ML20127N752

Insp Repts 50-269/85-11,50-270/85-11 & 50-287/85-11 on 850422-26.Violation Noted:Failure to Submit Annual Rept of Nuclear Station Mods within Required Time Frame

ML20127N752
Person / Time
Site:	Oconee
Issue date:	05/13/1985
From:	Casey Smith, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20127N720	List: ML20127N716 ML20127N730 ML20127N752
References
50-269-85-11, 50-270-85-11, 50-287-85-11, NUDOCS 8507020106
Download: ML20127N752 (9)

See also: IR 05000269/1985011

Text

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$2 E4 UNITED STATES

'o NUCLEAR REGULATORY COMMISSION

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REGION 11

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101 MARIETTA STREET,N.W.

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Report Nos.: 50-269/85-11, 50-270/85-11, and 50-287/85-11

Licensee: Duke Power Company

422 South Church Street

Charlotte, NC 28242

Docket Nos.: 50-269, 50-270, and 50-287 License Nos.: DPR-38, DPR-47, and

DPR-55

Facility Name: Oconee 1, 2, and 3

Inspection Conducted: April 22-26, 1985

Inspector: [M [ 6 $[84'

C. F. Smith g Djfte Signed

Accompanying Personnel: R. M. Latta, Region II

L. R. Moore, RII

Approved by: MM

C. M. Upright, J' ion A ief

C/[8

Dage S14ned

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Division of Rea tor Ssfety

SUMMARY

Scope: This routine, unannounced inspection entailed 92 inspector-hours on site

in the areas of design control and tests and experiments.

Results: One violation was identified - Failure to submit an Annual Report of

Nuclear Station Modifications Within Required Time Frame.

8507020106 850520

PDR ADOCK 05000269

G PDR

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REPORT DETAILS

1. Persons Contacted

Licensee Employees

S. Baldwin, Associate Engineer - Projects Services

• R. Bond, Compliance Engineer

C. Cooper, Assistant Engineer - Project Services

• G. Davenport, Performance

B. Davis, Associate Engineer

• W. Foster, Maintenance

• T. Glen, Maintenance

R. Haynes, Corporate Licensing Engineer

• R. Knoerr, Project Sgrvices - Engineering Manager

• T. Mathews, Compliance - Technical Specialist

J. McCool, QA Surveillance Superintendent

• J. McIntosh, Superintendent Station Services

• T. Owen, Superintendent of Maintenance

R. Ridings, SRO

C. Tomkins, Engineering Manager, SSD

• M. Tucker, Station Manager

E. White, Project Support Engineer

NRC Resident Inspector

• J. C. Bryant, Senior Resident Inspector

• Attended exit interview

2. Exit Interview

The inspection scope and findings were summsrized on April 26, 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.

Violation, Failure to Submit an Annual Report of Nuclear Station

Modifications Within Required Time Frame, Paragraph 4.a.

Inspector Followup Item, Working Level Procedures for Project Services

Group, paragraph 4.b.

Inspector Followup Item, Correction of Design Deficiency in Nuclear

Station Modification ON-1826 Part A, paragraph 4.c.

3. Licensee Action on Previous Enforcement Matters

This subject was not addressed in the inspection.

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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 Require-

ments for the Design of Nuclear Power Plants,

Revision 2

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

for the Design of Nuclear Power Plants

(d) Regulatory Guide 1.33, Quality Assurance Require-

ments (Operations) November 1972

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

Assurance for the Operational Phase of Nuclear

Power Plants

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

(g) Technical Specifications Section 6.1.2, Technical

Review and Control

-The inspector reviewed the license 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 following 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 esta-

blished including responsibilities and methods for conducting safety

evaluations.

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Administrative controls for design document control have been esta-

blished for the following:

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 modifica-

tions

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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

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

Nuclear Station Modification Manual

Section 3.0 Responsibilities, Revision 0

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, Administrative of Exempt and Temporary Changes,

Revision 0

Oconee Nuclear Station Directive

Section 2.2.2 (TS) Independent Verification, dated 12/1/84

Section 2.3.4 (TS), Nuclear Station Modification Program, dated

12/1/84

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Section 2.3.5 (TS), Control of Temporary Modifications, dated

12/1/84

Section 4.4.3(M), Qualification of Interfacing Individuals, dated

12/1/84

Section 4.5.3, Qualified Reviewer, dated 12/1/84

Administrative Policy Manual for Nuclear Stations, Revision 21

Section 2.5, Qualification and Training of Personnel

Section 4.8, Safety Related Analyses

Quality Assurance Procedure

QA-506, QA/QC Requirements for Nuclear Station Modifications

(NSMs)

The inspector 1nterviewed 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.

