IR 05000213/1979020

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IE Insp Repts 50-213/79-20,50-245/79-26 & 50-336/79-28 on 791127-30 & 1203-07.No Noncompliance Noted.Major Areas Inspected:Qa Program Implementation Re Qa/Qc Administration, Design Changes & Mods & Document Control Program
ML19309C667
Person / Time
Site: Haddam Neck, Millstone  File:Connecticut Yankee Atomic Power Co icon.png
Issue date: 02/07/1980
From: Baunack W, Napuda G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML19309C660 List:
References
50-213-79-20, 50-245-79-26, 50-336-79-28, NUDOCS 8004090138
Download: ML19309C667 (15)


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O u. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT

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REGION I

50-213/79-20 50-245/79-26 Report No.

50-336 /79-28 50-213~ 50-245 Docket No.

50-336 DPR-61, DPR-21 License No.

OPR-65 Priority Category C

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Licensee:

Connecticut Yankee Atomic Power Company; Northeast Nuclear Energy Company P.O. Box 270 Hartford, Connecticut 06101 Facility Name: Haddam Neck Plant and Millstone Nuclear Power Station, Units 1 & 2 Inspection At:

Haddam, Waterford and Berlin, Connecticut Inspection Conducted:

November 27-30 and December 3-7, 1979 Inspectors:

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/ # fa G./)dapuda, Reactor Inspector

/ dats W. Belke, Reactor Engineer (NRR-QAB)

date

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date Approved by:

  1. ~

O 1-7- [o

/. ii. BaunacTc Acting ief uclear Support date

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Section N 2, RO&

Br Inspection Summary:

Inspection on November 27-30 and December 3-7, 1979 (Combined Inspection Report 50-213/79-20, 50-245/79-26, 50-336/79-28)

Areas Inspected:

Routine, unannounced inspection by a regional based inspector and an NRR engineer of the Quality Assurance Program (QAP) implementation in the areas of QA/QC administration; design changes / modification program; design changes and modifications; document control program; QAP changes; and, followup on pre-viously identified items.

The inspection involved 125 inspector-hours onsite and 23 inspector-hours at the corporate offices by one NRC regional based inspector and one NRC headquarters (NRR-QAB) based engineer.

Results:

No items of noncompliance were identified.

Region I Form 12 40901%

(Rev. April 1977)

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DETAILS 1.

Persons Contacted NUSCO

  • W. Counsil, Vice President-Nuclear Engineering and Operations
  • D. Diedrick, Quality Assurance Manager
  • W. Fee, Executive Vice President-Engineering and Operations K. Gray, Supervisor-Construction QA
  • G. Johnson, Director-Reliability Engineering and Quality Assurance
  • J. Kufel, Superintendent of Nuclear Operations H. Miksztowicz, Staff Engineer-QA
  • D. Nordquist, QA Engineer

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  • G. Pitman, Electrical Design Engineer CONN YANKEE
  • R. Blewett, QA Supervisor
  • R. Graves, Station Superintendent R. Thomas, Mechanical Engineer R. Traggio, Unit Superintendent G. Tylinski, Electrical Engineer NNECO M. Bigliarelli, Nuclear Engineer
  • F. Dacimo, Quality Services Supervisor E. Mroczka, Station Services Superintendent
  • J. Opeka, Station Superintendent V. Papadopoli, Quality Control Engineer

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CROUSE CO., INC.

R. Fitch, Jr., Project Manager D. Holmes, Senior Technical Engineer P. Olsen, QA Manager Other Accompanying NRC Personnel

  • R. Zimmerman, Resident Inspector-Millstone Station (NNECO)

The inspectors also held discussions with and interviewed other members of the power stations and corporate offices administrative, engineering and technical staff.

  • Denotes those present at the exit intervie.

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2.

Followu) on Previously Identified Inspection Findings Haddam Neck (Closed) Unresolved Item (77-12-04):

Accomplishment of audits within the required time frame.

