IR 05000213/1978029
| ML19276E434 | |
| Person / Time | |
|---|---|
| Site: | Haddam Neck File:Connecticut Yankee Atomic Power Co icon.png |
| Issue date: | 01/15/1979 |
| From: | Kehoe D, Kister H, Napuda G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19276E433 | List: |
| References | |
| 50-213-78-29, NUDOCS 7903120594 | |
| Download: ML19276E434 (16) | |
Text
.
.
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. go p11/7s_pg Docket No. 50-213 License No. DPR-61 Priority
--
Category C
Licensee:
Connecticut Yankee Atomic Power Company P. O. Box 270 Hartford, Connedticut 06101 Facility Name:
Haddam Neck Plant Inspection at:
Berlin and Haddam, Connecticut Inspection conducted:
December 11-15, 1978 Inspectors: M.b @ h
/ jf.7 7 G. Napudd, Reactor fnspector date signed
/ -)S ~]f
.
D.Kehoe,ReactorInsp$ctor date signed 7P.711 & & L
/-w-79 R.Markowski,ReactorInspecDor date sig'ned
,aproved by:
8-
/[fg h HI Kiste7 Chief, Nuclear Support Section
'date signed No. 2, R0 & NS Branch Inspection Summary:
Inspection on December li 15,1978 (Report No. 50-213/78-29)
Areas Inspected: Routine, unannounced inspection by regional based inspectors of the Quality Assurance Program (QAP) implementation including: QAP changes; procurement; records management; and audits.
The inspection also included followup of previously identified unresolved items and an item of noncompliance. The inspection involved 84.5 inspector-hours onsite by three NRC regional based inspectors and 19 inspector-hours at the corporate offices by one NRC regional based inspector.
Results: of the six areas inspected, no items of noncompliance were identified in five areas and one item of noncompliance was identified in one area (Deficiency - a number of warehouse storage conditions did not comply with ANSI N45.2.2 requirements - para-graph 5.c).
Region I Form 12
"l903120 M (Rev. April 77)
.
.
DETAILS 1.
Persons Contacted D. Bement, Records Supervisor Q. Billingsley, Staff Engineer
- R. Blewett, QC Coordinator G. Bouchard, Electrical Foreman N. Burnett, Operating Supervisor J. Chiarella, I&C Foreman R. Davenport, Nuclear Records Manager (NUSCO)
- D. Diedrich, QA Manager (NUSCO)
- R. Dilaura, Assistant QC Coordinator
- J. Ferguson, Engineering Supervisor S. Fleming, Training Coordinator
- R. Graves, Plant Superintendent J. Levine, Maintenance Supervisor
- R. Traggio, Assistant Plant Superintendent W. Ventres, Mechanical Foreman Other Accompanying NRC Personnel N. Blumberg, Reactor Inspector The inspectors also contacted other plant and corporate personnel including operating, engineering, quality and administrative staff.
- denotes those present at the exit interview.
2.
Licensee Action on Previous Inspection Findings (Closed) Infraction (213/77-12-01): Failure to properly document audit performance and adverse findings per procedure requirements, and receive timely corrective action responses.
During the review of plant audits (paragraph 7), the inspector noted that audits were being documt 'ed as specified, adverse findings were entered into the followup system, and corrective action responses were timely with any target date extensions properly documented.
These obser-vations were consistent with the licensee's statements in their letter dated September 23, 1977.
This item is resolve.
.
(Closed) Unresolved Item (213/77-12-02): Auditor / Lead Auditor signatures on audit reports.
During the review of plant audits (paragraph 7) the inspector verified that plant audit reports were signed by the appropriate auditor (s). This item is resolved.
(Closed) Unresolved Item (21J/77-12-03): Delegation of responsibility to initiate corrective action reports.
The inspector verified that recently issued Procedure ADM l.1-45, Revision 0, describes and assigns responsibilities for the " Commitment Follow System." This item is resolved.
(0 pen) Unresolved Item (213/77-12-04): Accomplishment of audits within the required time frame.
NUSCO (corporate) Audit A60105 identified that the QC Coordinator did not perform the required audits during 1977 and early 1978.
The inspector noted that reaudit A60111 verified the implementation cf the previously accepted corrective action responses.
During the review of plant audits (paragraph 7) the inspector verified that, currently, the audits are being conducted as scheduled.
