IA-85-613, Advises That Allegation RI-84-A-0061 Re Improper Disposition of QA Audit Findings Entered Into NRC Allegation Tracking Sys.Allegation Reviewed & Evaluated for Followup Actions During Allegation Panel 840430 Meeting
| ML20138C072 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 05/03/1984 |
| From: | Haverkamp D NRC |
| To: | Starostecki R NRC |
| Shared Package | |
| ML20138C032 | List: |
| References | |
| FOIA-85-613 NUDOCS 8510220176 | |
| Download: ML20138C072 (4) | |
Text
{{#Wiki_filter:.. . .. ..~ _. . ._ . . ~.. _ . _ _ - . e MAY 0 0 La4 MEM0kANDUM FOR: Richard W. Starostecki, Director, Division of Projects and Resident-Programs FROM: Donald R. Haverkamp, Acting Office Allegation Coordinator , i
SUBJECT:
ALLEGATION RI-84-A-0061 (NINE MILE POINT 2): IMPROPER DISPOSITION (" EDITING") 0F QA AUDIT FINDINGS The subject allegation, r eceived by NRC Headquarters about April 16, 1984 and by NRC Region I on April 27, 1984, has been entered in the NRC Allegation i' Tracking System '(see enclosure 1). The allegation was reviewed and evaluated for follow-up actions during an i allegation. panel meeting on April 30, 1984 (see enclosure 2). I W (4 2t N Up Donald R. Haverkamp i Acting Office Allegat l on Coordinator 1 I
- Enclosures.
i 1. NRC Form 307 l
- 2. NRC Region I-Form 207 cc w/encis: ;
H. Kister S. Collins i R. Gramm ' S. Ebneter L. Bettenhausen A. Gody l 0..Caphton J. Gutierrez R. Christopher, 01:RI Allegation File j t i 4 I 4 4 8510220176 851010 PIWt FOIA , GARDE 85-613 PDR
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. em c ro'rm ao7 ALLEGATION DA1/ . U.S. NUCLEAR REO. A70RY COM'.? ;
(11 823 Instructions on re. RECEIVING OFi .. } Docket Number (if applicable) '
- 1. Facility (les) Involved: INamel tot more in.n 3. or se NINE MILE POINT " 0 5 0 0 0 4 1 0 genene. wnte GENERICI ~
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- 2. Functional Ares (s) Involved:
(Check approonete beates: I operations onsite health and safety 3 construction offsite health and safety _. safeguards _. emergency preparedness _ other (specifyl 3.
Description:
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- 4. Source of Allegation:
- (Check opproonste bod contractor emp. . s _ security guard
_ licensee employee news media NRC employee private citizen
._ organization tspecifyl 3 other (specify Anonymous Former Employee MM DD YY
- 5. Date Allegation Received:
- 0 4 1 6 8 4
- 6. Name of Individual trices two inist s. .nd i , n.m.: Unknown Receiving Allegation: .
- 7. Office:
ACTION OFFICE
- 8. Action Office
Contact:
trir twa inities. .nd s.., nom. S. J. Collins
- 9. FTS Telephone Number:
4 8 8 " l l 2 6
- 10. Status:
(Check ones [
- Open,if followup actions are pending or in progress Closed, if followup actions are completed MM DD YY
- 11. Data Closed:
l l ""'**'"*: l (Lwrut to 50 characterst IIIIIIII IIIIIIl l l l l l l l l l l l IIIIIIII IIIIIIIIIIIIIIIIl l
- 13. Allegation Number:
R - 8 4 -A- 0 0 6 1
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ALLEGAT :C ' '~ REPORT NAME: l ALLEGATION: IFACILITY: Aeowy-. a L A:v & o\ ;l L, ,, g ,; , g ,(*ggh l 9 -
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I , April 10, 1984 I t {. Mr. Richard C. DeYoung, Director Office of Inspection 6 Enforcement U. S. Nuclear Regulatory Commission . Washington, D. C. 20555
Dear Mr. DeYoung:
I recently resigned from Niagara Mohawk Power Corporation - (the Quality Assurance Department). I hope you might forgive me if I do not sign this letter. If the NRC is interested in getting to the root cause of the Q. A. problems at Nine Mile Point Unit No. 2, I direct your attention to the following: 3 Seek the original draft of Q. A. Audit No. 4 conducted internally between January 24 - February 3, 1984. The computer reference is 4048C which had some 30 findings. Seek the final " edited" version of this same audit, same date. Computer reference 4162c. Seek an interview with the company auditors of Audit No. 4 who have been unmercifully harrassed since their conclusion of this audit. ' Seek the April 5, 1984 letter (QA840573 "B" 17.0-A1) and
- review all auditors thereon. Two of them on page 2 were i Lead Auditors who had their credentials pulled - they were leading Audit No. 4. They will talk to you.
A friend of the industry. l 0 l
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INTERN L CORRESPONDENCE
,o- ,n , . 2 = ** o n M V NIAGARA l RuMOHAWK i' FROM D. P. Dise DISTRICT System 340573 TO C. Beckham DATE April 5, 1984 FILE CODE 17.0-Al L. Cole W. Connolly SUBJECT Auditor and Lead Auditor List J. Dillon W. Friedrich A. Kordalewski B. Morrison R. Norrix D. Palmer K. Rafferty A. Spiddle W. Treadwell K. Tyger I have reviewed the Lead Auditor List and have made several changes.
Below is the list of employees that can perform as lead auditors for any type of audits conducted by the Quality Assurance Department: Balestra, Bill Doyle, Gerry Bassett, Tom Dowd, Richard Bohanske. Tom genton;Roys E
.........%.y,,,,,,
Breigle,' Tom Kordalewski, And:' Bryant, Walt McDonnell, Mike (((( { (Bdekley Jack Palmer. Dave Aop 1019N Consaul, Roger Todd, Roger Cummings, John QUAL.lTY ASSURANCE Van Nest, Fred DEPARTMENT e NMP 2 Dillon, Jim gildesPaul The status of the following Lead Auditors is in question until more infor-mation is gathered on them:
, Dahlin, Roger Daniels, John
;Fassler, Richard Kovac, Al Norrix, Bob The following employees are lead auditors that are restricted until further notice to the audit areas listed below:
} Aiello, Frank vendor, non-nuclear Baumler, Charles vendor, non-nuclear Diana Tony vendor, non-nuclear, NMP1 1 Murphy, Cecil vendor, non-nuclear
Auditor and Lead Auditor List . Page 2 April 5, 1984 Peceri, Ron vendor, non-nuclear, NMP1 Winegard, Al vendor Connolly, Bill vendor, NMPI Leskiv. Gary vendor NMPI Sconzert, Perry' vendor, NMP1 Shea, Kevin vendor, NMP1 Stucky, Larry vendor, NMP1 The following employees have been temporarily removed from the Lead Auditor List and can.only participate on the Quality Assurance Department audits as auditors: Laratta. Tony g Manning. Ed
$1AM I Norman, Rudy Osypiewski, Frank Swenszkowski, John I
k 'M D. P. Dise DPD/dmb xc: Auditors and Lead Auditors above l J. A. Mitchell I l
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DISTRICT System 840365 raoM D. R. Palmer DATE March 9, 1984 FILE CODE 3-N2.2-M58.38 To D. P. Dise SUBJECT Report of Quality Assurance. Audit #4 - Nine Mile Point No. 2 QA Site Activities 4 Attached is the report of the results of'the subject audit. This audit was conducted in accordance with the audit program procedures and the audit plan furnished to you previously. hkb D sid R. Palmer /
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*W. Gramm.(NMP-2 NRC Inspector,' i Q.A. Department File i
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NIAGARA MOHAWK POWER CORPORATION 3 REPORT OF QUALITY ASSURANCE AUDIT NO. 4 STATION: Nine Mile Point Unit No. 2 ORGANIZATION: Niagara Mohawk Power Corporation Quality Assurtnce Group LOCATION: Scriba, New York 4 DATES: January 24 - February 3,1984 AUDITORS: A. Laratta (Lead) J. Ryan L. O'Connor l R. Norman FUNCTIONS Nonconformance report system, surveillance program, lead AUDITED: auditor certification process, employee training program, organizational description and the document control system. PURPOSE: The purpose of the. audit was to review the implementation of the nonconformance system and surveillance program, the documentation of the employee training program'and the lead auditor certification program, the definition of the organization and the document control-system. SCOPE: The audit was limited to a review of selected l nonconformance and surveillance reports and logs, the i accuracy and maintenance.of some lead auditor certifications, the handling of selected employee training and the maintenance of some training records, the i definition of organizational responsibilities and the i control of selected procedures. I EVALUATION: There was a total of eight findings identified and they are shown on nonconformance report sheets in this report. It is considered the program is adequate but that improvements in the implementation of the program need to be made in the areas identified.
- OBSERVATION: A. Nonconformance Report System All Nonconformance Reports (NR's) and the NR log were reviewed for accuracy and completeness.. Some NR files had been misplaced, some NR's were closed before the corrective action was verified, some responses on NR's were not
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reviewed, there were some discrepancies between the information on some NR's and the information in the site I log for those NR's and the. site NR log was not being j maintained up-to-date. These deficiencies are identified t in NR #0034. t 4162C
B. Surveillance Program The Surveillance Report (SR) is the main tool that the Quality Assurance group uses to accomplish resolution to i problems identified during surveillances. Many SR's that had been written in 1982 and 1983 were reviewed. Some surveillance reports had not been clearly stated, properly signed, nor appropriately reviewed and closed out. There was no schedule to define the type and frequency of surveillances to be conducted. There were some differences between the information contained on the surveill_ance reports and that recorded in the log book. These deficiences are identified in NR #0035. C. Lead Auditor Certification Process The training qualifications and certification records of , five site lead auditors were reviewed. Two'of the five lead auditors had not maintained cualifications but were carried on the list of qualified lead auditors. Further, four of the five lead auditors had been certified. based 4 upon their participation in surveillances, not audits. There were no records in their training files to document the lead auditor training they had received. These deficiencies are identified in NR #0036. D. Employee Training Program The training files.of five employees were reviewed. There was one record identified that had not been duplicated as required. Action was initiated to duplicate this record ar.d no NR was initiated. It was identified however, through' interviews that the three and six months progress reports from new employee supervisors to the QAD manager have not always been prepared. This deficiency is i identified on NR #0037. E. Organizational Description The organizational . charts and responsibility / authority descriptions were reviewed and compared to the existing organization. Several differences were identified between the current organization and the charts and descriptions. for this organization. The charts were found out-of-date ~ and the procedures either defined job functions that no longer exist or did not define the existing job function. Tnese deficiencies are identifieG on NR #0038.
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F. Document Control System The fully controlled copies of some Q.A. procedures assigned to four different individuals were reviewed. During this review, one manual was found where revised procedures dating back several months had not been placed in the manual. This deficiency is identified in NR #003( ' Additionally, it was identified that . letters have been us I
! in-some instances to direct and document quality-related ' activities, bypassing the procedures. This ' deficiency is identified in NR #0040.~
i 4162C i
R'EGARDING The carrective action to resolve Nonconformance Report #13, PREVIOUS identified in audit #3 was reviewed during this audit. It AUDITS: was found that the checklists were not being used to review , procurement documents as required by QAP 4.10. Further, the nonconformance had been closed out by the Quality Assurance Department without verifying the implementation of the corrective action. This deficiency is identified in NR #0041. ! The entrance meeting was held at the site on January 24, 1984, and the exit meeting was held at the site on February 3, 1984. The following list identifies those present at the entrance and exit and those contacted during the audit: i PERSONNEL *J.L. Dillon C. Beckham CONTACTED: *J. Swenszkowski D. Morrison
*D.G. Lundeen G.J. Doyle
*F.J. Osypiewski A.P. Kordalewski
- M.A. Balduzzi R.O. Norrix
- J.G. Rocker 0.P. Dise
- E.H. Epperson D.R. Palmer
- L.G. Fenton L. Brown -
- J.C. Shepherd J.E. Scoates J.A. Mitchell E. Manning J.J. Janas J. Sovie L. Cole
- Present at entrance meeting
- Present at exit meeting Audit Report Prepared By: .c__ Date: y / ,-r / A V Audit Report Reviewed By: /,g /g e d g e /_; Date: J//3//-y g': .
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_3 ma uw r- cem 7 nme sama o.e ~ a . NITNCONFORMANCEFACILITY: REPORT 0034 '""""'""'"'"""""' ' soma '-n-" DEPARTMENT GROUP O QA. ooc-S. 00C-0 .rt i QA DEPARTMENT AUDIT NUMBER: 4 INSPECTION REPORT NUMBER: SURhEILLANCE REPORT NUMBER: OTHER: ORGANIZATION: Nianara Mnhawk Pnwer enrocration. NMP-2 ADDRESS: p n_ nnr 61 RESPON5E REQUIRED BY: CITY: Ivenmino. NY 13093 ATTENTION OF:_ Mr charles Reckham pt
$UBJECT .
O VIOLATION, O INADEQUACY, 'O OTHER: ' REGARDING OREGULATORY REQUIREMENT OSTANDARD OPROGRAM O NONCONFORMING ITEM OC00E O MALFUNCTION OPROCEDURE O DRAWING OSPECIFICATION O WORK PRACTICE 00THER DESCRIPTION: Quality Assurance Procedure 16.40, Rev.1,1978, Section 3.0 states, "The purpose of this procedure is to describe the use of the Nonconformance Report (NR) form used by NNPC's Quality Assurance Department as well as the mechanisms used to ensure follow-up and closure". FINDINGS: The requirements for use of the NR are not always implemented. The NR log is not maintained up to date, responses to NR's are not always reviewed within two weeks of receipt and implementation of corrective action is not always verified. RECOl3ENDATIONS: Review open NR's to verify they are being handled according to the requirements and train personnel so that future NR's will be processed properly. ( ACTION BY QA DEPARTMENT: k ORIGINATOR ED 8 - .
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DEPARTMENT GROUP O QA, GQC-S. OQC-0 nart ( QA DEPARTMENT AUDIT NUMBER: a
, INSPECTION REPORT NUMBER:
SURVEILLANCE REPORT NUMBER: 0THER:
- ORGANIZATION: Niacara Mohawk Power Corooration. NMP-2 ADORESS: p.0- Rnr M RESPONSE REQUIRED BY:
CITY: tveomino. NY 13093 , ATTENTION OF: Mr charles Rockha-, " na r SUBJECT .
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O VIOLATION. O INADEQUACY. O OTHER: REGARDING OREGULATORY REQUIREMENT OSTANDARD OPROGRAM O NONCONFORMING ITEM OC00E OMALFUNCTION OPROCEDURE ODRAWING O SPECIFICATION O WORK PRACTICE 00THER DESCRIPTION: QAP 10.20, Rev. 1, 1978, Section 1.0 states in part, " Monitoring is to be accomplished in accordance with this procedure..." FINDING: t The surveillance program is not accomplished in accordance with this procedure. Surveillance reports are not always correctly signed, clearly stated, and properly : closed. A schedule for surveillance activities has not been established. Surveillance log sheets have not been correctly completed and checklists used during surveillances I have not been reviewed and approved. j i RECOPNENDATION: Review the procedure and identify the requirements, train personnel performing surveillances are following the on these requirements, and evaluate their performance to verify they procedure. l
-verify they meet the requirements. Review all past and future surveillance reports to i ACTION BY QA DEPARTMENT: !'
