IR 05000245/1986016
| ML20206U954 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 09/18/1986 |
| From: | Dev M, Eapen P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20206U927 | List: |
| References | |
| 50-245-86-16, 50-336-86-17, 50-423-86-26, NUDOCS 8610080463 | |
| Download: ML20206U954 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos. 50-245/86-16, 50-336/86-17 and 50-423/86-26 Docket Nos.53-245, 50-336 and 50-423 l
l License Nos. DPR-21
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Licensee: Northeast Nuclear Energy Company P. O. Box 270 i
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Hartford, Connecticut 06141-0270
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l Facility Name: Millstone Nuclear Power Station Units 1, 2, & 3 I
Inspection At: Waterford, Connecticut
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Inspection Conducted: July 21 - August 8, 1986
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i Inspector:
h. M. kdk 9//9/[6(,
. Dev, Reactor En'gineer
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Approved by:
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kch/afA 9//8/W
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Dr. P. K. Eapen, Chief dat'e Quality Assurance Section Inspection Summary: Routine, unannounced inspection on July 21-August 8, 1986
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I (Combined Inspection Report Nos. 50-245/86-16, 50-336/86-17 and 50-423/86-26T
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Areas Inspected: Quality Assurance Programs for Audits; Receipt, Storage and
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i Handling; Procurement Control; Plant Design Changes and Modifications.
Results: No violations were identified.
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B610080463 860929 PDR ADOCK 05000245
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i DETAILS j
1.0 Persons Contacted
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Northeast Nuclear Energy Company (NNECo)
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- R. Asafaylo, Quality Services Supervisor, NNECo
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- R. Bates, Assistant Engineering Supervisor, Millstone Unit 2, NNECo
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- G. Closius, QA/QC Supervisor, NNECo
- J. Crockett, Unit Superintendent, Millstone Unit 3, NNECo
- R. Gavensky, Procurement Engineering Specialist, NNECo
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j E. Gilbert, Millstone Unit 1, Engineering Staff, NNECo
- R. Griswold, Store Supervisor, NNEco 3'
- J. Harris, Engineering Supervisor, Millstone Unit 3, NNECo
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E. Hemmingway, Assistant Store Supervisor, NNECo
- M. Hornyak, Operation Quality Assurance Specialist, Corporate (NUSCo)
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- J. Kelley, Station Service Superintendent, NNECo
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l F. Libby, Supervisor Operation QA, NUSCo
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- D. Odland, Engineering Supervisor, Millstone Unit 1, NNECo
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- R. Palmieri, Operations Supervisor, Millstone Unit 1, NNECo
- W. Romberg, Station Superintendent, Millstone, NNECo
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- S. Scace, Unit Superintendent, Millstone Unit 2, NNEco M. Sforza, OQA Engineer, NUSCo S. Sudigala, Millstone Unit 2 Engineering Staff, NNECo j
0. Yapchanyk, Millstone Unit 1 Engineering Staff, NNECo l
United States Nuclear Regulatory Commission (NRC)
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- F. Casella, Resident Inspector, Millstone Unit 3
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- G. Grant, Resident Inspector, Millstone Units 1 and 2
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J Shedlosky, Senior Resident Inspector, Millstone Unit 3 A. Finkel, Lead Reactor Engineer, Region I
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- Denotes those present at the exit interview on August 8, 1986.
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2.0 Factitties Tour i
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The inspector toured the Millstone Unit 1 Control Room to verify the installation of Agastat Time Delay Relays in the cubicle. The inspector also toured Millstone Unit 3 Containment, Auxiliary Building, Engineered Safety Features (ESF) Building, Fuel Handling Facility, 4160 V Switchgear
Room and Control Room, and obserwd Power Operated Relief Valve repair
work, and Reactor Protection System and ESF Actuation System Testing.
3.0 Licensee's Annual Quality Assurance Program Review
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The effectiveness of the licensee's quality assurance program implementa-
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l tion was assessed by reviewing the safety-related activities in Procure-I ment; Receipt,' Storage and Handling; and Audit areas.
In addition, the j
licensee's Design change and modification activities were also reviewed.