The apparent improvement in this area seems to be the result of adding an individual to assist in plant QA/QC functions. The inspector also noted that senior NUSCO management are presently involved in the review of plant corrective action responses.
The inspector determined that this item would remain unresolved pending verification during a subsequent inspection (s) that the plant auditing activities continue to be conducted in accordance with established requirements.
(Closed) Unresolved Item (213/77-12-08): Procedural description of NUPOC design verification activities.
The inspector verified that Procedure QA 1.2-3.1, Revision 8, describes the review process.
This item is resolved.
(Closed) Unresolved Item (213/77-12-09): Corrective action as related to PDCR checklists.
The proposed corrective action as a result of Audit 77-2 was to revise Procedure 1.2-3.1.
The implementation of the approved corrective action was verified during Audit A70006.
This item is resolved.
(0 pen) Unresolved Items (213/77-12-10): Corrective action as related to written notification of function completion of design changes.
The accepted proposed corrective action as a result of Audit 77-2 requires the Engineering Supervisor to enter the actual completion date in the PDCR Log.
Because of the nature of the time frame needed to implement modificatior._, additional time is required to determine the effectiveness of the implemented corrective action.
Pending further review of this area during a subsequent inspection (s) this item remains unresolve.
.
(0 pen) Unresolved Item (213/78-11-01): Review corrective action for design change control with respect to Audits A000154 and 285.
The inspector noted that the implementation of approved corrective action with respect to Audit A000285 was verified but final correc-tive action was not yet completed with respect to Audit A000154.
Pending the review of followup action on this "open" audit this item remains unresolved.
(Closed) Unresolved Item (213/78-21-04): Review corrective action responses from vendor with respect to Audit A00983. The inspector noted that the implementation of the approved responses had been satisfactorily re-audited. This item is resolved.
3.
Quality Assurance Program Review The inspectors noted that NUSCO had submitted a Topical Quality Assurance Program to NRR in February 1978.
It was further noted that the NRR review had progressed through two rounds of questions with the latest description being Revision 2, dated October 1978.
Only three questions require resolution prior to NRR approval of the Topical.
The licensee is in the process of revising implementing procedures to be consistent with the currently submitted program to ensure prompt implementation upon NRR final approval.
In fact, in those areas where no further resolution is needed, several revised pro-cedures have already been reviewed and approved by the appropriate management, including PORC, and are being implemented.
The examination of the implemented revised quality assurance program will be conducted after final NRR approval of the sub-mitted topical program.
4.
Inspection Program a.
References
--
QA 1.2-2.3, Certified Inspection Personnel at Connecticut Yankee, Revision 1 QA 1.2-10.1, Installation Inspections, Revision 3
--
QA 1.2-11.3, Retest Requirements, Revision 2
--
.
.
QA 1.2-11.4, Product Acceptance Tests, Revision 2
--
b.
Review of Installation Records Associated with Plant Modifications PDCR The inspector requested installation records associated with the below listed completed modifications to verify by detailed review of documentary evidence that the performance of inspections and tests, and the procurement and control of material and servica were conducted in accordance with the established procedures.
The completed modifications selected were:
PDCR 243, Charcoal Filter Spray Header Modification
--
PDCR 244, Alternate Power Supplies for Containment
--
Recirculation Fans PDCR 258, LPSI Piping Support Modification
--
--
PDCR 261, "B" Charging Pump Internal Modification All the records associated with each of the selected modifi-cations were not retrieved prior to the conclusion of the inspection. Also, licensee supervisory personnel were unavail-able at various times during this inspection due to medical and training requirements.
Furthermore, full implementation of ANSI N45.2.9 requirements for the collection, storage, and maintenance of Quality Assurance Records is not scheduled for completion until August 1,1979.
Although some of the records were retrieved and reviewed, the inspector stated that verification of the performance of inspections and/or tests; and, the procurement and control of materials and/or services were in conformance with established measures, could not be completed at this time. The licensee acknowledged the inspector's statement and stated that all
'
required records would be available by January 15, 1979.
Pending retrieval of all the records associated with each of the selected modifications, and review by RI, this item is unresolved (213/78-29-01).
O
Inspection Activities Associated with the Conduct of Maintenance c.
