IR 05000293/1980011
| ML19320C839 | |
| Person / Time | |
|---|---|
| Site: | Pilgrim |
| Issue date: | 05/20/1980 |
| From: | Greenman E, Napuda G, Roberts K NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19320C825 | List: |
| References | |
| 50-293-80-11, NUDOCS 8007180101 | |
| Download: ML19320C839 (11) | |
Text
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%s U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT
REGION I
Report No.
80-11 Docket No.
50-293
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License No.
DPR-35 Priority Category C
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Licensee:
Boston Edison Company M/C Nuclear 800 Boylston Street Boston, Massachusetts 02199 Facility Name:
Pilgrim Nuclear Power Station, Unit 1 Inspection At:
Plymoutn, Massachusetts and Boston, Massachusetts Inspection Conducted:
March 10-14, 1980
- !ld Inspectors:
!h I
G. Napuda, Reactor Inspector
'date Qk dourzwDs rhJ8o K.Mroberts, R si' dent / Inspector f!
"d' ate
// $s.
N(W vbr J. S'praul, Repctor Engineer ~(NRR-QAB)
date I/2d!80 Approved by:
[r
E 'Greenman, Chief, Nuclear Support Section date Inspection Summary:
Inspection on March 10-14, 1980 (Report No. 50-293/80-11)
Areas Inspected:
Routine, unannounced inspection by a regional based inspector and an NRR engineer of the Quality Assurance Program (QAP) implementation including:
QAP annual review; QA/QC administration program; design changes /
modification program; plant modifications; previously identified items; and, a plant tour.
The inspection involved 74 Inspector hours onsite by a regional based inspector, an NRR engineer (NRR-QAB) and a resident inspector and 52 inspector hours at the corporate offices by a regional based inspector, an
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l NRR engineer, two resident inspectors and one supervisor.
Results:
No items of noncompliance were identified.
i Region I Form 12 (Rev. April 1977)
8007180/0/
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DETAILS 1.
Persons Contacted J. Frazer, Records Center Supervisor E. Graham, Senior Plant Engineer
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E. Kearney, Quality Control Supervisor
- R. Kennedy, Quality Assurance Program Service Group Leader
- B.
LaScala, Records Management Group Leader-NED
- S. Rosen, Nuclear Engineering Manager-NED P. McGuire, Plant Manager
- W. Sides, Quality Assurance Manager M. Yessallian, Quality Assurance Procurement Group Leader 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.
Other Accompanying NRC Personnel
- D. Kehoe, Resident Reactor Inspector-Pilgrim I
- T. Martin, Chief, Reactor Projects Section No. 3, RO&NS Branen, Region I
- Denotes those present at the exit interview conducted at the corporate offices at the conclusion of the inspection.
2.
Action Taken on Previous Inspection Findings (0 pen) Unresolved Item (293/78-06-06):
Review adequacy and timeliness of corrective action for QAD Audit 78-5.
The inspector noted that corrective action has been escalated and a recent audit of this area identified some descrepancies.
This item remains open pending further review of timeliness of corrective action associated with records.
(Closed) Infraction (293/78-06-07):
Failure to incorporate the latest approved revisions of prints E-6, E-24 and M-247 (yellow copies) at the Technical Document Room (TDR).
The inspector verified that the latest approved revision of the aforementioned prints are now on file in the TDR.
This item is closed.
(0 pen) Unresolved Item (293/78-26-02):
Implementation of revised procedures that address DCN's and corrective action associated with Audit 78-17.
The audit finding has been escalated to higher management for resolution and the inspector identified a concern in this subject area (reference Paragraph 5).
This item remains open pending further review during a subsequent inspection.
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(Closed) Unresolved Item (293/78-26-03):
Licensee to establish interim and permanent procedural controls for certification, identification and issuring of "Q" items purchased between 1972-5.
The inspector verified that Temporary Procedure 78-63-1, Review of "Q" Material for Conformance, Revision 1, discussed the reclassification of the subject material.
The inspector reviewed Procedures 3.M.1-5, Procurement of Items and Services, Revision 13; 3.M.1-7.2, Removal and/or Return of Inventoried Material, Equipment, Parts from Warehouse, Revision 2; and 1.5.3, Maintenance Requests, Revision 10.