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INSPECTION REPORT NUMBER: SURVEILLANCE REPORT NUPSER: 0THER: ORGANIZATION: Niacara Mohawk Power Corocration. NMP-2 ADDRESS: P.O. Box 63 RESPONSE REQUIRED BY: CITY: Lycomino. NY 13093 l ATTENTION OF: Mr. Charles Beckham urt SUBJECT . O VIOLATION. O INADEQUACY, O OTHER: REGARDING
@ REGULATORY REQUIREMENT OSTANDARD OPROGRAM DNONCONFORMING ITEM OCODE O MALFUNCTION
@ PROCEDURE ODRAWING OSPEC1FICAT10N O WORK PRACTICE 0 0THER DESCRIPTION:
i QAP 18.01, Rev. 1, Nov. 1980, Section 5.0 states, "The minimum requirements regarding personnel qualifications for those NMPC and contracted personnel involved as Lead l Auditor are described in Paragraphs 5.1.1 through 5.1.4." ' i FINDING: All requirements always followed. described in this' procedure for lead auditor qualifications are not In some instances, lead auditors have been approved for certification j before participating in the required five audits or surveys. The list of names i identifying qualified lead auditors is not being maintained current. Additionally, i certification records are not always~ maintained in the Quality Assurance Department files as required. 1 RECOW.ENDATIONS: Review and verify that the certification records of lead auditors are proper. Evaluate any audits in which improperly certified lead auditors participated. Revise current practices for certification in the revised practices. to conform to requirements and train appropriate personnel auditors. Update and maintain proper records of qualified lead ACTION BY QA DEPARTMENT: k
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soma DEPARTMENT GROUP 0 41 OQC-S. OQC-0 o.rt g QA DEPARTMENT AUDIT NUMBER: 4 INSPECTION REPORT NUMBER: SURVEILLANCE REPORT NUPEER: 0THER: ORGANIZATION: Niacara Mohawk Power Corocration. NMP-? ADDRESS: P.O. Bor 63 RESPONSE REQUIRED BY: CITY:- tveomino. NY 13093 ATTENTIUN OF:_ Mr. Charles Reckham ut ;
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O VIOLATION. O INADEQUACY. O OTHER: I
.REGARDING D REGULATORY REQUIREMENT OSTANDARD f ONONCONFORMING ITEM O PROGRAM ElPROCEDURE OCODE ODRAWING OMALFUNCTION '
O SPECIFICATION O WORK PRACTICE r 00THER ' DESCRIPTION: Quality Assurance Procedure 2.10. Rev. 3. May 1982, Section 5.1 states in part, "Within six months of each new department member's joining the QAD, the approrpiate QAD supervisor submits at least two reports to the Manager QAD." i FINDING: i i The three and six months progress reports from new employee supervisors to the QAD manager have not always been prepared and submitted. } RECOMMENDATIONS: t L Take steps reports to ensure that new employee supervisors prepare and submit the two program as required. { t ACTION BY QA DEPARTMENT: i' f I I i ORIGINATOR V ED BY: , l at / D daa
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REPORT nn,a "'"* "' * " '"' "" "" 2 man 3-11-84 DEPARTMENT GROUP G QA. OQC-5 OQC-0 .n I QA DEPARTMENT AUDIT NUMBER: 4 INSPECTION REPORT NUMBER: SURVEILLANCE REPORT NUPEER: OTHER: ORGANIZATION: Nianara Mnhawle pnwar rnennratinn ADDRESS: inn Frip R1vd Lfp e t RESPONSE REQUIRED BY: CITY: Svraente. NY 197n1 ATTENTION OF: Mr navid palmar 4-2-84 un SUBJECT U VIOLATION, O INADEQUACY, O OTHER: REGARDING i E REGULATORY REQUIREMENT OSTANDARD ONONCONFORMING ITEM O PROGRAM OCODE O MALFUNCTION EPROCEDURE 0 0RAWING O WORK PRACTICE O SPECIFICATION 00THER DESCRIPTION: The Design and Construction Manual (D&CM), Revision 3, November 1981, Section 1 Paragraph 1.2 states in part, "The independence of Quslity Assurance functions from performing functions is depicted on the organizational chart....Further definition of the administrative and functional organizations is included in the procedures... t i FINDING: The organizational charts in Appendix 8-1 of the D&CM and the functional descrip-tionsfunctional and in Quality responsibilities. Assurance Procedure 1.01 do not reflect the current organization RECOMMENDATION: Review to updatethe them organizational as needed. charts and functional definitions in the program and revise ACTION BY QA DEPARTMENT: ( ORIGINATOR E BY- . Gat _/ D 4h~!zn st a tunt
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sunuwr-en~m- m aao m o - NONCONFORMANCE FACILITY: ' REPORT'^.mwan 9 "'"e Moe P int Unit No. 2 3,33 ,, DEPARTMENT GROUP @ QA. OQC-S. OQC-0 mri ( 4 QA DEPARTENT AUDIT NUM8ER: INSPECTION REPORT NUMBER: SURVEILLANCE REPORT NUMBER: 0THER: ORGANIZATION: wtana a Mnh awt- pnwar enrnnratinn- NMP-7 ADDRESS: pn any s1 RESPONSE REQUIRED SY: CITY: fyrnminn_ NY 11001 ATTENTION OF: Mr navid palmar ~ ~ # utt SUBJECT O VIOLATION. O IMADEQUACY, O OTHER: REGARDING O REGULATORY REQUIREMENT OSTANDARD ONONCONFORMING ITEM O PROGRAM OCODE O MALFUNCTION
@ PROCEDURE ODRAWING O WORK PRACTICE O SPECIFICATION 00THER DESCRIPTION:
QAD 6.10, Rev. 1, Dec. 1981, Section 5.3.4 states in part, "With the receipt of a revised QAP all preceding change notices and the previous revision of that QAP are removed from the manual and destroyed." FINDING:
- k. - Fully Control Copy #8 of the QAP manual is not being maintained current. Several revisions dating back several months have been received but not pro p rly placed in the manual.
RECOMMENDATION: Incorporate all received revisions into the manual and take steps to ensure that future revisions will be incorporated in a timely fashion. I l l l ACTION SY QA DEPARTMENT: i I I ( , ORIGINATOR E ,ED 8Y: . m/ stwwt / sff, ) siwtwt 3// lt h RESPOND ON REVERSE Side w
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NONCONFORMANCE FACILITY: REPORT nnan " ' " * " " " ' " ' " ' " " " " "' 3-11-84 sueca , DEPARTMENT GROUP 0 QA. ooc-s, 00C-0 a.rt i QA DEPARTMENT AUDIT NUMBER: 4 INSPECTION REPORT NUMBER:
, SURVEILLANCE REPORT NUPEER: OTHER:
ORGAN!ZATION: Nianara Mohawk Pnwer Onennratinn ADDRESS: ann Fri, Rivd unet RESPONSE REQUIRED BY: CITY: Svracoep NY 19041 ATTENTION OF: Mr nnnata nien 4-2-8d
,7t SUBJECT O VIOLATION, O INADEQUACY, O OTHER:
_REGARDING 0 REGULATORY REQUIREMENT OSTANDARD O NONCONFORMING ITEM O PROGRAM OCODE O MALFUNCTION
@ PROCEDURE O DRAWING - O WORK PRACTICE O SPECIFICATION 00THER DESCRIPTION:
The Design and Construction Manual, Section 5.1 states in part, "... ensure that quality-related activities are prescribed by documented instructions, procedures, j and drawings..." ; FINDING: 1 In some instances, the quality assurance program is bypassed by using letters to t prescribe quality-related activities. One letter dated 8/16/82 (File Code 17.0-A1) ' delegated responsibility for QAD training and another letter dated 8/25/82 (File Code 17.0) further delegated this activity. This use of letters conflicts with i the current quality requirements defined by the program, i RECOMMENDATION: Review appropriately to identify any other letters that bypass the quality program. i Take steps to ensure that personnel use procedures, instructions or drawings to document and direct cuality-related activities in the future. , i ACTION BY QA DEPARTMENT: ! i 5 l
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REPORT 0041 3-n-84 esea DEPARTMENT GROUP O QA. 00C-5 DQC-0 Issue oATt PROJECT. Niacara Mohawk Power Corooration. NMP-2 M.0.. NUMBER: QA DEPARTMENT AUDIT NUMBER: 4 INSPECTION REPORT NUMBER: SURVEILLANCE REPORT NUMBER: OTHER: pRGANIZATION: Niacara Mohawk Power Corporation. NMP-2 i ADDRESS: P.O. Box 63 RESPONSE REQUIRED BY: CITY: tynmbn NY 19041 ATTENTION OF: Mr. Charies Beckham
# ~2'[t SUBJECT O VIOLATION. OINdDEQUACY. O OTHER:
REGARDING O REGULATORY REQUIREMENT OSTANDARD OPROGRAM O NONCONFORMING ITEM OCODE O MALFUNCTION GPROCEDURE ODRAWING O WORK PRACTICE OSPECIFICATION 00THER DESCRIPTION: - QAP 4.10, Rev. 3 Dec. 1978. Section 5.2 states in part, "The standard checklist used...is that of Attachment 7.0a." k FINDING: ,
) Checklists are being used to perform procurement document reviews as required.
This was utilized previously in Audit #3, Nonconformance. Report #13. RECOMMENDATION: Initiate use of the checklists'as required. I e h ACTION BY QA DEPARTMENT: l i l k
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L seu Emt Po=ca catroution-Oa.!tity Auuwer ptPa%t PtDNCONFORMANCE REPORT NtNBER 0014 RESP 045E: (RETURN TO NMPC-QA DEPARlMENT) A. Laratta, ( r0RRECTIVE/ PREVENTIVE ACTION PROPOSED: (TO BE COMPLETED BY April 30, 1984 ) l-DATE
.orrective Action: 1. CAR #84.0001 was issued February 24, 1984, identifying open i NRs and requiring' prompt implementation and correct, closure.
- 2. All safety-related NRs that were closed prior to the issuance , ;
of CAR #84.0001 will be reviewed to assure proper closure. ' t)" Any NRs that were improperly closed will be identified on a CAR and processed in accordance with QAP 19.03. [
. Action to Prevent Recurrence: QAP 16.40 was revised in February' des 1934, via Change
-The revision exclu f!MPC site QA I Note Number 4 personnel from further issuing NRs. Ide nti fica t ion ,
and control of deficiencies is now controlied via QAP 19.02 and QAP 19.03 under the direct supervision of new management personnel. , Date Action to be completed: April 30, 1934 Note: llaintaining the NR Log was not the responsibility of the Site QA organization. i.:is deficiency should be addressed to the organization responsible (Syracuse). RESPONDENT'S 51G%TURE : &1 8 <_pe G A - DATE: 71- h c- u ! PISPONSE ACCEPTED BY: DATE: QA DEPARTMENT FOLLOW-UP AND VERIFICATION: ( l i
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DATE _ __ __
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iONCONf0FM 9CE REPORT CLOSED l l 3Y: TATE: )] NY W
- N. Rada.acher, D. Chalifoux
a_ _ . ,p v . . s.__;,s , , _, wa sL,haut rower coy:cuben-Q.~ rity Auuwc.t Dqnerb, ext 0035 HONCONFORMNCE REPORT NtNBER l (ESP 0ti$E: (RETURN TO NMPC-QA pEPARTMENT) A. Larat_ta ,
- 0RRECTIVE/ PREVENTIVE ACTION PROPOSED: (TO BE COMPLETED BY March 31,1984 _)
QAP 10.20, Rev. I was revised in February ,4, via Change Corrective Action: The revision excludes NMPC site QA personnel from f,urther F Notice' Number 3. This activity is now con-i issuing Surveillance Reports per this procedure. Review of past Surveillance Reports trolled via a new procedure QAP 19.02. (total of 6,466) is not prudent. The surveillance activity is not the "First Line Inspection" function for acceptance. Therefore, quality of items would r not be affected due to lack of clarity or appropriate signatures. t Action to prevent recurrence: QAP 19.02 has been issued for controlling site QA > Surveillance activities. New management personnel have been contracted for Personnel l assuring correct and accurate implementation of this program. i implementing the requirements of QAP 19.02 have received training to the ! procedure. : l Date Action to be completed: March 31,1934 t i i i t f I
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l r ' RESPONDENT'S 8 S R o O, S~ DATE: 5"- 3"- P v SIGNATURE: l RESPONSE : j DATE: r ACCEPTED BY: l QA DEPARTMENT FOLLO'i-UP AND VERITICATION: > l i, ( i I ! l
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. .1 A. Laratta
{3 RESPONSE: (RETURN TO NMPC-QA DEPARTHENT)
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J" s .; CORRECTIVE / PREVENTIVE ACTION PROPOSED: (TO BE COMPLETED BY N/A )
. 1 Corrective Action: Change Notice Number 1, Rev.1, issued Julh83, to QAP 18.01 j Rev. 1, delineates the following responsibilities: ,
i$ "The Manager Quality Assurance Nuclear has the authority and responsibility to make the determination of certification of personnel for Lead Auditor W) status. The Supervisor Quality Assurance Nuclear has the authority and responsibility to assure that qualified personnel are assigned to perform
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internal or external audits. . .."
$%s B,Y It is therefore, not the responsibility of the site QA organization (Quality i '
Assurance Manager - Construction) to provide a proposed corrective action to this Nonconformance Report.
$Gj Action to Prevent Recurrence: N/A Date Action to be completed: N/A '[!
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n:kg1u sMu:ut ts=ca capov21en-tmUry Auuue_t 9ptbeat NONCONFORMANCE REPORT NtNBER 0037 RESPONSE: (RETURN TO NMPC-QA DEPARTMENT) A. Laratta , ~ 4 CORRECTIVE / PREVENTIVE ACTION PROPOSED: (TO BE CD!PLETED BY fiay 31,1984
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CORRECTIVE ACTION DATE Though the deficiency was'a procedural violatior., it was administrative is nature and l would not affect the quality of items. However, the files of all active site QA per-s sonnel will be reviewed. Those individuals for whom the 3 and 6 months r'eports were
;J not issued, shall be identified and the following process utilized:
a A. If a report has been issued since the 3 or 6 month period expired, it shall be so noted and no further processing required. i B. If a report has not been issued, and the 3 or 6 month period has 3 expired, a report will be generated and processed in accordance with QAP 2.10. ACTION TO PREVENT RECURRENCE A r.emo will be issued to on site QA supervisory type personnel, re-emphasizing the s requirements of QAP 2.10, Section 5.1. j RESPONDERT 'S-SIGNATURE: OS 9 O/ CJ~ DATE: 8 2 0- 6~ /
RESPONSE
ACCEPTED BY: _ DATE- _ - - QA DEPARTMENT FOLLCil-UP A.ND VERIFICATION: t - l 5
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FILE CODE TO A. D. Laratta , DATE May 7, 1984 3N2.2-M58.48 'l SUBJECT NMP2 Nonconformance 0039 i On May 3, 1984 I oversaw the updating of Controlled Copy 8, Quality Assurance Procedures Manual at Nine Mile Point Unit 2. At this time, Sue Spilberg of the Nine Mile Point Unit 2 cleri-cal staff and I placed revisions in the Manual from the July, 1983; March 8, 1984; and March 30, 1984 distribution. The man-ual is up to date as of May 3, 1984. 1 In order ts wevent a recurrence of the norconformance con--
' dition, described in NR 0039 I have made arrangements with the Assistant Supervisor, NMP2 Administration for clerical support in maintaining this manual.
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Reference:
- 1) Letter of Authority - J. G. Haehl November 29, 1982 a
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- 2) 0AP's 1.01, 1.10, 2.10 and 18.01 in particular -
4 1 fail to see where any confli~ct or violation has occurred by either letter. On the contrary, the i
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UNIMD STATES
.[*U. ?,, NUCLEAR REGULATORY COMMISSION ,y 7a REGI!NI c '?f $30 PARK AVENUE of KING DF PRUSSI A, PCNNSVLV ANI A 19406 AUG 0 61964 .
Docket No. 50-410 Niagara Mohawk Power Corporation ATTN: Mr. William G. Hooten Executive Director-Nuclear Operations c/o Miss Catherine Seibert 300 Erie Boulevard West Syracun, New York 13202 Gentlemen:
Subject:
Inspection No. 84-09 This refers to the routine inspection conducted by Mr. R.A. Gram of this office on May 14 to June 15, 1984 at Nine Mile Point, Unit 2, Scriba, New York of activities authorized by NRC License No. CPPR-112 and to the dis-cussions of our findings held by Mr. Gram with your staff at the conclu-sion of the inspection. Areas examined during this inspection are described in .the NRC Region I . Inspection Report which is enclosed with this letter. Within these areas, the inspection consisted of selective examinations of procedures and representative records, interviews with personnel, and observations by the inspector. Based on the results of this inspection, it appears that two of your activi-ties were not conducted in full compliance with NRC requirements, as set forth in the Notice of Violation, enclosed herewith as Appendix A. These violations have been NRC Enforcement categorized Policy (10 CER 2,.byAppendix severity)Clevel in accordance~with published the in the Federal Reg-ister Notice (49 FR 8583) dated March 8,1984. You are required to respond to this letter and in preparing your response, you should follow the in-structions in Appendix A. In accordance with 10 CFR 2.790(a), a copy of this letter and the enclosures will be placed in the NRC Public Document Room unless you notify this office, by telephone, within ten days of the date of this letter and submit written application to withhold infomation contained thereir. within thirty days of the date of this letter. Such application must be consistent with the require-ments of 2.790(b)(1). The telephone notification of your intent to request withholding, or any request for an extension of the 10 day period which you believe.nec_essary, should be made to the Supervisor, Files, Mail and Records, USNRC Region I, at (215) 337-5223. ( l N 5D
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AUG 0 61984 Niagura Mohawk Pcwer Corporation 2 The responses directed by this letter and the accompanying Notice are not subject to the clearance procedures of the Office of Management and Budget as required by the Paperwork Reduction Act of 1980, PL 96-511. Your cooperation with us in this matter is appreciated. Sincerely, m ichard . tarostecki, Director Division of roject and Resident Programs-
Enclosures:
- 1. Appendix A, Notice of Violation
- 2. Region I NRC Inspection Report Number 50-410/84-09 cc w/ enc 1: -
Troy B. Conner, Jr. , Esquire John W. Keib, Esquire W. Morrison, NMP-2 Project Director NMPC OA Department of Public Service, State of New York Public Document Room (PDR) Local Public Document Room (LPDR) Nuclear Safety Information Center (NSIC) NRC Resident Inspector State of New York bec w/ encl: Region I Docket Room (with concurrences) Senior Operations Officer (w/o encis) Chief, Engineering Programs Branch Section Chief, DPRP-DPRP S.K. Chaudary, J. Grant, DPRP / I
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- I N APPENDIX A NOTICE OF VIOLATION Niagara Mohawk Power Corporation Docket No. 50-410 Nine Mile Point Unit 2 License No. CPPR-ll2 As a result of the inspection conducted on May 14-June 15,1984 and in accordance with the NRC Enforcement Policy (10 CFR 2, Appendix C) published in the Federal Register on March 8,1984 (49 FR 8583), the following violations were identified:
- 1. 10 CFR 50, Appendix B, Criterion XVI and the Nine Mile Point, Unit 2 PSAR state that conditions adverse to quality shall be analyzed for root cause identification and for recommendation of corrective actions to preclude the recurrence of the adverse conditions. Stone and Webster Engineering Corporation procedure QCI-16.01 "Short Term Trend Analysis" established a system to analyze and correct adverse trends identified during first line inspection activities.
Contrary to the above, on June 15, 1984, the licensee was informed that re-view of Stone and Webster Engineering Corporation data contained within monthly Field Quality Control reports indicate that adverse trends identi-fied during first line inspection activity have not been adequately corrected to prevent recurrence. Excessive inspection reject rates within the elec-trical; Heating Ventilating and Air Conditioning; preventive maintenance ^ and equipment storage areas were documented to have been recurring over a seventeen month period. This is a Severity Level IV Violation (Supplement II)
- 2. 10 CFR 50, Appendix B,. Criterion V and the Nine Mile Point, Unit 2 PSAR state that quality activities shall be performed in accordance with the '
appropriate documented procedures and drawings. Stone and Webster Engi-neering Corporation Specification E021P " Electrical Penetrations" requires that electrical penetration assemblies receive nondestructive examination inspections by radiography and surface examination techniques. Chicago
- Bridge and Iron Co. (CB&I) drawing 434-1 further defines the requisite
, radiographic and magnetic particle examinations and states that CB&I is to perform the required nondestructive tests. Stone and Webster Engi-neering Corporation telex 12177/10239 instructs CB&I to perform all re-quired examinations on the electrical penetrations.
