IR 05000220/1987022

Insp Rept 50-220/87-22 on 871019-23.No Violations Noted. Major Areas Inspected:Design Change/Mods,Maint & Previously Identified Items

ML20237C114
Person / Time
Site:	Nine Mile Point
Issue date:	12/09/1987
From:	Blumberg N, Napuda G, Oliveira W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20237C112	List: IR 05000220/1987022 ML20237C109
References
50-220-87-22, NUDOCS 8712210040
Download: ML20237C114 (13)

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I U.S. NUCLEAR REGULATORY COMMISSION l REGION I Report N /87-22 Docket N License N DPR-63 Licensee: Niagara Mohawk Power Corporation 301 Plainfield Road Syracuse, New York 13212 Facility Name: Nine Mile Point Unit 1 Inspection At: Scriba, New York Inspection Conducted: October 19-23, 1987 Inspectors: /

~G.jf4apuda, Senior Reactor Engineer

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Mi U W. Oliveira, Reactor Engineer date Approved by: i{ . 4 2 ~~

/%/ '7 N. 81umbWg', Chief / / date '

Operational Programs Section, 08, DRS Inspection Summary: Routine, unannounced inspection on October 19-23, 1987 (Inspection Report No. 50-220/87-22).

Areas Inspected: Design Change / Modifications, Maintenance and previously identified item Results: No violations were identifie k k

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DETAILS Persons Contacted

• S. Agarwal, Lead Site Licensing Engineer

• C. Beckham, Manager Quality Assurance (QA) Operations

• M. Boyle, Lead NC&U Technician

• C. Cary, I&C Training Supervisor

• W. Conally, QA Program Manager

• K. Dahlberg, Site Superintendent Maintenance

• Drews, Technical Superintendent

• P. Eddy, Site Representative (Public Safety Commission)

C. Fischer, Electrical Maintenance Supervisor W. James, Supervisor I&C

• Larizza, Unit 2 Site Representative

• L. Logoein, Site I&C Superintendent R. Longo, Mechanical Maintenance Supervisor T. Lucas, Assistant Planning Coordinator

• D. Lundeen, Modification Coordinator

• T. Perkins, General Superintendent

• Pilce, Unit 2 Engineering

• T. Roman, Station Superintendent C. Stuart, Superintendent Chemistry and Radiation Management

• L. Wolf, Licensing Engineer K. Yackel, Assistant Supervisor I&C

• K. Zo111tsch, Superintendent Nuclear Training U.S. Nuclear Regulatory Commission

• Schmidt, Resident Inspector Discussions and interviews were held with other licensee administrative, engineering, maintenance, operations, QA and technical support personnel, supervision and managemen * Denotes those who attended the October 23, 1937 exit meetin . Previously Identified Items (Closed) Unresolved Item 220-84-26-01: . Verify Purchase Orders /Requisi-tions of replacement parts are independently reviewed. Procedure AP-7.0,

" Control of Material and Services," Revision 2, was reviewed. Para-graphs 4.8. and 4.9 now require all requisitions to be prepared by Engineering Department personnel and reviewed by Quality Department i personnel. Paragraph 6.0 elaborates on the engineering review proces ' Based on the above and the findings pertaining to procurement discussed l in paragraph 3.2 of this report, this item is resolve ;

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(Closed) Unresolved Item 220/84-26-02: Review implementation of shelf life and preventive maintenance programs for stored items. The computer based Material Management System (MMS) has been fully implemented and a review of the data base indicated that shelf life provisions and preventive maintenance as appropriate have been included in the program control The warehouse was toured and several non-metallic items were selected and the data base was then checked to verify their inclusion in shelf life con-trol It was noted that the acceptance tags on such items were annotated as to shelf life expiration dates. Those items requiring preventive maintenance during storage had been identified and transported to the Unit 2 warehouse which was recently transferred to the licensee's contro The licensee engineering personnel are reviewing the preventive maintenance requirements for stored items previously under the control of the architect engineer (A/E) for Unit 2 and combining all schedules into the MM It was verified that the MMS data base does include preventive main-tenance schedules. Based on the above this item is resolve (Closed) Unresolved Item 220-84-26-03: Verify elimination of water leak-age problem in the onsite warehouse. Modification Package 85-43, " Instal-lation of a Perimeter Drainage System for Administrative Building Addition" was reviewed by the inspector. The development, review, installation and acceptance of engineering services and onsite work was conducted in ac-cordance with established controls based on a review of the package and discussions with licensee personnel. The warehouse was toured and parti-cular attention was directed to the area that had the leakage problem. No evidence of recent leakage or dampness was observed and all items stored in and about the area were free of dampness or wetness. Based on the above this item is resolve (Closed) Unresolved Item 220/85-07-01: Post-maintenance testing (PMT)