The inspector reviewed the audit schedule since the last NRC QA inspection (December 1978) to the present.

The inspector noted that the in plant audits scheduled to date have been conducted except the one this inspection interrupted.

The licensee representative stated that this audit would recommence subsequent to this inspection.

The inspector stated that he had no further questions and this item is resolved.

(Closed) Unresolved Item (77-12-10):

Written Notice of Functional Comple-tion of Design Changes.

The inspector noted that the PDCR logs are being annotated with the completion date of the modification.

The inspector also noted that followup action with respect to Audit 77-2 was satisfactorily closed.

This item is resolved.

(Closed) Unruolved Item (78-11-01):

Review corrective action as related to Audit A000154.

The inspector reviewed the stated corrective action asso-ciated with this audit.

The inspector also reviewed Audit A60117, A60122 and A60125.

The inspector determined that appropriate and timely corrective actions are being taken in the modification control area.

He stated that he had no further questions and this item is resolved.

(0 pen) Unresolved Item (78-29-01):

Complete the review of records asso-ciated with PDCR's 243, 244, 258 and 261.

The inspector reviewed the records associated with the stated modifications.

The inspector stated that he had no further questions except with respect to PDCR 258.

The records package for the subject modification did not contain the design inputs or make reference to them.

The licensee stated that the requested recoras or refer-ences to them, if appropriate, would be obtained.

Pending review of the specified records, this item remains open.

(Closed) Unresolved Item (78-29-02):

Verify that inspection personnel are independent of personnel who performed the activity.

The inspector reviewed the qualification records of selected staff engineers and foremen who had performed inspections.

The inspector did not identify any instance where an immediate supervisor or co-worker of the worker performing an activity had performed the required inspection.

The records indicated that the selected individuals were qualified to the stated level.

The inspector stated that he had no further questions and that this item is resolved.

(Closed) Unresolved Item (78-29-03):

Bases of certifications to comply with ANSI N45.2.6 requirements.

The inspector verified that Procedure 1.2-2.3, Revision 4, addresses the requirements of ANSI N45.2.6, including adequate records.

Also refer to Item 78-29-02, above.

This item is resolve.

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(Closed) Unresolved Item (78-29-04):

Verify implementation of drawing con-trol commitments.

The inspector verified that:

Procedure ADM 1.1-53, Revision 2, requires receiving departments to update their files; Nuclear Records Facility blueprints are stamped as controlled; and, memo Records Supervisor /QA Supervisor, dated March 13, 1979, states that the plant is in compliance with ADM 1.1-53.

However, an internal audit addressed draw-ing control discrepancies and Paragraph 4 discusses a new unresolved item.

This item is considered resolved for record purposes.

(Closed) Unresolved Item (78-29-05):

Review procurement and receipt inspec-tion documentation associated with Job Order 15765.

The inspector reviewed the specified records and stated that he had no further questions.

This item is resolved.

(Closed) Deficiency (78-29-06): Verify corrective action for the three uncorrected examples.

The inspector verified that the three items had been corrected.

This item is closed.

Millstone Point 1 (Closed) Unresolved Item (78-14-01):

Review corrective action associated with internal Audits A000154 and 285.

The inspector noted that approved corrective action for the subject audits was verified and the audits closed.

This item is resolved.

Millstone Point 2 (Closed) Unresolved Item (78-15-01):

Review corrective action associated with internal Audits A000154 and 285.

The inspector noted that approved corrective action for the subject audits was verified and the audits closed.

This item is resolved.

(Closed) Unresolved Item (78-26-01):

Review controls to be established for drawings having pre control revision status on computerized drawing summary index.

The inspector utilized the computerized index while reviewing the modification control activities (see Paragraph 4) and noted that this system now appears to be current in that no discrepancies were identified between the master index and the drawings selected for review.

The inspector stated that he had no further questions and this item is resolved.

