IR 05000245/1990019
| ML20058E626 | |
| Person / Time | |
|---|---|
| Site: | Millstone  |
| Issue date: | 10/26/1990 |
| From: | Blumberg N, John Dixon, Drysdale P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20058E624 | List: |
| References | |
| 50-245-90-19, 50-336-90-21, 50-423-90-17, NUDOCS 9011070249 | |
| Download: ML20058E626 (11) | |
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S. NUCLEAR REGULATORY COMMISSION
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REGION I
l-Report Nos. 50-245/90-19 t
50-336/90-21
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50-423/90-17
Docket No.
50-245-
50-336 50-423
License No. -DPR-21-
-DPR-65 NPF-49
' Licensee:. Northeast Nuclear Ener'gy Company
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P. O.< Box 270
= Hartford, Connecticut- 06141-0270 Facility Name: Millstone Nuclear Power Station,-Units 1, 2, and 3
_ Inspection _At: LWaterford, Connecticut InspectionLConducted:
September 4 - September 7,~1990 Inspectors:
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-P.
rysdaleg Sr. - Reactor Engineer date
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h J. Dixon Rdactor Engineer-
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L. Approv'ed : by :
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N. Blumbercy( Chief -
date
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' Operational Programs Section
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Operations Branch, DRS Inspection Summary:
Inspection conducted on September 4-7, 1990 TReportNo.50-245/90-19,50-336/90-21and50-423/90-17)-
" Areas' Inspected: > Routine' announced inspection by-two region based inspectors
's of:the-11icensee's-QA program and its implementation in the areas of procurement; i
- receipt inspection',Estorage..and handling'of equipment and materials; quality
- verification function; and the QA audit program.
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Results:
No: violations or deviations were identified. The licensee's QA program-was'found to be established in-full-accordance_with requirements of their
. technical: specifications, FSAR, and 10 CFR Part 50, Appendix B; and consistent with regulatory and_ industry. guides and standards.
The implementation of those QA program elements reviewed in this inspection'were observed to be well
, documented and effectively administered.
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9011070249 901026 PDR ADOCK 0500024b, o
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-1.0 : Persons Contacted
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Northeast Nuclear Energy Company 1-
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1*C, Clement,= Unit Director, Unit 3
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- G. Closius, Supervisor. Plant Quality Services Millstone
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.J. Coleman,: Supervisor Procurement Inspection Services y
. F. ' Libby,; Supervisor Assessment Services-
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- D-Nordquist, Director Quality Services Department d
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' T. Sullivan,.; Supervisor Plant Quality Services Millstone-t
- W. Varney,' Manager Plant Quality Services J!
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LunitedLStates Nuclear Regulatory Commission i
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TK. 'Kolaczyk,1 Resident Inspector, Millstone Unit 3 p
- W 4Raymond; : Senior-Resident Inspector
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- Denotes those_present at;the exit meeting on September 7, 1990'
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LThsiinspector also held.' discussions' with other licensee supervisors and employees,during thelcourse'of -the inspection.
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The-purposeiof this. inspection was to ensure'that the-licensee is
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F, cimplementing?a quality assurance:(QA) program that is in conformance with j
the; Technical Specifications, ' regulatory requirements, FSAR commitments,
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.and industry; guides'andLstandards. The following five areas'were-j
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' selected to ascertain.whether the implementation of the program was'in Y
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< ne o Jconformance!
the procurement program;ithe' receipt,! storage and handling
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aofiequipment and mat'erials program;. the quality verification function;
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thelau'dit program and the implementation of:the: audit program; t
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.0itic' nsee? Action on Previously Identified Items (IP92701)
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e r3.1I L(Closed) Unresolved : Item 50-423/90-01-01
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. This item was originally identified in Report No.- 50-423/90-81, y
but"wasiof ficially.-. numbered as :an ' unresolved item in; Report No. 50-423b;
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090-01).
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. Inspection: Report 50-423/90-01 documented a lack;of coverage of j
mai ntenance.-retests iby. qua li ty. control Lpersonnel.