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3.1 Design Changes and Modifications i
The inspector reviewed the licensee's administrative procedure ACP-QA-3.10, Preparation, Review and Disposition of Plant Design Change Requests (PDCRs). This procedure establishes responsibilities for implementing plant design changes by the Nuclear Plant Operating Company (NUP0C) or Northeast Utility Service Company (NUSCo) groups.
The procedure also provides instruction to develop and process PDCRs, design description, design review and verification, implementation, preoperational testing, PORC/SORC review, and training and certifi-
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cation of personnel performing related quality control activities.
All safety-related plant design changes and modifications are ana-lyzed and evaluated in accordance with the administrative procedure ACP-QA-3.08 to determine that the changes meet the requirements of 10 CFR 50.59. The procedure establishes responsibilities to conduct safety evaluations; provides instruction for performing safety evalu-ation, integrated safety evaluations, and unreviewed safety question determinations; and implements final dispositions.
If the safety evaluation concludes that the proposed design changes and modifica-tions involve unreviewed safety questions, the changes are reviewed
by the licensee's PORC, and Nuclear Review Board (NRB), and NRC approval is required prior to implementation.
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The inspector selected the following PDCRs for Millstone Units 1, 2 and 3 to verify the program implementation.
PDCR TITlf MP1-36-85 Feed System Time Delay Relay Replacement MP1-21-86 FRV Internals Replacement MP2-43-85 Replacement of Suction Pressure Switches MP2-45-85 Replacement of S/G Blowdown Stop Valves MP3-85-34 DG TKZ Relief Valve Addition and Set Point Change MP3-86-09 Isolation of 3 MSS *CTV27 A, B, C & D Test Circuits MP3-86-43 3 MSS *CTV 27 A, R, C & D current attenuators The above design changes and plant modifications woro properly im-
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plemented in accordance with station procedure ACP-QA-3.10.
The inspector also reviewed the associated Autoinated Work Orders (AW0s)
to verify QA/QC, operations and maintenance interface, and program compliance; and procurement documentation to verify the effectiveness of the licensee's procurement processes including the material 4.
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d receipt and inspection report (MRIR), material issue / release, inspec-tion plan, tagging of materials, and disposition of nonconforming materials.
The Millstone Unit 1 Plant Design Change Request 1-36-85 indicated that the proposed modification replaced the time delay portion of two GE Type CR-2820, 120 VAC relays 601-107 A and B with Class IE devices in the Feedwater Timing Circuit for valves 642A
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and 6428.
The modification was incorporated by paralleling the coils of new Agastat time delay relays designated 601-107 Al and B1 with
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existing relay coils of 601-107 A and B GE type CR-2820. The as-built schematic drawings designated these new Aga;. tat relays as 601-120 A and B, which differred from the original design change documentation such as PDCR, marked-up drawings, related test pro-cedures, Production Maintenance Management System notification and Notice of Design Change Completion. The modification package did not
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include any design change notices or related reviews to support these final changes. The inspector walked down the Millstone Unit 1 Con-trol Recm to verify physical installation of new Agastat time delay relays in the relay cubicle. There were no name tags attached to the relays and as such relay designation could not be verified. Also, the modification was incorporated through two AW0s, M1 85-08383 and M1 84-02416. A document search conducted by the Millstone Nuclear Record Facility could nct retrieve AWO M184-02416. However, a copy i
of AWO M184-02416 was available with the cognizant engineer.
This item remains unresolved pending licensee actions to (1) resolve
the discrepancy between the n -built drawing and approved PDCR and (2) determination of the causes for the discrepancy (50-245/86-16-01).
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The above PDCR packages and AWO documentation indicated that, in
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several instances, redundant information, such as duplicate or trip-
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included, whereas some pertinent information, such as procurement licate copies of P0, drawings, vendor information and PMMS were information, and the status of commitments and related procedure j
updates were left out. The loose pages of the PDCRs were not adequately organized, or filed. The licensee's PDCR documentation process dces not assure adequate pagination for the PDCR packages and identification of the PDCR attachments, prior to their transfer to the nuclear record facility (NRF).
