IR 05000245/1989021
| ML20011F031 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 02/01/1990 |
| From: | Blumberg N, Finkel A NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20011F029 | List: |
| References | |
| 50-245-89-21, NUDOCS 9002230488 | |
| Download: ML20011F031 (7) | |
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U.S. NUCLEAR REGULATORY COMMISSION REGION'I~
Report No._
50-245/89-21 Docket'No.
50-245 License No. -OPR-21'
Priority Category C
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Licensee:
Northeast Nuclear Energy Company-P.O. Box 270 Hartford, Connecticut 06141-0270
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Facility.Name: Millstone Nuclear Power Station Unit 1
~ Inspection At: yaterford, Connecticut Inspection _ Conducted:
December 4-8, 1989
. Inspector:
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A. Finkel, Senior Reactor Engi er date Approved by:
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'N..Blumberg, Chief, Operatiotal Programs dats e
Section, Operations Branch,/DRS Inspection Summary:
Routine unannounced quality assurance annual review (Report No. 50-245/89-21)
~ Areas Inspect'ed: Routine unannounced inspection of the licensee activities in implementing a Quality Assurance Program that is in conformance with the tech-nical specification, regulatory requirements, commitments, and industry guide-and standards. The following areas were inspected:
Test and Experiments Program;' Receipt, Storage, 'and Handling of Equipment and Material Program; and the Audit Program. The inspection was conducted on site ty one region based inspector.
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.Results:.One violation was identified:
Failure to implement and comply with
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the requirements of 10 CFR 50 Appendix B, Criterion XIII, (Paragraph 3.3) in that, equipment designated for safety related uses including electronic equip-
' ment and piping did not have appropriate caps or covers installed to prevent p
damage or deterioration.
9002230488 9002O2
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PDR ADOCK 05000245
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Details
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--1.0 Person Contacted No_rtheast Nuclear Energy Company
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- R. Asafaylo, Quality Services Supervisor
- N. Bergol, Supervisor Unit 1 Maintenance
- J. Coleman, Supervisor - Procurement Inspection Services
- R. Griswold, Material Supervisor
- C. Libby, Supervisor Assessment Services
- S. Scace, Millstone Station Superintendent
- M.-Sforza, Senior _ Engineer
- J.-Stetz, Millstone Unit 1 Superintendent
- W. Varney, Manager Plant Quality Services United States Nuclear Regulatory Commission W. Raymond, Senior Resident Inspector D. Dempsey, Resident Inspector i
- Denotes those present at the exit interview
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The inspector also held discussions with managers, supervisors and other licensee employees during the course of the inspection, including opera-
tions, technical and administrative personnel.
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2.0_ Follow Up of Previously Identified Items (92701)
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f-(Closed) Unresolved Item 89-18-02: Untimely responses to licensee's quality assurance audit findings. The following steps have-been taken by the licensee to address the unresolved item:
. Station superintendent for the Hillstone Nuclear Power Station re-
affirmed the management position on audit findings and responses.
l(Memo dated August' 10, 1989 - MP-13383 and August 16, 1989 - MP-13410.)
Nuclear Engineering and Operations Procedure (NED 3.07) " Response to
Audit Findings" has been revised to provide stronger management over-view of the audit responses.
The revised procedure NEO 3.07 was in the review cycle during this inspec-
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tion and was not released for use.
The procedure addressed previous
concerns regarding more timely responses to quality assurance findings.
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This items is closed.
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3.0- Quality Assurance Program Annual Review (35701)-
The purpose of this inspection was to review and evaluate the licensee's implementation of its quality assurance (QA) program for handling :afety-
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related systems and components.
The inspector reviewed and evaluated the
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below listed areas of its QA program for compliance to the requirements of the QA program as described in the Final Safety Analysis Report (FSAR),
Technical Specification, applicable codes, standards, and regulatory
guides:
Quality Assurance Program
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Tests and Experiments Program
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Receipt, Storage, and Handling of Equipment and Materials Program
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Audit Program
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3.1 Quality Assurance Program (35701)
The quality assuranco program was inspected to determine if changes made to the organization since the last annual review were documented, understood by the personnel and did not change the intent of the-overall function of the quality assurance programs.
