ML20127K190

Insp Repts 50-369/85-09 & 50-370/85-10 on 850304-08. Violation Noted:Failure to Specify post-mod Testing Requirements & Acceptance Criteria

ML20127K190
Person / Time
Site:	Mcguire, McGuire
Issue date:	04/09/1985
From:	Casey Smith, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127K170	List: ML20127K166 ML20127K176 ML20127K190
References
50-369-85-09, 50-369-85-9, 50-370-85-10, NUDOCS 8505220066
Download: ML20127K190 (13)

See also: IR 05000369/1985009

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AIUCLEdR REGULATORY COMMISSION ~

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iReport Nos.: 50-36h/85-09and50-370/85-10

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Licensee: DukeIPowerCompany

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-422 South' Church Street.

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-Charlotte, NC .28242-

.u m Dockst"Nosl: ~50-369'and 50-370 ,

License Nos.: NPF-9 and NPF-17-

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Facility Name: McGuire'l_and 2

Inspection Conducted

March 4-8,-1985

A' LInspector:# [h A,N

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', _ C. F.%V Date/ Signed

g_' / Accompanying. Personnel': =R. M. Latta, Region II .

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Appro'ved by:

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C. M. Upr.ight/,JSect)g6 Chief D'te

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' SUMMARY

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Y Scope: This routine, unannounced inspection entailed-70 inspector-hours

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't  : on -: site and at' Duke Corporate offices in .the areas'of design control, tests a'nd .,~ H

• f~ experiments, and. licensee action on previously identified inspection findings.

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~Results: One violation was identified . Failure _ to Specify Post Modification .

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.' iTesting Requirements.and. Acceptance Criteria. '

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' REPORT DETAILS

J1. -Persons Contacted

l Licensee - Employees

• J. Barber,' Quality' Assurance Manager, Operations, Quality Assurance

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• A. Batts, Quality Assurance Engineer, Quality Assurance-

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• Ei Brafford, Project Engineer,. Design Engineering-

*G. Cage, Superintendent Operations, Nuclear _ Production Department

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s~ *E. Estep, Project Services Engineer, Nuclear Production Department

• C. Fish; Contract Coordinator, Nuclear Production Department-

D. Franks, Quality-Assurance-Surveillance _ Supervisor, Quality Assurance

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~ *G. Grier, Corporate Quality Assurance Manager,. Quality Assurance

. *P.;Herran, Supervising Design Engineer, Design Engineering,, Mechanical /

Nuclear

W.. Houston,. Senior Engineer, Project. Management Division, Design ~ Engineering

J. Keirnan~ Project Engineer, Design Engineering / Electrical Project

,

. Management Division

.T. : Ledford, Supervising Design Engineer, Design _ Engineering / Electrical

D. . Marquis, Performance Engineer, Nuclear Production Department-

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• T.' McConnell, Station Manager, Nuclear Production Department-

• N. McGraw,. Compliance Engineer, Nuclear Production Department

S. McInnis,-Associate Engineer, Compliance Group, Nuclear Production

Department

• R. Medlin,' Quality Assurance

• D. Mendezoff, Engineering Specialist, Compliance Group, Nuclear Production

Department

D. Murdock,LPrincipal Engineer,-Design Engineering / Electrical

• P.;Nardoci, Licensing Engineer, Nuclear Production Department

-B.-Peele,1 Design Engineer, Design Engineering, Mechanical / Nuclear

• D. Rains, Superintendent of Maintenance, Nuclear Production Department

R.. Revels,. Design Engineer II,- Design Engineering Mechanical / Nuclear

• T._ Roberts, Quality Assurance

R.: Ruth, Site Quality Assurance Supervisor

• B. Travis,: Superintendent Integrated Scheduling

M..Tully, Design Engineer II, Research and Projects

D. Vass, Design Engineer II, Design Engineering / Electrical

• R. Webar, Director of Nuclear Projects-

NRC Resident Inspectors

*W. Orders, Senior Resident Inspector

• P. Skinner, Visiting Senior Resident-Inspector

• Attended exit interview

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2. Exit-Interview

The inspection scope and findings were summarized on March 7,1985, with :

those persons . indicated in paragraph 1 above. The inspector described the

areas inspected. and discussed in detail the inspection findings listed

below. . The licensee did not identify as' proprietary any of the materials

,provided to or reviewed by the. inspector during this inspection.

