IR 05000367/1978007
| ML20062G438 | |
| Person / Time | |
|---|---|
| Site: | Bailly |
| Issue date: | 11/13/1978 |
| From: | Hayes D, Maxwell G, Phillips H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20062G432 | List: |
| References | |
| 50-367-78-07, 50-367-78-7, NUDOCS 7812280244 | |
| Download: ML20062G438 (12) | |
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U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENTORCEMENT
REGION III
Report No. 50-367/76-07 Docket No. 50-367 License No. CPPR-104
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Licensee: Northern Indiana Public Service Company 5256 Hohman Avenue Hammond, IN 46325 Facility Name: Bailly Generating Station Nuclear I Inspection At: Bailly Site, Porter, IN Corporate Offices, Hammond, IN (..
Inspection Conducted: October 3-6, 1978 Inspectors: G. F. Maxwell / /Vo /. 9 /T 7[
f H. S. Ph llip /VOd 9 / 97 T
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Other Accompanyin Personnel: F. C. Hawkins J-Approved by: . k'. Havi!Is, C // [f /
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Projects Section Inspection Summary Inspection on October 3-6, 1978, (Report No. 50-367/78-07)
Areas Inspected: Previously identified items documented in NRC Report Nos. 50-367/78-01 and 50-367/78-02; licensee's system for handling IE bulletins and circulars; and vertical test of indicator ,
pile AB-155. The inspection involved 57 inspector-hours on site by j two NRC inspecter j Results: One item of-noncompliance was identified in one of the '
four arear inspecte (Infraction - failure to assure that; pre- 1 requisites are met prior to testing; failure to properly calibrate equip entr failure to properly document test resultsSection I, paragraph 3).
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(Closed) Item of Noncompliance (367/78-01-03): Failure to properly store main steam line spool pieces. The inspector visually inspected the storage area and verified proper storage of spool piece (Closed) Item of Noncompliance (367/76-02-01): Audit schedules were not maintained in record files for previous years. Schedules will be maintained in files for future audit (Closed) Item of Noncompliance (367/78-02-02 and 367/78-02-09): Audit findings were not properly documented. The inspector was informed that findings and supporting information are now reviewed very closely for the problems previously identifie (Closed) Item of Noncompliance (367/78-02-03 and 367/78-02-07): Audit followup for corrective action was found inadequate. The inspector was informed that all previous reports were reviewed to assure that similar problems do not exist in other reports which were not reviewed by the NR Also a new form is being develeped to provide better f tracking and closeout of negative finding (Open) Item of Noncompliance (367/78-02-05): QA records were not indexed and were not readily retrievable. NIPSCo letter paragraph B.1(3) (dated July 26, 1978) stated that, "Our interim program is now in compliance".
The inspector found the indexing to be only 10 percent complet The difference in corrective action accomplished versus reported was apparently caused by a misunderstanding. The licensee committed to vigorously followup on this ite (Open) Item of Noncompliance (367/78-02-08): No procedure was available which described how 50.55e reports would be made. The subject procedure l
was reviewed and was acceptable except for the time allowed to report deficiencies. See Section I paragraph 2 for details. This item remains open pending necessary revision .. ., .-. - - .. . -
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DETAILS i Persons Contacted-Principal Licensee Employee i
J. Boh'n , Manager; Nuclear Staff
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- *J. W. Dunn, Nuclear Staff Engineer
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- C. A. Carlisle, General QA Engineer
- E. Kritzer Jr., Senior QA Enginee *A. T. Shahbazi, Nuclear Staff Engineer C. F. Braun Company J. S. Fiedler, Project QA Engineer
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D. Maxwell, Site QC supervisor
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Thatcher tagineering Corporation (TEC).
E. Hutson. QA Officer
- Denotes those present at the exit interview.
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l Functional on Program Areas Inspected Details of functional or program areas inspected are documented in
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Sections I and I ,
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Section I Prepared by H. S. Phillips F. C. Hawkins Approved by R. L. Spessard, Chief Engineering Support Section 1 1. Review of Svstem for Handling IE Bulletins and Circulars The Region III inspector reviewed the NIPSCo system for handling bulletins and ci culars. The NIPSCo Nuclear Staff is responsible for receiving, .eviewing, evaluating and acting on bulletins and circulars. The Manager Nuclear Staff receives bulletins and circulars and assigns them to the lead electrical, mechanical, or structural engineer. The engineer assigned evaluates bulletins or circulars and contacts the Architectural Engineer (AE) and/or the Nuclear Steam Supply Systems (NSSS) Contractor when necessary.