The latter two procedures have undergone revision and the reclassification of the subject material is complete.
This item is closed.
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 in May, 1979.
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.
Tnese procedures reviewed were:
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QADP 2.01, Preparation, Issuance, and Control of QAD Procedures, Revision 4 QADP 2.03, Preparation, Issuance, and Control of the Boston
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Edison Quality Assurance Manual, Revision 2 QADP 2.05, Preparation of Project Quality Plans, Revision 3 j
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QADP 3.01, Review of Specifications, Revision 6
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QADP 4.01, Review of Procurement Documents Prepared by BECo,
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Revision 2 QADP 4.02, Review and Approval of Supplier QA Program, Revision
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QADP 4.03, Survey of Suppliers, Revision 2
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QADP 4.4, Review and Approval of Deviations from Purchase
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Order / Contract (s), Reyision 2 QADP 4.05, Preparation and Issuance of the BECo QA Approved
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Suppliers List, Revision 2 I
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QADP 4.06, Procurement of Items and Services, Revision 0 QADP 7.01, Receipt Inspection, Revision 3
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QADP 10.01, Conduct and Reporting of Source Inspections,
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Revision 5 QADP 10.02, Conduct and Reporting of Installation Inspections,
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Revision 4 QADP 10.03, Conduct and Reporting of Surveillance Inspections,
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Revision 5 QADP 10.07, Visual Inspection of Welds, Revision 0
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QADP 15.01, Control of Nonconforming Material, P.evision 4
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QADP 16.01, Trend Analysis, Revision 5
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QADP 16.03, Deficiency Reporting and Follow Program, Revision
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QADP 16.04, Response to Deficiency Reports, Revision 1
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QADP 17.01, Correspondence Control, Revision 2
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QADP 17.02, Storage and Retention of Quality Assurance Records
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and Departmental Correspondence, Revision 3 QADP 18.01, Audits, Revision 7
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QPI-963, Project Quality Plan for Torus Modifications, dated
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10/12/79 NODP 1.53, Maintaining Requests, Revision 12
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NODP 1.57, Unplanned Maintenance, Revision 11
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NEDP 6.07, Maintaining the Q-List, Revision 2
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No items of noncompliance were identified.
b.
Implementation Review l
The inspector reviewed the implementation of selected procedures
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I to determine that established requirements were being accomplished, l
The results are discussed below:
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(1) NOD Procedure 1.53 established a new requirement in Revision 11 (dated October 23, 1979) for the QC representative to sign every Maintenance Request signifying his review.
The inspector noted that a number of MR's (MR) had not been so signed and determined that these MR's belonged to the early time period of this new procedural requirement.
The licensee representative stated that this early ommission was inadvertant but that presently, all MR's are being reviewed and signed.
The inspector verified that current samples of MR's are being signed and determined that this additional control by QC is now being implemented.
The inspector st:ted that he had no further questions.
(2) The inspector identified that the onsite Records Center copy of NODP 1.53 was Revision 11 rather than 12.
Immediate action was initiated to obtain the later revision.
The inspector determined that this was an isolated instance and stated that he had no further questions.
(3) Section 5 of the QA Manual requires tnat an index of QA Program related procedures be established.
The inspector noted that the Testing and Standards Section, and Nuclear Organization procedures had not yet been included in the index.
Pending review during a subsequent inspection that these procedures are included in the index in a timely fashion, this item is unresolved (293/80-11-01).
No items of noncompliance were identified.
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4.
QA/QC Administration A.
References Quality Assurance Manual, Volume II
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QADP 1.01, Organization, Revision 7
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QADP 2.02, Indoctrination and Training Program Revision
QADP 2.04, Review and Approval of QA Program Related
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Procedures, Revision 3 QADP 6.01, Preparation, Issuance, and Control of Quality
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l Assurance Program Descriptions, Revision 1 QADP 16.05, Review of Deficiency Reports for Potential
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l Defects, Revision 0 l
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QADP 16.06, 10 CFR 50.55(e) Reportable Deficiencies,
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Revision 0 QADP 18.02, Qualification and Certification of Auditors,
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Revision 3 j
QADP 18.03, Action Item Follow Program, Revision 0
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b.