~Vio14 tion, Failure : to Specify. Post Modification Testing Requirements

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and Acceptance Criteria, Paragraph 4.a.

Dissenting comments were received from licensee management concerning

this violation. Licensee. management stated that this responsibility

has been assigned to the Nuclear Production Department by Duke Power

Company.

Violation, Failure to Establish Measures for Reporting to the - NRC

pursuant to 10 CFR 50.59

Subsequent review by Regional Management verified that guidance for

reporting' design changes to the NRC in accordance with 10 CFR 50.59 is

delineated in _the : regulations. This violation was withdrawn and

licensee management was. informed of this action in a telephone

conversation on March 14, 1985.

Inspector Followup Item, Revision to Exempt Change Program, paragraph

4.b.

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Inspector Followup Item, Revision to Nuclear Safety Evaluation Check-

list,' paragraph 4.c.

Inspector. Followup Item, Preparation of Working Level Procedures for

Technical Services Staff, Paragraph 4.d.

Inspector Followup Item, Revision to Design Engineering Department

Procedure PR-160, paragraph 4.e.

3. Licensee Action on Previous Enforcement Matters

.This subject was not addressed in the inspection.

4. Design Program (37702)

References: (a) 10 CFR 50, Appendix B, Quality Assurance Criteria for

Nuclear . Power Plants and Fuel Reprocessing Plants,

Criterion III

(b) Regulatory Guide 1.64, Quality Assurance Requirements

for the Design of Nuclear Power Plants, Revision 2

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

the Design of Nuclear: Power Plants

(d) Regulatory Guide 1.33,- Quality Assurance Requirements  ;

(Operations) November 1972

-(e) ANSI N18.7-1976, Administrative Controls and Quality

Assurance for the Operational Phase of Nuclear Power

Plants

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(f) 10 CFR Part 50.59, Changes, Tests and Experiments

(g) . Technical Specifications Section 6.5, Review and Audit

The inspector reviewed the licensee design' change program required by

. references (a) through (g) to verify.that these activities were conducted in

accordance with regulatory requirements, industry guides and standards, and

Technical Specifications. The fc110 wing criteria were used during the

review to assess the overall acceptability of the established program:

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Procedures have been established to control design changes which

include assurance that a proposed change does not involve an unreviewed

safety question or a change in technical specifications as required by

10 CFR 50.59.

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Procedures and responsibilities for design control have been estab-

lished including responsibilities and methods for conducting safety

evaluations.

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Administrative controls for design document control have betn estab-

lished for the following:

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Controlling changes to approved design change documents

Controlling or recalling obsolete design change documents such as

revised drawings and modification procedures

Release distribution of approved design change documents

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Administrative controls and responsibilities have been established

commensurate with the time frame for implementation to assure that

design changes will be incorporated into:

• Plant procedures

Operator training programs

Plant drawings to reflect implemented design changes and modif t-

cations

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Design controls require that implementation will be in accordance with

approved procedures.

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Design controls require assigning responsibility for identifying

post-modification testing _ requirements and acceptance criteria in

approved. test procedures and for evaluation of test results.

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Procedures assign responsibility and delineate the method for reporting

design _ changes to the NRC in accordance with 10 CFR 50.59.

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-Controls require review and approval of temporary modifications in

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accordance with Section 6 of the Technical Specifications and 10 CFR

50.59.

The documents listed below were reviewed to verify that these criteria had

been incorporated into the licensee design program:

' Duke Power Company Topical Report, Quality Assurance Program, Duke-1

Section 17.2.3, Revision 8

Duke Power Company, Quality Assurance Manual, Design Engineering

Department

Section DEQAP, Department Quality Assurance Plan, Revision 15

Section PR-160, Nuclear Station Modification, Revision 6

Section PR-170, Design Specifications, Revision 4

Section PR-201, Variation Notice, Revision 22

Section PR-202, Design Nonconformance, Revision 7

Section PR-220, Nonconforming Item Report, Revision 15

Section PR-260, Nuclear Station Problem Report, Revision 6

Section PR-290, Nuclear Regulatory Commission Reporting Require-

ments, 9evision 11

Section PR-400, Quality Assurance Program for Client Projects,-

Revision 1

Section PR-931, Design Quality Assurance Records Review, Approval

and Storage, Revision 8

Design Engineering Department Manual

Section II.4.2, Station Modifications, Revised 10-01-84

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Section II.4.3, Station Modification Interim Procedure for McGuire

1, Revised 10-01-84-

. Section 11.5.1, Design Criteria Documentation, Revised 10-01-84

Electrical Division Procedure 9.0.1, Design Process Summary, Revision 0.