I The inspector reviewed the bulletin and circular file for 1978 and interviewed the electrical supervisor concerning the processing of bulletins. Bulletins Nos. 78-10. "Bergin Patterson Shock Absorbers" and 78-06, " Defective Cutler Hammer Type Relay with de Coils" were closely reviewed. Correspondence concerning the refgrenced bulletins between NIPSCo and the AE/NSSS was reviewe These evaluations and resulting actions appeared to be satisfactcr No items of noncompliance were identifie . Procedures for Renorting 50.55e Deficiencies The RIII inspector reviewed the procedure developed for reporting 50.55e deficiencies. The procedure appeared to be satisfactory except that Section III " Procedure" paragraph C.l. allows four (4)
working days to evaluate items and determine whether such items are reportable or if the evaluation would obviously take more than four (4) days the item would automatically become reportable. The inspector stated this was not consistent with NRC policy. The licensee representative showed the inspector paragraphs of Meyfrandum and Order, before the ATOMIC SAFETY AND LICENSING BOARD Decemoer 13, 1977, concerning the matter of Virginia Electric and Power Company (North Anna Nuclear Power Station Units 1 and 2). These paragraphs were interpreted by the licensee to mean that the licensee had several days to decide on the reportability of matter ,
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The inspector indicated that the licensee's interpretation would be discussed with RIII management. Subsequent to the inspection, the licensee was informed that the official NRC policy is "the licensee has twenty-four (24) hours f rom the time the deficiency is discovered to determine the reportability and report such deficiencies". The licensee committed to revise Nuclear Staff
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Procedure No. 21 to read twenty-four hour :
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No items of noncompliance were identifie . Review of Nuclear Staff Procedures The inspector reviewed the subject manual to assure that procedures described how Nuclear Staff personnel performed safety related functions described in Bailly PSAR, Appendix D and Questions / Answers described in Amendment 10 (June 30, 1971) paragraph D. 2- '
Procedure Nos. 1, 3, 8, 11, 18, 19, 22, 23 and 24 which cover Amendment 11 paragraph D.2-7.1. , items one through nine which are listed under Design, were reviewed and were found to address the subject functions except in the case of item nin Item nine, permanent file of documents, was not covered by a procedure. The inspector stated that there should be some guidance describing how safety related records will be transmitted to the site record center. This matter is considered unresolved since the manual is currently being reviewed and revise (367/76-07-01)
Items 12, 13, 14 and 15 in paragraph D.2-7.1 of Amendment 11 relate to the coordination, review and filing of documents with governmental agencies. No administrative procedures exist to describe who is responsible for submission or how it is accomplished. The inspector did not complete the review in this area, however, superficial review indicates a need for the licensee to review this matte This matter is considered unresolve (367/76-07-02).
No items of noncompliance were identifie . Review of OA Records Center Deficienev Identified in Report No. 50-367/78-02, dated June 26, 1978 The inspector reviewed item 367/78-02-05 which pertained to failure to establish and maintain a master index so that records are readily retrievable. NIPSCo letter dated July 26, 1978, stated in part,
"Our interim program is now in compliance". The inspector reviewed
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the matter with C. F. Braun personnel and found the index to be only ten percent complete. There appeared to be a misunderstand-ing. In any event, followup was not adequate and this matter remains unresolve The inspector reviewed C. F. Braun audit report No. 3, dated August 30, 1978, and found that findings JSF 026 through 039 iden-tified problems records and document control. As of the date of the inspection only one response, JSF 027, had been received. The '~
licensee QA representative agreed to give this matter close attention since it relates to the item discussed in the above paragrap No items of noncompliance were identifie . Vertical Load Test to Determine End Bearing Af ter Heaving The inspectot witnessed the Vertical Load test of Indicator Pile AB-155. The purpose of this test is to establish whether pile AB-155 has maintained end t aring after heaving 0.6". The test results were also to be used as a basis for relaxing heave criteria if the data were positiv A four pile reaction frame system was used for the test. Other test equipment included Load Cell "H", Hydraulic Jack number C822418, surveyor level number 501156, Telltale, and dial gauges numbers 3-1, 3-5, 3-6, 3-7, 3-8, 3-9, 4-1, 4-2, 4- Upon completion of the test, the following items were observed by the inspecto Lead Cell "H" and Hydraulic Jack Number C822418 were calibrated at the University of Illinois using the Baldwin-Southwork compression machine. Further investigation revealed that the Baldwin-Southwork compression machine was not calibrated and therefore was not traceable to rationally recognized standards as required by Thatcher Engineering Corporation (TEC) QA Manual, Section 12, paragraph 2.0 and ANSI N45.2-1971, Sectien 1 Load Cell "H" was calibrated through the loading range O to 500 tons. The vertical load test was performed through the loading range O to 600 tons. ANSI N45.2-1971, Section 13 requires that testing equipment and devices are of the proper range, type, and accuracy to verify conformance to established requirements.