The inspector requested the following maintenance department job orders (J0) for review:
J015754, "A" HPSI Pump Mechanical Seal Replac.ement
--
J0 15765, #4 RCP Seal Replacement
--
J0 15780, Overhaul of "A" HPSI Pump
--
J0 15973, Rebuild of Boric Acid Pumps
--
The above job orders and associated repair /mainte,ance documents were reviewed to verify that the inspection program associated with repair and maintenance was beingiimplemented.
Work documents which included inspection checkoff sheets were being used in each case.
The inspector noted that the inspector signoff block on the inspection checkoff sheets associated with Job Order 15780 was signed by the person that performed the work and cosigned by a person who was not a qualified inspector.
NUSCO Audit 109 had previously identified similar problems.
Repair / maintenance documents will be reviewed during a subsequent inspection to verify the independance and qualification of assigned inspection personnel.
This is an unresolved item (213/78-29-02).
d.
ANSI N45.2.6 Certification of Connecticut Yankee (Facility Staff and NUSCO Personnel 1)
NUSCO Personnel During the review of some of the inspection records that were available, the inspector noted that NUSCO personnel were utilized as inspectors during the installation of the modifications discussed in subparagraph b above.
The inspector reviewed the documentation at the NUSCO corporate office that served as the bases for tne subject NUSCO inspectors' certification to ANSI N45.2.6.
,
No items of noncompliance were identifie )
Facility Staff The inspector requested and received a listing of those facility staff personnel who had been certified to ANSI N45.2.6. A review of the documentation that the licensee stated served as the basis of the certification (" Request for Certification" (RFC)) was conducted.
It was noted that all but one individual was certified as Level III and all but one individual had been certified as of
-
November 18, 1978.
Furthermore, the inspector observed that the RFC's did not provide sufficient detail to substantiate that the sub,1ect individual's education and experience were consistent with the requirements of ANSI N45.2.6.
The licensee acknowledged the inspector's finding and stated that the Certification Program is being developed in response to NUSCO Audit 109 and that the basis of the certifications will be reviewed again by January 15, 1979.
Pending RI review of the completed action, this item is unresolved (213/78-29-03)
5.
Records and Drawings a.
References QA 1.2-17.1 Quality Assurance Records, Revision 3
--
ADM 1.1-53, Drawing Changes and New Submittals, Revision
--
b.
Record Storage and Retention The inspector selected the following records for review to determine the licensee's capability to store, control and retrieve records.
Surveillance Procedure SUR 5.1-23 - Routine Biweekly
--
Control Rod Motion Test (January 1977 thru February 1977)
Surveillance Procedure SUR 5.2-2 - Pressurizer Level
--
Calibration, Each Refueling (October 1977 thru November 1977)
Plant Status Report - Pressurizer Level, Each Shift
--
(January 1970)
'
.
Plant Status Log - Reactor Coolant Tenperature, Each
--
Shift (January 1970)
Surveillance Procedure CHM 73.4 - Reactor Coolant Boron
--
Concentration, 5 Days / Week (October 1977)
Routine Procedure 11.51M1 - HP SI, LP SI, and RHR Pump
--
Test Run on Recirculation and Containment Recirculation System Test, Monthly (October 1973 thru February 1974)
-
Shift Operating Log - Boric Acid Pt.mps Test Run, Monthly
--
(October 1977 thru December 1977)
Surveillance Procedure SUR 5.1-17, Monthly Diesel Start
--
and Two Hour Power Run and Associated Shift Operating Logs (November 1975 thru September 1976)
The inspectors also requested the records listed below at various times during this inspection and verified that they were retrievable and maintained as required.
Audit Reports Listed in Paragraph 7
--
Procurement Records Listed in Paragraph 6
--
Modification Packages and Related Records Listed in
--
Paragraph 4 No items of noncompliance were identified. However, there was difficulty in retrieving records associated with procure-ment and modification packages.
These difficulties and the resulting unresolved items are detailed in Paragraphs 4 and 6.
c.
The Records Storage Vault The Haddam Neck Nuclear Power Facility has a comitment date of August 1,1979 to be in full compliance with ANSI N45.2.9, Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants. A part of this system will be a vault for the on site storage of nonduplicate records.
The inspector conducted a tour of the site nuclear records facility vault.
The vault appeared complete and the inspector observed that nonduplicate records were being stored therei During the tour of the vault the inspector noted that the meter for monitoring humidity was below the posted lower limit. The inspector notified the Records Manager and was informed that no corrective action measures were identified for this condition.