(Closed) Unresolved Item (78-26-02):

Drawing Change Request Logs to reflect actual DCR status.

While reviewing the modification control activities (see Paragraph 4) the inspector noted that the logs reflect the DCR status and were accurate with respect to the drawings selected for review.

The inspec-tor stated that this area would be reviewed during a subsequent routine inspection.

This item is resolved.

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QA Program a.

References NUSCO NQA 1.01, Quality Assurance Department Organization, and Qualifi-

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cation of Personnel, Revision 1 NQA 2.09, Selection, Training, Qualification and Certification of

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NUSCO and NUPOC Inspection, Testing and Examination Personnel, Revision 2 NQA 2.10, Quality Assurance Department Orientation and Training

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Program, Revision 0 NQA 4.01, Procurement Document Review, Revision 5

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NQA 4.03, Evaluation / Periodic Re-evaluation of Engineering Con-

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tructors, NUSCO Contractors, Suppliers and Engineering Services Organizations, Revision 3 NQA 6.01, Preparation, Issuance and Control of PSAR, FSAR/FDSA

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and MSAR Quality Assurance Program Descriptions, Revision 1 NQA 18.03, Procedure to Stop Work, Revision 1

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Haddam Neck QA 1.2-2.3, Certified Inspection Personnel. Revision 4

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QA 1.2-4.1, Procurement Document Control, Revision 5

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QA 1.2-7.1, Material Receipt and Inspection, Revision 5

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QA 1.2-10.1, Installation Inspections, Revision 4

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QA 1.2-15.1, Nonconformance Reports, Revision 4

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QA 1.r-18.1, Quality Assurance Audits, Revision 5

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Millstone 1 & 2 QA 1.02, Organization and Responsibilities, Revision 7

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QA 1.04, Plant Operations Review Committee, Revision 6

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QA 1.06, Quality Assurance / Quality Control Program, Revision 3

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QA 2.01, QA Program Boundary, Revision 4

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QA 2.02, Performing Category I Work, Revision 15

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QA 2.02A, Installation Inspections, Revision 5

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QA 2.028, Retests, Revision 6

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QA 2.07, Control of Special Processes, Revision 2

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QA 4.02, Procurement Control and Identification of Material,

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Revision 10 QA 4.05, Product Acceptance, Inspection and Testing, Revision 3

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QA 4.07, Control of Weld Material, Revision 7

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QA 5.01, Nonconforming Material and Parts, Revision 4

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QA 8.16, Training, Certification and Identification of Qualified

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Inspection, Examination and Testing Personnel, Revision 5 QA 8.21, Indoctrination and Training of Audit Personnel, Revision 2

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QA 9.01, Internal Inplant Audit Program, Revision 7

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QA 9.04, Control and Calibration of Test Equipment, Revision 5

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QA 9.05, Monitoring of QA Activities, Revision 6

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QA 10.04, QA Records, Revision 13

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QA 10.07, Substantial Safety Hazard Reports, Revision 2

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b.

Program Review The inspectors reviewed the changes made to the implementing quality assurance procedures subsequent to the last NRC QA inspections con-ducted during 1978.

The above and other procedures listed under

" References" in the following paragraphs were reviewed to determine if they were consistent with the NRC accepted Northeast Utilsties Quality Assurance Program Topical Report (NU-QA-1, Revision 3A).

No items of noncompliance were identified, however, one unresolved item is discussed below and a number of other unresolved itens are discussed in appropriate following paragraphs.

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c.

Contractor Evaluation The inspector noted that under the new organization the possibility exists that a given contractor /sub-contractor at the plants will be monitored by cne or more of three independent QA/QC groups (units).

Such monitoring (e.g., audits, inspection, surveillance) could be done by one of the units entirely or divided among more than one unit.

The inspector expressed concern that the disemination of quality informa-tion, other than audit results, important in assessing the performance of a contractor, is not presently addressed in any procedure.