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. Dial gauges were not calibrated in accordance with TEC QC Procedure 12-1 Section 2(B)l. Section 2(B)1 specifies that for comparison calibrgtion, the accuracy of the calibrated gauge must be within -2 percent of two recently calibrated gauges. Thatcher QC personnel utilized only one gauge for comparison calibratio The inspector reviewed appropriate personnel training records and found they did not include calibration qualifications of personnel performing calibration as required by TEC QC Procedure 10-5 and ANSI N45.2.6, Section Hydraulic jack calibration was not performed in the same manner in a
which it was used in the field under actual test condition TEC QA Manual Section 12, paragraph 2.0, requires that, "The calibration frequency and method will be based on intended project use. . ." The hydraulic jack calibration was per-formed at three different ram extensions by applying the load to the jack with the Baldwin-Southwork compression machin Field testing was performed by applying the load with the hydraulic jack ram. Licensee nersonnel expressed concern to the inspector, regarding mechanical differences in operation of the hydraulic jack due to the two different (field versus calibration) loading techniques, Applie d war during the vertical load test was monitored by both the long t ill and hydraulic jack. Correlation of applied load between the load cell and hydraulic jack was not achieved. The load cell indicated 600 tons and the hydraulic ja:k indicated 540 tons when pile unloading sequence was starte N1PSCo personnel, Braun Site QC Supervisor, and Braun Project QA Supervisor revealed that the load cell indicated approximately 10 tons after all load had been removed and the test terminate The Thatcher Corporation vertical pile load test report Form VPT-1 indicates the load cell returned to zero. This was noted subsequent to the completion of the inspection. *herefore, the matter was discussed in a telephone conversatioc, with the General Quality Assurance Engineer on October 17, 1978. The inspector was assured that this item would receive thorough followu Noncompliance Areas inspected and recorded in Paragraphs Sa-5f above demonstrate that all prerequisites for the given test had not been met and that adequate test instrumentation was not available and used. Therefore, this item is censidered to be in noncompliance with 10 CTR 50, Appendix B, Criterion XI, NIESCo QA Manual Section XI and Thatcher Engineering QA Manual Section XI
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as noted in Appendix A. (367/78-07-03)
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Section II Prepared by C. P. Maxwell Reviewed by R. L. Spessard, Chief Engineering Support Section 1 1. OA Program Review - Northern Indiana Public Services Company (NIPSco) The inspector compared the NIPSCo Quality Assurance Program, prescribed in the NIPSCo Quality Assurance Manual, with the requirements of 10 CFR 50 Appendix B and ANSI N45.2 (1971).
As a result, the inspector had the following concerns about selected sections of the Quality Assurance Manual:
(1)Section I of the manual and the supportive chart do not clearly indicate "on-site" versus "off-site" organizational elements which function under the control of the QA progra (2)Section I of the manual does not indicate the interf ace functions between the C. F. Braun Site QC Supervisor and the NIPSCo Supervisor of Quality Assurance (to include lines of communications between these two elements on the organizational chart).
(3)Section I of the manual does not clearly indicate that the Manager of General Engineering does not have responsibilities which may affect the organizational freedom of his responsi-bilities to assure control over the NIPSCo Quality Assurance Program for BCSN- The inspector noted that the General Quality Assurance Engineer reports directly to the aforementioned manage (4)Section II of the manual, QAP-2, and QAP-3 do not require NIPSCo's review of contractors QA Programs to assure that the programs comply with the various quality assurance Regulatory Guides / ANSI Standards to wh!ch NIPSCo has committed. Also, there are no provisions to assure rhat contractors QA manuals, policies and procedures are controlled in accordance with written procedures. There are no measures to assure that QA/OC personnel are trained and qualified in accordance with the requirements of the applicable ANSI standard (s).