procedures for safety-related systems and components not covered by Technical Specifications have not been develope The inspector verified that Administrative Procedure (AP)-5.0 does contains the requirements that PMT be performed after corrective maintenance on safety-related components. The inspector also verified during the review of work requests (WRs) that PMT is performed and documente Based on the above, this item is resolve (Closed) Unresolved Item 220/86-07-01: Design and modification verifica-tion process weaknesses were identifie Nuclear Engineering and Licens-ing Procedure (NEL)-027, Design Verification, Revision 2, is now explicit on who and how the design verification is accomplished and documente It also assigns the responsibility in the process for decision making as to the need for design verificatio Nuclear Department Procedures (ND)-100,

" Plant Modifications," Revision 2 and ND-220, " Plant Configuration Verifi-cation," Revision 0 also address particulars in this area. Based on the above and the results of the review discussed in paragraph 3.2 of this report, this item is resolve . _ - _ _ _ _ _ .____- ___ _

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(Closed) Unresolved Item 220/86-07-02: Deficiencies were noted in Procedure AP-6.0, Procedure for Modification and Addition. The procedure (Revision 4) now delineates the responsibilities, steps and tasks in the overall modification process. Based on the above and the results of the review discussed in paragraph 3.2 of this report, this item is resolve (Closed) Unresolved Item 220/86-07-14: QA surveillance of onsite contractors is not sufficiently effective with respect to corrective actions. Quality Assurance Department Procedure (QAP) 10.3, " Quality Assurance Department Surveillance Activity," Revision 3, paragraph now requires that a Corrective Action Request (CAR) or Nonconformance Report (NCR) be written and issued immediately when an identified devia-tion or deficiency is associated with a contractor performing onsite modification wor Based on the above, this item is resolve (Closed) Unresolved Item 220/86-24-01: Maintenance procedures are not being fol? owed. Management met with supervision to describe the what, why and how to manage their positions, the importance of following the pro-cedures, and observing their personnel at the work site. Management revised the Maintenance Instructions (S-MI-GEN-002) for writing procedures and provides continuing training regarding the development, use and changes to maintenance procedure The inspector reviewed S-MI-GEN-002 and observed supervision following up on a jo Based on the above, this item is resolve . Design Changes and Modifications 3.1 Overview of Design Modification Control Weaknesses in the design change / modification process have been previously identified by the NRC and are discussed in the Systematic Assessment of Licensee Performance (SALP) Report 50-220/85-98 and Inspection Report 50-220/86-07. The objective of this portion of the inspection was to assess the improvements / enhancements to the licensee modification control process including activities completed to date in preparation for the 1988 refueling outag Selected administrative, engineering, procurement, licensing and quality assurance procedures (Documents reviewed are identified in Attachment I to this report) which establish the requirements for performance of design change / modification activities were reviewed to determine whether previously identified unsatisfactory areas were adequately addressed, particularity the areas listed belo * Safety evaluations

Design interfaces

• Design inputs

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• Design verification

Site committee review of proposed modifications

Control of onsite contractors  !

• Installation plans

• Inspection plans a QA/QC interfaces and quality verification

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3.2 Modification Process implementation

To assess the effectiveness of implementation of the revised modification process four modifications (listed in Attachment I),

that are scheduled to be installed prior to and during the upcoming outage, were selected for review. All the modifications had been turned over to the station for final reviews and implementation when purchased items arrived at the site and or the outage started. Pro-curement was essentially complete only for the Reactor Building Closed Loop Cooling modification where the new heat exchangers were in the fabrication proces The modification process is divided into three major design phases namely the conceptual, preliminary and final design. The onsite committee must review the final design package and'normally reviews the output of the first two phase Committee reviews were conducted on all three phases of the modifications sampled. The four modifi-cations turned over to the station contained all required outputs including the followin j

• Detailed description of the proposed modification

Functional and system specifications

• Installation procedures, quality assurance requirements and j testing i

• Comprehensive safety evaluations  !