Contrary to the above, on June 15, 1984, the licensee was informed that CB&I inspection records for electrical penetrations Z-201 through Z-210 document that CB&I' did not perform the requisite magnetic particle examina-tion for the total weld connecting the twelve inch pipe to the weld neck flange, but had only examined weld repair areas. This is a severity Level IV violation (Supplement II). i I l l _ ,_ _. _. _ _ . . -. ~ . ~ , - - - - - ---- - - - - -
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? c Appendix A 2 Pursuant to the provisions of 10 CFR 2.201, Niagara Mohawk Power Corporation is hereby required to submit to this office within 30 days of the date of the letter transmitting this Notice, a written statement of explanation in reply including: (1) the corrective steps which have been taken and the re-suits achieved; (2) the corrective steps which will be taken to avoid further violations; and (3) the date.when full compliance will be achieved. Where good cause is shown, consideration will be give,n to extending time. O D I 1 l l
_ __ s ,~ .m - ( ( U. S. NUCLEAR REGULATORY COMMISSION REGION I Report No. 84-09 Docket No. 50-410 License No. CPPR-ll2 Priority Category A Licensee: Niagara Mohawk Power Corporation - 300 Erie Boulevard Syracuse, New York 13202 Facility Name: Nine Mile Point Unit 2 Inspection At: Scriba, New York Inspection Conducted: _May 14 - June 15, 1984 Inspectors: W I Gr R.A. Resident Inspector 7/26 [S4 da e NMa.4 'v.! S.K. Cifsdha'[ Senior Res/dnt Inspector
)> ' date '
date Approved by: N//)////pf Bl3M S.J'. Collins Chief, Reactor Projects da t'e Section 2C, DPRP Inspection Summary: Inspection on May 14-June 15,1984'(Report No. 50-410/84-09) Areas Inspected: Routine inspection by the assigned resident inspector and a site detailed senior resident inspector of work. activities, procedures and records relative to allegations; corrective action programs; electrical penetrations; component supports; pipe whip restraints; and followup to construction appraisal team inspection. The inspectors also reviewed licensee action on previously identified items and performed plant inspection tours. The inspection involved 179 hours by the inspectors. Results: Two violations were identified: Inadequate implementation of effective corrective action to quality control identified deficiencies (paragraph 5); and failure to perfonn requisite nondestructive examination of electrical penetration welds- (paragraph 6). Regina I Fcrm 12 (Rev. february 1932) 8448L'!ARS.sa59
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c .c A DETAILS
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- 1. Project Organizations [
, Niagara Mohawk Power Corporation (NMPC) ! f Stc :e and Webster Engineering Corporation (SWEC) 4 I Gene'ral Electric Company (GE) i
-ITT - Grinnell Industrial Piping, Inc. (ITT)
~ John Controls, Inc. (JCI)
Reactor Controls, Inc. (RCI) [ i
- 2. Plant Inspection Tours l
. The inspectors observed work activities in-progress, completed work and I plant status in several areas during general inspection tours. Work was f examined for any obvious defects or noncompliance with regulatory require- ~
ments or license conditions. Particular note was taken of the presence of quality control inspectors and quality control evidence such as inspec- . tion records, material identification, nonconfonning material identification. { j housekeeping and equipment preservation. The inspectors interviewed craft i personnel, supervision, and quality inspection personnel in the work areas. j i Observations are noted below: 1 1 .I , During a mutine inspection tour the inspector observed unattended pre- ! 1 heat applied to pipe restraint MSS-037. Upon questioning the practice ! } he was informed that only the minimum pre-heat temperature was checked j i at approximately 6 hour intervals. Upon review of the ITT " Pre-Heat I Control Procedure" P301 X - ITTG2 the inspector noted that the instruction ! requires the maximum interpass temperature to be checked during the welding i i process. The licensee examined the restraint and found it to be below the i interpass temperature limit. For corrective action, the licensee com- l l mitted to review all contractor pre-heat procedures to assure that both ! minimum and maximum temperature limits will be monitored and documented. , The inspector will verify the fulfillment of this comitment during a future inspection (84-09-01). -
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! The inspector observed that debris, mostly pieces of cut tie wire, had i i entered cable tray 2TK5026 from adjacent fire protection coating activity. } The inspector notified the licensee of the condition and imediate steps - were taken to clean out the cable trays. The inspector subsequently re- ! 1 viewed SWEC Inspection Report (IR)'E4007361 which documents.the cable i tray cleanliness and subsequent removal of the debris and SWEC IR'S4027457 l 3 which was generated to note that the fire coating application sub-contractor ' had not cleaned up the debris. The inspector will monitor the effective- i ness'of preventing debris from entering similar raceways during future ' inspections (84-09-02). i __ __-.~___ _--_-_ _. _ . _ _ . _ - - . . _ . _ - . _ , . . _ _ , _
c C 3 The inspector reviewed the SWEC training department and SWEC Site Engineering Grvup (SEG) training matrices. He observed that inconsis-tencies existed as to whether training courses were required or optional for some personnel within SEG. The licensee corrected the SEG training matrix to reflect that SEG engineers are required to participate in training regarding Engineering and Design Change Requests -(E&DCRs) . Ad-vance Change Notices (ACNs) and Nonconformance and- Disposition (N&D) reports. The inspector was informed that engineering personnel had been routinely participating in these classes. The inspector reviewed the SWEC procedure regarding the evaluation of rebar cuts. All rebar cuts within safety related structures are dis-positioned by SWEC Cherry Hill design engineers. Specific criteria exists to review the cut requests. The inspector was informed that Cherry Hill maintains cut rebar logbooks and associated drawings. The inspector had no further questions on the handling of rebar cut requests. During the inspection period the inspector received notification that the Rockbestos Company had filed a 10CFR Part 21 report with the NRC in re-gards to possible insulation damage to 12 reels of Class IE cable sent to the Nine Mile Point - 2 site. The inspector ascertained that the licensee had received this notification and had made a followup 10CFR 50.55 (e) re-port to Region I.
- 3. Licensee Action on Previously Identified Items +
- a. (Closed) VIOLATION (81-13-018): Insufficient training for subcon-tractor employees. Stone and Webster Engineering Corporation (SWEC) assigned a Training Department Coordinator to the site. Training matrices were developed which outlined the necessary training for sub-contractors working within the SWEC QA program. A computerized program and database was developed which tracks all site employees and documents their completed training status. Monthly training programs are now distributed which denote classes available, such that supervisors can assign appropriate employees. A trainina ::ss ss:::ent was performed by SWEC which identified that a lower percentage of time was devoted to training at the NMp-2 site in relatfor. ship to other SWEC sites. Addi-tional training was accomplished whica eliminated the disparity between site training time. This item is clo:ed.
- b. (Closed) VIOLATION (81-13-01C): Over reliance upon contractor construc-tion personnel to monitor quality activities. SWEC QC has increased performance of structural steel weld fit up inspections to a rate of over 50%. The QC inspection plan has been modified to assure that the 50% inspection rate is a minimum level. The QC frequency of perfonning i concrete curing inspections has been increased in accordance with ANSI (
N45.2.5. SWEC QC performed periodic surveillances to assure that thasdr-ind and 'icst Equipment-(M&TE) held by construction personnel were prop-erly utilized, handled and stored. Training programs have been developed l for construction personnel regarding proper control of M&TE. This item is closed.
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- c. (Closed) VIOLATION (81-13-01E): Untimely SWEC corrective action in response to Niagara Mohawk Power Corporation (NMPC) audit findings.
NMPC QA procedure 16.40 was issued with a built-in escalation feature so that in the event that a satisfactory response is not received to a NMPC Nonconformance Report (NR), the issue is escalated to upper management for resolution. A review of the NMPC NR trend analysis report dated September 30, 1983, showed a trend of more timely re-sponses and that NR closecut has been accomplished in a shorter period than for NRs generated in 1981. The NMPC construction QA program has recently been restructured. The new procedures provide for manage-ment escalation of both NMPC audit and surveillance findings in the event of untimely or unsatisfactory response by SWEC. This item is closed.
- d. (Closed) VIOLATION (81-13-OlG): Licensee OA program deficiencies.
.In accordance with corporate NMPC directive, the pay and mileage incentives were retroactively applied to personnel within the QA department. These benefits were also provided to all new QA employees at the NMP-2 site. The licensee has stated that all NMPC QA employees involved with NMP-2 have access to the site either through permanent badging or temporary visitor access. The site QA staff has been aug-mented with additional experienced personnel. Additional QA management has been provided in the form of a corporate QA director and a site con-struction QA manager. As of November 1983, the five original QA staff members who were onsite during inspection 81-13 were still assigned to the site QA staff. Employee longevity indicates that the previous high staff turnover rates have been rectified. During NRC inspection 83-18, it was found that the licensee QA program was not effectively imple-mented. The licensee actions to NRC open items resulting during the con-struction appraisal team inspection (50-410/83-18) will be evaluated at a future date in regards to corrective action implementation. This item is closed.
- e. (Closed) UNRESOLVED (82-09-01): Improper cable tray cantilever lengths and drawing hold system implementation. The inspector reviewd Engi-neering and Design Coordination Reports (E80CRs) P01318 and PG1403.
These documents identified the locations of excessive cable tray canti-lever lengths beyond a support. Drawing holds were initiated against the appropriate design documents. SWEC engineering' at Cherry Hill con-ducted training on procedure DP-E-30.9-0 " Drawing Hold Procedure" as confinned by NRC vendor inspection report 99900509/83-01. E&DCRs have been written by SWEC engineering to address the disposition of the 10-cations of excessive overhang. SWEC QC will assure implementation of the promulgated design during normal inspection of the raceways. The current criteria established the maximum overhang to be 36" beyond a tray support. This item is closed. l l i
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- f. (Closed) UNRESOLVED (83-02-04)': Instrumentation support drawings in conflict with generic qualification design. The inspector re-viewed'E&DCR C 42343 which corrected the design qualifier s.otation ,
for the two support drawings which had the discrepancy. S;EC site ' engineering reviewed 29 additional instrumentation supports and did not identify any further discrepancies to the qualification designs. The inspector reviewed the log documenting this engineering review. The inspector randomly reviewed BZ-420BT which' identified the design qualification to be BZ-407PB. The qualification design and the support were found to be consistent. This item is closed.
- g. (Closed) UNRESOLVED (83-03-01)
- Installation and inspection require-4 ments for Kellum grips. The inspector reviewed E&DCRs F00831 and F01601 which direct the grips to be installed in accordance with the i
manufacturers instructions, the electrical specification E061A has been revised to reflect this information. SWEC QC inspection plan ~ N20E061AFA025 has been revised to reflect the necessary critcria for QC to inspect the cable Kellums grips. The engineering direction pro-vides the required steps to retrofit the Kellums grips where required on previously' pulled cable. This item is closed.
- h. (Closed) FOLLOWUP ITEM (83-12-02): Installation of cable connector bracket assemblies to Unistrut channel. The licensee determined that General Electric (GE) design record file H 13-0071-15 has been amended
- l to reflect that two bolts provide. adequate support for the bracket and that three bolt installations are not detrimental. This item is closed.
- 1. (Closed) UNRESOLVED (83-12-04): Welding of structural steel shim plate. The observed condition was documented on Nonconfonnance and
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i Disposition (N&D) 6803. The welding was accepted-as-is based on tho' , fact the connection function was not affected. SWEC QC verified acceptable weld fillet size as documented on Inspection Reports W3021618 and W3021643. This item is closed.
- j. (Closed) FOLLOWUP ITEM (83-17-03): Material traceability records
, for piping welds. ITT-Grinnell (ITT) ascertained that the documenta-tion for field weld 13 Iso. 47-1 had been improperly transcribed.
^ l The documentation listed the heat number as 4648-131 when in fact'it should have been 4644B-131. The QC inspector was retrained as to ! entering of proper heat numbers. For weld 12 on 150.57-2, ITT deter-3 mined that the sales number had.been inserted in lieu of the heat
- r. umber. The weld' records for both field welds were corrected by ITT.
l ITT will review other weld documentation records during the turnover l review process to identify and correct other instances where the sales , number had been improperly entered on the weld documentation. This I item is closed.
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- k. (Closed) CONSTRUCTION DEFICIENCY REPORT (83-00-05): Undersized welds on PGCC floor module fillet welds. The weld design had specified k in.-
fillet welds but the licensee had identified the existence of 5/32 in. welds on the floor modules. GE inspected the accessible floor module welds to scope the weld size as documented on inspection report RAG 280. The undersize welds were found to be acceptable by analysis. After the fabrication of the floor modules, GE has held training sessions for welders and inspectors on weld details, applicable procedures and drawing interpretation. The GE weld inspection procedure has been revised to include weld size verification with fillet gages. This item is closed.
- 1. (Closed) CONSTRUCTION DEFICIENCY REPORT (83-00-08): Control Rod Drive (CRD) system clamps were not ASME qualified. The inspector reviewed the actions taken to correct the deficiency of non-qualified shipping clamps having been installed on the CR0 system. He reviewed GE drawing 769E377; GE Field Deviation and Disposition Request (FDDR) KGI-0127, Revision 0,1,2,3,4; GE FDDR KGI-0136 Revision 0 and I; SWEC Inspection Report M3020902; EEDCR, P12201, P12201A and P12166; and SWEC Inspection Report X 3000781. These documents provide for the removal, redesign and replacement of the shipping clamps with ASME NF qualified hardware.
All of the original shipping clamps have been removed and discarded and
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SWEC designed clamps have been installed where required. This item is closed.
- m. (Closed) CONSTRUCTION DEFICIENCY REPORT (83-00-22): Seismic adequacy of the Control Building interior partitions. The licensee determined that the partitions had not been analyzed previously for seismic loads.
The partitions were reanalyzed and redesigned in accordance with SWEC calculation A46-TAB 1 which considered seismic loads. E&DCRs P40689 and F40943 transmitted the new partition design criteria to the field such that the seismic partitions could be installed. This item is closed.
- n. (Closed) VIOLATION (1-83-005): Intimidation and restriction of quality control personnel. NRC inspection Report 83-12 documents a verification that the statements were retracted by the contractor ITT, and that em-ployees acknowledge their ability to surface problems to the attention of NRC. The inspector has been informed by the licensee that the ITT VP-QA was counseled on OA organizational freedom and unrestricted NRC access. NMPC and SWEC have distributed literature to all site employees which. amplifies the right of free access to the NRC. This literature was disseminated to employees at the close of a workday and was further attached to all paychecks on February 8,1984. NMPC QA has developed surveillance checklist G-001 " Surveillance of QA/QC Personnel at Nine Mile Point Unit 2" which will be performed on a periodic sampling basis to ascertain whether quality personnel have been intimidated. This item is closed.
- o. (Closed) CONSTRUCTION DEFICIENCY REPORT (84-00-12): Improperly torqued hardware on Foxboro panel filler assemblies. The licensee identified nine Foxboro supplied 00126SA panel filler assemblies which were torqued to questionable values. E&DCR C42803 directed that the screws holding the filler and load plates were to be torqued to 24-28 f t.-lb. SWEC
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7 Inspection Report (IR) E4015639 documents the torque verification and rework of the screws which were not initially torqued to , adequate values by the vendor. This item is closed.
- p. (Closed) FOLLOWUPITEM(84-05-04): Review of spent fuel pool heat exchanger support planner sheets. The inspector reviewed the per-tinent weld data sheets for assurance that the. activities were com-pleted under the auspices of the ASME control program. This item is closed.
- 4. Allegations During the inspection period the inspectors conducted inspections and interviews in response to allegations presented to the NRC, additionally the inspectors monitored licensee actions resulting from the presenta-tion of selected issues to the licensee as noted below:
- a. (RI-84-A-0081) The NRC received an allegation. that conduit installa-tions located in the Main Steam: Isolation Valve (MSIV) area were improperly supported such that the cables within the conduit were being overstressed. The inspector toured the MSIV area and examined the installed conduits and noted the safety related raceway displayed no apparent deficiencies. Additionally, no Class lE safety related cables were observed to have been pulled through the conduits. No deficiencies were identified during the followup on this allegation.
- b. (RI-84-A-0086) The NRC received an allegation that NMPC. corporate auditors had been harassed as a result of their having generated nega-tive audit findings. The inspector interviewed the auditor and re-viewed related documentation supplied by the alleger. This allega-tion remains under evaluation.
- c. (RI-84-A-0075) The NRC received an allegation of improprieties in the electrical termination area. The alleger identified the following concerns:
That power cable terminations have been improperly made to transformer bus bars of tin plated aluminum m.terial without providing the necessary bolting hardware. That craft have bypassed QC holdpoints through the application of heatshrink sleeves over crimped lugs prior to QC visual exam-ination of the lugs. That craft have crimped lugs without the presence of a QC inspector. That construction has recalled in-process documentation prior to QC having generated an unsatisfactory inspection report. That the alleger's signature was forged on work tracking docu-mentation. That the alleger had been intimidated both by his intnediate super-visor and contractor engineers during the process of identifying L
, , ( (
8 the concern of dissimilar bus bar material. The inspector coordinated a meeting during which the alleger expressed the above concerns to NMPC QA so that the alleged deficiencies could be promptly investigated and corrected. The licensee's followup provided the following responses to the alleger's concerns: SWEC QC field inspection identified several instances of dis-similar transformer bus bar material and improper bolting hard-ware as documented in Inspection Reports E4007319. E4007353 and E4K00486. SWEC has issued Corrective Action Request (CAR) AA002 to document the improper tennination bolting materials. SWEC has ccmmitted to review applicable vendor specifications to verify bus ~ bar material and perform reinspections of the field connections. Additionally, SWEC reviewed inspections conducted between January 1984 and May 1984. During this timeframe SWEC determined: that 3995 cables were inspected with 14 cases of bypassed hold points; 779 cable terminations were inspected with 11 cases of bypassed hold points; and 104 electrical equipment inspections were conducted with 4 bypassed hold points. As a result of these findings SWEC electrical construction committed to issue a memorandum to the craft personnel to reiterate the adherence to QC holdpoints during the installation process. The SWEC QC inspection personnel were provided additional training on the use of work tracking documents. The training encompassed the use of inspection report documents and the proper way to document unsatisfactory conditions. SWEC management comitted to issue a memorandum to personnel re-garding the interface between QC personnel and other SWEC departments.
- Two unresolved issues remain pending licensee response and further NRC follow-up. The licensee has been requested to pruvide documentation regarding the alleger's hardware concerns generated prior to the alleger having contacted the NRC. (84-09-03) The NRC will conduct additional followup to ascertain whether the alleger was intimidated by either SWEC engineering or QC personnel (84-09-04).