Program Review The documents referenced above were reviewed on a sampling basis to determine that administrative controls for QA/QC administrative have been established in accordance with the requirements described in the licensee's accepted Quality Assurance Plan.
The subject review determined that administrative controls have been established for:
Defining those structures, systems, ccmponents, documents
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i and activities to which the QA Program applies The revision of documents to which the QA Program applies
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Administrative control of QA/QC department procedures
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The overall review of the effectiveness of the QA Program
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Personnel and organizations who perform activities for
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which the QA Program applies No items of noncompliance were identified.
5.
Design Change / Modification Control a.
References NEDP 3.01, Review, Evaluation and Approval of Contractor
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Design Documents, Revision 4 NEDP 3.02, Preparation, Verification, Approval and Revision
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of Design Documents for PDCR's, Revision 6 NEDP 3.03, Field Revision Notice, Revision 4
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NEDP 3.05, Design Calculations, Revision 4
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NEDP 3.06, Design Verification, Revision 0
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NEDP 3.07, Preparation and Approval of Safety Evaluations,
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Revision 0
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NEDP 4.03, Field Change Orders, Revision 1
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NEDP 6.01, Preparation and Review of Safety Analysis Reports, Revision 1 NEDP 6.02, Drawing Control System, Revision 3
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Program Review
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The documents listed above were reviewed to determine whether administrative controls for design changes / modifications have been established which verify the following:
procedures for control of design changes / modifications
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have been developed design document control has been established
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channels of communications between the design organization
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and the individual responsible for implementation exist design change / modification packages are being converted
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into plant records methods exist for identifying and reporting those design
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changes / modifications which are within the scope of 10 CFR 50.59 procedural controls exist for temporary modifications,
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lifted leads and jumpers responsibilities have been delineated in writing to
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assure the implementation of the above No items of noncompliance were identified.
However an unresolved item is discussed below.
(1) During the review of modification packages discussed in the following paragraph the inspector noted that a time l
interval existed between the completion of a modification l
and the issuance of Drawing Change Notices for the affected drawings.
The inspector further determined that no established procedures described a formal method whereby the plant operations personnel are alerted or notified in this interim that a particular modification has been implemented.
The licensee stated that this area would be reviewed and appropriate action taken.
Pending review of appropriate licensee action, this item is unresolved (293/80-11-02).
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c.
Implementation Review F
The inspector selected and reviewed the design changes /
modifications 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.
79-05, ADS Solenoid Splices
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79-13, Seismic Support Modification (RHR Piping and
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High Pressure Coolant Injection)
79-14, Reactor Feed Pump Auto Trip on Reactor High
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Water Level 79-15, HPCI/RCIC Motor Operated Valves 1301-1792301-
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79-34F, Core Spray Line Rerouting-Torus Modificiation
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79-45, Scram Discharge Header (Taste No. 3206)
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No items of noncompliance were identified.
d.
Drawing Control l
The inspector selected the following drawings associated with
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modifications to determine that established controls were implemented.
The selected drawings and aperture cards, as applicable, were examined in the Control Room, corporate and station Records Centers and compared to be corporate office originals.
They were also compared with the master computer index as to revision numbers.
E 216, Sheet 3, Connection Diagram 480v Load Center,
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Revision 6 i
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E 298, Conduit and Tray Layout, Revision E4
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C 252, Sheet 2, Turbine Pedestal, Revision 3
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E 217, Sheet 91,480v Connection Diagram, Revision E1
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MIG 16-7/730 E905, Sheet 6, RCIC System, Revision 9
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MIN-12-6, Reactor Protection System, Revision 4
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MIU-39-5 EO 41500 1099, Source Range Monitor, Revision 6
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MIU-57-3/730E907, Sheet 8, Offgas Monitoring System,
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Revision 14
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E-10, 480v Line Diagram, Revision 12 M 204, Sheet 1, Turbine Ext. Steam, Revision 9
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M 205, Sheet 2, Turbine Ext. Steam, Revision 9
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M 207, Condensate and Feedwater System, Revision E2
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M 213, Condensate Demin System, Revision E1
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M 214, Condensate Demin System, Revision El(14)
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M 216, Cooling Water System, Revision E1
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M 218, Fire Protection System, Revision E1
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M 230, Chemical and Waste Sample Rack, Revision El(5)
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M 231, Fuel Pool Cleaning and Demin, Revision E2
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M 237, Sheet 2, Plant Heating Diagram, Revision E1
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M 241, RHR System, Revision E2
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M 249, Standby Liquid Control System, Revision E1
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M 250, CRD Hydraulic System, E3
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M 252, Sheet 1, Nuclear Boiler, Revision E1
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M 254, Augmented Offgas System, Revision E2
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M 233, Clean Radwaste System, Revision E4
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The results are disussed below.