This is an unresolved item (50-245/86-16-02, 50-336/86-17-01 and 50-423/86-26-01).
3.2 Procurement Controls The licensee has established and implemented the station administra-tive procedure ACP-QA-4.02A which delineates the program for the preparation and review of quality related purchase requisitions.
In addition, administrative procedure ACP-QA-4.06 providos for the procurement and evaluation of age-sensitive safety related shelf-life
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materials; and the evaluation and upgrade of degradable items ini-
tially procured without shelf-life provision, which are stored in the warehouse.
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Prior to thg award of a purchase order, the licensee evaluates the supplier's ability to provide materials, equipment and services in accordance with the technical, design, manufacturing and quality requirements of NUSCO Quality Assurance Branch Procedure NQA-2.04, Supplier Evaluations.
The licensee compiles and maintains an Approved Supplier Listing to identify the suppliers who were evaluated and qualified for meeting the station quality requirements.
The listing is periodically reviewed and updated by the NQA Procure-ment Section.
The licensee administrative control procedure ACP-QA-4.05 establishes the requirements for performing Product Acceptance Inspections and Tests. The qualific: tion and certification of the inspection and test personnel are conducted in accordance with procedure ACP-QA-8.16 to meet the requirement of ANSI N45.2.6 (1978)
The procedure establishes the level of j
qualification based on education, experience, training, written and
oral examination, and physical and visual ability. The certification l
remains valid for a period of 3 years provided a satisfactory annual proficiency review is documented on the individual's certification i
forms. The QC department maintains, updates and issues, each quarter, a list of all certified inspection, test and examination personnel and forwards the list to the cognizant department heads.
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The inspector reviewed the licensee's procurement process by veri-fying the procurement requests (prs) purchase orders (P0s) and
material receipt and inspection reports (MRIRs) for the automated work orders (AW0s), and the plant design change request (PDCRs)
discussed in paragraph 3.1 above.
UNIT prs P0s MR irs MP-1 J-60535 695228 185-060 t
MP-1 J-78807 (Not issued)
186-071 MP-2 E-41181 682459 185-010(*)
MP-2 E-41301 688428 688428(*)
MP-2 E-41340 841759 841759(*)
MP-2 E-49517 841954 841954(*)
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MP-2 J-47751 939112 284-246
The MRIRs designated by (*) were not readily traceable. The licensee l
representatives provided satisfactory answers and documentary evidence to establish traceability of these items. The materials procured against PR No. E-41181, though belonging to Unit 2, were receipt inspected against Unit 1 MRIR No. 185-010. They pertained to the earlier material requisition whereby the surplus materials were taken
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back in the stores by inspecting against Unit-1 MRIR.
In other instances, the materials were procured by NUSCO and transferred to
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NNECo, and thus, complied with NUSCo receipt inspection and MRIR identification requirements.
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A discussion with the site QC Supervisor indicated that the licensee has currently developed a procedure to uniformly implement the pro-curement process and receipt inspection at the Millstone Nuclear Plants. The procedure is in the stations management review cycle.
The effectiveness of the procedure will be evaluated in a future NRC inspection.
3.3 Receipt, Storage and Handling Program The inspector reviewed the licensee's administrative control procedure ACP-QA-4.04 which establishes the detailed requirements for packaging, shipping, receiving, storage and handling of safety-related materials, equipment and parts at the site Warehouse.
In addition, the licensee has implemented NUSCo Generation Construct-ion Quality Control Procedure QC-G-6.01 which defines the quality control measures for receiving and handling in accordance with NUSCo Engineering Project Documents.
The procedure also establishes responsibilities for the review of purchase requisitions, specifying quality assurance requirements including ANSI N45.2.2 assigned level of packaging and storage, verifying 10 CFR 21 compliance, shelf-life l
requirements, and the disposition of non-conforming materials. The
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Millstone Warehouse meets the Level B storage requirements for the
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materials which are sensitive to the environmental conditions.
The procedure also provides instructions for preliminary receipt inspection including visual inspection for fire, excessive exposure, environmental damage and rough handling. A detailed receipt inspection of the item is conducted to verify identification and marking in accordance with the purchase orders, drawings and standards; manufacturing documentation including test reports, certificate of compliance, and required operating procedures and instruction; electrical insulation; physical properties, dimension,
configuration and workmanship; welds; and lubricants and oils.