The licensee has a formal program for notifying its personnel of I
changes to the quality assurance program for operations.
The latest organization change split the Station Services Organiza-tion into two saparate service organizations (Unit Services and Site
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Services). The current schedule indicated that staffing and procedure-issuance will be completed by the third quarter of 1991. This organization change appears not to degrade the original mariagement involvement or control, but strengthens the organization by con-solidating various engineering functions under one service organization.
This change is scheduled to be submitted to the NRC during the next scheduled Quality Assurance Program revision in accordance with 10 CFR 50.54'(a)(3).
3.2 Test and Experiments Program (37703)
The purpose of this inspection was to verify that a formal method for conducting plant tests and experiments involving safety-related com-ponents, systems, structGres, or modes of operation different from those described in its FSAR are identified and controlled.
The licensee has described its test and experiments program in the Northeast Utilities Quality Assurance Program Topical Report (NVQAT),
Section 5.0, Instructions and Procedure. To support this program and implement the program the licensee (Millstone Site) has issued the following documentation:
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i Administrative Control Procedures (ACPs)
ACP-QA-3.02, " Station Procedures and Forms"
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ACP-QA-3.02A, " Writers Guide For Millstone Procedures"
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- ACP-QA-2.01,. " Quality Assurance Program Boundary"-
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ACP-QA-2.02C, " Work Orders"
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ACP-QA-10.04, " Nuclear Power Plant Records"
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The above listed ACP's and documents referenced in the procedures define test and experiments documentation that address the following criteria:
Test and Experiments are performed with written and approved
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procedures.
Responsibilities are defined for reviewing and approving the
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adequacy of the documentation issued.
Unreviewed safety questions for proposed test and experiments l
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are reviewed as required by 10CFR50.59(b).
Exceptions to the above requirements are described in the applicability paragraph 2.0 of ACP-2.020. Each exception taken has specific docu-mentation criteria describing the method and reason for deviating from a prescribed plan.
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.To assure that the test and experiments program was being conducted as described in the site documentation and its Northeast Utilities l
Quality Assurance Program Topical Report (NUQAT), the inspector selected reports from the Millstone Unit 11988 Summary Of Safety Evaluations I
listing. The inspector verified through selected reports that the
licensee complied with the requirements of 10 CFR 50.59(b) for report-ing. The inspector also verified that Nuclear Engineering and Operat-L ing Procedures NEO 4.01-4.04-described the methods that the licensee communicates various Technical Specification (TS) requirements to the
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NRC.
No violations or deviations were identified.
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3.3 Receipt, Storage and Handling of Equipment and Materials Program L
(38702).
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The scope of this inspection was to verify that administrative controls and written requirements for receipt of safety related items conform to FSAR and Technical Specification requirements.
The licensee has written both Administrative and Quality Service Department (QSD) procedures for receipt, storage and handling of equipment and materials. See Attachment A for documentation listing.
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, The inspector selected fifteen purchase orders to verify that the engineering requirements of the Nuclear Engineering Operation proce- + dure (NEO) 6.05, " Processing and Control of Purchased Material, ' Equipment, Parts, and Services," ann the Quality Services Department (QSD) 3.08, " Performance of Receipt Inspection Activities" were refer- ' - enced in the purchase order (PO) system and that-the receiving and receiving. inspection personnel were following the requirements of these documents.
The-inspector determined that the personnel were following their .i documentation requirements, but the NE0 6.05 and QSD 3.08. procedures - cid not fully implement with the guidance of Regulatory Guide 1.38.
Revision 2, May 1977, nor with the American National Standard Institute (ANSI)445.2.2-1972. ANSI-N45.2.2-1972 paragraph 6.4, " Control of Items 1,n Storage" actions were alto not performed nor~specified by the selected purchase orders reviewed. The inspector identified a ' ' large number of the P0s not requirements the storage requirements of NED 6.06, nor the guidance of. ANSI N45.2.2-1972. Also during the inspection of P0 919951, " Anchor Darling Pressure Switches;" P0 930879, " Westinghouse Boards;"'and P0 872457, " Weed Instrument Company's RTDs;" the inspection for covers, caps, plugs or other closu.e methods was not required or verified either by the receiving or receiving inspection personnel. An inspection of the equipment in the warehouse ' identified that there was not-a criterio for stacking items to assure that the integrity of the stored item would not be damaged during storage.