The licensee stated that this problem would be examined and that a plan for corrective action for Hi/ Low humidity and temperature would be developed prior to August 1, 1979.
The inspector had no further questions.
d.
Drawing Control The inspector selected ten drawings and made the following comparisons to verify that orawings were being maintained in a controlled manner.
The computer index was compared against the original tracings.
The computer index was also compared to the backup index, the aperture card decks maintained by the Nuclear Plant Records Facility, engineering, and operations control room, and the blueprints maintained by the Maintenance Supervisor, the I&C Supervisor and the Nuclear Plant Records Facility (NPRF).
The inspector noted that a single controlled copy of drawings is maintained at the si,te, in the NPRF, which is in accordance with the applicable procedures.
All other drawings are distributed in accordance with a plant superintendent memo and are designated information only.
No items of noncompliance were noted; however, one unresolved item was identified and is discussed below.
The inspector noted the following with respect to drawing control: a copy of blueprints was being maintained in a controlled manner in the NPRF but was not annotated as controlled; drawings / aperture cards were not being distributed in accordance with the procedure and the plant superintendent's memo in that the control room had blueprints in lieu of an aperature card deck; a large number of blueprints and aperture cards were identified which were not annotated as information only copies; and a number of obsolete re/isions of (information only) drawings were identified througi.qut the plan.
In response to the inspector's findings, the licensee stated that he would accomplish the following by August 1, 1979:
The set of blueprints maintained by the NPRF shall be
--
annotated to reflect that they are controlled drawings A'l copies distributed throughout the plant in accordance
--
with the distribution list shall be annotated as information only except for the controlled set maintained in the
-
NPRF
--
Each department on the site shall purge their files of all drawings with obsolete revisions and shall ensure that they have the latest revisions
--
The established distribution for information only drawings as specified in Administrative Procedure 1.1-53 and the plant superintendent's memo shall be implemented
--
Administrative Procedure 1.1-53 shall be changed to require all stations on the drawing distribution list to file new revisions when received and to destroy obsolete revisions This item is unresolved pending review of the above actions by RI subsequent to August 1, 1979 (213/78-29-04).
6.
Procurement / Material Control a.
References
--
QA 1.2-4.1, Procurement Document Control, Revision 2
--
QA 1.2-5.1, Maintenance Requests and Job Orders, Revision 5 QA 1.2-7.1, Material Receipt and Inspection, Revision
--
QA 1.2-8.1, Identification of Materials. Parts and
--
Components, Revision 2 QA 1.2-8.2, Material Issue, Revision 2
--
QA 1.2-13.2, Storage of Material and Equipment, Revision
--
QA 1.2-13.4, Packaging of Material and Equipment, Revision
--
Original
.
b.
Procurement Document Review The purchase orders (P0) listed below were selected based on a review of maintenance job orders and the materials used for those job orders.
The purchase orders were reviewed to verify that proper approvals were obtained, quality control inspection require-ments were specified, and traceability from the item through
.
_
the purchase order, receipt inspection and job order were established.
The purchase orders reviewed are listed below.
P0 228169, Spare Parts for "A" HPSI Pump
--
P0 183211, QA Welding Electrodes
--
P0 446627, Spare Parts for Boric Acid Pumps
--
--
P0 436711, Spare Parts for Reactor Coolant Pumps The inspector reviewed the inspection records documenting the receipt inspection of the selected items and confirmed that the inspections had been conducted and reported as required and the items were procured from vendors included on the licensee's list of approved suppliers.
No items of noncompliance were noted.
However, one unresolved item was identified and is discussed below.
During the course of the inspection, the procurement documen-tation and receipt inspection documentation associated with job order 15765 (Replacement of Number Four RCP Seal) could not be located. This item is unresolved pending review of the subject documentation by RI during a subsequent inspection (213/78-29-05).
c.
Storage Area Tour The inspector toured the station warehouse area and observed the following: General Storage Conditions; Conforming and Non-conforming Material Identification and Segregation; and General Housekeeping Practice The inspectors identified the following nonconformances with respect to ANSI N45.2.2 requirements.
Item CYSN 1034, QA Welding Rod; conthiner was damaged
--
(punctured)
Items CYSN 9-47, 098, 120,.... Pipes and Tubing; ends
--
were not capped, plugged, or sealed
~
Item CYSN 1359, Pacific gate valve; the valve's open
--
ends were not capped or plugged and it was being stored on a pallet with non-QA valves A filter (out of its container) was discovered on a
--
stack of like filters.,The like filters were in con-tainers and were designated QA-Category I.