Each purchase order is assigned an MRIR identification number by the i
procurement QC department. The receipt inspection is documented
on the MRIR form by QC inspectors. The QC inspectors are qualifibd and certified in accordance with ANSI N45.2.6-1978.
The licensee has also developed procedure ACP-QA-4.06 to identify and upgrade shelf-life for the age-sensitive equipment and components stored in the warehouse.
Procurement of new safety-related age-sensitive items requires that the vendors specify shelf-life. The warehouse maintains a list of such items indicating the date of
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expiration and quantity on-hand. Six months prior to the expiration date procurement orders for substitutes are initiated.
The inspector walked down the Millstone Units 1 and 2 Warehouse and randomly selected certain stored items and verified the procurement process including the review of MRIRs, MIRFs and purchase orders.
The inspector noticed that sealant type RTV with an expired shelf-life was on the shelf, unsegregated without any warning to prevent inadvertent issue for use. The licensee representative indicated that all shelf-life designated items are checked for the shelf-life expiration date prior to issue. The expired shelf-life items are left in place and the cognizant group or organization is informed to initiate evaluation for their disposition.
In this particular case, the warehouse provided a purchase order to support that the sealant reorder was initiated.
In addition to the MRIRs mentioned in the previous paragraph 3.2, the inspector verified procurement documentation including the purchase orders, receipt inspection and storage of the following randomly selected items and found them to be satisfactory:
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Stock No.
MRIR Items 185-096-1 185-096 Weld Rods 185-185-2 185-185 RTV Sealant
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196-008-24 186-008 Asco Solenoid Valve 183-037-1 183-037 3-Way Solenoid Valve 283-232-2 283-232 Solenoid Valve Repair Kit Cr The inspector verified that chemicals, abrasives and inflammable
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materials were properly stored and segregated. The warehouse is in the process of reorganization to consolidate Millstone Units 1, 2 and 3 stored materials into one station warehouse, for ease of proper control, storage, access and housekeeping.
The inspector found that some materials issued against previous
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Millstone Units 1 and 2 project authorizations were held in the, Project Hold area for about two years. These were the items either returned to the warehouse as surplus after the project completion or items awaiting project restart.
Dirt and debris were found accumu-lated on these materials. The licensee's disposition of these ma-terials constitutes an unresolved item (50-245/86.16-03 and 50-336/86-17-02).
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The inspector also verified that the following Millstone Unit-3 Warehouse safety-related expired shelf-life materials were removed from the shelf and transferred to the licensee's remote warehouse for proper disposition:
Stock No.
Item 61700178 Dow Corning DC-4 Grease 57402886 Limitorque Gasket 59406605 Presray Pneuma-Seal 56200557 Pall Trinity Filter Cartridge 3.4 Audit Program The licensee procedure ACP-QA-9.01 delineates the methods and process for conducting audits as required by the Northeast Utilities Quality Assurance Topical Report. The procedure is applicable to QA program audits conducted by Northeast Nuclear Energy Company (NNECo)
and Northeast Utilities Service Company (NUSCo) jointly, o~r internal plant audits conducted by NNECo QA of quality related activities.
In addition, NUSCo Quality Assurance Branch Procedure NQA-2.06 pro-vides instruction for the conduct, reporting and followup of audits and establishes responsibilities for the conduct and implementation of the audit programs. Audit schedules are prepared by the assigned NQA Section Supervisor on a yearly basis. The QA program audits related to the nuclear plant operational phase activities are com-pleted on a two year cycle.
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The administrative control procedure ACP-QA-8.21 delineates the requirements and guidance for the qualification of personnel performing audits at Millstone Power Station and provides for the certification of qualified auditors. The auditors are required to prepare a comprehensive audit checklist to insure depth and i
continuity of audits. At least two corrective Action Audits are j
conducted each year for verification of the implementation of the J
corrective actions for previously identified deficiencies and nonconformances.