- d. (RI-84-A-0061) The NRC was informed that audit findings resulting from NMPC corporate audit number four had been edited and that the partici-pating auditors had been harassed. The NRC inspector subsequently ob-tained: a draft copy of audit number four; the final audit number four report; and NMPC correspondence which forwarded direction that the two lead auditors who participated in audit four be decertified.
The inspector reviewed the nonconfonnances which document deficient con-l ditions identified within the draf t and final versions of the audit and ascertained that the technical deficiencies noted were similar for both audit reports. The inspector also notes that the NMPC site QA organiza-tion which was reviewed during audit number four has subsequently been completely restructured, additionally new QA procedures have been issued which replace the deficient systems identified in audit four. Resulting
(
, '. ( 9 from NMPC review of the issues, the licensee conunitted to reinstate the lead auditor status of the two auditors involved in audit four.
The inspector noted during his review that the draft audit recom-j mended the findings be reviewed for reportability under 10CFR 50.55(e). No documentation could be produced by the licensee to demonstrate a _ timely review of this issue. This constitutes a further example of a deficient reportability program as identified within NRC Inspection
- Report 84-01, violation 84-01-06. The site and corporate reportability I
system has subsequently been revised by the licensee and will be evaluated during the review of licensee corrective action to violation 84-01-06.
- 5. Corrective Action Programs The inspector reviewed the following documents which define QA/QC re-sponsibility for identification, trending and application of corrective '
action to ident.fied nonconformances: 1 Nine Mlle Point Unit 2 FSAR Section 1.8 Nine Mile Poir.t Unit 2 PSAR Section 0.3.16 and 0.3.17 Regulatory Guide 1.74
) --
ANSI N45.2.10 SWEC 05-15.1 "Nonconfonnance and Otsposition Report" - SWEC QS-14.2 " Inspection Report System" ; SWEC OCI 10.08 " Surveillance Inspections" SWEC QCI-15.1 " Category I N8D Nonconformance : Cause Analysis" '
' SWEC QCI-16.01 "Short Term. Trend Analysis SWEC FQC Monthly Ouality Assurance Department -
Reports covering period from January 1983 - , j May 1984. i ! t The inspector noted the PSAR states that nonconforming conditions shall ' be analyzed to develop corrective action measures. These corrective ! actions shall be implemented to control and prevent recurring discrep- , ancies. The inspector reviewed the SWEC topical QA manual which describes that nonconformances will be documented on either an inspection report ; or a Nanconformance and Disposition (NAD) report depending on whether ' engineering resolution is required. I The inspector reviewed QCI 10.08 regarding the conduct of surveillance inspections. The QCI identified that for reject rates in excess of ten
- i percent that either the frequency or percentage of inspections should be increased. The inspector interviewed SWEC personnel and determined that the intent was to maintain reject rates below the ten percent level and ;
that rates above ten percent were considered to be indicative of quality problems. I 6
- - , , . - - , , . , - _ ,n.,, _ _,
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. _ . - _ . - , . __ . ....... - _ 4 . _ _ _ . . -
( ( i j 10 i The inspector reviewed SWEC QC data published within the monthly QG l department reprts. This data lists the number of QC inspections per-formed and details the number of reject inspections for various types of installations. The inspector recorded reject rates in excess of 2 fifteen percent over a seventeen month period. A summary of the data ' is tabulated below: t i Reject Rate Range Number of Months Comodity (% of Inspections) Reject Rate Identified ' j Exposed Raceway 17-43 9 i Cable Pulls 17-58 6 l j ' HYAC Duct In-process 20-87 9 j Electrical Equipment Installation 23-47 8 1 j Cable Teminations 20-97 8 i l 1 l Preventive Maintenance 16-61 10 j : Storage & Housekeeping 22-72 13 ; l [ ! The data revealed that within the comodity groups excessive deficiency rates ! l are recurrent. This trend indicates that installations are not initially ! i fabricated in accordance with specifications and drawings and relies upon
' quality control to inspect quality into the installation. The failure of :
the SWEC QA program to assure effective corrective action implementation to ! i prevent recurring deficiencies is a violation of 10CFR50, Appendix B, Cri-j terionXVI.(84-09-05). . i
- 6. Electrical Penetrations l
The inspector reviewed the following documents which contain installation ; criteria for containment electrical penetrations. i 1 -- NMP 2 FSAR Sections 1.8,z 3.8 ! } -- Regulatory Guide 1.19 " Nondestructive Examination , of Primary Containment Liner Wolds" , i -- ASME Div I, Section III; NE Specification E021P " Electrical Penetrations l Specification P283B " Shop Fabrication and Field ! Erection of Primary Containment Stect Plate Liner" ! l -- SWEC Drawing 12177-EV-1J-11 " Primary Containment i j Electrical Penetrations" [ ] -- Conax Corp Manual IPS-636 " Installation and Main- ! tenance Manual for Electric Penetration Assemblies l ! for NMP-2" ' Graver drawing NL-10806-4 " Sectional Elevation and ! Details of Multiple Electrical Penetration Assembly ! j P196" i
I ( 11 i Chicago Bridge and Iron Company (CB&I) drawing 434-1
" Shop Assembly Penetration Z201 thru 2210"
- a. The inspector noted that CB&I drawing 434-1 requires CB&I to examine weld H of penetrations Z-201 to Z-210 by both radiography and magnetic particle methods. To verify this requirement the inspector reviewed selected CB&I inspection records as follows:
Penetration NDE Inspection Performed on Weld 11 Z-202 . Radiography only Z-203 Radiography and magnetic particle examination of repair areas Z-204 Radiography and magnetic particle examination of repair areas Z-208 Radiography only Z-209 Radiography only Contrary to the inspection requirements of CB&I drawing 434-1, CB&I records indicate partial surface examinations of repair areas and only volumetric examinations of certain welds. The failure to per-form the requisite NDE examinations is a violation of 10CFR50, Appendix B Criterion X. (84-09-06) i
- b. SWEC Specification E021P requiresthat the welding of the penetration embedmc t, plate to the containment liner plate be examined by spot radiography and either magnetic particle ~or liquid penetrant methods.
The inspector reviewed the CB&I inspection documentation for penetra-tion Z-216 and observed that no spot radiography was performed for the embedment to containment if ner weld. The inspector was informed that spot radiography was applied to particular welders for the first 10 feet of weld and 10 inch segments fron each 40 foot interval beyond the initial 10 feet. He was informed that A record book is maintained by CBSI to support the fact that penetration Z-216 weld was not radio-graphed. This concern regarding the absence of spot radiography for i weld Z-216 is unresolved pending review by the inspector of the CB&I weld logbook and confirmation from SWEC engineering as to the in-
- tended NDE requirements for the embedmont to containment liner welds.
(84-09-07)
- 7. Component Supports The inspector reviewed SWEC drawing ES-53P-7 and EADCR P12829. The docu-ments describe the spent fuel pool heat exchanger support installation requirements. The support was oriqinally classifled as ASME NF. The inspector verified the existence of the appropriate ASME wold planner sheets. The inspector noted that EADCR p12829 reclassified portions of the support as non-ASME. Ile noted that the inspection records had been marked void and subsequently reinstated. SWEC QA issued a Corrective Action Request to identify and prevent recurrence of the inspection re ,,
port void stamping. The inspector reviewed a River Bend Station correspondence regarding the definition of NF boundarle . lie was informed that a similar TSAR
( ( 12 amendment is forthcoming for the Nine Mile Point Unit 2 Station. The inspector has no questions at this time in regards to the spent fuel pool heat exchanger supports or the generic NF boundary definition.
- 8. Pipe Whip Restraints
- a. The inspector reviewed the following documents which pertain to the installation of main steam line whip restraints:
-- Specification P301X SWEC drawing EV-10H-2 " Pipe Rupture Restraint MSS Reactor Buildino" SWEC drawing EY-107K-3 " Pipe Rupture Restraints All Systems OMNI Washer Detafis" He examined whip restraint MSS-PRS-024 which had an ITT inspection tag affixed to the structure. The bolting hardware was observed to be in variance with the above drawings. The inspector interviewed ITT personnel and reviewed records to indicate that only the PRS portion of the restraint has been inspected which is exclusive of the bolting hardware. The inspector was informed that the stainless steel studs and aluminum energy absorption material will be in-stalled after adjacent welding activities have been ccmpleted.
The inspector has no questions at this time.
- b. The inspector reviewed the following design criteria and RCI in-spection documents for selected reactor recirculation line restraints:
GE drawing 767E119 "Recirc.Susoension Hangers Installation Kit - Recire. Loo'p Pipe Whip RST" GE drawing 131C8495 " Pipe Whip Restraint (L)" GE Specification 22A2598 " Installation Specifica-tion Pipe Whip Restraint" RCI W-8 " Process Requirements Sheet for Snubbers 1. Pipe Whip Attachments Requiring the Use of Heavy Weldment Criteria" The inspector examined the welding and documentation to date for restraints RCR-10 and RCR-20. The work was found to be in accordance with the design criteria. The inspector has no further questions at this time regarding the RCI installed restraints.
- 9. followup to Construction Appraisal Team Inspection During the conduct of this inspection, tne inspector monitored the corrective actions impicmented by the licensee in response to the Con-struction Appraisal Team (CAT) inspection. The CAT inspection findings are documented within HRC inspection report 50-410/83-18 issued on January 31, 1984.
l
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i . { *., ', ( i 13 l
- The licensee installed several 3/4 inch and 1 inch diameter Hilti bolts j in the condensate building floor slab. The concrete slab was ascer-4 tained by the licensee to be representative of the concrete mix typically
! utilized within Category I areas of the plant. The installed Hilti bolts l were pull tested to values of four times their design load. The inspec- ; tor observed the pull tests for two bolts. The inspector observed that neither the concrete nor Hilti bolt failed. The maximum slippage of the ; Hilti bolt at the maximum loading was 3/4 inch.
i } The inspector reviewed the re-inspection program applied to. the 'Cives ! Steel structural welds. The licensee had utilized a statistical sampling ! plan as defined within MIL-STD 414 " Sampling Procedures and Tables for i Inspection by Variables for Percent Defective". The inspector noted I that the individual reinspection deficiencies had been dispositioned
, accept-as-is by SWEC engineering. Review of the sampling plan and the l obtained data indicated that further analysis would be required by the
! Ifcensee to determine the acceptability of the Cives weld lot. 1 The licensee QA verification of CAT deficiency corrective action plans was initiated. The NMPC QA verification effort identified several in-consistencies between the planned and accomplished corrective actions. i The inspector has no questions at this time regarding the CAT followup
; efforts.
I
- 10. Unresolved Items
! Unresolved items are matters for which more information is required in ! order to ascertain whether they are acceptable items, violations i or deviations. Unresolved items disclosed during the inspection are dis-
- cussed in paragraph 4c. and 6b.
l 11.. Management Meetings t l At periodic intervals during the course of this inspection, meetings were held with senior plant management to discuss the scope and findings j of this inspection. The inspector attended periodic meetings with the NMPC QA manager and the project director to discuss the status of CAT corrective actions. Apparent violations of NRC requirements were dis-cussed with licensee plant management during exit meetings held on June
- 8 and June 15, 1984.
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, ,, 4048C 4
O <&gD M < : r-i
- NIAGARA M0 HAWK POWER CORPORATION (NMPC) f REPORT OF QUALITY ASSURANCE AUDIT NO. 4 ,
i i STATION: Nine Mile Point Unit 2 (NMP-2) ORGANIZATION: NMPC Quality Assurance Group (QAG) at Nine Mile Point - ! Unit #2
. I i , LOCATION: Scriba, New York i DATES: January 24-27, January 31 - February 3, 1984 i i
AUDITORS: A. Laratta (Lead) ' J. Ryan L. O'Connor 3 R. Norman
- FUNCTIONS
! AUDITE0: Quality Assurance Group - NMP-2 Activities, Training for Site OAG, follow-up from previous audits, and ! l
~
~
. .l-- u organizational structure for site QAG.
PtlRPOSE: The purpose of this audit was to determine compliance to the required documents listed in the scope below. SCOPE: Bases of the Audit: Appendix B 10CFR50, Preliminary Safety Analysis Report (PSAR) Unit #2, NMPC Quality Assurance Manual for Nuclear Reactors and Associated Electric Generating Facilities Design and Construction Phase - Rev. 3, Quality Assurance Procedures (NMPC), ANSI Standards, Open Items from previous Audits, and other applicable procedures and instructions. INTRODUCTION: The Preliminary Safety Analysis Report (PSAR) states in Appendix 0 at D.1'3 under Program Control and Implementation, "The NMPC QA Manual - Design and Construction Phase describes the NMPC controlling policies and procedures." The NMPC Manual - Design and construction Phase (D & CM) states in Section 1 at 1.3 under Program Responsibility: 1
" Total responsibility for the Quality Assurance Program is retained by Niagara Mohawk. The Quality Assurance I Department is responsible to a Senior Vice President for administration of the Quality Assurance Program. This includes overall control through audit or surveillance, review and/or approval for Quality Assurance compliance of the engineering, design, fabrication, construction and test of the facility or modification thereto."
i i l
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i
" ' 4048C
; INTRODUCTION: (Continued)
I In Appendix Al of the D & CM, a matrix is shown which invokes at Section 10.3 of'the D & CM a reference to
- Quality Assurance Procedures (QAP) Section 10.20. At DAP I
10.20 a procedure is defined for conduct of site [ ,
- surveillance.
i j . 1 By letter dated August 20, 1981, from the responsible ' engineer at NMP2 site (file code 3N2.2-M58.18) to I
" distribution" an instruction was written which "provided- ,'
as an aid in reporting surveillance activities." This i l instruction references QAP Section 10.20.
)
i . t EVALUATION: A. SURVEILLANCES - The NMP2 site QA group was found by r l Auditors to be inconsistent in its approach to compliance i to Section'10.20 of the QAP. Varied noncompliances were
}
identified and are listed in the Observation Section of ' .j this report. A review of all 1982 and 1983 Surveillance { Reports should be conducted for compliance to QAP 10.20 as ; i well as verification of proper corrective action. I l !
- B.
NONCONFORMANCE REPORTS (N.R.) - Auditors found evidence !
'L that the site nonconformance program is in many instances i deficient in complying with requirements delineated in QAP i
16.40. A review of all site generated NR's should be i conducted to ensure follow-up and resolution. 4
+
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. . ~ ~
. C. TRAINING - Evid2nce was not provided to the Auditors to corroborate training of site personnel for conduct of Surveillance Activities and Nonconformance Procedure (QAP !
10.20, QAP 16.40 and instruction cited above, i.e., letter 3N2.2-M58.18 8/20/81). I D. LEAD AUDITOR QUALIFICATIONS - Auditors identified five site personnel possessing Lead Auditor Certifications. Investigation revealed that original qualifications and maintenance of proficiency were not totally in compliance to QAP 18.01 at paragraphs 5.1 and 5.2 respectively. Audits conducted by the five personnel should be reviewed to determine compliance to 0AP 18.10. E. PROCEDURES - Fully controlled copies of Quality Assurance P.rocedures maintained at the site were generally in compliance. Only one (1) set was found to be in need of i updating. F. ORGANIZATION - Responsibility is erroneously assigned to contractors in the PSAR. The authority and duties of the NMPC Site QA Group is not. defined, the D & CM organization and project descriptions are not current and the OAP 1.01 designations of duties and authorities are also not current. k 6 t i hI
4048C , .' .' RECOMMENDATION: Based upon the above evaluations and the findings identified in this report, the auditors recommend a review of the Site Surveillance Program, the site nonconformance system, and the site audit participation for applicability of 10CFR50.55(e). OBSERVATIONS: A. SURVEILLANCES - Auditors found that the main tool for the Nine Mile Two Quality Assurance Group is the Surveillance Report (SR). The Surveillance Program is described at QAP 10.20 and further delineated in a letter from the responsible engineer on the NMP2 site to his staff dated August 20, 1981. Auditors reviewed a sample of SR's extracted randomly from the 1200 written in 1982 and the 2000 written in 1983. The approach' to the requirements of OAP 10.20 was found to be inconsistent and violations are identified. The site utilizes two logs to list all SR's written. The first log follows attachment 7.0b of QAP 10.20 in that all Sr's are listed by order of numbers which follow a chronological pattern. This log is kept up-to-date in the OA site. office. Auditors noted that the " Follow-up Required" box was left open in most cases. This is in violation of the OAP and is identified as NR . The second log is kept by listing SR's under assigned engineers' names. Although unofficial, this log carries more information useable in follow-up items. i l l 1 _ __ ___ _ _ . _ .I
In the first log, auditors identified SR 0679-83 as listed open in the log and shown closed on the SR as of 9/29/83. This is identified as NR . In the sampling reviewed by auditors, checklists were used less than 20% of the time: The SR's were prepared as an observational basis with no specific set of guidelines listed. 0AP 10.20 states: "For some activities it may be necessary to prepare checklist in advance of performing a surveillance. This section (5.1) also stipulates that
" familiarity is required with the basic requirements...".
The inconsistent and infrequent use of checklists coupled with lack of evidence that SR was performed by personnel knowledgeable in the discipline places the result of many of the survbillances in doubt. NR is issued to address this item. Auditors found evidence that the follow-up of surveillance is not always pursued routinely or regularly. The site intent is to advise the originators of SR's of follow-ups on a 30-day cycle for each open SR listed at #2 Log-mentioned above. SR's were reviewed which showed follow-up on more widely divergent time elements (0005-83, 0129-83) up to one year.