Electrical Design Manual, Revision 17

Nuclear Station Modification Manual

Section 4.2, Design Engineering Designed Modifications, Revision 0

.Section 4.3, Station Designed Modifications, Revision 0

Section 4.4, Exempt Changes, Revision 0

Section 7.0, Administration of Nuclear Station Modifications,

Revision 0

Section.7.6, Design,. Revision 0

Section 7.7, Drawing Control, Revision 0

Section 8.0, Administration of Major Construction Projects,

Revision 0

Section 9.0, Administration of Exempt and Temporary Changes,

Revision 0

Station Directives Manual, Revised 02-20-85

Section 4.4, Modification

The inspector interviewed licensee onsite QA staff to determine the degree

of involvement of QA staff members in the performance of surveillance in the

functional area of plant modifications. The following surveillance reports

were reviewed by the inspector:

Surveillance Report MC-84-71, Nuclear Station Modifications dated

January 10, 1985. No deficiencies were identified by this surveil-

lance. The surveillance summary states that in October 1984 the

nuclear station modification program was changed to improve the

modification program system. A Nuclear Station Modification Manual

which clearly delegates responsibilities and introduces new forms into

the program had also been prepared. Because of the " newness" of this

program change, this surveillance was performed on nuclear station

modifications performed prior to October 1984.

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Surveillance Report MC-84-39, Station Modifications, dated

September 14, 1984. This surveillance identified two deficiencies in

connection with procedural non-compliance. The deficiencies were noted

as having been corrected.

Surveillance Report MC-84-62, Station Modifications, Temporary

Modifications and Lead Shielding, dated March 27, 1984. No deficien-

cies or nonconforming items were identified by this surveillance.

Surveillance Report MC-84-12, Station Modifications, Temporary

Modifications. This surveillance identified one deficiency in

connection with the independent ~ verification for restoration of

temporary modification. This deficiency is listed as having been

corrected. One deficiency was identified and noted as not having been

corrected. This concerned the determination of seismic classifications

of system piping by a qualified reviewer, who is required to be a

Safety Review Committee (SRC) member. Station Directive 2.10.12 was

subsequently revised to delegate responsibility for determination of

seismic requirements to non-SRC reviewers.

The inspector intery,ewed licensee management in the Engineering Design

Department to verify that a quality assurance program for design had been

established and documented to comply with the requirements of ANSI

N45.2.11-1974.

In October 1984 the nuclear station modification program was revised. This

resulted in the preparation of a Nuclear Station Modification Manual which

specifies the appropriate requirements which shall be met to implement a

modification at an operational nuclear station.

Additionally, the Design Engineering Department Manual was reformatted,

revised, divided into two volumes, and reissued to allow a better under-

standing and handling of the Department Manual procedures. The licensee has

established a Design Engineering Department Manual Review Committee

consisting of representatives from each Division. This committee meets

monthly for reviewing any proposed changes to the Department Manual for

merit and for assuring appropriate interdepartmental review. Procedures

have been established to assure that design activities performed by Design

Engineering are carried out in a planned, controlled, orderly, and correct

manner. ,

Specific types of modifications can be designed by the Nuclear Production

Department following concurrence from Design Engineering. Nuclear Station

Modification Manual Section 7.6, Design, delineates the administrative

controls applicable to both Design Engineering Designed Modifications (DDMs)

and Station Designed Modifications (SDMs). Additional requirements for the

processing of Nuclear Station Modifications are delineated in Station

Directive Section 4.4.

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Nuclear Safety. Evaluations are performed for DDMs and'SDMs to assure that a

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. proposed change does' not involve an 'unreviewed safety- question or. a change

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in -the Technical . Specifications (TS) as required.by 10. CFR 50.59. . Addi-

tionally, measures.have been established to control temporary modifications

including the performance of a~ Nuclear: Safety Evaluation - for determination

.'of an unreviewed ~ safety question in accordance with 10 CFR 50.59. Station

.

