IR 05000293/1978026
| ML19263B582 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 11/28/1978 |
| From: | Kehoe D, Kister H, Napuda G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19263B566 | List: |
| References | |
| 50-293-78-26, NUDOCS 7901220034 | |
| Download: ML19263B582 (16) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-293/78-2 6 Docket No. 50-293 License No. DPR-35 Priority Category c
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Licensee:
Boston Edison Company M/C Nuclear
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800 Boylston Street Boston, Massachusetts 02199 Facility Name:
Pilgrim Nuclear Power Station, Unit 1 Inspection at:
Plymouth and Boston, Massachusetts Inspection conducte -
tober 30-November 3, 1978 uc%
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Inspectors:
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G'. Napuda, Reacto Ilspe tor date signed
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D./ K re, eactor Inspector date signed ll~17#7 {
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ww kman R or. Inspector date signed Approved by:
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HI *Kister,'Dfief, Nucle $r Support
'date signed Section No. 2, RO&NS Branch Inspection Summary:
Inspection on October 30-November 3,1978 (Report No. 50-293/78-26)
Areas Inspected:
Routine, unannounced inspection by regional based inspectors of the Quality Assurance Program (QAP) implementation including: QAP revisions; design changes / modifications; procurement; records management; audits; previously identified items; and, a plant tour.
The inspection involved 25 inspector-hours at the corporate offices and 53 inspector-hours onsite by three regional based inspectors.
Results: Of the seven areas inspected, no items of noncompliance were identified in six areas; one apparent item of noncompliance was identified in one area.
(Deficiency - failure to forward NSRAC audit reports to appropriate management within the time frame designated in the Technical Specifications, Detail 7.b).
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790122003 '
Region I Form 12 (Rev. April 77)
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DETAILS 1.
Persons Contacted
- H. Balfour, Methods, Training and Compliance Group Leader J. Clifford, Storekeeper M. Das, Structural Engineer W. Deacon, Sr. Instrument and Control Engineer L. Fheldon, Sr. Mechanical Engineer
- J. Fulton, Sr. Plant Engineer E. Hegerich, Assistant Quality Control Engineer
- R. Kennedy, Quality Assurance Program Service Group Leader
- B. LaScala, Records Management Group Leader C. Mathis, Sr. Plant Engineer
- P. McGuire, Station Manager J. Nicholas, Staff Assistant J. Powlack, Sr. Electrical Engineer S. Rosen, Nuclear Engineering Manager R. Sevigny, Chief Maintenance Engineer J. Sullivan, Quality Control Group Supervisor R. Sylva, Maintenance Engineer R. Titcomb, Quality Assurance Audit Group Leader
- M. Yessaillian, Quality Assurance Procurement Group Leader E. Ziemianski, Sr. Operations Engineer
- denotes those present at the exit meeting.
The inspectors also interviewed other licensee employees during the course of the inspection. They included engineering, maintenance, operations, administrative, plant technical support, quality assurance and stores personnel.
2.
Previously Identified Inspection Items (Closed) Infraction (293/78-06-01):
Failure to perform audits as required by Technical Specification (T.S.) 6.5.B.8.
The licensee conducted the required audit in accordance with their letter to RI dated April 14, 1978.
However, the report was not forwarded to appropriate management within the required T.S. time frame and is discussed in Detail 7.b.
The inspector had no further questions.
This item is closed.
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(Closed) Unresolved Item (293/78-06-02):
Review of Open Items List and planned corrective a;. tion associated with NSRAC item 77-18-1 (meeting 77-10).
Memorandum QP l-517, QA Manager /NSRAC, stated that the. Quality Assurance Department (OAD) reviewed Audit 77-18 and established Items List 190-211.
NSRAC accepted QAD's actions / decisions during meeting 78-3.
The inspector reviewed the sub,iect list and noted that corrective action was at various stages of completion.
The inspector had no further questions.
This item is resolved.
(0 pen) Unresolved Item (293/78-06-04):
Review timeliness and acceptability of corrective action for QAD Action Item 151.
