plant chemistry laboratories, the containment building, the reactor auxiliary building and concluded after a tour of the diesel generator building. The Chairman's visit ended after a tour of the Harris Plant simulator and an exit meeting with CP&L management. Following the exit meeting, the Chairman met with various representatives from the media and responded to their questions concerning the Harris site.

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