• Onsite safety committee reviews )

• Various technical reviews such as Equipment Qualification, Fire i Protection / prevention and As Low As Reasonably Achievable (ALARA)

exposure to radiation

• Identification of design inputs and criteria

• Design verifications

Drawing, instructions and procedures affected j

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Notable features of the enhanced modification process are (1) ]

acceptance of the completed modification only after critical drawings j that depicted the as-installed configuration were actually in the 1 Control Room, (2) those critical drawings are distributed to the Technical Support Center and Emergenr.y Offsite Facility within 72 )

hours of acceptance of the modification for operability, (3) engineer- l ing personnel have verified as-installed conditions by walkdowns, (4)

specific identification of design verifications were conducted and I (5) there was increased involvement and overview by QA/QC. An i example of increased QA/QC monitoring were the several QA visits to

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the facilities of the vendors who p ovided engineering services and {

fabrication of heat exchangers. It was noted that installation '

procedures had inspection hold points inserted at appropriate intervals and all executed purchase orders had been reviewcf by quality assurance personne .3 Conclusions and Findings The design modification process contained detailed instructions and procedures for the control of various aspects of the proces Especially noteworthy was the delineation of responsibilities and explicit description of the process in applicable procedure Discussions with cognizant engineers and other technical support personnel indicated them to be knowledgeable of their responsibili-ties and the particular modifications that were sampled for revie Quality assurance personnel were aware of activities associated with the modifications that were' ongoing and the status of the rest. The monitoring of vendors was at a higher level than had been done pre-viously and identified deficiencies were aggressively pursued to resolutio Safety evaluations were comprehensive as were the other technical reviews contained in the modification output packages. . The process now appears to provide adequate information and time for meaningful review and planning by quality assurance personne The licensee was informed that further review of the modification process wo.uld be conducted during future stages of activities such as installation and testin It was determined that the licensee has improved the design modi-fication process and implementation of requirements was effective with respect to the current status of activitie No violations were identifie . Maintenance Program 4.1 Maintenance Organization The Site Maintenance Superintendent Nuclear is responsible for the Maintenance Program for the Nine Mile Nuclear Site (Units 1 and 2).

The Technical Superintendent Nuclear is responsible for the Instru-ment and Control (I&C) Maintenance Program, the tracking of Work Requests (WRs) by use of the Work Tracking System (WTS), and the Preventive Maintenance Activities (PMAs) for Units 1 and _ _ _ _ _ - _ -

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4.2 Scope and Criteria Administrative controls were reviewed to evaluate the licensee's program for implementing the requirements associated with preventive and corrective maintenance which includes instrument and control (I&C)

activitie The objectives were to ensure that the licensee's n.ain-tenance program conformed to the following requirement + 10 CFR, Appendix B

+ Technical Specifications

Regulatory Guide 1.33, Quality Assurance Program (Operation)

+ ANSI N18-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants 4.3 Program Review / Implementation The maintenance program was reviewed to determine: (1) whether the program was being implemented in accordance with regulatory require-ments; and (2) the ability of the maintenance staff to conduct an effective maintenance program. The determining factors included the NRC inspector witnessing maintenance and support activities, and discussing these activities with the maintenance and support craft as well as with management and supervisory personnel. The inspector also selected four completed maintenance activities to review and discuss with the cognizant maintenance personnel. The maintenance activities and the documentation reviewed are listed in Attachment Interviews were held with maintenance and I&C personnel to determine that their qualifications, experience and training were commensurate with their responsibilities and duties in performing the maintenance activities as required in the documented corrective and preventive maintenance (PM) program The principal procedure for corrective maintenance is Administrative Procedure (AP) 5.0. and the principal document is the work request (WR) form. The Work Tracking System is a computerized system that parallels the WR and may later take the place of the WR when sufficient experience is accumulated. The  !

principal procedure for PM is AP-8.1 and the principal documents are the PM activity (PMA) and the PM Work Request (PMWR) form These procedures and documents describe the controls used to identify, schedule, track and document maintenance activitie In the case of training for mechanics and the electrical maintenance personnel, the inspector reviewed the proposed 1988 Training Schedule and some of the Training Modification Recommendations (TMRs). The schedule included all the requests for training that were submitted by the mechanics and electricians, e.g. computer school for mechanics,