- ~
~ 4048C
' *
- 4 OBSERVATIONS: A. SURVEILLANCES (Continued)
The timeliness of resolution and follow-up led auditors to question whether action parties were informed of the open SR concer_ns. At QAP 10.20 section 5.4 the requirement is "... the appropriate first action of the responsible QA Department Engineer will be to inform the person responsible for controlling quality at the jobsite of the reported condition." In some cases, no evidence was found of such communication existing. (SR 005-83, 0129-83). NR is issued to address this item. Auditors noted that at blocks 5 & 7 of the SR report, the sign-offs for review and closure (a responsibility of the responsible QA Department Engineer) was often executed by the same person who filled in the preparation and/or verified box (the QA engineer or staff member). This practice was addressed by special memo by the site QA supervisor during the audit. (SR 0005-83, 0026-83, 0135-83, 0208-83, 1088-83, 1509-83, 1681-83, 0006-80,0063-80). NR is written to address this item. In follow-up type SR's written, auditors found repeated examples of such follow-up recorded on small slips of paper stuck onto the SR report. This was addressed orally by the site leads to staff engineers during the audit (SR 01201-83, 0349-83, 0042-83). NR is written to address this item. Auditors requested evidence of scheduling for surveillance I
activities involving compliance to QAP 10.20. There were schedulesinvarying3egreesofcompletionwithnoconsistent application by all engineers. Some were blank, some had proposed surveillance dates, but completion not identified, and some were filled in for both. The use of the schedule is a requirement of QAP 10.20. NR if issued to address this Concern. Auditors noted that on " follow-up" SR's where corrective action was required, evidence was available to show that where corrective action was accepted, the SR was closed without verification of action taken. This practice included the acceptance of a Nonconformance and Disposition Report (N & D) from Stone & Webster, a Deviation Report (DR) from ITT Grinnell i or Field Deviation and Disposition Request (FDDR) from General Electric. Verification of the Disposition of.the actions j promised on these documents was not included in the SR (SR f 0135-83, 0444-83, 0830-83, 1907-83, 0006-83, 0619-83). NR t is issued to address this item.
- i e
Auditors found that SR originators did not always reconstruct events in enough detail. The necessity to be as specific as necessary to document satisfactory work performance or to allow clear identification of actions was not always observed. Omission of sufficient detail in the SR contributes a lack of f prescribed intent of surveillance activity. Checklists would have bee'n helpful in this area. (SR 0010-83, 0135-83, 1088-83, 1103-83,1115-83). NR is issued to address this item. C l
_ . _ _ _ 7. _...___ _ _ _ ... _ _ _ _ . _. _ _ a, e
' i 4048C i l
B. NONCONFORMANCE REPORTS (NR) !
' l l
l The Syracuse QA office retains responsibility fcr follow-up and i i I i closure of most NR's written on the Nine Mile Point - Unit #2 ' Project. On March 30, 1983, the Supervisor of Nuclear 4 7 ). Construction QA Group (site) initiated an I.O.C. #NMP2 QA1383 to ! { the Syracuse Supervisor QA Nuclear Services to accept responsibility for tracking and developing the status of site generated NR's. I 1 : Included in the referenced memo were the following NR's to be } tracked and statused by the site QA group: i I NR NUMBER ORIGINATED , i i r
- NMP_-2-0295 1981 NMP-2-0385 -
1982 I 3 NMP-2-0359 ' 1982 NMP-2-0362 1982 i ,' NMP-2-0377 1983 s
,, G. E. 47 1982, G. E. 48 1982 ,
!- NMPC 24 1983 i i i ! 4 s Five more site generated NR's were written in 1983. They are: NMP-2-0387 i NMP-2-0392 ' l u ;
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.,.-.. . ... - __.. .- -. . - ..- ... - .... - . - - . - . - ..... ~.. . ,. . ~ - . . - -- .
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. NMP-2-0393 i
NMP-2-0417
- NMP-2-0419 i'
A These five NR's and G.E.-48 and NMPC-24 remained open at the #
- time of the audit. '
I f The auditors reviewed the NR files at the site and noted the !
' t following: -
l
; i NR-0295 - Site QA personnel were unable to provide a file for i i
the auditors. The' auditors obtained a file from the
- Syracuse QA office.
i f ) ! l The review of the NR indicated that the response Accepted block was filled out on 8/10/83. However, l letter No. QA82128 dated 2/2/82 indicated acceptance i of response. The NR was subsequently closed on , 8/26/83. ( i i NR-0358 - The auditors noted that response was required 7/28/82 , 4 s and received on 8/6/82. The NR was closed after observing final inspection testing, Surveillance-Report #0870-83 dated 7/29/83. I i r i t r I i i ! i l L
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' 4048C i
- 8. NONCONFORMANCE REPORTS (NR) (Continued) 1 NR-0359 - The auditors noted that the Facility block was not filled out on the NR form. While closure was listed at 1/3/83 in the NR Log, no documentation was available of such closure in the site file.
j NR-0377 - Auditors noted that NR is listed as closed on 5/3/83 in the NR Log, whereas no documentation of such l, closure was available in the site file. i NR-0387 - Site QA personnel were unable to provide a file for the auditors. A copy of a letter dated 5/19/83 transmitting this NR to the site OA office was found in a file marked " closed NR files." The body of 'the letter required a response date of 6/1/83, but the heading required a response date of 6/30/83. The log indicated a response requirement of 6/6/83 and lists I receipt of response on 6/6/83. Further review of the i log indicated that the response.was verbally rejected t. on 8/25/83 and this entry was not initialed. No follow-up documentation to corroborate the entry was available. The log held no further entries since 8/25/83. NR-0392 - Auditors noted in the log that the NR was issued on 7/7/83, response was required on 8/5/83 and received on 8/11/83. However, the file contained no response .. f L ! 4
~ . . . . . , , ~ ~ - ,, . . . . . . , . . . .
. . .,,-.4. . _ -
or follow-up documentation. l Y NR-0393 - Site QA personnel were unable to provide a file for the auditors. The NR log showed that this NR was issued on-7/25/83 with a response required date of i 8/5/83 subsequently changed to 8/24/83 and then to 9/1/83. A copy of the NR obtained by auditors lists the~ response required date as 8/25/83. The site NR log indicates a response dated 9/1/83 was actually logged on 11/4/83 and not accepted until 2/2/84. NR-0417 - Auditors noted that the NR was issued on 12/30/83 with a response required date on 1/30/84. The site NR log indicates the issue date of 12/15/83 and a response , required date of 1/18/84 Response was not received as of 2/2/84 Site NR log was not initialed for the entries made. 1 NR-0419 - Auditors noted that the NR was issued on 12/30/83 with a response required date of 1/30/84 The site NR log concurs with these dates, however, the entries in the
- log were not initialed. A response was received a
1/31/84 i 1 -
- _ , . . . . . - _ . . . _ _ _ . , _ .- . . . _ - . . _ _ _ _ . _ . . ~ _ , - - , ~ . - - , - - - . _
O 4048C B. NONCONFORMANCE REPORTS (NR) (Continued) GE 47
- Auditors noted that this NR was issued on 6/9/82 with a response required date of 7/17/82. ~ Response was received on 7/19/82. No reference was found as to acceptance of this response. No further status was made until 12/16/82. The site NR log shows this NR as closed on 8/3/83. The files contain no documentation of closure.
GE 48
- Auditors noted that this NR was issued on 6/89/82 with a response required date of 7/17/82. A response was received on 7/19/82. The site NR log shows no further entry and no documentation was found as to acceptability of the response. However, site file did contain a letter from GE dated 11/3/83 claiming the NR was not applicable. Documentation referenced was not available.
NMPC Auditors noted that the site NR log listed dates of response received on 6/29/83 and accepted on 7/26/83. However, the NR form carried a response date of 7/12/83 with acceptance on 8/5/83. Documentation of follow-up was not available. 1 A review of the above NR's has resulted in the issuance of the , following three NR's-l
NR is issued to address the lack of timely response.
- i '
4 , , NR is~ issued to address the lack of a responsible QA i engineer to follow up and status site generated NR's. NR is issued to address the lack of verification of t corrective action. f Auditors requested the site NR log on 1/24/84 The log could i not be located until the afternoon of 1/26/84 Upon reviewing the log, it was found that it was last updated in October, 1983. Auditors informed the site QA personnel of this oversight and the log was updated during the audit on 1/27/84. After the { log was updated, the auditors again reviewed it and found that irregularities still' existed as noted above. t NR is issued to address the lack of updating the NR ! log. 4 d In reviewing Nonconformances, auditors' determined that NR-NMP-005 was not generated by site QA personnel, but it was assigned to their. responsibility for corrective action by letter
- l. dated 7/9/81 - QA 81512. The NR was found in the open file at l the site and has been open since 7/81. The response was due on 1
- 8/3/81. Auditors were not provided with evidence of corrective action by site personnel since 7/81.
t l .
, . _., _. ... . _ . _ . . _ . . .. . .. . _. . _ . . ~ . . . .__... _ _ > . . .
. ~. .t.
- 4048C C. TRAINING
-TRAINING RESPONSIBILITY:
The Niagara Mohawk Power Corporation commitment for Q.A.D. training is stated in the Preliminary Safety Analysis Report (PSAR) as contained in Appendix "D", Paragraph D.2.1 Organization.
... Additional specific duties of the Manager of Quality i
Assurance - Nuclear are as follows ...
"(2) Ensure that training is' conducted for NMPC Ouality !
g Assurance Personnel." l Training was further annunciated and made a connitment-in the 1 Design and Construction Manual, Section 2, specifically paragraph 2.6 which states, "... Within the Quality Assurance Departnent, the Manager is responsible for assuring that proficiency is developed and maintained. Within the i task-oriented organizations, their respective managements are responsible for-the development and maintenance of personnel 1 i proficiency..." 6 All of the above three commitments for training Q.A. personnel placed the responsibility for training in charge of highly ! qualified and experienced nuclear supervision and management. , The PSAR, for example, states the requirements for a Manager in ; l II e
i -
. ~ - -
nuclear operations must have "At least 15 years experience in g , .' I construction or operation of a nuclear facility." The Y t requirements for a Supervisor in nuclear operations states that t i he must have "At least 8 years of Quality Assurance related work experience (recently revised from 10 years) in the design, [ i l construction or operation of a nuclear facility." Educational , t requirements for both the Manager and Supervisor of Nuclear must I have at least the Bachelor of Science Degree (BS) or equivalent. [
- ~ i L
During the course of this audit, auditors discovered two letters which appeared to have significantly changed the intent of the , a j
.PSAR and the Design and Construction Manual commitment for 0.A.
i 4 ( training. The letters were dated August 16, 1982 and August 25, 1 f 1982. The latter further transferred the training function from
!' f I
the Manager of Quality Assurance-Nuclear and the appropriate j I supervisor. i i I i
- ~
t QAP 2.10 Section 4.0 states in part, "The. scheduling, planning ! and presentation of lectures, seminars and training sessions for QAD personnel may be delegated by the manager QAD." t ! \ Auditors determined that such delegation was done by letter , dated August 16,1982(17.0-A1). However, QAP 2.10, Section f 4.0, goes on'to state "... the training of personnel is the l \
\
i responsibility of the QAD Supervisors. They are also ( i responsible for maintaining the training program within the ! ! guidelines set-up by the Manager 0AD and this QAP." i-f
- i l !
l l l : i ! i :
- l l._.__ _ . . , _ . . . _ - . , ___ . . , , ,___,.___-,._..--,,___,-,_._,_.._,.,_.,.m.,.__ . , _ , _ . _ _ , . _ _ _ _ . , , , ,
~ :.~- - - - -
4048C . , ,i C. TRAINING (Continued) Section 5.1 of QAP 2.10 states, "The content of the initial training program for.new members is developed by each QAD Supervisor. Each supervisor also revises the program periodically to reflect new policies and standards. Since the organization of training functions can be delegated, the letter of August 16, 1982, is within the purview of the procedures. However, by letter dated August 25, 1982 (QA821197), the recipient of the delegation passed this assignment on to a subordinate and expanded its scope. This action now gives the subordinate authority to determine ...
" assignment will be to determine what training is needed and when it is needed." This second delegation goes beyond the first and invades the responsibilities of "each OAD Supervisor."
NR is issued to address this item. DOCUMENTATION OF PROFICIENCY: Niagara Mohawk Power Corporation in their Quality Assurance Procedures (QAP 2.10, paragraph 5.3) established the following:
"A personnel file is maintained by the Manager QAD to document the progress of proficiency development of each member of the QAD staff. The file contains information on background experience, progress reports and evidence of base-level proficiencies in terms of successful performance on assigned
eh h e
. duties,"
Design & Construction Manual Section 2.6 states in part:
" Personnel performing activities affecting quality are trained and indoctrinated to assure that suitable proficiency is achieved and maintained. They receive instruction sufficient to ensure that the particular activity which they perform in quality-related areas is carried out correctly. This policy applies to areas such as design; procurement; special processes; inspection; tests; measuring and test equipment; handling, storage and shipping; construction, operation and maintenance; auditing; and the review and retention of records.
4 "Within the Quality Assurance Department the Manager is responsible for assuring the proficiency is developed and maintained. Within the task-oriented organizations, their respective managements are responsible for the development and maintenance of personnel proficiency, under the guidance of the Quality Assurance Department.
"Both the Quality Assurance Department and other departments involved in the Program establish procedures which describe material and the method of presenting the training program subject matter at training sessions. Additionally, these procedures include schedules for conducting the training t
sessions and identification of those individuals required to participate by job description, title or group." i I t
l
- 4048C
, C. TRAINING (Continued)
Auditors discovered that there was no documentation trail to the individual's pre-employment background and history. The hiring manager had made no contributions to this record. The supervisor made no. contributions to this record that revealed background experience, training or experience associated to base-levels of competence. There was no matrix record in the
' personnel files which revealed base-levels of competence to ! current daily activity vs. recommendations of individual training required to bring that individual to a level of proficiency to perform in a nuclear environment.
The files did not contain sufficient information, which if i ! duplicated and submitted to the Supervisor, that would enable the Supervisor to make an accurate assessment of the individual i in his annual evaluations for additional training per QAP 2.10, paragraph 4 i i NR is issued to address this item. Auditors reviewed personnel files maintained in the site QA office to determine compliance with QAP 2.6 and QAP 2.10. Auditors reviewed five personnel records at random which revealed: One had a three-month review, as required, and two i had a six-month review, as required. Three of the five samples I i had a one-year review included in their personnel file in lieu l l l l r _, _, _ .- - - - - . . - - - _ - - - - - - , - - - - - - - - - - - *- ~ ' - -
of the required'three-month and six-month reports. NR is issued to address this item. PRESERVATION OF RECORDS: Niagara Mohawk Power Corporation has some specific commitments to established A.N.S.I. Standards, specifically in the areas of record retention and storage... ANSI (N45.2.9) (from contex) "... records are to be maintained in a fire-proof safe or comparable fire-proof file. As an alternate, the records may be duplicated and filed in two separate facilities...etc." Auditors discovered during the course of this audit that the training records':- (a) Were not maintained in a fire-proof safe or file; (b) They were not duplicated and retained in two separate facilities. NR is written to this item.
- _ . - . - . , .. . - ~ . . . . .
, _ . . - . . . - . . . ~ . . - -
4 ,4 4048C C. TRAINING (Continued) A I Auditors requested from site QA supervision specific files for j training of site people. Auditors were informed that these files had been maintained at the site for all personnel until j August 1982. At that time, a direction was received from the ) i l Syracuse QA office to discontinue maintenance of these files at i the site QA office. i ' i , This is addressed as NR . 1 i i L I In the course'of the audit, auditors were advised that duplicate j { records of training were maintained on a microfilm record at ! I l Nine Mile Point Nuclear Station Unit No. 1. I (There was no 1 i
. evidence of any connection of a shared responsibility between the Supervisors of Nine mile Point Units No. I and No. 2.) This
- statement and explanation did not meet the requirements of QAP l i
I i 2.10, paragraph 5.3 for Unit No. 2 specifically. A duplicate of j i the file was not available to the appropriate supervisor. I i NR is written to this item. I l r } l Auditors discovered that personnel records could be accessed on l the Unit No.1 computer and microfilm rolls, after proper } ) identification. The microfilm records could be scanned and l ' printed. However, the printing was a wet process paper which I [
- soon faded and could not be used for any type of I
[ ! i I _- . _- - . _ _ ._- - - ._- - _ - . - - _ . .
\
c
. . , Auditors discovered that more than one microfilm record _ existed
,.' for each individual. It was not determined how many more than l one microfilm record existed on each individual. { Auditors found training material in Syracuse QA0 files that was j not duplicated on the microfilm records at Nine Mile Point Unit No. 1. l l l Microfilm records revealed several dozen pages of superfluous j class attendance sheets was maintained on each individual which l did not serve any useful purpose toward achievement of a 4 i certification. In several cases the achievement of j certification was not revealed in the microfilm record, i.e., on I I the Lead Auditors, there were no documentation records (Form 7.0-b) to prove compliance for certification. There was no training matrix in any of the microfilm records that the
- auditors reviewed.