Subsequent to the conclusion of the audits, an audit report is generated and any nonconformances are documented as audit findings. The Supervisor, Quality Assurance reviews and approves audit reports. The reports are then distributed to the audited organization, Senior Vice President - NE&O, the Manager, Quality Assurance and the appropriate Division Vice President, as applicable.
The inspector reviewed the site NQA audit schedule for the year 1986-87. The schedule addresses all major QA-related activities such as design, modifications, purchase, refueling, preventive maintenance, in-service testing, inspection, storage and handling, L
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m corrective action, and fire protection for Millstone Units 1, 2 and 3.
A review of the completed audits indicated that they were adequately planned and were within the targeted schedule. The audit checklists were comprehensive and covered all applicable aspects of 10 CFR 50 Appendix B criteria, other applicable industry standards and the licensee's commitments.
The inspector reviewed the following completed audits and found them in compliance with the facility's procedural requirements:
A60424, Material Control, Millstone Units 1 & 2 A60381, Plant Design Change Request, Millstone Unit 1 A60383, Plant Design Change Request, Millstone Unit 2 A60443, Storage, Handling & Shipping The inspector also reviewed completed corrective action audit reports and closed audit report files. Although the identified audit findings were indicated as closed by the NQA audit open item list, the closed audit report file did not include QA verification documentation.
The inspector reviewed the licensee's audit open item lists and randomly selected six audits to verify the implementation of the corrective action. The on-site records indicated that the corrective actions were incomplete for five of the six audits reviewed.
Subsequent to the conclusion of this inspection, the licensee's corporate QA personnel provided adequate information to support the
implementation of the corrective action identified in the above audits. The inspector has no further questions.
4.0 Exit Meeting The inspector met with licensee representatives (denoted in paragraph 1)
at the conclusion of the inspection on August 8, 1986 to summarize the scope and findings of the inspection as described in this report.
At no time during the inspection was written material provided to the licensee by the inspector. The inspection did not involve any proprietary
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REFERENCES l
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Administrative Control Procedure (ACP) -QA-2.02C, Work Orders, Rev. 10 2.
ACP-QA-2.06A, Station Tagging, Rev. 12
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ACP-QA-3.08, Safety Evaluation, Rev. 2
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ACP-QA-3.10, Preparation, Review and Disposition of Plant Design Change Requests, Rev. 1
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ACP-QA-4.01, Plant Housekeeping, Rev. 13 6.
ACP-QA-4.02A, Preparation and Review of Quality Related Purchase Requisitions, Rev. 0 7.
ACP-QA-4.04, Instruction for Packaging, Shipping, Receiving, Storage and Handling, Rev. 9 8.
ACP-QA-4.05, Product Acceptance Inspection and Testing, Rev. 3 9.
ACP-QA-4.06, Procurement and Evaluation of Shelf-Life Materials, Rev.1 10. ACP-QA-8.07, QA Training Program, Rev. 3
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m 11. ACP-QA-8.16, Training, Certification and Identification of Qualified Inspection and Testing Personnel, Rev. 13 12. ACP-QA-8.21, Qualification of Audit Personnel, Rev. 5
13. NUSCo Quality Assurance Branch Procedure (NQA) - 1.05, Audit, Survey and Inspection Computer Program, Rev. O l
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14. NQA-2.03, Procurement Document Review, Rev. 5 15.
NQA-2.04, Supplier Evaluation, Rev. I 16.
NQA-2.13, Processing, Control, and Followup of Design Drawing
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Nonconformance and Disposition Reports, Rev. O i
17. NQA-3.01, Indoctrination and Training Program, Rev. 0 18.
NQA-3.02, Training and Qualification of NQA Branch Lead Auditors and Surveyors, Rev. 0
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19. Nuclear Engineering and Operation Procedure, NE0-3.01, Conduct and Format of Nuclear Review Board Audits, Rev. 1
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'a 20. NUSCO Generation Construction Quality Control Procedure, QC-G-6.01,
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Receiving and Handling of Materials, Equipment and Parts, Rev. 5
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21. EPRI Report No. NP-3444, Wear Measurements of Nuclear Power Plant Components, dated May 1984
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