This filter had no identification A damaged filter (out of its container) was discovered
--
on a stack of like filters. The like filters were in containers and were designated QA. This filter had no identification A coffee mess 'and several boxes of bottled soda were
--
discovered inside the warehouse Item CYNS 1082, a large cable reel which was not on
--
a pallet Paints, solvents, oils, and other volatiles were located
--
adjacent to QA storage areas.
These eight examples are considered to be an item of noncom-pliance at the deficiency level (213/78-29-06).
The first five items were corrected prior to the completion of the inspection.
The licensee stated that the latter three itens would be corrected by January 15, 1979.
The inspector verified the above implemented corrective action and based on the implemented and comitted corrective action this item of noncompliance does not require a respons.
Audits The inspectors reviewed the below listed audits that were performed since the last QA inspection con'ucted during August 1977.
The review verified that the audits were accomplished within the prescribed frequencies,in accordance with written checklists /proce-dures, and by trained personnel not having direct responsibilities in the areas audited.
It was also verified that the findings were documented as required, reviewed by the appropriate management, and that followup actions were initiated / completed / closed out as required. The general conduct of the audits was also determined to be in accordance with established procedures and standards.
a.
References
--
QA 1.2-18.1, Internal Audits, Revision 2 ADM 1.1-45, Controlled Routing - Comitment Follow
--
System, Revision 0 b.
Review (1) Quality Assurance Audits (NUSCO)
The following audits of plant activities by the corporate Quality Assurance Department were reviewed with respect to the criteria specified above.
--
A60015, Design Change Requests
--
A60025, Security
--
A60040, Conn Yankee QA Program A60042, Corrective Action Followup
--
--
A60051, Criterion XIV A60062, Personnel Qualifications
--
--
A60063, Criteria XII and XIII A60064, Criteria XI and XV
--
A60043, Criteria IV and VII
--
.
--
A60100, Conn Yankee QA/QC Program A60101, Drawing Changes
--
ado 105, Audits and Followup on NRC Inspections
--
A60106, Category I Evaluation Requests and Housekeeping
--
~~
A60107, Document Control
--
A60110, Packaging, Shipping, Receiving, Storage, and
--
Handling A60108, Nonconformances
--
A60109, Installation Inspections and Record Retention
--
--
A60lli, Audit Corrective Action Followup (2) Plant Quality Control Audits The following internal audits by plant QA/QC personnel were reviewed with respect to the criteria specified above.
--
A70002, Chemistry Followup of NRC Findings
--
A70003, Design Document Control, Records Retention and Administration A70004, Chemistry Followup of NRC Findings
~
--
A70005, Chemistry Re-Audit
--
--
A70006, Engineering A70007, Fire Protection
--
A70008, Engineering
--
A70009, Nuclear Record Re-Audit
--
.
A70010, Health Physics
--
A700ll, Chemistry Re-Audit (A70002)
--
A70012, Fire Protection Re-Audit (A70007)
--
A70013, Chemistry
--
-
A70014, Engineering Re-Audit (A70006)
--
A70015,EngineeringRe-Audit (A70008)
--
A70016, Health Physics Re-Audit (A70008)
--
A70017, Operations Followup of NRC Findings
--
A70018, I&C
--
A70019, Maintenance and Training Followup of NRC
--
Findings A70020, Operations Followup of NRC Findings
--
A70021, Operations Department Re-Audit (A700ld)
--
--
A70022, NRB Spring 1978 Audit Followup No items of noncompliance were identified by the inspector during the above review, however, it was noted that the licensee identified thirty-five items during the corporate audits and thirteen items during the site QA/QC audits that required followup action.
8.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.
Unresolved items identified during this inspection are discussed in paragraphs 4.b, c, and d, and.
.
9.
Exit Interview The inspectors met with licensee representatives (denoted in para-graph 1) at the conclusion of the inspection on December 15, 1978.
The scope and findings of the inspection as stated in this report were presented during this meeting and in a subsequent telephone conversation between the inspector and the QA Manager and the Plant Superintendent on December 20, 1978.
The Plant Superintendent
.
verified the target dates for the unresolved items as discussed herein.