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Valvetek valve training by factory representatives, and Ingersoll Rand Air Compressor training. A TMR was written for NRC Information Notice 87-48 regarding concerns in using anaerobic adhesive / sealant Another TMR requested that Cutting, Welding and Grinding Permit ]

procedure be included in the monthly Safety Meetings. The 3-5 hour j monthly safety meetings now include a detail review of one procedure per month. The training instructor has met with maintenance personnel and they reviewed the lesson plans for their future training commitment The inspector selected test equipment used in the maintenance activities and discussed the calibration history of each test equip-ment with the equipment technician. The test equipment records were found to be complete, current, accessible and stored in accordance with AP-8.4. The usage log that is attached to each piece of test equipment has been revised to better record the usage data. The equipment technician showed the inspector calibrated two channel Gould Chart Recorders. During the discussion, the inspector observed a technician fill out a request for and being issued a piece of calibrated test equipmen The results of the maintenance program review and witnessing of maintenance activities included verification that:

• Required administrative approvals were obtained for each maintenance activit * Approved procedures, instructions, vendor manuals and technical data were used and properly recorded and signe *

Hold points and PMT were appropriately completed and documented for each maintenance activit * Acceptance criteria were identified and me *

Qualified test equipment and tools were identifie *

Appropriate reviews were completed as require * Maintenance history (records) were current, completed, accessible and stored properl In conclusion, the maintenance program is documented and effectively j implemented in accordance with regulatory requirements. No violations or deviations were identifie !

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4.4 Witnessing of Maintenance Activities 4. Repair of High Pressure Heads on Instrument and Air Compressor No. 1 The inspector observed the removal of the high pressure heads from the instrument air compressor. The work was done in accordance with procedure N1-MMP-3 A vendor manual was to be used for the inspection, repair ar d the reinstallation of the new or rebuilt heads. The chief mechanic, the QA auditor and QC inspector questioned whether they had a controlled copy of the vendor manua The supervisor was summoned and he stopped the work until the problem was resolved. QA immediately conducted a surveillance which included a purge of all the vendor manuals in the maintenance tool crib. The vendor manual was determined to be an uncontrolled document stamped for

" Plant Use Only" and to be used on nonsafety-related equip-ment such as the house servica air compressor which is identical to the instrument air compressor. The manual was surveyed by radiation protection personnel, removed and destroyed since it was the only uncontrolled document in the maintenance tool crib. The QA surveillance report (N MM-SR87.20196) that was generated also recommended removal and destruction of the manual. The QA surveillance report also recommended the preparation of a directive to maintenance supervisors and follow up training regarding control of vendor manual . Repair of the Alarm Potentiometer Monitor A p

A WR was being prepared to repair a broken wire in the monitor that was undergoing a quarterly functional calibra-tion in accordance with N1-ISP-Q-PM-8. The inspector observed the repair being made followed by completion of functional calibration of the monitor. The trainee that was assisting the I&C technicians in the repair and functional calibration of the monitor was a former radwaste operator that had transferred into the I&C Department three months ago. The inspector interviewed the trainee regarding the training he had received since the transfe The trainee said that he had attended a blue print reading class and was given an on-the-job training (0JT) qualification manual. The trainee was familiar with the OJT manual concept as a radwaste operator. The inspector discussed the trainee's training with the Unit 1 I&C supervisor and later with the I&C instructor at the Training Center. A formal training program is being developed for the traine In the interim, the first line supervisor will continue to

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assign the trainee to technicians performing work related to the trainee's OJT qualifications and progression to the next promotion. The Unit 1 I&C supervisor was later ob-served by the inspector discussing the training with the trainee to be sure there were not any misunderstandings by the trainee regarding the training he has received and is expected to receive. The inspector was satisfied that the trainee will receive the proper trainin The qualified personnel were well trained and knowledgeable of procedural and technical requirements. Supervisory awareness and involvement was eviden No violations or deviations were identified during the conduct of the above maintenance activitie .5 QA/QC Interface with the Maintenance Program The inspector reviewed QA audit reports NM-RG-IN-86021 and 87006, and SRAB Audit A-1985 that addressed the Maintenance Program. The QA report s were comprehensive and corrective actions were taken in a timely manner. During the review of WRs, the inspector requested evidence that a certain contractor was on the Qualified Contractor List. The inspector was provided a letter from the QA Department, dated September 12, 1984, approving the contractor to perform the modification work. The inspector also reviewed ten surveillance reports (SRs) and found the reports were thorough, complete, and the