Report No. 0-S84/17, Station Modification Implementation,

performed March 12-22, 1984

Report No. 0-S84/32, Station Modification Documentation and

Approval, performed May-10-21, 1984

Report No. 0-S84/44, Station Modification Implementation,

performed June 21 - July 3,1984

Report No. 0-S84/59, Station Modification Documentation and

Approval, performed Sepu ber 11 - October 1, 1984

Report No. 0-S84/80, Station Modification Implementation,

performed December 21 - January 3,1985.

The inspector selectively verified that appropriate corrective actions

were taken by the responsible organizations for identified deficiencies

documented in surveillance reports.

The licensee has established a Modification Management System (MMS)

intended to support the station needs and the efficient scheduling of

associated engineering activities. A quota of 100 active Station

Problem Reports (SPRs) and Nuclear Station Modifications (NSMs) has

been assigned to this system. The Project Services group administers i

the MMS by performing evaluations of SPRs and subsequently initiating i

request for modifications. An Accountable Engineer from Project

Services is assigned to each NSM to ensure proper implementation of

the NSM program.

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The inspector interviewed licensee staff members within Project

Services to ascertain their understanding of, and the degree of their

involvement in, the nuclear station modification program. Addi-

tionally, the following nuclear station modification packages were

reviewed by the inspector:

NSM # ON-1550, Revision 1, Remove existing non-code valves 2, 3,

Dwg-275 and 276, and replace with valves which are qualified to

ANSI B31.1, Renumber to 2, 3, Dwg 262 and 263

NSM # ON-1762, Revision 0, Replace existing Limitorque Motor

Operator with environmentally qualified substitute

NSM # ON-1240, Revision 0,1, 2, Modify device lead terminations

and bypass / seal personnel hatch electrical penetrations with

materials and procedures that are qualified to function in post-

accident environment (NRC Bulletin 79-01)

NSM # ON-1826/0A+0B Revision 0, Motor driven emergency feedwater

pump automatic initiation pressure switches test circuits

Station Support Division (SSD) performs the implementation of NSMs

assigned to them by Nuclear Production. An informal training program

for SSD staff members is presently being implemented, in that SSD

engineering personnel are assigned to Project Services to acquire the

training and experience commensurate with their responsibilities as

Accountable Engineers. The training required to meet the minimum

qualification delineated in Station Directive 4.4.3 is in the initial

stage of implementation for SSD staff members.

Within this area, one violation and two inspector followup items were

identified and are discussed in the following paragraphs.

a. Failure to Submit an Annual Report of Nuclear Station Modifica-

tions within required time frame.

10 CFR 50.59 paragraph b requires the licensee to submit an

annual report of facility changes to the NRC. The licensee in a -

letter from Hal B. Tucker to Dr. J. Nelson Grace, Regional Admini-

strator, dated March 7, 1985, submitted a description of '.he

nuclear station modifications completed during 1983. The licensee

normally submits this annual report during July to August of the

succeeding year. Failure to submit an annual report of facility

changes in accordance with the requirements of 10 CFR 50.59 is

identified as violation 269, 270, 287/85-11-01.

b. Working Level Procedures for Project Services Group.

The licensee has identified a need for working level instructions

for staff members within the Project Services Group. The

inspector reviewed an incomplete ccpy of the Project Services

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Manual. Additionally, the status of the manual was discussed with

licensee management. Sections 4 and 5 which address activities

performed by this group in the functional area of station modift-

cation are still being developed. Until the licensee develops

working level instructions for activities performed by the Project

Services Group in the modification program, this is identified as

Inspector Followup Item 269, 270, 287/85-11-02.

c. Correction of Design Deficiency in Nuclear Station Modification

ON-1826 Part A.