) j NR is written to this item. l i i I l L l l
4048C
, .' 0. LEAD AUDITOR QUALIFICATIONS / CERTIFICATIONS:
Addressing items No. I and 2 of the Audit Plan, auditors reviewed the training records.and qualifications of Lead Auditors at the site. It was noted that five people at the site had Lead Auditor Certification cards. Verification was made on
, each card. ,
While the ANSI Standards establish a minimum requirement for Lead Auditcr status, the Niagara Mohawk Power Corporation Q.A. Procedures 18.01 established more specific requirements for certification and maintenance of proficiency and this audit addresses QAP 18.01 requirements. Paragraph 5.1.4 Audit Participation states, "A prospective Lead Auditor shall have participated in a minimum of five nuclear quality assurance program audits or surveys within a period of time not to exceed three years prior to the date of qualification, one audit of which has to be within the year prior to his qualification." Auditors discovered that the time requirement in the conduct of audits had expired on two of the five site Lead Auditors. March 1980 and June 1981 were the last audit activities shown for two site Lead Auditors. Since they failed to maintain proficiency in accordance with paragraph 5.2.1 of QAP 18.01, "A Lead Auditor must participate in at least one nuclear audit within a period of two years or he will require requalification in accordance with the requirefrents of paragraph 5.2.2..." Which state, Requalification, "Any Lead Auditor who falls to participate in
.. . .... ~ . _. - .. _ .. _ . . . . . . . . _ _ . _ _ _ _ _ _ _ _ _ _ _ . . _ _ . . _ . . - - . _ _ - - - - . . . _ .
i - thG program for a period of two years or more shall require I '
- requalification. Requalification shall include retraining in !
accordance with the requirements and re-examination and > j- participation as an auditor in at least one quality assurance j program audit or survey." I i l Auditors discovered in further investigation of Lead Auditors at the site that in addition to two of the five who did not l maintain proficiency, the remaining Lead Auditors attained their ' j qualifications based on the conduct of surveillances, not on i audits or surveys as stipulated in Paragraphs 5.1.4 and 5.2.2. It was further revealed that one of the latter two performed as , the lead on the surveillance which he used as a qualification. - i i j NR is written to this item . I Using the above criteria, auditors determined that none of the i I { five Lead Auditors who claimed qualifications by virtue of having a signed card, were indeed qualified as Lead Auditors per the requirements of QAP 18.01. I
- f NR is written to this item.
i 1 1 l 1 i 1 i l i e
, . . . . . , . , . . _ . - .-._, . _ _ _ _ - . _ _ _ , . _ . - ..y.-_,_,-._c,.,,__,._~_,_._,,_,.,__.m.m__,_.., .-._,,_m_J
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a 4048C f D. LEAD AUDITOR QUALIFICATIONS / CERTIFICATIONS: (Continued) ( Auditors discovered, after additional investigation on audits, ;
! surveys and surveillances which were used as a basis for !
qualification, that one of the Lead Auditor's records indicated i two surveys were conducted on September 9 and September 20, 1982 and Part VI (of the Qualification of Quality Assurance Program l Audit Personnel Form) Certification for approval was signed and , dated April 22, 1982 by the Manager-Quality Assurance. i l ! j NR is written to this item. 1 None of the five Lead Auditors had any Documentation Records l (Form 7.06) in their training records file to support the i i activity for which they were claiming sufficient qualification for certification. 1 1 I i j NR is written to this item. I
, While the audit was in progress, auditors were made aware of a !
i letter issued on January 23,1984 (QA840107 "D" - 17.0-TI) l which revealed the names of thirty-eight (38) people who were 1 listed in the records of the QAD as Lead Auditors. The five ! (above) site Lead Auditors appeared on this list. Therefore, , auditors question the completeness of the files of any other l Lead Auditors who appeared in this letter and in the QAD l l training records. { I i f I __ . . _ _ _ _ _ . _ . . . - . . , _ _ . . , _ . _ . . . - . ~ . . . _ _ _ _ . _ _ - . _ . , _ , _ . _ _ - . _ , _ _ _ . _ . _ _ , , . _ . . . _ , _ . _ ,
- - . . ~ . . ..
-~..------
j ,
- TRAINING - CERTIFICATION & DOCUMENTATION:
j . . During the course of the audit, the auditors had an interview J with the training coordinator (which was recorded on tape by the coordinator). A copy of the transcript was requested and ' subsequently made available to the audit team. During the course of the interview with the training coordinator, auditors reviewed training records for the five 'l site Q.A. personnel listed as " Lead Auditors". These filed i contained evidence that material contained had been sent out for microfilm processing on a selected basis. 1 t 1 r e Auditors determined that the selective process is not conducted with the concurrence of the " appropriate site supervisor." i i NR is written to address this subject. l
^
l Auditors further learned that the files were not consistent in 1 l maintaining accurate data on audits (logs) participated in by the personnel reviewed. The omission of some of those logs is addressed as NR . Some of the logs, in the files, had no evidence of being microffimed. e 1 t i i ! l I I I i i
h a . 4048C 1 ! E. PROCEDURES 1 Auditors reviewed the fully controlled copies of QA Procedures , and Design & Construction manuals assigned to site QA i personnel. The fully controlled copies of QA Procedures are
; assigned to four site personnel. Three were found to be
! + current. The QAP Manual assigned to the Manager - QA Nuclear was found to be incomplete.
- NR is issued to address this condition.
I l 1 F. ORGANIZATION I ! j The Preliminary Safety Analysis Report (PSAR), Appendix D-1.3 : l states: "NMPC has the ultimate responsibility for control of j the QA program and implementation is accomplished through i auditing. Specific responsibilities for Quality Control activities have been delegated to S & W ... and to GE-NEBG ..." This delegation of responsibility is in violation of 10CFR50, i
; Appendix 8, Criteria 1, which states in part ... "The applicant i j may delegate to others, such as contractors, agents or consultants, the work of establishing and executing the quality j
{ assurance program, or any part thereof, but shall retain j responsibility therefor." i
- i
! l NR is issued for delegation of such responsibility. j l I i t The authority of the Site QA Supervisor and his group is not l ! j i l ! i i f
delineated ir. CAP 1.01 10CFR50 Appendix B, Criteria I, states in part... "The authority and duties of persons and organizations performing activities affecting the safety related functions of structures, systems, and components shall be clearly established and delineated in writing." The PSAR section on organization assigns responsibilities to the Site QA Supervisor - Nuclear. Construction, but does not define his authority. NR is issued against the inadequacy of 0AP 1.01 to delineate the authority. The Design and Construction Manual Rev. 3, Nov. 1981 -
" Describes the Quality Assurance Program to be followed for the design, procurement, fabrication, installation, erection and testing (to commercial operation) of Niagara Mohawk Power Corporation's new Nuclear Fueled Electric-Generating Units." (D
& CM) This manual is referenced in.Section D.1.3 of the PSAR.
The organization charts contained in Appendix B-1, of the D & CM do not reflect the current organizational and project structures. NR is issued to address this concern. t t -
. . . . ~ - . .
4048C
, .j F. ORGANIZATIdN (Continued)
The Quality Assurance Procedure - (QAP) 1.01, Rev. #2, dated: December 1978 does not reflect the current organization. This QAP is referenced in the D & CM, Appendix A-1 " Quality Assurance Procedural Matrix". Any of the positions described in QAP 1.01 Sections: 4.2, " Supervisor - Quality Assurance Group"; 4.3,
" Group Leader - QA Projects"; 4.4, " Responsible QA Department Engineer"; and 4.5, " Quality Assurance Department Senior Site Representative" could apply to the current position of QA Supervisor - Nuclear Construction. This position exists without the benefits of documented instruction or procedures.
NR is issued to address this concern. OPEN ITEMS AND FOLLOW-UP FROM PREVIOUS AUDITORS The auditors reviewed the corrective action stated in NR #13 dated 4/22/83 for implementation. The response stated in part "The checklist is now being used for all SWEC FPR (Field Purchase Requisitions) reviews by NMPC Site QA". NR #13 indicated in part that "the responses have been verified and found to be satisfactory." The auditors were not provided evidence that a checklist has been employed since 8/9/83. NR for non-compliance to procedure 4.10. I l l l
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i NR against Nuclear - QA Services for not verifying accepted corrective action. s PERSONNEL CONTACTED: *J. L. Dillon C. Beckham i,
*J. Swenszkowski D. Morrison 4
*D. G. Lundeen G. J. Doyle
*F. J. Osypiewski A. P. Kordalewski
- M. A. Balduzzi W. Williams t
j - J. G. Rocker. T. Lee j - E. H. Epperson R. O. Norrix i L. G. Fenton D. P. Dise i J. C. Shepherd D. R. Palmer i J. A. Mitchell L. Brown J. J. Janas J. E. Scoates L. Cole E. Manning l J. Sovie Present at Entrance Meeting i Present at Exit Meeting I 1 l 1 r I I _ - - - . _ - - - -.,_ - __ , _ . - ~ . .
..-,u... _ _._, _ __ _ .,_ _ _ __ _.._,. _ .-. _ ._. _
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4048C 1 l j PERSONNEL CONTACTED: (Continued) On 2/3/84 the auditors conducted the formal exit critique at the site which included the audit team members, site supervision and l site leads. From 2/2/84 through 2/4/84 the exit critique was repeated by the audit team members for the benefit of other concerned parties: i ! A) Designated personnel from Management Analysis Co. (MAC) l l l B) NMPC-Nuclear QA Management ! l l l C) Involved Syracuse QA Supervisory personnel i RESULTS: Nonconfonnances were initiated during this audit: ' l , A) Surveillance l I l B) Nonconformance i C) Training i
, 1 I l
, 0) Lead Auditor Qualification 4 j E) Procedures ! i l F) Organization i
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NIAGARA M0 HAWK POWER CORPORATION REPORT OF QUALITY ASSURANCE AUDIT NO. 4 STATION: Nine Mile Point Unit No. 2 ORGANIZATION: Niagara Mohawk Power Corporation Quality Assurance Group LOCATION: Scriba, New York DATES: January 24 - February 3, 1984 AUDITORS: A. Laratta (Lead) J. Ryan L. O'Connor 1 R. Norman FUNCTIONS Nonconformance report system, surveillance program, lead AUDITED: auditor certification process, employee training program, organizational description and the document control system. PURPOSE: The purpose of the. audit was to review the implementation of the nonconformance system and surveillance program, the do:umentation of the employee training program and the lead auditor certification program, the definition of the organization and the document control system. SCOPE: The audit was limited to a review of selected nonconformance and surveillance reports and logs, the accuracy and maintenance of some lead auditor certifications, the handling of selected employee training and the maintenance of some training records, the definition of organizational responsibilities and the control of selected procedures. EVALUATION: There was a total of eight findings identified and they are shown on nonconformance report sheets in this report. It is considered the program is adequate but that improvements in the implementation of the program need to be made in the areas identified. OBSERVATION: A. Nonconformance Report System All Nonconformance Reports (NR's) and the NR log were reviewed for accuracy and completeness. Some NR files had NOI M6jY g'4') been misplaced, some NR's were closed before the corrective f act' ion was verified, some responses on NR's were not
/ p?lCh'# C. Wrtr /[ reviewed, there were some discrepancies between the v information on some NR's and the information in the site C.4 8 e d #^' b. log for those NR's and the site NR log was not being maintained up-to-date. These deficiencies are identified R NO in NR #0034.
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e. 4162C I A
- 8. Surveillance Program The Surveillance Report (SR) is the main tool that the Ep'
~
/ E ,uJw K'y 1 Quality Assurance group uses to accomplish resolution to
' 4
- f. ' g . problems identified during surveillances. Many SR's that d> 41 -
had been written in 1982 and 1983 were reviewed. Some
". "" M fja h Jsurveillance reports had not been clearly stated, properly
,/ Signed, nor appropriately reviewed and closed out. There f r4 Y r e. dt di d ?"d/was no schedule to define the type and frequency of
/'", , ^, " gj , j p*. u de.) , surveillances to be conducted. There were some differences between the information contained on the surveillance
[.9 , .. , ; .yso .d reports and that recorded in the log book. These
,,J , 4 ,) , 'jr, J ,. ..Lt) deficiences are identified in NP #0035.
f i l f'-7 b _ C. Lead Auditor Certification Process
,; . , W lhe training qualifications and certification records of i'A pb five site lead auditors were reviewed. Two of the five lead auditors had not maintained aualifications but were
/\h /1' N( r g carried on the list of qualified lead auditors. Further, four of the five lead auditors had been certified based
/e,c{ D o' i
h~w G g# W upon their participation in surveillances, not audits. p" /[I M ,,q r' - There wereauditor no records in they their had training files to document s v the lead training
,f gc,,4p)d g g f defigiencies are identified in NR #00 6. ,,j g g . received. These h y ).Ibt 'd , . , .d.M y -f ' M *M W N ^ 8% 9 ,t co- N 'r/ b, /m) '7 [' b .
1 7 D. Employee Training Program J,v q ,, ,r [ar: "~ .'.._. f The training files of five employees were reviewed. There Uke' ' j u7 pp. was one record identified that had not been duplicated as p/ required. Action was initiated to duplicate this record W .f,.,. and no NR was initiated. It was identified however, N 'feftfl'j7,g ,[,d' , through interviews that the three and six months progress
'j' [' , , . ,, .,,I3 )g M 4'A reports from new employee supervisors to the QAD manager k have not always been prepared. This deficiency is
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jr:.in d c l e < E -/ ga ; identified on NR #0037.
/'h Y c j Organizational Description
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N'# The organizational charts and responsibility / authority f,fg ly $ b # ' p t ,~ organization. -
) <) I [:,o,f < p ). descriptions were revie Several differences wre identified between p t.b '^ L - , the current organization and the charts and descriptions f ,
7 for this organization. The charts were found out-of-date YOf' O rd i
'A !(l'h,h-l d'/ r .longer U J)and exist or the did notprocedures define the existing either defined jo job function.
d,, c.t. b/ ' e , # g ) i Inese deficiencies are identified on NR #0038.
- 1. ; ' (( :p - a tJ 'I: (F . Document Control System A' The fully controlled copies of some Q.A. procedures i assigned to four different individuals were reviewed.
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During this review, one manual was found where revised
/[ tvg / u/r procedures dating back several months had not been placed
'~in the manual. This deficiency is identified in NR #0039.
0 6W nN . Additionally, it was identified that letters have teen used in some instances to direct and document quality-related activities, bypassing the procedures. This deficiency is identified in NR #0040. 4162C
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s
s.. The corrective action to resolve Nonconformance Report #13, REGARDING identified in audit f3 was reviewed during this audit. It PREVIOUS was found that the checklists were not being used to review AUDITS: Further, procurement documents as required by QAP 4.10. the nonconformance had been closed out by the Quality Assurance Department without verifying the implementation of the corrective action. This deficiency is identified in NR #0041.
~
The entrance meeting was held at the site on January 24, 1984, and the exit meeting was held at the site on February 3, 1984. The following list identifies those present at the entrance and exit and those contacted during the audit:
*J.L'. Dillon C. Beckham PERSONNEL
- *J. Swenszkowski D. Morrison CONTACTED: G.J. Doyle
*D.G. Lundeen
*F.J. Osypiewski A.P. Kordalewski
- M.A. Balduzzi R.0. Norrix
- J.G. Rocker D.P. Dise
- E.H. Epperson D.R. Palmer
- L.G. Fenton L. Brown
- J.C. Shepherd J.E. Scoates J.A. Mitchell E. Manning J.J. Janas J. Sovie L. Cole
- Present at entrance meeting
- Present at exit meeting QA..' _ <^4 3l/3hY y/f r//e/
Audit Report Prepared By: , 9 c Date: Audit Report Reviewed By: t/Msf8 /// /'M Date: J//3/pq 'I f l 4 4162C I i
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IC t / i j NINidRA MOHAWK POWER CORPORATION (NMPC) J REPORT OF QUAllTY ASSURANCE AUDIT NO. 4-1 y l a j i ; i 1 STATION: Nine Mile Point Unit 2 (NMP-2) ORG ANIZATION: NMPC Quality Assurance Group (QAG) at Nine Mile Point - Unit #2 ll LOCATION: Scriba, New York l I t DATES: January 24-27, January 31 - February 3,1984 AUDITORS: A. Laratta (Lead) J. Ryan L. O'Connor R. Norman il I FUNCTIONS i AllDITED: Quality Assurance Group - NMP-2 Activities, Training for Site ONi, follow-up from prr vinus audits, and l
q . ___ t t A organizational structure for site QAG. l s
.r The purpose of this audit was to determine compliance to l PURPOSE: 1 the required documents listed in the scope below. 9 1
i Bases of the Audit: Appendix B 10CFR50, Preliminary Safety SCOPE: i
~
Analysis Report (PSAR) Unit #2, NMPC Quality Assurance f
$ Manual for Nuclear Reactors and Associated Electric b,
Generating Facilities Design and Construct ion Phase - Rev. f i 3, Quality Assurance Procedures (NMPC), ANSI Standards, l'
-y l Open Items from previous Audits, and other applicable il procedures and instructions.
I e
.71 The Preliminary Safety Analysis Report (PSAR) states in h I NTRODUCT ION:
Appendix D at D.l.3 under Program Control and t-d Implementation, "The NMPC QA Manual - Design and Construction Phase describes the NMPC controlling policies and procedures." The NMPC Manual - Design and construction L;' l lj ! Phase (0 & CM) states in Section 1 at 1.3 under Program l e Responsibility: f
..I
' " Total responsibility for the Quality Assurance Program is I l
J The Quality Assurance f retained by Niagara Mohawk. il' l Department is responsible to a Senior Vice President for l administration of the Quality Assurance Program. This 3 I includes overall control through audit or surveillance, I review and/or approval for Quality Assurance compliance of l
' the engineering, design, fabrication, construction and test I of the facility'or modification thereto."
9 l . 4048C
' , , ~7 0
A INTRODUCTION: (Continued)
- 1 3 :
y i In Appendix Al of the D & CM, a matrix is shown which 1 l li %r' invokes at Section 10.3 of the D & CM a reference to l Quality Assurance Procedures (QAP) Section 10.20. At QAP $l < r 10.20 a procedure is defined for conduct of site ; l f , surveillance. l
.do By letter dated August 20, 1981, from the responsible g; l El engineer at NMP2 site (file code 3N2.2-M58.18) to
' distribution" an instruction was written which "provided j
as an aid in reporting surveillance activities." This
- .i instruction references OAP Section 10.20.
l n
.g A. SURVEILLANCES - The NMP2 site OA group was found by ,3 j EV ALU ATION: .q Auditors to be inconsistent in its approach to compliance ']2 to Section 10.20 of the QAD. Varied noncompliances were
'f [N f identified and are listed in the Observation Section of 51 this report. A review of all 1982 and 1483 Surveillance Reports should be conducted for compliance to QAP 10.20 as a
.Il i well as verification of proper corrective action.
B. NONCONFORMANCE REPORTS (N.R.) - Auditors found evidence that the site nonconformance program is in many instances deficient in complying with reouirements delineated in QAP 16.40. A review of all site generated NR's should be i conducted to ensure follow-up a.id resolution. 4
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k ~ C. ]R41NING - Evidence was not provided to 'the Auditors to' l
- corroborate training of site personnel for conduct of Surveillance Activities and Nonconformance Procedure (QAP l l 10.20, QAP 16.40 and . instruction cited above, i .e. , letter 3N2.2-M58.18 8/20/81).