The inspector reviewed Audit Report 78-41. The inspector noted that this comprehensive audit indicated that the progress of the identified tasks were being accomplished at a satisfactory rate and offered a number of recommendations to enhance final resolutions. The inspector stated that this area would be reviewed further during a subsequent inspection (s).
This item remains unresolved.
(0 pen) Deficiency (293/78-06-05):
Document Control Center for storage of nonduplicate reccnis did not meet facility requirements of ANSI N45.2.9. The inspectors toured the Records Vault presently under construction and approximately 80% complete.
The licensee revised the previously estimated corrective action completion dates (letters 78-88 and 115 to RI dated April 14 and July 7,1978, respectively) and now expects the vault to be completed December 15, 1978 The licensee also stated that, based on that completion date, str tion nonduplicate records would be in the vault by March 15, 1979. The inspector stated that this area would be reviewed further during a subsequent inspection (s).
This item remains open.
(0 pen) Unresolved Item (293/78-06-06):
Review adequacy and timeliness of corrective action for QAD Audit 78-5.
The licensee stated that based on the expected completion date for construction of the Station Records Vault (see above item) that corporate nonduplicate records would be in the vult by July,1979.
The inspector stated that this item would be reviewed furtner during a subsequent inspection (s).
This item remains unresolved.
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(Closed) Infraction (293/78-06-07):
Failure to properly control drawings in Station Document Control Center.
The station's controlled drawing sets were inspected and determined to be in compliance with established document control procedures.
The corrective action taken by the licensee was determined to be consistent with that stated in their letter of April 14, 1978.
This item is closed.
(0 pen) Unresolved Item (293/78-06-08):
Review adequacy and timeliness of corrective action associated with QAD Action Item 129.
The inspector reviewed the hand written notes of recent Audit 78-45.
The inspector noted that the involved parties arrived at various resolutions and that the auditor concluded corrective action was being accomplished at a satisfactory rate.
The inspector stated that this item would be reviewed further during a subsequent inspection (s).
This item remains unresolved.
3.
Quality Assurance Program Review The inspectors reviewed, on a sampling basis, the changes made to the below listed Quality Assurance Program implementing procedures since the NRC QA inspection on February 16, 1978.
The revisions were reviewed for consistency with the licensee's accepted Quality Assurance plan. These procedures also served as the basis for inspection in the areas discussed within this report.
During the conduct of the inspection, discussions were held with licensee personnel which indicated that they were aware of and were implementing the procedural changes.
These procedures reviewed were:
3.M.1-7.2 Removal and/or Return of Inventoried Material,
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Equipment, Parts from Warehouse, Revision 2;
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3.M.1-7.1 Handling and Storage of Material, Eauipment and Parts, Revision 3; 1.3.8 Document Control, Revision 16;
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1.3.7 Records, Revision 12;
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1.3.28 Location, Filing and Disposal of Recorder Charts,
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Revision 6; QAP 16.03, Deficiency Reporting and Follow Program, Revision 3;
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QAP 16.04, Response to Deficiency Reports, Revision 0;
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QAP 16.05, Review of Deficiency Reports for Potential Defects,
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Revision 0; QAP 16.06,10 CFR 50.55(e), Reportable Deficiencies, D.evision
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0; QAP 18.01, Audits, Revision 3;
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QAP 18.02, Qualification and Certification of Quality Assurance
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Auditors, Revision 3;
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NED 2.01, Preparation, Issuance and Control of Nuclear Engineering Department Procedures, Revision 1; NED 3.03, Use of Field Change Requests / Notices, Revision 1;
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and, N0D 3.01, Plant Design Change Requests, Revision 3.
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No items of noncompliance were identified.
4.
Modifications a.
References NED 3.02, Preparation, Revision, Review Evaluation and
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Approval of BECo Originated Design Documents, Revision
NED 3.04, Control of Design Documents with the Field,
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Revision 1
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NED 3.05, Design Calculations, Revision 0
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Applicable procedures as referenced in Paragraph 3
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b.