The inspector discussed the following points with the licensee:

contractor performance information is addressed in documents

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such as nonconformance reports, surveillance reports, etc.

a system exists for the transmittal of audit results to a central

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point where such information is reviewed, assessed and appropri-ately utilized it is essential to establish full control over the flow and use

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of all information pertaining to the performance of quality affecting activities a system similar to that for audit results would be appropriate

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the procedure that addresses this subject should be one in the

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top tier of corporate procedures The licensee acknowledged the inspectors' comments and stated that they would be considered and the subject addressed in an appropriate proce-dure.

Pending the review of the licensee's actions this item is unresolved (213/79-20-01; 245/79-26-01; 336/79-28-01).

4.

Design Changes / Modifications a.

References NUSCO NQA 3.03, Inclusion of Quality Assurance Requirements in Plant

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Design Change Requests, Revision 0 Haddam Neck QA 1.2-3.1, Design Change Control, Revision 9

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QA 1.2-14.2, Equipment Control (Locking and Tagging), Revision 2

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Millstone Point 1 & 2 QA 2.06, Station Tagging and Bypass / Jumper Control, Revision 7

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QA 3.04, Design Change Control, Revision 4

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b.

Program Review The documents listed above were reviewed to determine whether adminis-trative controls for design changes / modifications have incorporated the requirements described in NU-QA-1, Revision 3A.

This review de'. ermined that administrative controls have been estab-lished which verify the following:

procedures for control of design changes / modifications have

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been developed design document control has been established

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channels of communications between the design organization and

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the individual responsible for implementation exist design change / modification packages are being converted into

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plant records methods exist for identifying and reporting those design changes /

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modifications which are within the scope of 10 CFR 50.59 procedural controls exist for temporary modifications, lifted

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leads and jumpers responsibilities have been delineated in writing to assure the

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implementation of the above The licensee is in the process of revising and rewriting the corporate manuals / procedures that control and describe design change / modification activities performed by them.

The inspector,therefore,did not review those procedures from a programatic standpoint but stated that these corporate type procedures would be reviewed during a subseouent inspec-tion.

The licensee acknowledged the inspector's statement.

No items of noncompliance were identified.

c.

Implementation Review The inspector reviewed the design change packages (DCP's) of the modi-fications listed below to verify that the following requirements have been implenented:

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10 CFR 50.59 reviews were performed and documented

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design changes / modifications were reviewed in accordance with

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the itquirements of the technical specifications and the QA Prograi design changes / modifications were accomplished in accordance with

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written orocedures acceptance testing was accomplished and deemed satisfactory

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procedures and drawings required to be changed or generated as a

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result of the design change / modification were updated or generated the design change / modification package has been transmitted to

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the records retrieval department for incorporation as a plant record Haddam Neck PDCR 257, Auxiliary Feed Pump System-Modify Electric Motor Base

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(work partly done)

PDCR 274/276,10mporary Removal of Charging Pumps P18A and P188

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from Automatic ELCS (rewiring inside Control Room Panel examined by the inspector)

PDCR 290, Reroute of Charging Pump P-18-1B 4160 Power Supply Cable

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(Accessible portions as-built configuration verified by the inspector)

PDCR 298, Pre;;"rizer Relief and Safety Valve Discharge Piping

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Modification PDCR 312, Emergency Diesel Generator Bus Potential Transformer

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Installation (work partly done)

Millstone Point 1 PDCR 1-73-78, Numerous Cable Splices and Cable Replacement

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PDCR 1-4-79, Safety Relief Valve Discharge Piping Modification

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(work done, DCP still in process)

PDCR 1-37-79, Removal of Recirculation Pump) Suction Valves f

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LPCI Logic (work done, DCP still in process l

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Millstone Point 2 PDCR 2-7-78, Expansion Loop for Charging Pump Discharge Header

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(work done, OCP still in process)

PDCR 2-9-79, Vital ac Power Cable Installation between Vital ac

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Panels C03R and C04R (work done, DCP still in process)

During discussions with the licensee the inspector stated that in a number of DCP's both the " Safety Evaluation" and the " Technical Evalua-tion" (licensee titles on the PDCR) are needed to satisfy ANSI N45.2.11 and 10 CFR 50.59 safety evaluation and review requirements, while in other instances the " Safety Evaluation"could stand alone and the " Tech-nical Evaluation" was indeed an evaluation of technical aspects of the modi ficeti on.