(1) The inspector noted that P&I Drawing M-233 (Control Room Yellow Book) did not have annotated on it the applicable PDCR number (78-44).
The licensee representative stated appropriate action would be taken.
Since this was not a Safety Related drawing the inspector stated that he had no further questions.
(2) The inspector identified that the ape-ture card for P&I Drawing M-241 was annotated that DCN 241-xx-01-1 was applicable.
The inspector determined that this Drawing Change Notice had been incorporated into the current drawing revision, applied to Revision El of the drawing, and an apparent clerical error caused it to be annotated on the current drawing.
The licensee representative stated that appropriate action would be taken to correct this error.wherever it appears.
Pending review of the licensee's action this item is unresolved (293/80-11-03).
(3) The inspector identified that P&ID Aperture Cards M204, 213, 214, 218, 231, 237, (Yellow Book also missing applicable PDCR), 252 and 254 located at the corporate Records Center did not reflect the applicable PDCR's.
The licensee stated that appropriate action would be taken to correct these ommissions.
Pending review of the licensee's action, ti.is item is unresolved (293/80-11-04).
No items of noncompliance were identified.
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6.
Audits a.
References QADP 18.01, Audits, Revision 7
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QADP 18.02, Qualification and Certification of Auditors,
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Revision 3 QADP 18.3, Action Item Follow Program, Revision 0
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NEDP 15.01, Nonconformance Reports, Revision 1 NEDP 16.02, Response to Deficiency Reports, Revision 1
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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; 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, procedures and Technical Specification requirements.
The following audits conducted by QA0 (the audit identified by a * was conducted under the cognizance of the Nuclear Safety Review and Audit Committee) were reviewed.
79-41, QA Program (Operational)
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80-4, Design Control
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79-25, Security *
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No items of noncompliance were identified, however an unresolved item is discussed below.
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(1) During a cursory review of correc.tive action requests the j
inspector noted that lengthy time intervals seemed to exist between the identification of a descrepancy and completion of related corrective action.
The inspector
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also noted that corrective action requests had been
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referred to higher management in certain instances.
Typical examples are Deficiency Reports 534 and 546 issued in October, 1979, which requested responses by November 12, 1979.
Extensions for response due dates were granted and responses received December 3, 1979.
These were found unacceptable and a January 1, 1980 memorandum requested further responses by February 11, 1980.
Responses had not been received by March 24, 198,
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The inspector expressed concern that the corrective action system might be deteriorating and may become untimely and inadequate.
The inspector stated that the corrective action system would be reviewed in detail during a subsequent inspection to determine that it was adequate and timely.
Pending this review this item is unresolved (293/80-11-05).
7.
Plant Tour At various times during the inspection, the inspector toured accessible areas of the Turbine Building, Control Room, Warehouse, Records Vault and Document Control Cantar.
The inspectors also toured the corporate engineering offices and various corporate records management areas.
No items of noncompliance were identified.
8.
Unresolved Items Items about which more information is required to determine acceptability are considered unresolved.
Paragraphs 3.b(3), 5.b(1), 5.d(2) and (3) and 6.b. of this report contain unresolved items.
9.
Exit Interview The inspectors met with the licensee representatives (denoted in paragraph 1) at the corporate offices at the conclusion of the inspection on March 14, 1980.
The purpose, scope and findings of this inspection were presented.
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