ML20199G261
| 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: |
| 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
Text
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, u. M MCo UNITE] STAT ES
f fo NUCLEAR HEGULATORY COMMISSION
REGION ll
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ATLANT A. GEORGI A 30323
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Report No.: 50-416/86-03
Licensee: Mississippi Power and Light Company
L -Jackson, MS 39205
Docket No.: 50-416- License.No.: NPF-29
,- Facility Name: . Grand Gulf
Inspection Conducted: February 10-14, 1986
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Inspectors: ' [ [5 a I f V$
J. L. Caldwell -V- /
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Date Signed
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L. R. Moore 'V / Date Signed
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T H. Moorman,'Iri / Date/ Signed
~ Approved by: - Ze C:7 _T [ d //,?,
G. A.'Belisle, Acfing Section Chief Date Signed
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-
tion.
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Results: One violation was identified - Failure te train decontamination workers
. .c -in accordance with procedures.
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8604090101 860329
PDR ADOCK 05000416
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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
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- A Cross, Site Director
- 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
- F. Titus, Director, Nuclear Plant Engineering
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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
- 2. 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
inappropriate. Mr. S. Feith was notified of this position during a
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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
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
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tracking system which caused the evaluation for SER 2-84 not being completed
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in a prompt manner.
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
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
_ 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
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
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their calculations. The current TS did not reflect this proposed change.
Investigation of the change processing revealed a March 14, 1985, memo
[ 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
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
_ action completion on an MNCR.
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Investigation of the TS change issue demonstrated an inconsistency between
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
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Specifications", Revision 0, described the detailed method by which TS
__ 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
r conjunction with the NPE procedures enhancement program recently instigated
{' by the Quality Engineering Group.
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.The Quality Engineering Section of NPE currently performs Quality .
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 '
QE 85/002 Design Change Control
QE 85/001 Performance of Design and Preparation of DCPs 1
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 g
correr+.ive actions after the evaluation and corrective actions, if any, have I
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 -
root causes. All of the evaluations listed above, except 85/005, identified )
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 _
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 e
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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
n motivated to quality work and company goals. All professional staff members -
are participating in formal Engineering Analysis Training. In addition, the -
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
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Within this area, no violations or deviations were identified.
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References: (4) 10 CFR 50.54(a)(1), Conditions of License
(b) Mississippi Power. and. Light Operational Quality -
i Assurance Manual (MPL-10P-1A), Revisian 4
(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
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Audit Report No. 85/0037 Shift Technical Advisor Training
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 ,
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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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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