The inspector further stated that this practice could lead to potential problems.

The licensee acknowledged the inspector's statement.

No items of noncompliance were identified.

5.

Document control /Drawinas a.

References NUSCO NQA 2.01, Preparation, Issuance and Control of NUSCO Quality

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Assurance Procedures, Revision 4 Haddam Neck QA 1.2-6.2, Master Document Index, Revision 4

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Millstone Point 1 & 2 QA 3.03, Document Control, Revision 9

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b.

Program Review The documents referenced above were reviewed to verify that adminis-trative controls for document and records managemant have incorporated the requirements described in NU-QA-1, Revision 3A.

The inspector stated that he did not complete the program review in this area and it would be examined during a subsequent inspection.

The licensee acknowledged the inspector's statement.

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No items of noncompliance were identified, however, one unresolved item is discussed below.

Haddam Neck The inspector noted that there is no clear description (flow charting)

of the routing of procurement documents to NUSCO for necessary approval.

The licensee stated that a procedure will be written or QA 1.2-4.1 revised to clearly reflect the routing.

Pending review of the licens-ee's actions during a subsequent inspection this item is unresolved (213/79-20-04).

c.

Documents The inspector compared 12 randomly selected procedures from Controlled Copy No. 2 with those in the Master Copy, at the Millstone Point Sta-tion.

The inspector also compared 35 randomly selected procedures at the Haddam Neck Control Room and Library with the Master Index.

No items of noncompliance were identified, however, one unresolved item is discussed below.

Haddam Neck There were three instances where Control Room and Library procedures were of a later revision than shown in the Master Index.

Internal Audit A7063 had previously identified that the Master Index was not up to date vs. the Control Room and Library.

This item is unresolved pending review of the licensee's corrective action associated with Audit A7063 (213/79-20-05).

d.

Drawings The inspector selected drawings from the master drawing and revision listing (computer system) and selected certain drawings associated with modifications (Paragraph 4) to determine that established con-trols were being implemented.

The selected drawings and aperture cards, as applicable, were examined at the Control Rooms and Nuclear Plant Records Facilities to specifically verify that:

Drawings were maintained in accordance with governing procedures.

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New and obsolete drawings and drawing changes were controlled.

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"As-built" conditions were incorporated (selected sample).

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Current drawings were distributed as required.

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Drawings were legible.

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t The selected drawings are listed below.

Haddam Neck 16103-22200-10005A, Sheet 1, Revision 3

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16103-22200-10005B, Sheet 2, Revision 3

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16103-22200-10005C, Sheet 3, Revision 3

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16103-22200-10006A, Sheet 1, Revision 3

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16103-22200-10006B, Sheet 2, Revision 3

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16103-22200-10007A, Sheet 1, Revision 2

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16103-22200-100010, Revision 2

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16103-22200-1000158, Revision 3

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16103-22200-100016A, Revision 3

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l 16103-26010, Revision 9

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16103-29142, Revision 2

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16103-54012, Revision 1

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16103-59001, Sheet 2, Revision 2

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16103-59001, Sheet 3, Revision 2

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Millstone Point 1 25202-20019, Revision 12

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25202-29208, Revision 6

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25202-29212, Revision 5

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25202-29216, Revision 7

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25202-31001, Sheet 488, Revision 7

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25202-29133, Sheet 11, Revision 8