, ~ Directive .(SD) '4.4.2 Revision 5 delineates the ' administrative controls '

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, applicable - to the - control of - temporary modifications. The inspector

reviewed 'a draft copy. (revision 6) of SD -4.4.2 which .is being revised -to

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include a ; Temporary ~ Modification Evaluation Checklist in addition. to

providing more prescriptive' guidance for the controls of temporary .modif t-

cations.-

Jithin this area, one violation and four inspector . followup items were

fidentified and they.are discussed in the following paragraphs,

a. Failure to:Specify Post Modification Test- Requirements and Acceptance

Criteria

-The ' Nuclear Station. Modification Manual Section 7.6 states that the

design of modifications is normally the responsibility.of the Design

Engineering Department. .Section 7.6.1, Design Engineering ~ Designed

Modification (DDMs)', further states that modifications designed by

' Design Engineering .should be' processed 'in accordance with Design

Engineering Department Quality Assurance Manual Procedure PR-160 and

Design Engineering Department Manual Procedure VI.E.2.

Licensee accepted QA program endorses Regulatory Guide 1.64 Revision 2

and ANSI N45.2.11-1974. Regulatory guide 1.64 paragraph C, Regulatory

position and ANSI N45.2.11 Section 3.2.20 requires that test require-

ments including in plant test and the conditions under which they will

be performed be specified as design inputs.

The administrative controls delineated in procedure PR-160 do not

address the requirements of ANSI N45.2.11-1974 Section 3.2.20 in that

test requirements including in plant tests and the conditions under

which they will be performed are not provided as design inputs for

station modifications designed by Design Engineering.

Additionally, licensee lower tier document Design Engineering Depart-

- ment Manual Section II.4.2, Station Modifications, revised October 1,

1984, does not address requirements for post modification tests and

post modification test acceptance criteria.

This failure to establish measures required by the accepted QA program

section 17.2.3 is identified as violation 369/85-09-01 and

370/85-10-01.

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b.  ; Revision to Exempt Change Program

-Exempt changes . are . defined 1 as a change to. a structure, system, or__

component that ~f s exempt-from .the requirements' of Section 7.0 of the

Nuclear Station' Modification. Manual. Exempt changes are intended to be

' changes to structures, systems, or ' components that do not require the

same 1evel of- approvals, reviews, and documentation as a . station .

designed modification (SDM) or a Design Engineering designed modiff-

cation (DOM).

Nuclearf Station Modifica' tion Manual Sectioni 9.0, 4 Administration of

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Exempt 'and _ Temporary Changes, delineates the ' requirements for changes

conducted under.the Exempt Change Program and provides typical examples

of. changes that may be performed in paragraph 9.2.1. The inspector

u . expressed a concern at the . lack of specificity contained in the program

for activities that'may be performed as exempt changes. Additionally,

the inspector stated in a telephone conversation to licensee management

on March 13,~1985,~that all changes to QA Condition 1 Systems (Nuclear

Safety Related) must be conducted within the controls of the nuclear

station modification program as required by licensee commitments

delineated in the accepted QA Program.

Licensee management stated in the telephone conversation _that not all

controls of the nuclear station modification program would be applic-

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able to some activities performed on QA Condition. I system as exempt

changes. -Licensee management expressed concern regarding the use.of

resources and the . documentation requirement for changes of this type.

The licensee has previously identified the need to revise the require-

ments of the Exempt-Change program to provide prescriptive guidance for

activities . to be conducted under_ this program. Until the program

description 'has been delineated in appropriate documents, this is

identified as Inspector Followup Item 369/85-09-02 and 370/85-10-02.

c. Revision to Nuclear Safety Evaluation Checklist

Station Designed Modifications 1(SDMs) are performed by qualified

designers and checked by. qualified design verifiers in the Nuclear

Production Department. A safety evaluation is required to be performed

for determination of an unreviewed safety question in accordance with

10 CFR 50.59. A qualified designer in the Nuclear Production Depart-

ment originates a . Nuclear Safety Evaluation Checklist form for each

SDM. The checklist documents the safety evaluation for the modifica-

tion including the reviews of the FSAR, Technical Specifications (TS),

all appendices to the TS, and potential unreviewed safety questions.