The Quality Services'
- Department'-(QSD)' developed a~ retest, checklist to assit,t in the-
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surveillance of retest activities and.~ set a requirement to complete at'-
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Lleast-one' retest surveillance per quarter.in response to the concern; In-g
.additionq QSD Instruction OSDI-PS-MP-2.07 was implemented on October 30, f'
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i 1989.
This o,cument ine'ludes maintenance retests in a list of routine
surveillances'u be completed during a two year cycle.
The licensee
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stated that this 'ist is reviewed eighteen months into the cycle to
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identify areas that.fere not covered during the cycle to insure that they were covered:in the_lae six months.
The inspector reviewed the last (
quarters surveillances for unit three and found that the retest checklist h
was used in each of the three surveillance reports on retests.
Due to
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the' issuance of the instruction: requiring surveillances of maintenance
retests to be completed on a regular basis, and the increase in the
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number of maintenance retests reviewed, this item is considered closed, j
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3.2' (Closed) Unresolved Item 59-423/89-15-02 I
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' Inspection Report 50-423/89-15 identified a weakness in the timeliness of
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licensee responses to-QA audit findings.
Revision four to Nuclear _
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Engineering and 0perations Procedure (NED) 3.07, " Response to Audit
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Findings,"< dated February 20, 1990, limits to one the number of
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y extensions a QSD supervisor can give for an audit response due date.
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.Any ;further extensions must now be authorized by the QSD Director or
' higher management. A comparison of the first (August 9, 1989) and last
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V, (August 416, L1990): reports -on the resolution of audit findings indicated a i
w significant_ reduction _in the number of single due date extensions granted
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_for'auditifinding.. resolution, and multiple extensions were eliminated l
. completely. 'Due to the revision of the procedure NEO 3.07 and the j
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Limpro'vement in response time, this= item is-considered closed.
"4.0- Quality Assurance Program 4.1' Quality Assurance Program Annual Review (IP35701) and Quality
Verification Function (IP35702)
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The-QSD program was reviewed (refer to Attachment-A) to determine whether d
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organizational and program changes sirce the last annual review were
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documented,- understood by personnel, and did not' change.the intent of the-j program's'.overall function.
Small changes that.were made were documented i
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'or the' documentation was foundLto be in progress. The staff was found'to
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be very stable over the past several' years. =All those interviewed were, i
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~ knowledgeable on the; plant-QSD procedures.
The total QSD inspection effort-
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'is now divided thre ways.
A set' group of areas are scheduled-for audit-
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-each year, nine areas ~ are set aside for mandatory hold point inspection l
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and all other areas are subject to random QA surveillance, i
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c The-QA Surveillance ^ methods 'were adapted recently by QSD. QSD made a-
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determinatio> that strict hold point inspections were not as effective-in
quality contrt.' as, a combination of hold point -inspections and surveillances.
'l owould be, A separat.e section within QSD is responsible for the QA _.
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l surveillance effort. ' These efforts.were found to be ef fective with the a
exception of or,a concern noted by the inspector as follows. Although one of_the main purposes of-the section was to accomplish QA surveillances,
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col. lateral duties assigned to personnel in-the section took a great deal i
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of their time. -In addition to the responsibility for plant surveillances
for three units and rad waste, the eight personne. in this section are
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responsible for tracking all plant Non-Conformance Reports (NCRs), tracking
_ surveillance deficiencies, reviewing plant procedures, completing cost
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estimates, reviewing construction documents, reviewing AWO documentation, and assisting the other Plant Quality Services (PQS) section with hold point inspections as' required. One hundred and twenty-four surveillances
.were completed between January 1 and September 9, 1990. Of these Lsurveillances, sixteen were paperwork reviews and seven were follow-up
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surveillances.
A review-of unit three w rveillances indicated that long
periods of time passed where no sur.eillances were accomplished.
For
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example, no surveillances were $ sued for Unit 3 between June 3 and August 23, 1990.
Review of a database recording all surveillances conducted and
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the outage history for all three units ' indicated that surveillances on two
- units fell loff significantly during the' third unit's outage.
The i
inspectors discussed the concern with QSD managers and supervisors that
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lengthy periods.of time elapsed when essentially no surveillances were
- being performed in the other two units not.in an outage.