. recommendations for corrective actions were followed by recipients of the SR The QA and QC personnel were observed performing surveillance and inspections were knowledgeable of the procedural and technical requirements. It was the quick action by the QA engineer that resulted in the separate surveillance of the maintenance tool crib during his surveillance of the Instrument Air Compressor No. 11 work discussed in paragraph 4. No violations or deviations were identifie . Management Meetings Licensee management was informed of the scope and purpose of the inspection at the entrance meeting conduc.ted October 19, 1987. The findings of the inspection were discussed periodically with licensee representatives during the inspection. An exit meeting was conducted on

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October 23, 1987 at the conclusion of the inspection (see paragraph I for attendees) at which time licensee management was informed of inspection result At no time during this inspection was written material provided to the licensee. The licensee did not Indicate that proprietary information was involved within the scope of this inspectio i

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ATTACHMENT 1 Procedures Reviewed AP-6.0, Modification and Addition, Rev. 4 ND-100, Plant Modification, Rev. 2 ND-130, Design Input, Rev. 2 ND-180, Spare Parts Equivalency Evaluations, Rev. 0 ND-220, Plant Configuration Verification, Rev. 0 NEL-015, Procurement of Materials and Services, Rev. 2 NEl-027, Design Verification, Rev. 2

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NEL-028, Equipment Qualification, Rev. 0 QAP-10.3, Quality Assurance Department Surveillance Activity, Rev. 3 N1-MMP-32-207, Rev. O, Overhaul of Recirculating Pump and Discharge Valves N1-MI-GEN-008, Maintenance Instruction for Staging of Maintenance Work, Rev. O AP-8.4, Procedure for Control and Calibration of Equipment Used in Test and Inspections, Rev. 6 S-MI-GEN-002, Maintenance Instructions for Writing Procedures, Rev. 2 AP-5.0, Procedure for Repair, Rev. 9 AP-3.3.2, Control of Equipment Temporary Mods, Rev. 4 AP-8.1, Preventive Maintenance, Rev. 3 AP-8.2, Surveillance Testing and Insp. Program, Rev. 3 AP-9.0, Administration, Rev. 2 S-SUP-1, Root Cause Evaluation Program, Rev. 1 Documents Reviewed L

QA Audits NM-RG-IN-86021, NM-RG-IN-87006, SRAB Audit A-1985 and 1987 QA Surveillance Reports IST-SR-87.20009, 20027, 20047, and 20067; NM-SR87.20145; MP-SR-87.20022, 20039, 200053, 20062, 20064 and 20082 NM letter of September 12, 1984 regarding a contractor (C.P.S. Electric Ltd)

being retained on the NM QAD Qualified Contractor List Internal Memorandum of July 23, 1987, regarding Liquid Poison Pump No. 11 Troubleshoot Unit 1 Temporary Modification Log in the control room and the quarterly reviews by Superintendent of Operations in March, June and August 1987. Quarterly reviews were conducted in accordance with N1-PM-Q5, Rev. O  ;

Modification Work Request M00153, Emergency Condenser Modifications Work Requests 111350, 112123, 112591 regarding the Liquid Poison Pump No. 11 Troubleshoot Work Requests (WRs) 106061, 106063, 112499, 111858, 15961, 121783, 126034 l

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Attachment 1 1 a Activities Reviewed WR-127503, Repair Air Leak on Valve Operator (Vent-Isolation Valve 05-011)

in accordance with (iaw) procedure N1-MMP-9.5 (Rev. 0), Maintenance of' Emergency Condenser Vent Isolation Valves WR-126984, Instrument Air Compressor No.11 HP Heads Repair in accordance with. N1-MMP-34.1, Rev. O, Maintenance of Instrument Air -

Compressor Monthly Functional Calibration of Reactor Protection System (RPS) Auto trip System.in accordance with N1-ISP-M-36-081 Rev. 1, Instrument Trip Channel Test / Calibration High Reactor Pressure - Emergency Cooling / Low Reactor Pressure - Core Spray Permissive, Quarterly Functional Calibration of the Alarm Potentiometer Monitor A in

,accordance with N1-ISP-Q-PM-8, Rev. 6, Radwaste Discharge Monito Modifications Reviewed 80-72, Alternate Rod Injection 85-48, Replace Reactor Building Closed Loop Cooling Heat Exchangers 86-44, Safety Parameter Display System-Phase II 86-66, Liquid Poison Enrichment

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