Review The inspector selected and reviewed the design changes /modifi-cations listed below and associated documents, on a sampling basis, to verify as applicable that:
they were accomplished in accordance with 10 CFR 50.59 and the licensee's QA Program requirements; code requirements and specifications were included; acceptance tests including values and standards were specified; records of equipment performance were reviewed and accepted; and prints / drawings and operating procedures were appropriately revised.
77-30, CRD Return Line (MR's 77-2380 and 2765)
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77-43, Reactor Water Cleanup System Mods (MR's 77-2541,
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42, 43 and 2800)77-102, RHR Seismic Restraints (MR's 77-2801 and 40)
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78-31, Battery Replacement (MR 78-1098)
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78-35, Recirc Suction Valve Logic (not completed)
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The inspector identified a number of discrepancies in the current modification control process such as interface between internal design groups, documentation retention, clarity of procedural descriptions, assignment of responsibilities and other administrative weaknesses.
The licensee had previously identified similar items requiring followup during the conduct of Audit 78-22.
During the review of documents associated with that audit (Paragraph 7.b) the inspector noted that corrective action was in various stages of completion.
Further interviews with professional and technical staff established that involved personnel were aware of the problem areas and had the opportunity to provide inputs into proposed solutions.
The inspector also reviewed draft procedures that were intended to resolve identified problems.
Further, the licensee did retrieve all requested documents for the inspector's review.
Based on the foregoing and current unresolved (Paragraph 2)
items, the inspector stated he had no further questions.
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No items of noncompliance were identifie.
5.
Records and Drawings
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a.
References QAM Volume II, Section 17, Quality Assurance Records,
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Revision 3 QAD Procedure 17.02, Storage and Retention of Quality
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Assurance Records and Departmental Correspondence, Revision 2 Applicable procedures as listed in Paragraph 2
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b.
Record Storage and Retention The inspector selected the following records for inspection in order to determine the licensee's capability to store, control and retrieve operating records.
Recorder Charts (Charts not forwarded for long term storage)
Reactor vessel flange temperature
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ARM-IRM/RBM HPCI exchanger pressure
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ADS relief valve temperature
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Surveillance Tests (For period of flovember 1977 - October 1978)
8.M.1-18 High Drywell Pressure Functional Test (Monthiy)
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8.M.1-13 MSL High Radiation Calibration (Quarterly)
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8.5.3.1 RBCCW Operability and Capacity (Quarterly)
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8.5.4.1 Test Containment Isolation Valves (Quarterly)
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8.7.4.3 Test Containment Isolation Valves (Quarterly)
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The inspectors also requested the records listed below at various times during this inspection and verified that they were retrievable and that they were maintained as required.
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Audit reports listed in Paragraph 7
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Procurement records listed in Paragraph 6
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Modification packages listed in Paragraph 4
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The inspector toured the construction area for the proposed ANSI N45.2.9 permanent storage facility. This facility, as discussed in Paragraph 2, is not yet complete.
Notwithstanding that status of permanent record storage, no items of noncom-pliance were identified.
c.
Engineerino Drawing Control The inspector selected the d awings listed below to determine that the established control. were implemented and that as built drawings are being maiitained.
The inspector compared the original tracings agains c the master index (station and corporate office); corporate central files aperture card deck; station central files aperti re card dock; and applicable hard copies distributed to the Control Room, Chief Maintenance Engineer, Maintenance Engineer, Watch Engineer, Document Control Center and Training Office.
Drawing Revision M203
M210 E3 M227 E-1 M247 E-1 M254 E-1 M41
M8681 2F E419 E-1
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Drawing Revision
- E216(CoverSheet)
E-2
- E216 Sheet 1
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- E203 Sheet lA El
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1B El
- E215 (cover sheet)
E2
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Sheet 1
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Sheet 2
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Sheet 4
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Sheet 5
- inspected as part of " Controlled Selected Document Sets" maintained in the Control Room, Electrical Engineer's Office, and Training Office only.
During inspection of engineering drawing control activities in the Maintenance Office, the inspector observed that six file cabinets and a smick file contained drawings (Series MIA through M390 and Series El through E46) which were neither marked as controlled copies nor as "for information only" as specified in Procedure 1.3.8, Document Control.
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The licensee stated that these drawings are used for reference purposes only and are not used for safety related activities.