Licensee
' representatives indicated that although surveillances were required by-
.l the current QA program, they were not being performed to meet any
- regulatory requirement..In addition, QA surveillances are intended to be flexible'and are only one part of a threefold program (QA surveillances',
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6, QA, audits', and QC inspections) designed to cover a multitude of site
activities. QA managers did not consider that concentrating
- surveillances_on one plant in an outage sacrificed the overall program
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since the arcas planned for surveillances would still be covered over a
- two year period.
The hold point inspection program was reviewed _with th'e program
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. supervisor and a quality ' services specialist.
All Automated Work Order -
(AW0)' packages are reviewed when written by maintenance to determine'
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whether QA coverage.is required.
A. form is added to the packages'to q
(identify.the type of QA coverage ma.intenance has. determined is needed or.
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- to_ provide:a reason for'not needing coverage. 'All packages identified'as.
D 4QA: packages:are reviewed by QA inspectors in the (PQS) section that'
s performs. hold point inspections.
The form identifying the _ type of QA'
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- coverage needed_is used as input in the review process.
Those-packages ic requiring. hold point inspection are identified, a form listing mandatory hold points -is prepared for' sign-of f, and the ' package is forwarded back to
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maintenance prior to initiating work. All ' packages identified as requiring surveillance coverage are forwarded to the PQS= surveillance section. AWO packa'ges identified as not needing QA coverage.and non-QA packages are 1ran'domly reviewed by the surveillance section.
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?The inspector's review of program procedures and a large sample of
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completed AW0s indicated the program was being effectively implemented in
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accordance with the procedures, i
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-4.2 Procurement! Program (IP38701)'and Receipt, Storage and Handling of'
' Equipment and Materials Program (IP38702)
The inspectors toured one warehouse and the licensee's new receipt
inspection spaces.
The warehouse was spacious, neat and appeared to be well organized.
The spaces for receipt inspection were in the process of being set up during the tour.
They were previously located outside of the protected area in the warehouse (the rear of the warehouse was separated by the protected area fence).
This was a
convenient for deliveries, but created a logistic problem in bringing: equipment and materials onto the site after the completion of_the_ receipt-inspection.
The old space will still be used for
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delivery, but items wil1 be moved into the protected area through a
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gate in the fence ~to the receipt inspection area.
The move wi.11 allow QA to_more effectively implement the receipt inspection
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program in that an environmentally controlled space has been constructed in:the warehouse for use during the inspections.
This area is fenced in to separate it from the remainder of.the warehouse in the protected area.
Addi_tional space'is fenced off on one side of the structure for the storage of materials. and equipment that are not in conformance or that.
have not undergone receipt inspection.
= 4.3 Audit Program'(IP40702) and Implementation of the Audit Program TTP40704)
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" The inspectors reviewed the-QA. audit program administrative documents (NE0s, QSDIs, QSDs, etc.) and audit reports to verify that this. program is: organized and implemented in.a manner which fulfills the'QA audit functions prescribed byfl0 CFR and technical specification' requirements, FSAR commitments, and industry guidos
and standards ~
The : inspectors. found. no instances :where these
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- requi.rements were absent or incomplete in the licensee's audit programs.or activities.
'i The licensee's' audit' program has been structured to meet the intent of
' ANSI' Standards 18.7-1976, and N45.2'.12-1977.
This has been made explicitly apparent by the scope of the QA audit program. defined in the QA Program Topical Report, Se_ction QAP-18.0.
Program elements defined by this document were found.to'be consistent with technical specifications and the FSAR.
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The inspectors noted that the audit program responsibilities are well defined for all. levels of. QA personnel by explicit. descriptions within the-administrative instructions.
All QA audit personnel interviewed were knowledgeable of their responsibilities and were noted'to'be exercising them effectively.
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.The audit program octivities are generally prescribed by the Vice President
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of Nuclear Engineering and Operations (VP-NEO) and the reporting of audit results are provided directly to him. The FSAR designations of QA program responsibilities are also subjected to periodic audits'and the fulfillment
of-personal responsibilities with the audit group are reviewed by aud-iting
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groups outside of QSD.