Nuclear Station Modification ON-1826 Part A was prepared and

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implemented in response to a licensee commitment contained in

NUREG-0578. It involved the addition of test circuitry to

facilitate Technical Specification (TS) required periodic testing

of the control oil pressure switches on both the motor-driven and

turbine-driven emergenc', feedwater pumps (EFWPs).

Subsequent to the implementation of the modification, a design

deficiency was identified. This deficiency concerned the contact

development of the test switch in that a jumper is required to be

installed across contacts 9 and 10 of the test switch each time

the functional test is performed of the motor-driven emergency

feedwater pumps (MDEFWPs) initiation pressure switches. Uninten-

tional start of the MDEFWP results if the jumper is not used. The

switches presently in use were installed in June 1982 for Unit 2,

September 1982 for Unit 3, and July 1983 for Unit 1.

The inspector interviewed licensee management concerning the

status of the corrective actions taken and reviewed the following

documents in connection with the resolution of this deficiency.

Procedure I.D. No: TN/1/A/1826/0/A, Procedure for Imple-

mentation and Verification of NSM ON-1826 Revision 0, Part A.

Drawing # OEE-117-90, Elementary Diagram, 4160 Volts Switch-

gear ITE Unit 0, Motor Driven Emergency Feedwater Pump Motor

1A.

Drawing # OEE-117-91, Elementary Diagram, 4160 Volts Switch-

gear ITE Unit 0, Motor Driven Emergency Feedwater Pump Motor

18.

Procedure ID No: IP/0/A/275/6C, Safety Related Functional

Test of the MDEFWP Initiation Pressure Switches.

Duke Power Company, Oconee Nuclear Station, Transfer of

Completed or Partially Completed Modifications Forms for

Units 1, 2, and 3 NSM No. 1826, Revision 0, Part A.

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The licensee stated in Hal B. Tucker's letter to Dr. J. Nelson

Grace dated March 7, 1985, that NSM ON-1826 was completed for Unit

I and partially completed for Units 2 and 3. The inspector

determined that this modification is presently incomplete for all

three units. The documentation for Unit #1 modification package

was reviewed and signed off by the responsible organizations as

being completed prior to identification of the design deficiency.

Additionally, the inspector inquired as to the status of the TS

required periodic tests, and licensee management confirmed that

the tests are conducted on a monthly basis by use of the jumper

between contacts 9 and 10 of the test switch. The inspector

verified that provisions have been made for independent verifica-

tion of the addition and removal of the jumper in procedure ID No.

IP/0/A/275/6C. In addition, the inspector verified that a nuclear

station evaluation was performed and documented in connection with

the development and use of procedure ID No. IP/0/A/275/6C.

Until the licensee has developed and implemented corrective

actions for elimination of the design deficiency in NSM ON-1826

Part A, this is identified as Inspector Followup Item 269, 270,

287/85-11-03.

5. Tests and Experiments (37703)

References: (a) Appendix B to 10 CFR 50 - Quality Assurance

Criteria for Nuclear Power Plants and Fuel

Reprocessing Plants

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

(c) Duke Power Company Topical Report, Quality

Assurance Program, Duke-1, Section 17.2.11, '

Revision 8

(d) Technical Specification Section 6.1.2, Technical

Review and Control

(e) Regulatory Guide 1.33, Quality Assurance Require-

ments (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

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

to 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

components.

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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 proposed tests will be reviewed to

detprmine whether they are as described in the FSAR.

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Responsibilities have been assigned to assure that a written safety

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

Section 4.8, Safety Related Analyses, Revision 21

Section 4.8, Administrative Instructions for Temporary Station

Procedures, Revision 21

The inspector reviewed licensee test and experiments program documents and

determined that a test program had 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. The

inspector verified that provisions had been established for written safety

evaluations required by 10 CFR 50.59 for special tests to assure that

unreviewed safety questions or changes to the TS do not exist.

The inspector conducted a review of plant QA surveillance reports for plant

tests conducteu over the past 12 months and determined that surveillances

were not performed on special tests. In subsequent discussions with

licensee management, the inspector was informed that special tests as

defined in 10 CFR 50.59 were not performed by plant personnel within this

time frame.

Within this area, no violations or deviatigas were identified.

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