The drawings consisted of a set of vendor prints turned over to the station by their A/E-Constructor.
Although the Boston Edison Quality Assurance Manual and its implementing procedures do not specifically prohibit the existence of such uncontrolled drawing files, the licensee stated that these files were not consistent with a new document control system being implemented in the near future.
Prior to the completion of the inspection, the subject drawings were removed to controlled storage where they will be incorporated into the new document control system.
No items of noncompliance were identified.
d.
Drawing Change Notice The inspector reviewed Plant Design Change Request (PDCR)
packages to insure Drawing Change Notices (DCN's) are issued in a timely manner. The inspector observed that in most cases, the DCN's for the system P&ID's were issued as part of the PDCR package.
Other drawings affected by the PDCR did not have DCN's issued for them one year subsequent to completion of the work.
In one case, the inspector observed a DCN that existed in a work package that had been issued in November 1977 that did not appear in the master drawing index.
The licensee had previously identified similar problems with DCN's in Audit Report 78-17 and the inspector verified procedure revisions are in process which will resolve the above problems.
The licensee assured the inspector that a greater emphasis would be applied to DCN's in the interim time prior to implementation of the procedure revisions.
This item is unresolved pending implementation of the procedure revisions and review by RI during a subsequent inspection (293/78-26 ']2).
e.
Tests and Experiments The licensee informed the inspector that no tests or experiments pursuant to 10 CFR 50.59(b) have been conducted since February 16, 1978, the date of the last QA program inspection.
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6.
Procurement a.
References 3.M.1-9, Identification and Control of Material, Parts,
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and Components, Revision 2 QAP 4.04, Review and Approval of Deviations from Quality
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Assurance Requirements in Purchase Orders / Contracts, Revision 1 QAP 7.01, Receipt Inspection of Q Materials, Parts, and
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Components, Revision 0
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QAP 15.01, Control of Nonconforming Material, Revision 1
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Applicable Procedures as listed in Paragraph 3
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b.
Implementation Review The inspector selected a sample of items which had been installed in plant systems, had been released from storage for installation, or had been identified as nonconforming.
Review of maintenance records, Stores Department warehouse records, and QA/QC records, established traceability for cach item to its procurement requirements.
Documentation 6_sociated with the items listed below was reviewed to verify that proper approvals had been obtained, quality control inspection requirements had been specified, and quality record requirements had been provided.
P0 No_._
Item Description 00958 MSIV Replacement Parts 41157 MSIV Replacement Parts 32155 Salt Water Service System Pump Parts 12986 MOV Replacement Motors 21788 Safety / Relief Valve Replacement Parts 05495 RHR System Replacement Hardware 06860 RHR System Replacement Hardware
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The inspector reviewed the Quality Control and Stores Department records of receipt inspections conducted for the items selected and confirmed that the inspections had been conducted and reported as required by the applicable procedures.
The inspector also reviewed the documentation associated with nonconformances and quality document deficiencies identified during the inspection process and determined that the nonconforming items were being controlled in accordance with applicable program requirements.
The inspector further verified that the items selected were procured from vendors which had been evaluated and approved in accordance with the Boston Edison Quality Assurance Manual.
No items of noncompliance were identified.
c.
Storage Area Tour The inspector toured the station warehouse area, observing general storage conditions, conforming and nonconforming material identification and segregation, and general housekeeping practices.
During this inspection, construction of new facilities within the warehouse were underway.
This activity has resulted in some relocation of equipment, material, and parts and has generated dust levels which have somewhat degraded the cleanliness and general housekeeping in the storage areas.
The inspector confirmed that protection of stored items from the construction environment was generally consistent with the requirements of the licensee's housekeeping procedure, 3.M.1-7.2.
Licensee representatives stated that, upon completion of the warehouse construction activities, storage and housekeeping conditions will be restored to their normal conditions.
Current estimates indicate that the construction will be completed near the end of December 1978 and the warehouse restored to normal shortly thereafter.
This area will be reinspected during future inspections.
d.