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25202-29133, Sheet 10, Revision 8

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25202-29127, Sheet 180, Revision 6

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Millstone Point 2 25203-22000, Sheet 1, Revision 0

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25203-30022, Sheet 10, Revision 8

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25203-30022, Sheet 11, Revision 7

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25203-30022, Sheet 12, Revision 6

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25203-30022, Sheet 13, Revision 7

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25203-31069, Sheet 4, Revision 0

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25203-31069, Sheet 5, Revision 0

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25203-31070, Sheet 3, Revision 0

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25203-31070, Sheet 4, Revision 0

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No items of noncompliance were identified, however, two unresolved items are discussed below.

Haddam Neck (1) The inspector did not identify any instance where the drawings in the Control Room that were being used to operate the plant on a day-to-day basis showed other than as-built conditions.

How-ever, a number of other drawings were outdated.

Internal Audit A60122 previously identified a problem in depicting design changes on drawings and this was followed up in Audit A60125.

Resolution is targeted for January 31, 1980.

Pending review of the completed corrective action associated with drawings, this item is unresolved (213/79-20-06).

(2)

IE Inspection Report 213/78-29, Paragraph 5.c, had previously discussed a humidity problem with respect to the records storage vault.

At that time the inspector had no further questions.

During this inspection the inspector noted that internal Audit

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A60122 identified a humidity problem with the vault.

The inspec-tor asked the licensee what were the anticipated actions to i

resolve the humidity problem.

The licensee stated that a study had been conducted and the contractor is to submit recommenda-tions for interim humidity control until a vault is incorporated into the proposed new administrative building.

The licensee stated that in the meantime close surveillance is being performed on the vault humidity.

Pending review of the licensee's action with respect to Audit A60122 and this subject, this item is unresolved (213/79-20-07).

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6.

LA/QCAdministration a.

The inspectors reviewed the documents referenced in other paragraphs of this report to verify that:

The scope and applicablity of the QA Program was defined, includ-

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ing consumables utilized in safety systems.

Appropriate controls were established to prepare, review and

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approve QA Program procedures, including changes thereto.

A mechanism was established to review and evaluate the QA

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Program.

No items of noncompliance were identified, however, two unresolved items are discussed below.

(1) Millstone Point 1 & 2 A reorganization has just been effected at the station and Proce-dure QA-1.02 has not yet been revised to reflect this change.

Pending review of this procedure to verify that authority, res-pcnsibilities and organization have been defined, this item is unresolved (245/79-26-04; 336/79-28-04).

(2) All Plants NU-QA-1-3A, Sections 10.2.4.c, 11.2.1 and 15.2.4 require that reworked, repaired and other such items be inspected and tested in accordance with original requirements.

The inspectors could not identify any implementing procedures at Millstone 1 & 2 that specifically address these requirements.

Haddam Neck Procedures 1.10, 1.11 and 1.15, which were awaiting PORC review, were immediately revised to address the subject.

Pending review of the appropriate procedures at Millstone Point, which are to be revised to address the subject and the approved specified pro-cedures at Haddam Neck, this item is unresolved (213/79-20-02; 245/79-26-02; 336/79-28-02).

b.

NUSCO A recent reorganization has established a number of new groups (units)

that will monitor quality affecting activities during "Backfit and Betterment" projects.

The authority, duties and responsibilities of these units have been addressed in " Jurisdiction Statements" (JS-192 and JSc-367) but as yet have not been incorporated into controlled procedure _

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Pending review of the appropriate procedures that delineate the autho-rity, duties and responsibilities of the Construction Quality Assurance Unit and the Quality Control Unit and their interface with plant quality units, this item is unresolved (213/79-20-03; 245/79-26-03; 336/79-28-03).

7.

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 dis-cussed in Paragraphs 3, 5 and 6.

8.

Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

at the conclusion of the inspection on December 7, 1979.

The scope and findings as stated in this report were presented.