1 l i i D. LEAD AUDITOR QUALIFICATIONS - Aud~ tors identified five site personnel possessing Lead Auditor CE-t'.fications. 1
- l a
l. 4 l ' investigation revealed that original qualifications and S maintenance of proficiency were not totally in compliance i i to QAP 18.01 at-paragraphs 5.1 and 5.2 respectively. - j I f Audits conducted by the five personnel should be reviewed to determine compliance to 0AP 18.10. , I E. PROCEDURES - Fully controlled copies of Quality Assurance f Procedures maintained at the site were generally in compliance. Only one (1) set was found to be in need of [ updating. I F. ORGANIZATION - Responsibility is erroneously assigned to l J i . contractors in the PSAR. The authority and duties of the NMPC Site 0A Group is not defined, the D & CM organization : and project ' descriptions are not current and the QAP 1.01 f i designations of duties and authorities are also not current. fi l ! i ( ! l t l t o ,
l l. 4048C 4
., s ,
- i RECOMMEND ATION:
Based upon the above evaluations and the findings identified in this report, the auditors recommend a review h l of the Site Surveillance Program, the site nonconforma'nce 3 system, and the site audit participation for applicability g I of 10CFR50.55(e). [. l SURVEILLANCES - Auditors found that the main tool for the OBSERVATIONS: A. l Nine Mile Two Quality Assurance Group is the Surveillance
! l l Report (SR). .The Surveillance Program is described at QAP y
10.20 and further delineated in a letter from the responsible engineer on the NMP2 site to his staff dated
'j August 20, 1981. Auditors reviewed a sample of SR's
' extracted randomly from the 1200 written in 1982 and the 2000 written in 1983. The approach to the requirements of 0 QAP 10.20 was found to be inconsistent and violations are identified.
h The site utilizes two logs to list all SR's written. The first log follows attachment 7.0b of OAP 10.20 in that all Sr's are listed by order of numbers which follow a chronological pattern. This log is kept up-to-date in the QA site office. Auditors noted that the " Follow-up L. fpA h; 3 hN g Required" box was left open in .iast cases. This is in
'l g ,7
,j ' .) violation of the OAP and is identified as NR .
h 4 The second log is kept by listing SR's under assigned 1 engineers' names. Although unofficial, this log carries l more infonution us, able in folicw-up items. l l
g l a6 in the first ing, auditors identified SR 0679-83 as listed j e,l . open in the log and shnwn closed on the SR as of 9/29/83.
, Aud This is identified as NR .
il'l lyM p{ herj.
, JJ ~
In the sampling reviewed by auditors, checklists were used less than 20% of the time: The SR's were prepared as an observational basis with no specific set of guidelines t $3' QAP 10.20 states: "For some activities it may be j A M(( listed.
; i 19 necessary to prepare checklist in advance of performing a 9 '\} g j,'
p / I g g surveillance. This section (5.1) also stipulates that ( i- " familiarity is required with the basic requirements...". [
' ~
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' } [ The inconsistent and inf requent use of checklists coupled p
)I i'ij';>pW with lack of evidence that SR was performed by personnel
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'I , .h knowledgeable in the discipline places the result of many j}
. ,j) ' of the surv'eillances in doubt. NR is issued to
[r# ) address this item. Auditors found evidence that the follow-up of surveillance is not always pursued routinely or regularly. The site intent is to advise the originators of SR's of follow-ups on a 30-day cycle for each open SR listed at #2 Log QW mentioned above. SR's were reviewed which showed follow-up on more widely divergent time elements (0005-83, 0129-83) up to one year.
, 4048C
-a-OBSERVATIONS: A. StlRVEIL LANCES (Continued) l The timeliness of resolution and follow-up led auditors to question whether action parties were informed of the open SR concerns. At QAP 10.20 section 5.4 the requirement is "... the appropriate first action of the responsible QA Department Engineer will be to inform the person responsible for controlling quality at the jobsite of the reported condition."
In some cases, no evidence was found of such communication I l f krN existina. (SR 005-83, 0129-83). NR is issued to address 44 s p(M[p; ..g this item.
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os Auditors noted that at blocks 5 & 7 of the SR report, the f sign-offs for review and closure (a responsibility of the responsible QA Department Engineer) was often executed by the l n l same person who filled in the preparation and/or verified box i
' (the QA engineer or staff member). This practice was addressed l
[ by special memo by the site QA supervisor during the audit. (SR l 0005-83, 0026-83, 0135-83, 0208-83, 1088-83, 1509-83, 1681-83, i l 0006-80, 0063-80). NR is written to address this item. I I In follow-up type SR's written, auditors found repeated examples of such follow-up recorded on small slips of paper stuck onto j the SR report. This was addressed orally by the site leads to { staff engineers during the audit (SR 01201-E3, 0349-83, N 0042-83). NR is written to address this item.
'l ,
5 1 .%ditors requested evidence of sch. doling for surveillance
activities involving compliance to QAP 10.70. There were schedules in varying degrees of completion with no consistent application by all engineers. Some were blank, some had proposed surveillance dates, but completion not identified, and some were filled in for both. The use of the schedule is a requirement of 0AP 10.20. NR is issued to address this concern.
; Auditors noted that on " follow-up" SR's where corrective action was required, evidence was available to show that where corrective action was accepted, the SR was closed without i This practice included the j verification of action taken.
acceptance of a Nonconformance and Disposition Report (N & 0) j from Stone & Webster, a Deviation Report (DR) from ITT Grinnell i or Field Deviation and Disposition Request (FDDR) from General i Electric. Verification of the Disposition of the actions promised on these documents was not included in the SR (SR j lj 0135-83, 0444-83, 0830-83, 1907-83, 0006-83, 0619-83). NR I i is issued to address this item. l i
" Auditors found that SR originators did not always reconstruct i I events in enough detail. The necessity to be as specifi: as l
l k necessary to document satisfactory work performance or to allow l clear identification of actions was not always observed. l I Omission of sufficient detail in the SR contributes a lack of i prescribed intent of surveillance activity. Checklists would I have been helpful in this area. (SR 0010-83, 0135-83, 1088-83, 1103-83,1115-83). NR is issued to address this item. r=d- Y SR k~- ~+ a k u s k ] '" "'" pp dy. Pi.- an m p c + .4 ~4 [. DA.
4048C B. NONCONFORMANCE REPORTS (NR) The Syracuse QA office retains responsibility for follow-up and
]j closure of most NR's written on the Nine Mile Point - Unit #2 l
Project. On March 30, 1983, the Supervisor of Nuclear
! Construction QA Group (site) initiated an 1.0.C. #NMP2 QA1383 to the Syracuse Supervisor 0A Nuclear Services to accept responsibility for tracking and developing the status of site generated NR's.
I I included in the referenced memo were the following NR's to be tracked and statused by the site QA group: NR NUMBER ORIGINATED i 1 NMP-2-0295 1981 NMP-2-0385 1982 f NMP-2-0359 1982 NMP-2-0362 1982 1983 I NMP-2-0377 G.E. 47 1982 f G.E. 48 1982 l NMPC 24 1983 l n ! d Five more site generated NR's were written in 1983. They are: [ I NMP-2-0387 l t NMP-2-0392 I t. ll i 1_--_-.--__--_
NMP-2-0393 NMP-2-0417 - NMP-2-0419 These five NR's and G.E.-48 and NMPC-24 remained open at the time of the audit. The auditors reviewed the NR files at the site and noted the following: i I NR-0295, Site QA personnel were unable to provide a file for the auditors. The auditors obtained a file from the l Syracuse QA office.
.l h
~
> The review of the NR indicated that the response Accepted block was filled out on 8/10/83. However, i
letter No. QA82128 dated 2/2/82 indicated acceptance of response. The NR was subsequently closed on 8/26/83. 1. NR-0358 - The auditors noted that response was required 7/28/82 and received on 8/6/82. The NR was closed after i j, - 7 ' #' observing final inspection testing, Surveillance p f' Report #0870-83 dated 7/29/83. h
^L l
l l
i
- 4048C l .
! B. NONCONFORMANCE REPORTS (NR) (Continued)
- l l
i NR-0359 - The auditors noted that the facility block was not i' p 7 filled out on the NR form. While closure was listed i j at 1/3/83 in the NR Log, no documentation was A available of such closure in the site file. NR-0377 - Auditors noted that NR is listed as closed on 5/3/83 0 in the NR Log, whereas no documentation of such closure was available in the site file. NR-0387 - Site QA personnel were unable to provide a file for the auditors. A copy of a letter dated 5/19/83 transmitting this NR to the site QA office was found in a file marked " closed NR files." The body of the letter required a response date of 6/1/83, but the heading required a response date of 6/30/83. The log indicated a response requirement of 6/6/83 and lists receipt of response on 6/6/83. Further revie.v of the log indicated that the response was verbally rejected on 8/25/83 and this entry was not initialed. No follow-up documentation to corroborate the entry was available. The log held no further entries since 8/25/83. NR-0392 - Auditors noted in the log that the NR was issued on 7/7/83, response was required on 8/5/83 and received on 8/11/83. !!owever, the file contained no respon*e
I l nr follow-up documentation. l l. I NR-0393 - Site QA personnel were unable to provide a file for the auditors. The NR log showed that this NR was issued on 7/25/83 with a response required date of 8/5/83 subsequently changed to 8/24/83 and then to 9/1/83. A copy of the NR obtained by audit 6rs lists the response required date as 8/25/83. The site NR I log indicates a response dated 9/1/83 was actually logged on 11/4/83 and not accepted until 2/2/84. l NR-0417 - Auditors noted that the NR was issued on 12/30/83 with a response required date on 'l/30/84. The site NR log indicates the issue date of 12/15/83 and a response required date of 1/18/84. Response was not received as of 2/2/84. Site NR log was~not initialed for the entries made. l
- l 1 NR-0419 - Auditors noted that the NR was issued on.12/30/83 with
,l a response required date of 1/30/84. The. site NR log concurs with these dates, however, the entries in the log were not initialed. A response was received I ' ,j i
1/31/84 t 1 L_
- 4048C B. NONCONFORMANCE REPORTS (NR) (Continued)
GE 47 - Auditors noted that this NR was issued on 6/9/82 with a response required date of 7/17/82. Response was received on 7/19/82. No reference was found as to acceptance of this response. No further status was made until l?/16/82. The site NR log'shows this NR as closed on 8/3/83. The files contain no documentation of closure. GE 48 - Auditors noted that this NR was issued on 6/89/82 with a response required date of 7/17/82. A response was received on 7/19/82. The site NR log shows no further entry and no documentation was found as to acceptability of the response. Ilowever, site file did contain a letter from GE dated 11/3/83 claiming the NR was not applicable. Documentation referenced was not available. NMPC Auditors notec that the site NR log listed dates of response received on 6/29/83 and accepted on 7/26/83. liowever, the NR form carried a response date of 7/12/83 with acceptance on 8/5/83. Documentation of I follow-up wts not available, 1 l A review of the above NR's has resulted in the issuance of the following three NR's:
i NR _ is issued to address the lack of timely response. h NR is issued to address the lack of a responsible QA engineer to follow up and status site generated NR's. NR is issued to address the lack of verification of corrective action. Auditors requested the site NR log on 1/24/84. The log could not be located until the afternoon of 1/26/84 Upon reviewing h the log, it was found that it was last updated in October, l
; 1983. Auditors informed the site QA personnel of this oversight i and the log was updated during the audit on 1/27/84. After the
- log was updated, the auditors again reviewed it and found that irregularities still existed as noted above.
I 1 [ NR is issued to address the lack of updating the NR log.
- l
-1 in reviewing Nonconformances, auditors determined that {l 'l MR-tMP-005 was not generated by site QA personnel, but it was g. assigned to their responsibility for corrective action by letter .I dated 7/9/81 - QA 81512. .l The NR was found in the open file at ll the site and has been open since 7/81. The response was due on
- I 8/3/81.
Auditors were not provided with evidence of corrective
- j I'
action by site personnel since 7/81. I !f {_p b 3 Ag Pm N *~a d 4 1 'I na e. .
4048C , i l , C. TRAIN]f6 l l
\
TRAINltG RESPONSIBILITY: The Niagara Mohawk Power Corporation commitment for Q.A.D. I training is stated in the Preliminary Safety Analysis Report [ f (PSAR) as contained in Appendix "D", Paragraph D.2.1 j I ' Organization. I i ! i f I
... Additional specific duties of the Manager of Quality
! Assurance - Nuclear are as follows ...
i
"(2) Ensure that training is conducted for NMPC Ouality ;
! ! Assurance Personnel." i' i Training was further annunciated and made a commitment in the Design and Construction Manual, Section 2, specifically paragraph 2.6 which states, "... Within the Quality Assurance j Department, the Manager is responsible for assuring that i k proficiency is developed and maintained. Within the task-oriented organizations, their respective managements are responsible for the development and maintenance of personnel { i e i proficiency..."
- i All of the above three commitments for training Q.A. personnel !
placed the responsibility for training in charge of highly { qualified and experienced nuclear supervision and management. The PSAR, for example, stat es the requirements for a Manager in i
nuclear operations must have "At least 15 years experience in
=
construction or operation of a nuclear facility." The i requirements for a Supervisor in nuclear Operations states that
; he must have "At least 8 years of Quality Assurance related
, ; work experience (recently revised from 10 years) in the design, construction or eperation of a nuclear facility." Educational requirements for both the Manager and Supervisor of Nuclear must have at least the Bachelor of Science Degree (BS) or equivalent. During the course of this audit, auditors discovered two letters which appeared to have significantly changed the intent of the i PSAR and the Design and Construction Manual commitment for Q. A. training. The letters were dated August 16, 1982 and August 25, 1982. The latter further transferred the training function from i i the Manager of Quality Assurance-Nuclear and the appropriate supervisor. I i ; 4 QAP 2.10 Section 4.0 states in part, "The scheduling, planning i
- $ lj and presentation of lectures, seminars and training sessions for i y QAD personnel may be delegated by the manager QAD."
l l I
]l' Auditors determined that such delegation was done by letter l
dated August 16, 1982 (17.0-A1). However, QAP 2.10, Section I 4.0, goes on to state "... the training of personnel is the responsibility of the QAD Supervisors. They are also responsible for maintaining the training program within the l guidelines set-up by the Manager QAD and this QAP." l
4048C C. TRAINI?G (Continued) Section 5.1 of QAP 2.10 states, "The content of the initial training program for new members is developed by each QAD Supervisor. Each supervisor also revises the program periodically to reflect new policies and standards. Since the organization of training functions can be delegated, the letter of August 16, 1982, is within the purview of the procedures. However, by letter dated August 25, 1982 (QA8?l197), the recipient of the delegation passed this assignment on to a subordinate and expanded its scope. This action now gives the subordinate authority to determine ... N, , " assignment will be to determine what training is needed and G/ when it is needed." This second delegatidn goes beyond the 4 first and invades the responsibilities of "each OAD Supervisor." NR is issued to address this item. DOCUMENTATION OF PROFICIENCY: Niagara Mohawk Power Corporation in their Quality Assurance Procedures (QAP 2.10, paragraph 5.3) established the following:
"A personnel file is maintained by the Manager QAD to document the progress of proficiency development of each member of the QAD staff. The file contains information on background experience, progress reports and evidonce of base-level proficiencies in terms of successful perfonnance on assigned
.-.-,_,,m._ _ _ ,_,
duties." Design & Construction Manual Section 2.6 states in part:
" Personnel performing activities affecting quality are trained and indoctrinated to assure that suitable proficiency is achieved and maintained. They receive instruction sufficient to ensure that the particular activity which they perform in This policy quality-related areas is carried out correctly.
applies to areas such as design; procurement; special processes; inspection; tests; measuring and test equipment; handling, storage and shipping; construction, operation and maintenance; auditing; and the review and retention of records.
"Within the Quality Assurance Department the '4anager is responsible for assuring the proficiency is developed and maintained. Within the task-oriented organizations, their j
l respective managements are responsible for the development and l maintenance of personnel proficiency, under the guidance of the l
'! Quality Assurance Department.
I i. I "Both the Quality Assurance Department and other departments 'l 8 involved in the Program establish procedures which describe material and the method of presenting the training program t subject matter at training sessions. Additionally, these ll
! procedures include schedules for conducting the training i
sessions and identification of those individuals required to l participate by job description, title or group." 1 l l !j
i 4048C C. TRAINING (Continued) Auditors discovered that there was no documentation trail to the , t 4 individual's pre-employment background and history. The hiring manager had made no contributions to this record. The l supervisor made no contributions to this record that revealed l background experience, training or experience associated to I base-levels of competence. There was no matrix record in the I personnel files which revealed base-levels of competence te ; i current daily activity vs. recommendations of individual l training required to bring that individual to a level of l proficiency to perform in a nuclear environment. l i l The files did not contain sufficient information, which if l
, duplicated and submitted to the Supervisor, that would enable j the Supervisor to make an accurate assessment of the individual j in his annual evaluations for additional training per QAP 2.10, b D j r
4 I paragraph 4 ! NR is issued to address this item. l i I Audito-s reviewed personnel files maintained in the site QA office to determine compliance with OAP 2.6 and QAP 2.10. l l Auditors reviewed five personnel records at random which i revealed: One had a three-month review, as required, and two had a six-month review, as required. Three of the five samples ; I had a one-yiar review included in their personnel file in lieu i l 5 15
of the required three-month and six-month reports. NR is iss'ued to address this item. PRESERVATION OF RECORDS: Niagara Mohawk Power Corporation has some specific commitments to established A.N.S.I. Standards, specifically in the areas of record retention and storage... ANSI (N45.2.9) (from contex) "... records are to be maintained in a fire-proof safe or comparable fire-proof file. As an alternate, the records may be duplicated and filed in two separate facilities...etc." Auditors discovered during the course of this audit that the training records: (a) Were not maintained in a fire-proof safe or file; i (b) They were not duplicated and retained in two separate facilities. NR is written to this item.
4048C C. TRAINING (Continued) l
. Auditors requested from site OA supervision specific files for I
training of site people. Auditors were informed that these l files had been maintained at the site for ,il personnel until August 1982. At that time, a direction was received from the Syracuse QA office to discontinue mair.tenance of these files at the site QA office. ' This is addressed as NR , in the course of the audit, auditors were advised that duplicate records of training were maintained on a microfilm record at j Nine Mile Point Nuclear Station Unit No. 1. (There was no evidence of any connection of a shared responsibility between the Supervisors of Nine mile Point Units No. I and No. P.) This statement and explanation did not meet the requirements of QAP 4 2.10, paragraph 5.3 for Unit No. 2 specifically. A duplicate of the file was not available to the appropriate supervisor. J NR is written to this item. Auditors discovered that personnei records could be accessed on the Unit No. I computer and microfilm rolls, after proper identification. The microfilm records could be scanned and However, the printing was a wet process paper which 1 printed. soon faded and could not be used for any type of i
Auditors discovered that more than one microfilm record existed for each individual. It was not determined how many more than one microfilm record existed on each individual. l Auditors found training material in Syracuse QAD files that was not duplicated on the microfilm records at Nine Mile Point Unit No. 1. Microfilm records revealed several dozen pages of superfluous class attendance sheets was maintained on each individual which did not serve any useful purpose toward achievement of a certification. In several cases the achievement of certification was not revealed in the microfilm record, i.e., on-the lead Auditors, there were no documentation records (Form 7.0-b) to prove compliance for certification. There was no j
+
training matrix in any of the microfilm records that the auditors reviewed. i NR is written to this item. f; 7 1 0 I l iI .I I I i l
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I 4048C 1.