The results of these reviews are also presented '
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directly to the VP-NE0 as a measure of the effectiveness of the audit s
program.
.The audit. program is. enhanced by multiple audit organizations and i
activities. Audits are performed by the Nuclear Review Board (NRB), the (ISEG), and_by a Combined Utilities Assessment team.
The Combined
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Site Nuclear Review Board (SNRB), the Independent Safety Engineering Group Utilities Assessment is an annual audit activity which provides a mechanism j
whereby an independent and objective evaluation of each member utility's-
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Nuclear Quality Assurance program is conducted.
Each assessment is.
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' performed by a team of QA auditors from all of the member utilities and
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the results are used to appraise senior. management on the adequacy and j
effectiveness of.their QA program. The inspectors reviewed the 1989 and t
1990~ Combined Utility Assessment reports and found them to be very
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p comprehensive in-depth examinations of the QA programs. The 1990 report focused specifically on NUSCOs QA audit program. The inspectors noted the j
site ~QA'and functional management were intimately-involved-in both the audit and'its. follow-up activities and that administrative controls were in place.which allowed station management to ensure follow-up actions were y
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-completed in a timely manner.
Examination of audit reports and follow-up'
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documentation contained in tb station's " Controlled Routing" correspondence
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system indicated that station _ managers-were. actively, involved in QA audits, j
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and. actively commi.tted to-resolving audit findings.
Corrective. actions l
wereLp'ursued by. formally documenting revised requirements and requiring
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-that-results be monitored to ensure _ effectiveness. _ Inspectors reviewed i
the 1989 and 1990 Audit Plans and schedules' and determined that the scope-
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of audit ' activities'at Millstone' Station -is sufficiently large to provide t-adequate evaluations, an adequate representation of audit subject. areas, j-end that mandatory audits were planned and executed.
The inspectors j
ve.rified that.the. audits required by. technical specifications and the FSAR'
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-were planned, scheduled, and closed out'for 1989. 'Those audits. planned foi11990 have'been completed to date os planned with only one exception.
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It was noted that the audit program planning requirements provide for at
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least an annual review of facility operations required by technical specifications and license-conditions, hnd reviews every six months'of the
results of corrective actions to correct deficiencies uncovered by QA'
j surveillances, inspections, and audits.
The planning requirements also j
provide for periodic reviews of the audit program.
In 1990, this was
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accomplished by-the Combined Utilities Assessment and by a Management
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' Review of the QA Program in accordance with NE0 2,08.
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~The inspectors completed detailed reviews of recently completed s
audits as follows. '
- A23014, Millstone Unit 3, NRB Audit
- A23015, Corrective Actions t
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- A24016, 1989 MP Triennial Fire Protection
- A30170, Procurement Quality Services
- A60488, Unit 1 Operations A
- A60489, Unit 2 Operations
- A60190, Unit 3 Operations
- A60497, 1989 MP3 Outage Audit-'
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C The contents of these audits were well documented, and the results were fully reported.
Each report contained an audit plan which v
fully described the' scope of the intended audit subject and
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activity.
All audit reports appeared-to contain sufficient material to support the findings.
Follow-up actions resulting from the
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findings were identified on management commitment and tracking
F mechanismsiwithin the site functional organizations, corrective
actions were documented and scheduled, and due dates were established.
Responses'to QA' audit findings have recently been performed on a timely basis,~. with minimal ev+~1sions of due dates for. corrective actions as a result of senior manage..ient directives.
The, inspectors ~ interviewed-QSD audit managers, suoervisors and auditors
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and.found all: individuals well qualified to perform audit activities effectively..All individuals interviewed were found to be knowledgeable
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and thoroughly understood those program requirements applicable to their-
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-areas of responsibility.
Lead auditors are required to be qualified in
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accordance with ANSI ~ standard N45.2.23-1978.
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'Thel inspectors determined that.the NUSCO Audit Program and QSD audit
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activities are very effective in providing-licensee management with meaningful.and accurate assessments-of how site functional activities-designed to ensure safe, plant operations are'being
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performed.