Identification and Control of Sparc Parts During review of Q-listed item identification and control activities, the inspector determined that the licensee's current implementing procedures do not specifically address
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the identification and control of Q-listed items purchased / received during 1972-1975 (prior to implementation of the current 0QA Program). A review of documentation associated with these items indicated that documentary evidence appears to be available onsite to support material conformance to procurement requirements for the general case, but the specific items are not identified as conforming by means of the licensee's current conformance tagging system.
Current stores and QC practices for issuing the subject items for use appear consistent with the 0QA program requirements but are not described in the procedures for control of these activities.
The inspector requested the licensee to identify the means by which he has assurance that the subject items conform to their respective procurement requirements and that the documentary evidience exists on site for the individual items prior to their installation or use. The licensee representatives acknowledged the inspector's concerns and stated that the following actions would be taken to clearly establish and document the conformance of the subject items prior to their installation or use.
(.1 ) Measures will be established to assure that individual existing items purchased / received during 1972-1975 and not currently identified by Material Conformance Tags will:
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be established as conforming to procurement documents by which they were obtained; (b)
have documentary evidence of such conformance at the plant; and, (c)
be identified as conforming, Q-listed items.
(2) Until such permanent measures are taken to implement the above, the station will establish interim procedures or instructions appropriate to the circumstances which will provide for the actions of (a) and (b) above to be applied to individual items issued for use in safety related functions.
The licensee stated that the interim procedure will be issued and implemented by December 8,197.
The licensee indicated that his tentative plans were to in-dividually inspect the items subject to Q-list usage, establish their conformance to their respective procurement requirements, and identify and control them in accordance with existing procedures. The interim measures discussed above will tentatively include a check, prior to installation or use, that the items'
certification records comply with the procurement documents; if this requirement is not met, such items will be identified and evaluated and the required documentation obtained prior to use.
The continued acceptability of the use of the subject items in safety related functions is unresolved pending institution of the interim and permanent control measures discussed above and their inspection by NRC:RI. (293/78-26-03)
7.
Audits a.
References NED 16.02, Response to Deficiency Reports, Revision 0
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N0D 16.02, Response to Deficiency Reports, Revision 1
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QAP 19.01, Action Item Follow Program, Revision 3
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Applicable procedures as referenced in Paragraph 3
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b.
QAD Audits The inspector reviewed a sample of the audits conducted by the Quality Assurance Department to verify that they were conducted as follows:
in accordance with written checklists / procedures;
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by trained personnel not having direct responsibilities in the area (s) audited; with audit findings documented and reviewed; with followup actions initiated / completed; and, with general audit conduct in accordance with established schedules, pro-cedures and Technical Specification requirements.
The following audits conducted by QAD (audits identified by a
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78-1, Health Physics
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78-2, Training and Qualifications *
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78-3, Maintenance Group *
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78-4, Security *
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78-5, Nuclear Engineering Department (NED)
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78-6, NED Electrical Penetration Connection Modification
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78-7, Nuclear Operations Department (N0D) QA Activities
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78-16, Fire Protection Program *
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78-19, Crouse Nuclear Engineering Services
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78 9.1, Q Procurements
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78-22, NED Design Control
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78-26, T.S. 6.5.B.8.c*
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78-41, Design Change Activities (Design Change Task
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Force)
During the conduct of the abou audits the licensee identified 36 items requiring followup.
Audits 78-2, 3,16 and 26 which had been performed for NSRAC did not have their respective reports distributed to appropriate management within thirty days of audit completion as required by T.S. Paragraph 6.5.B.10.c.
These examples of failure to issue the reports within the required time frame constitute a deficiency level item of noncompliance (293/78-26-01).
The licensee stated that their use of experts (who had been evaluated and approved as consultants) to assist in these audits led to logist c problems in the report writing and approval process resulting in the lateness of issuing the subject reports. The inspector acknowledged the ifcensee's statemen.
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Unresolved Items Items about which more information is required to determine accept-ability are considered unresolved.
Paragraphs 5.d and 6.d of this report contain unresolved items.
9.
Exit Interview The inspectors met with the licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on November 3, 1978.
The inspectors sunmarized the purpose and scope of the inspection.
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