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- 0. LEAD AUDITOR QUALIFICATIONS / CERTIFICATIONS:
i. i Addressing items No. I and 2 of the Audit Plan, auditors ]~ reviewed the training records and qualifications of Lead Auditors at the site. It was noted that five people at the site t' I had Lead Auditor Certification cards. Verification was made on J 4: each card. i! While the ANSI Standards establish a minimum requirement for *
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l
'l Lead Auditor status, the Niagara Mohawk Power Corporation Q.A. ' Procedures 18.01 established more specific requirements for certification and maintenance of proficiency and this audit addresses QAP 18.01 requirements. Paragraph 5.1.4 Audit e i
Participation states, "A prospective Lead Auditor shall have participated in a minimum of five nuclear quality assurance ' program audits or survtys_ within a period cf time not to exceed
' three years prior to the.date of qualification, one audit of i
i which has to be within the year prior to his qualification." . l ! 1 I Auditors discovered that the time requirement in the conduct of l l' audits had expired on two of the five site Lead Auditors. March l .
' 1980 and June 1981 were the'last audit activities shown for two l Since they failed to maintain proficiency-
~
f,) site Lead Auditors. in accordance with paragraph 5.2.1 of QAP 18.01, "A Lead Auditor' l b ' must. participate in at least one nuclear audit within a period ;
'l c l .' ' of two years or he will require requalification in accordance
+
l l Which state, ; with the requirements of paragraph 5.2.2..." . Requalification,_"Any Lead Auditor who fails to participate in l i i i I
q_m . the program for a period-of two years or more shall require requalification. Requalification shall include retraining in accordance with the requirements and re-examination and participation as an auditor in at least one quality assurance program audit or survey." Auditors discovered in further investigation of Lead Auditors at the site that in addition to two of the five who did not maintain proficiency, the remaining 1.ead Auditors attained their qualifications based on the conduct of surveillances, not on audits or surveys as. stipulated in Paragraphs 5.1.4 and 5.2.2. It was further revealed that one of the latter two performed as the lead on the surveillance which he used as a qualification. NR is written to this item. Using the above criteria, auditors determined that none of the five Lead Auditors who claimed qualifications by virtue of having a signed card, were indeed qualified as Lead Auditors per the requirements of QAP 18.01. NR is written to this item. I
e 404SC
' - i ,
D. LEAD AUDITOR QUAllFICATIONS/ CERTIFICATIONS: (Continued) Auditors discovered, after additional investigation on audits, surveys and surveillances which were used'as a basis for 1 I i qualification, thdt one of the lead Auditor's records indicated two surveys were conducted on September 9 and September 20, 1982 and Part VI (of the Qualification of Quality Assurance Program Audit Personnel Fcrm) Certification for approval was signed and l I dated April 22, 1982 by the Manager-Quality Assurance. , l i NR is written to this item. None of the five Lead Auditors had any Documentation Records (Form 7.0b) in their training records file to support the activity for which they were claiming sufficient qualification ! i for certification,
?
NR is written to this item. While the audit was in progress, auditors were made aware of a [
, t letter issued on January 23, 1984 (QA840107 "D" - 17.0-TI) which revealed the names of thirty-eight (38) people who were t
listed in the records of the QAD as Lead Auditors. The five ! l (above) site Lead Auditors appeared on this list. Therefore, [ t auditors question the completeness of the files of any other l Lead Auditors who appeared in this letter and in the QAD training records. I ! t
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TRAINING - CERTIFICATION & DOCUMENTATION: During the course of the audit, the auditors had an interview with-the training coordinator (which was recorded on tape by the coordinator). A copy of the transcript was requested and subsequently made available'to the audit team. During the course of the interview with the training l coordinator, auditors reviewed training records for the five l site Q.A. personnel listed as " Lead Auditors". These filed contained evidence that material contained had been sent out for l l microfilm processing on a selected basis. Auditors determined that the selective process is not conducted with the concurrence of the " appropriate site supervisor." NR 0 is written to address this subject. 4 i - Auditors further learned that.the files were not consistent in maintaining accurate data on audits (logs) participated in by the personnel reviewed. The omission of some of those logs is 1 addressed as NR . Some of the logs,-in the files, had no evidence of being microfilmed. io II l li f 41
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4048C E. PROCEDURES Auditors reviewed the fully controlled copies of QA Procedures and Des.ign & Construction manuals assigned to site QA personnel. The fully controlled copies of QA Procedures are assigned to four site personnel. Ihree were found to be current. The QAP Manual assigned to the Manager - QA Nuclear was found to be incomplete. NR is issued to address this condition. s F. ORGANIZATION The Preliminary Scfety Analysis Report (PSAR), Appendix D-1.3 states: "NMPC has the ultimate responsibility for control of the QA program and implementation is accomplished through auditing. Specific responsibilities for Quality Control activities have been delegated to S & W ... and to GE-NEBG ..." This delegation of responsibility is in violation of 10CFR50, Appendix 8, Criteria 1, which states in part ... "The applicant may delegate to others, such as contractors, agents or consultants, the work of establishing and executing the quality assurance program, or any part thereof, but shall retain responsibility therefor." NR O is issued for delegation of such responsibility. The aut horitysof. the Site QA Supervisor .noi his group is riot
e delineated in OAP 1.01 10CFR50 Appendix B, Criteria I, states in o . part... "The' authority and duties of persons and organizations performing activities affecting the safety related functions of structures, systems, and components shall be clearly es'ablished and de,lineated in writing." The PSAR section on organization assigns responsibilities to the Site QA Supervisor - Nuclear Construction, but does not define his authority. NR is issued against the inadequacy of OAP 1.01 to delineate the authority. The Design and Construction Manual Rev. 3, Nov. 1981 -
" Describes the Quality Assurance Program to be followed for the design, procurement, fabrication, installation, erection and testing (to commercial operation) of Niagara Mohawk Power Corporation's new Nuclear Fueled Electric-Generating Units." (D L CM) This manual is referenced in Section D.1.3 of the PSAR.
The organization charts contained in Appendix B-1, of the D & CM do not reflect the. current organizational and project structures. NR is issued to address this concern.
.a .-
4048C j , o - 1 F. ORG ANIZ ATION (Continued) i The Quality Assurance Procedure - (QAP) 1.01, Rev. #2, dated: December 1978 does not reflect the current organization. This QAP is referenced in the D & CM, Appendix A-1 " Quality Assurance Procedural Matrix". Any of the positions described in QAP 1.01 1 Sections: 4.2, " Supervisor - Quality Assurance Group"; 4.3,
" Group Leader - QA Projects"; 4.4, " Responsible QA Department Engineer"; and 4.5, " Quality Assurance Department Senior Site q
Representative" could apply to the current position of QA Supervisor - Nuclear Construction. This position exists without the benefits of documented instruction or procedures. NR is issued to address this concern. OPEN ITEMS AND FOLLOW-UP FROM PREVIOUS AUDITORS The auditors reviewed the corrective action stated in NR #13 dated 4/22/83 for implementation. The response stated in part "The checklist is now being used for all SWEC FPR (field Purchase Requisitions) reviews by NMPC Site QA". NR #13 indicated in part that "the responses have been verified and found to be satisfactory." f The auditors were not provided evidence that a checklist has i been employed since 8/9/83.
- R for non-compli u.re to prm edm e 4.10.
o
- o. , NR against Nuclear -~ QA Services for not verifying accepted corrective action.
PERSONNEL CONTACTED: *J. L. Dillon C. Beckham
*J. Swenszkowski D. Morrison
*D. G. Lundeen G. J. Doyle
*F. J. Osypiewski A. P. Kordalewski
- M. A. Balduzzi W. Williams-
- J. G. Rocker T. Lee
- E. H. Epperson R. O. Norrix
- L. G. Fenton D. P. Dise
- J. C. Shepherd D. R. Palmer J. A. Mitchell L. Brown J. J. Janas J. E. Scoates L. Cole E. Manning i
I J. Sovie l l
- Present at Entrance Meeting
- Present at Exit Meeting I
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PERSONNEL CONTACTED: (Continued) On 2/3/84 the auditors conducted the formal exit critique at the site which included the audit team members, site supervision and site leads. From 2/2/84 through 2/4/84 the exit critique was repeated by the audit team members for the benefit of other concerned parties: , A) Designated personnel from Management Analysis Co. (MAC) B) NMPC-Nuclear QA Management C) Involved Syracuse QA Supervisory personnel RESULTS: Nonconformances were initiated during this audit: A) Surveillance B) Nonconformince C) Training i l D) Lead Auditor Qualification E) Procedures i
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INTE 4.,,RNAL CORRESPONDENCE M Y NIAGARA l
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FROM W. D. Baker DISTRICT Nine-Mile Point Unit r*2 I To Distribution DATE June 7, 1984 FILE CODE l t SUBJECT NRC ]nspection 84-09 l Infonnal Exit i f Mr. R. A. Gramm conducted an informal exit for the noted inspection period which will cover the period llay 11 through June 8,1984 (tenta-tively). The following personnel were in attendance: P Name Title Company ! { W. D. Baker Lead Constr. Engr. - Liaison NMPC i C. H. Millian Lead Sr. NC&V Engineer NMPC j W. Morrison Project Director NMPC M. J. Ray Asst. to Project Director NMPC K. L. Tyger Quality Admin. Supv. NMPC J. E. Huston QA Department Manager SWEC l R. S. Hyslop Jr. Site Licensing SWEC
- 5. K. Chaudhary Senior Resident Inspector NRC R. A. Gramm Resident Inspector NRC i
l Mr. Gramm noted that he has received some old items to review for ! closure. The following additional concerns have'been identified: l t
- Preheat in accordance with ITT Grinnell Procedure P301-X-ITT-G-2 !
on an unattended restraint in the primary containment - Temperature was higher than the 1500 minimum; however, a construction log l indicated an infrequent basis for monitoring the temperatures (i.e. approximately every 6 hours); also, there appears to be no control , for monitoring maximum temperature; the frequency of temperature { checks is not adequately defined; in addition, the procedure does ! not address rate of heat up or cool down. [
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M-09 Informal Lxit Meeting Minutes Page 2 In the Control Building below elevation 261 where fire protection is being installed over structural steel with wire mesh held in place by wire ties - The concern is with regard to the wire ties falling on to installed Class IE cables (e.g. cable tray 2TK5026), and impact of wire ties in the cable trays on subsequent cable pulls; more control is needed to cover cables under this activity to avoid damage to existing cables or future cable pulls. NMPC Corporate Audit #4 conducted in January 1984 - Serious concerns have been raised about the handling of findings; the final audit report does not address findings which had been previously identified as program breakdowns with 50.55(e) impact and possible stop work actions needed due to noncompliance with procedures and lack of control; information has been requested from NMPC Corporate Audit group. 84-05-02 regarding small bore valve assembly - Action is being taken to resolve this concern including the use of data sheet to control the reassembly of these valves and ensure that bolt minimum torques are applied, and " beef up" of CSI activities were noted as being an appro-priate method of resolving these concerns. Mr. Gramm introduced Mr. S. K. Chaudhary, U.S. NRC Senior Resident Inspector at Limerick, who is visiting NMP2 during this inspection period to assist i.n'the conduct of this inspection and to review CAT actions. kM d W. Q) Baker M r.g WDB/bb Distribution Attendees C. G. Beckham C. D. Terry J. P. Thomas J. P. Ptak J. J. Bebko A. F. Zallnick B. Charlson R. L. Wagner
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INTERNAL CORRESPONDENCE M Y 41AGARA
,o~ = > a e> = RUWOHAWK W. D. Baker [MSTRICT ne Mile Point Unit #2 FROM June II, 1984 TO Distribution DATE FILE CODE xt ce ng Minutes SUBJECT 84-09 Mr. R. A. Gramm, U.S. NRC Resident Inspector, and Mr. S. Chaudhary, U.S.
NRC Senior Resident Inspector, conducted an informal exit meeting on f riday, June 8, 1984, for Inspection Period 84-09 covering the period May 11 through June 15,1984. The following personnel were in attendance: Name Title Company l W. D. Baker Lead Constr.' Engr. - Quality Liaison NMPC C. G. Beckham Manager QA - Projects NMPC E. R. Klein Asst. Manager - Project Engineering NMPC J. A. White Construction Engineer - Liaison NMPC T. T. Arrington Supt. of FQC SWEC J. J. Gallagher SEG - Licensing SWEC R. Hyslop Lic. Engineering SWEC I. M. Sheldon Construction SWEC C. L. Terry Project QA Manager SWEC S. K. Chaudhary Senior Resident Inspector NRC R. A. Gramm 7 Resident Inspector NRC lhe following items were noted as being closed during this inspection period: 83-12-02 (0 pen) - field versus factory installations of GE connector bracket assemblies 83-03-01 (Unr) - Use of Bellems grip for cable support 82-09-01 (Unr) - Engineering design electrical procedure
- 81-13-01 B, C, E, G - (Viol) - Cat inspection; QA Program 83-00 CRD Clamps
- 83-00 Control Building Seismic Partitions
/ NRC Exit Meeting 84-09 Minutes Page 2 lhe following additional concerns have been addressed: Potential Violation: SWEC trending of Unsat IR's - a review of SWEC's FQC trending reports since .lanuary 1984 indicate excessive negative trends and recurring high reject rates, yet no long term corrective action was provided. (II 28-84) follow Up: CAT Item 21 Cives Shop weld deficiencies - cable tray reinspections were performed using MIL-STD-414, yet the inspection results were not analyzed in accordance with the MIL standard. The Inspector also questions why MIL ST0-105 was not applied. (11 27-84) SWEC Training Program - A review of the SWEC training matrix indicates that training, as a minimum, is enforced for the quality organization and prinicipal engineers, yet excludes supporting engineering personnel, e.g., N&D training where engineers play a critical role in this. procedure. A committee has been established to review the training matrix. (II 39-84) Pr.eheat in accordance with ITT Spec P30lX - There appears to be no control for monitoring maximum temperature; in addition the procedure does not address rate of heat up or cool down. (II 31-84) Fire Protection coating installed over structural steel - Cut ends of tie wires and other material were observed dropping in an open Class lE cable tray. These sharp ended objects are capable of causing cable damage to existing cables and/or future cable pulls. More control is needed to cover cables under these conditions and make the contractor aware of these conditions. It was acknowledged that IR's have been written and addressed to the contractor who caused the condition. (II 29-84) NMPC Corporate Audit #4 - Serious concerns have bene raised about the handling of the findings; the final audit report does not address findings which had been previously identified as problem breakdowns with 50.55(e) reportability . An' analysis is still in process. Mr. Gramm noted that one item he will continue to monitor is Niagara Mohawk's definition of NF pressure boundary for heat exchanger 2SFC*ElB. FSAR clarification on this boundary will identify Niagara Mohawk's position at which time the Consniss ion will evaluate the situation. (11 40-84)
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FILE CODE TO DATE SUDJECT Exit Meeting Mr. R. A. Grann, US NRC Resident inspector, conducted a f orna l exit meeting on Friday, June 15, 1984 covering the period May 11 through June 15, 1984. The following personnel werc in attendance: Name Title Company W. D. Baker Lead Construction Engr - QL NMPC
- 5. E. Gener NC&V Engineer NMPC L. R. Klein Asst. Mgr. Project Engincering NMPC
- 8. R. Morrison Quality Engineering Manager NMPC M. J. Ray Asst. to Project Director NMPC C. D. Terry Project Engineering Manager NMPC K. L. Tyger Quality Admin. Supervisor NMPC
- 1. f. Arrington Superintendent of f0C SWEC G. P. Philipp) Prin. Mechanical Engineer SWEC A. H. Rovetti Supv. Engineer SWLC C. L. Terry Project Q. A. Manager SWEC R. A. Grann / Resident inspector NRC Mr. Grann connented that he was pleased with the number of open items presented for closure during this inspection period and he hoped the trend would continue. The following items were closed during this inspection period:
83-02-04 Unr Instrument support qualification sheets 83-12-04 Unr Shim plate installation 83-17-03 Open ITT Grinnell weld tracability 81-13-018 Vio 1981 CAT Inspection 81-13-01C Vio 1981 CA1 Inspection 81-13-01L Vio 1981 CA1 Inspection 81-13-01G Vio 1981 CAT Inspection 83-12-02 Open Connector bracket assemblies 83-03-01 Unr Kellems grip use and installation 82-09-01 Unr Drawing hold procedure COR83-26 COR83-05 COR83-08 COR84-12 SI83-005 Note: Mr. Grann commented that the 81-13 findings that he has noted as closed are particularly sensitive, but are being rec onrnended for closure based on corrective action having been' initiated and remaining concerns having been picked up on the recent CA1 Inspection. I
NRC Exit 84 09 m Meeting Minutes Page 3 Open (Continued) Niagara Mohawk QA Audit #4 S0.S$(e) evaluations were reconinended but not perf ormed until May $; why PPNMISI was not implemented sooner needs to be resolved. (11 30 84) Mr. Gramm further noted that he will be off site for a period of three i weeks. During that time, Mr. Cerne, NRC Resident Inspector from Seabrook, ' will be on site conducting a routine inspection and followup of some CA1 findings. rog W.g.' Baker - WDB/bb Distribution: Attendees i l W. Morrison ' C. G. Beckham ! J. P. Ptak
- J. P. Thomas A. f. Zallnick J. J. Bebko C. H. Millian C. R. Kolarz (PSC)
B. Charlson (SWEC) R. L. Wagner " C. E. Crocker " Project file
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