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- 4.4. Conclusions
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The QA program at Millstone Station is well documented and found to
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p be _ implemented effectively. The QA surveillance program was one
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relatively new area that,was.re<iewed in detail. -.The only concern
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-identified was that surveillance coverage in the plant was low and
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/was significantly reduced in the rest of the station when one unit i"
- was in an outage. As no deficieacies in plant activities subjected-
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to surveillances were identiftet as a' result of this concern, it is
c, antly'not a problem, but woaldibe something to considce as the
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.sur'veillance program-is further developed.
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15.01: Management Meetings?
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' Licensee' management'was informed of. the scope.and purpose of the-inspection.'atuan.entr'ance meeting-conducted'on September 4,' 1990.
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O cThe; findings of: the inspector were periodically' discussed with E._ ' <
.'1.icensee representatives during the-course'of the' inspection. ~The
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N extt meeting-was konducted:on-September 7, 1990, at.which time the-
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attendees)(identified.in paragraph '1,0) were informed of the Ti, (inspectors findings?and of-the closure of two-opensitems.
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Latino time"did;any licensee representative indicate that the subject'
., Jareas-(orf results of thisiinspection involved proprietary -infor_ ation.
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.,7 ATTACHMENT A
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DOCUMENTS REVIEWED l
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, ENuclear. Engineering and Dperations (NED) Procedures
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- NE0 2.08, Rev. 4, " Management Review:of the Northeast Utilities Quality f
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' Assurance Program." -
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NEO 3.07J, Rev. 4, " Response'to Audit Findings."
'NI.0 6.02,.Rev; 4, " Quality Purchase Requisitions."
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Ft0.6,01,:Rev. 3, " Material,; Equipment, and Parts Lists.for In-Service Nuclear
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' Generation Facilities"~
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.-NE0'3.08, Rev.'4,~" Processing PFoposed' Revisions to the' Northeast Utilities
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Quality-Assurance Program (NUQAp) : Topical. Report."'
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. NE0 3.01,1 Rev. 5, Conduct and' Format.of Nuclear ' Review Board Audits."
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> NEO 2.19,; Rev. 3. " Independent _ Safety Engineering Group Functions and
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' Responsibilities."
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ENE0L2!18DRev. 2,T" Corrective Action Requests."
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.NE0 2;11,t Rev. 3,J" Trend Analysis:from Quality Documents."
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-NE0:2i14,1Revy 3,." Nuclear Plant' Fire J Protection. Program".
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- NE013.05, Rev 1, "Nonconformance Reports",
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~NEO.2.02, Rev.f4,E"Cha'rter for NuclearfReview Boards."'
QualitW Services: Department Instructionsc(QSDI)-
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JOSDI-PS-MP-2.07;.Rev.0,[" Administration'ofMillstoneSurveillanceActivities"
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QSDI-D-1.01,?Rev,0, " Performance of Quality Services _ Department; Internal-
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,lA0dits."-
/QSDI-D-1.03kRev.0, " Inspector Training and Technical-Staf.f Manager Training-
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Program " '
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jQual'ihy Servic'esLDepartment-(QSD) Procedures-
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- QSD-1.05 sRev :4,f" Control,of Non-Conformances."-
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-QSD-2 03t Rev 4,l' Performance,~ Reporting, and Foll'owup ofLSurvetilance
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Activities."l
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QSD-4.02, Rev 0,;"_ Performance and1 Reporting of Inspection.andL!nspection
! Surveillance ActivitiesJ"i
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(QSD-4'.05,yRev.3 U" Work. Order. Review Millstone: Station."'
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g Administrative Control Procedures T
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'l jACP-QA-2.02B,.Rev.13, " Retests.",.
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C lACP-QA-2.02C,:Rev.24, " Work Orders."
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, Q QSDLSurveillance' Reports'
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L A-268,; Mil 1 stone Storeroom Shelflife ' Program.
JA-268A, Followup to Surveillance A-268 j
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- QSD Audit
- Reports i l P
A30170(6/11-16/90), Procurement Inspection' Services and Procurement Vendor
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