.The checklist is independently reviewed by a qualified design reviewer.

The inspector expressed concern that the Nuclear Safety Evaluation

Checklist does' not provide a basis for the decisions reached. The

checklist documents the decision that an unreviewed safety question

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does' not'. exist without: documenting the specific reviews and actions

taken.to arrive at this conclusion.

- The' . licensee . concurred. with. the inspector's observations and stated

-.that the Nuclear Safety Evaluation Checklist will be revised to' provide-

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substantiating information for the decision documented. The final form

for this checklist has not been completed. The. inspector. understands

that a narrative description of the justification for responses 'to

questions : delineated in . Parts A, B, and C of the Nuclear Safety

Evaluation Checklist Form will be provided.

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Until the licensee has revised the Nuclear Safety Evaluation Checklist

to1 incorporate justification for the decisions documented, this is

' identified as. Inspector Followup Item 369/85-09-03 and 370/85-10-03.

'd. Preparation- of Working Level: Procedures-for Technical Services Depart-

, . ment Staff

The inspector determined that the licensee has identified a need for

-working . . level instructions for staff- members within the Technical

Services Department. The inspector reviewed a draft copy of a table of

contents of a proposed manual which addresses appropriate activities 1

performed by this group.

Until the licensee has developed working level instructions for the

Technical Services Department, this is identified as Inspector Followup

Item 369/85-09-04, 370/85-10-04.

e. Revision to Design Engineering Department Procedure PR-160.

The ' inspector determined that the' licensee has identified a -need to

revise engineering department procedure PR-160. This is the control-

ling QA procedure for Nuclear Station Modifications performed by Design

Engineering and delineates requirements for processing, controlling,.

approving, and clearing nuclear station modifications within Design

Engineering.

The changes to PR-160 is intended to address the reorganization of the

Safety Review and Licensing (SRAL) group which is assigned respon-

sibility for performing the Nuclear Safety Evaluations for DOMS.

Additionally, other changes brought about by the reformatting and

reorganization of the nuclear station modification program will be

incorporated into the procedure.

Until the Licensee completes the revision to Design Engineering

Department procedure PR-160, this is identified as Inspector Followup

Item 369/85-09-05, 370/85-10-05.

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5. . Tests'and Experiments (37703)

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References: (a)1 Appendix;B to 10 CFR 50 - Qualits Assurance Criteria-for

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Nuclear-Power Plants and Fuel' Reprocessing Plants

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M! (b) 10 CFR 50.59 - Changes, Tests and Experiments

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1(c) Duke . Power Company . Topical--Report, Quality Assurance .

Program, Duke-1-A,' Section'17.2.11, Revision 7

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(d) Technical Specification, Section'6.5, Review and Audit-

(e) Regulatory Guide 1.33, Quality Assurance - Requirements

(Operations)' November 1972

(f) - ANSI ' N18.7-1976, Administrative Controls and ' Quality

Assurance for the Operational Phase of Nuclear Power

Plants

'The : inspector reviewed the licensee's test 'and experiment program required

by references (a) through (f) to verify that the program was:in conformance

with regulatory requirements, commitments in the application, and industry

^ guides and standards. The following criteria were used during this . review.

Lto assess the overall-acceptability of the established program:

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A formal method has been established to handle all- requests .or

' proposals for conducting plant tests involving safety related compon-

ents.

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Provisions have been made to assure that all tests will be performed in

accordance with approved written procedures.

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Responsibilities. have been assigned for reviewing and approving test

procedures.

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A' formal system, including assignment of responsibility, has been

established to assure that all uroposed tests will be reviewed to -

' determine whether they are as described in the FSAR.

f Responsibilities have been assigned to assure' that a written safety

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evaluation. required by 10 CFR 50.59 will.be developed for each test to

-assure that it does not -involve an unreviewed safety question .or a

change in Technical Specifications (TS).

The documents listed below were reviewed .to verify' that the previously

listed criteria had been incorporated into the licensee's tests and experi-

ments program.