Safety related equipment as well as non-safety related equipment stored in the warehouse did not have covers, caps, plugs or other closure methods in place.
l The failure of the licensee's procedures to incorporate Regulatory Guide 1.38, Revision 2, May 1977 and ANSI N45.2.2-1972; and the - failure provide appropriate storage and storage procedures and to provide acceptable protection of stored items is a violation of 10 CfR 50, Appendix B, Criteria.XIII (245/89-21-01).
' 3.4 Audit Program (40702) The scope of this inspection was to verify that the audit program has-been defined and that it is consistent with the Final Safety Analysis Report (FSAR), and industry guides and standards.
The licensee's audit schedule for the 2 year cycle 1987-1989 is in . the process of being. completed. The required audits identified in the Technical Specification (TS) and the FSAR have been complied
with for the lirted time span.
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. The audit program is structured to meet the intent of ANSI N45.2.
12-1977, " Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants." Action items identified during audits are . tracked in an " Audit Survey Inspection Schedule" program.
Timely response to audit findings has been identified in inspection report 50-245/89-18 as an unresolved item (50-245/89-18-02), Procedure NE0 3.07,." Response to Audit Findirgs" has been revised to address the NRC findings identified in inspection report 89-18 and licensee audit letterofAugust9,1989(CFS-89-133).
Revised procedure NE0'3.07 is-expected to be issued late in 1989.
The audit checklist appears to be comprehensive, relevant, and con-tains significant items and criteria in the areas reviewed by the inspector..However in the area of the Receipt, Storage and Handling of Equipment and Materials the audit checklist did not include ANSI N45.2.2-1972, paragraph 6.4, " Control of Items in Storage." See Paragraph 2.3-for discussion of an apparent violation regardin0 control-of safety related storage.
I 4.0 Exit Meeting Licensee management was informed of the scope and purpose of the inspec-tion at an entrance meeting conducted on December 4, 1989.
The findings of the inspector were periodically discussed with licensee representatives during the course of the inspection. An exit was conducted i on December 8, 1989 (see paragraph 1)-at which time the findings of the ! inspector were presented.
At no. time during the inspection, did the inspector provide written materi- ) al to the licensee nor did the licensee indicate that areas covered by this inspection contained proprietary information.
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. h . -s ATTACHMENT A . Documents Reviewed ' ' Technical Specification - Millstone Unit 1
Final Safety Analysis Report - FSAR Unit 1 Regulatory Guide 1.38, Revision 2, May 1977
ANSI N45.2.2-1972 American National Standards Institute, Packing,
-Shipping, Receiving Storage and Handling of Items for Nuclear Power Plants.
Audit Memos MP-13383 and 13410
NuclearEngineeringandOperationsProcedures.(NE0's)
NE0 3.07, Response to Audit Findings- - NE0 4.01, Communications with the NRC - NE0 4.02, Proposed TS Change Requests & Emergency Waiver ' - Requests NED 4.03, Changes and Updates-to FSAR - NED 4.04, Review and Approval of Proposed Changes to Selected - License Requirements NED-6.05, Processing and Control of Purchased Material, - Equipment, Parts, and Services NVQAT, Northeast Utilities Quality Assurance Program Topical
Report Administrative Control Procedures (ACPs)
' ACP-QA-3.02, Station Procer:.res and Forms - ACP-QA-3.02A, Writers Guide for Millstone Procedures - ACP-QA-2.01, Quality Assurance Program Boundary.
- ACP-QA-2.02C, Work Orders ' - ACP-QA-10.04, Nuclear Power Plant Records - Quality Services Department Procedures (QSDs)
Q50-2,12, Performing, Reporting and Followup of Procurement - Audits !. QSD-3.08, Performance of Receipt Inspection Activities - !
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