Administrative Policy Manual for Nuclear Power Station

, Section 3.2.3, Special Testing, Revision 21

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.Section'4.8, Safety Related Analyses, Revision 21

Station Directives Manual, Revised 02-20-85

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Section '3.2.1, Identifying,- Scheduling, and Performance of Plant

~ Testing, Revision 13 (draftLcopy)

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Section 4.2.1, Handling of-Station-Procedures

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4 The inspector reviewed licensee , test 'and experiment -program documents' to

determine the program scope and content. The inspector determined that:a

test program hast been established.to assure that all testing required to

.. demonstrate satisfactory operation in service - of structures, systems, and

components has been identified. Additionally, all . testing is performed in

accordance with approved written procedures.

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The inspector' verified that written safety evaluations required by 10 CFR'

50.59 are . developed for special tests to assure that ~ unreviewed safety-

questions" or ~ changes to . the - TS ? do . not. exist. The inspector expressed

concern - regarding the NuclearL Safety Evaluation Checklist used. for docu-

. menting nuclear: safety evaluations. This concern is addressed in paragraph

4.c where .an Inspector . Followup -Item was identified to monitor licensee

corrective action.

- The inspector - reviewed the following special tests to verify conformance

with licensee documented program:

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ID No: TT/1/A/9100/73, Procedure Title: Power Operation with Increased

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.Tave,' dates performed 11/1/83 thru 11/3/83.

ID No: TT/1/A/9100/82, Procedure Title: Dropped Rod Check, date

performed 5/3/84

ID No: TT/1/A/9100/68,. Procedure Title: Turbine Governor Valves Wide

Open Test, date performed 8/10/83.

- The inspector reviewed the nuclear safety evaluation of special test number

9100/73. The inspector determined that the basis for the decision docu-

mented in Part C of.the Nuclear Safety Evaluation Checklist did not specifi-

cally address requirements of TS Section 2.0, Safety Limits and Limiting

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Safety System Settings. Section 2.1, Safety Limits, specifically delineates

the safety limits for the combination of thermal power, pressurizer

pressure,-and the highest operating loop coolant temperature (Tavg).

The special test involved variation of two of the parameters delineated in

TS Section 2.1 which were the highest operating loop coolant- temperature

Tavg.and thermal power. Thermal ~ power was estimated during the test because

of inaccuracies in the power range detectors due to increased downcomer

-temperature. The third parameter, pressurizer pressure, was not documented

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, as a variable ~ to be monitored during the . test performance. Section'8.0 of

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-the special test procedure stated that, as a' prerequisite system condition,

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the- pressurizer pressure control.-is in the auto. mode. The . inspector _ wa's

linformed :- that.~ pressurizer; pressure during the' performance 'of the special

y  : test was as shown in TS Table 3.2-1 (DNB Parameters), g

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The inspector reviewed the nuclear safety evaluation for special test number

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9100/82., The iinspector could not~ determine the' basis for the decision ,

documented sin: Part'CLof the Nuclear Safety . Evaluation Check 11st in that  !

Jreferences were not';provided:in the writeup. This' example along with:the  !

one;that preceds it;is indicative of the inspector's concern regarding the

adequacy of the ' Nuclear Safety Evaluation tas -documented on' the Nuclear '

, Safety Evaluation Checklist.

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.The. inspector _ interviewed licensee management concerning actions taken upon

determination that- an u unreviewed safety - question exists. The. inspector

determined that once. station testing personnel decide - that an unreviewed

safety question exists, the special test requirements .are forwarded for -

review ;to Nuclear Production Department, Nuclear Safety Analysis : Group. .

.Special tests are not conducted until the unreviewed safety question

determination has been resolved.

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, Within this . area, no violations or deviations.were identified.

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6. . Licensee Action on Previously Identified Inspection Findings. (92701).

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(Closed)- Inspector Followup Item 369/82-34-01 and 370/82-29-01, Audited

Organization Not Responding to Audit Finding in-the Required Time Interval

The ' inspector reviewed biannual report periodic assessment of QA Audit

results,~ dated 10-15-84. Examination of the objective evidence contained in

this document indicates that the: licensee is providing responses to audit

findings within the prescribed time frame.

(Closed) Ins'pector Followup Item 369/84-33-02 and 370/84-30-02, Two year

Periodic-Review of I&E Periodic Test Procedures.

The ~ inspector reviewed McGuire action item completion documentation -

sequence No.~ 2401-030BC, dated 2-1-85, and verified that corrective actions

for. completion of the two year review of I&E periodic test procedures were

completed on 1-7-85 using PT/0/B/4700/04A.-