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(5)Section II of the manual does not prescribe requirements for all personnel, not just QA/QC personnel, which conduct activities affecting quality to be suitably trained for those activities for which they perform. The inspector observed that NIPSCo is developing a procedure to address this concer (6)Section II and Section VII of the manual do not require that surveillance activities must be in accordance with written procedures or instruction (7)Section XI of the manual does not require that modifications, repairs and replacements are tested in accordance with the original design and testing requirements or acceptable alternatives. Neither does it require that test results be reviewed by qualified, responsible individuals or group The inspector discussed each of the above listed concerns with
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the NIPSCo Quality Assurance Engineer and noted that the NIPSCo Quality Assurance Engineer has also identified the same concern ,
t The inspector was informed that the applicable sections of the NIPSCo Quality Assurance Manual and/or the applicable NIPSCo QAP's are being revised / written to resolve *.he above concern The inspector was informed, during the exit interview by NIPSCo Management, that action to resolve the above concerns will be completed within 90 day This matter was identified by the inspector previously as an unresolved item (367/76-02-09) in IE report 50-367/78-02; this item remains ope No items of noncompliance were identifie . QA Program Review - Thatcher Engineering Corporation The inspector reviewed selective sections of the Thatcher s Engineering Corporation Quality Assurance Program. Thatcher Engineering Cr.rporation is a site contractor responsible for installation and inspection activities related to the driving of safety-related piles at the Bailly Generating Station Nuclear 1. The Sections selected were compared with the requirements of 10 CFR 50 Appendix B and ANSI N45.2 (1971). The sections, which were reviewed, are as follows:
(1) Organizational Structure and QA Personnel - (reviewed Thatcher QA Manual. Section 1. Revision 2 and Thatcher QC Procedure 10-5, original issue).
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l (2) Quality Requirements - (reviewed Thatcher OA Manual Section 4 Revision 1 and Section 8 Revision 1; Thatcher QC procedures 7-1, original issue; 10-1, original issue and 15-1, original issue).
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(3) Work and Inspection Procedures - (reviewed Thatcher QA Manual, Section 5, Revision 1 and Section 10, Revision 1)
(4) Control of Material - (reviewed Thatcher QA Manual Section 7. Revision 1; Thatcher QC procedure 13-1, original issue; 10-1, original issue and 7-1, original issue).
(5) Control of Processes - (reviewed Thatcher QA Manual Section 9, Revision I and Section 17, Revision 1; S&L specification T-2964 and Thatcher QC procedure 10-6, original issue).
(6) Corrective Action - (reviewed Thatcher QA Manual, Section 16, Revision 1 and Thatcher QC procedure 16-1, original issue).
7-(7) Document Control - (reviewed Thatcher QA Manual, Section 6, Revision 2 and Section 1. Revision 2).
(6) Test Control and Control of Test Equipment - (reviewed Thatcher QA Manual, Section 11, Revision 1 and Section 12 Revision 2; Thatcher QC procedures 11-2, original issue and 12-1, original issue).
(9) Quality Records - (reviewed Thatcher QA Manual, Section 1, Revision 2. Section 7, Revision 1 and Section 10 Revision 1 and a list of records to be retained by Thatcher for trans-fer to C. F. Braun).
(10) Audits - (reviewed Thatcher QA Manual, Section 18, Revision As a result of the review, the inspector had several concerns about the Thatcher Quality Assurance Program. The concerns, listed as follows, were discussed with NIPSCo Panagement who indicated that action will be taken within 90 days to resolve the concerns. The inspector noted that Braun personnel have draf ted a letter to the Thatcher Engineering Corporation i addressing the inspector's concerns:
l (1) Neither Thatcher QA Manual Section I nor the Thatcher organization chart clearly indicate "on-site" versus
"off-site" organizational elements which function under the control of the QA Program.
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(2) The qualification requirements for Thatcher management personnel, who are responsible for the overall QA Program, are not delineated in the Thatcher QA Manual or any of the Thatcher QC procedure (3) The inspector had the following concerns about Thatcher's QC procedure for calibration of test and measuring equip-ment, procedure 12-1, original issue:
(a) The procedure does not require that measuring and test equipment be tagged / labeled to clearly indicate when it was last checked for calibration and the due date for the next calibration chec (b) There were no procedural / program requirements delineating the minimum qualification / training required for those Thatcher personnel that are allowed to perform calibration checks of test
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and measuring equipmen (c) Paragraph 3.B.(3) of Thatcher's QC Procedure 12-1, original issue could not be clearly understood by the RIII inspector, and it could not be clearly explained by the Thatcher personnel responsible for inspection functions at the site. The RIII inspector was informed by Braun QA/QC personnel, that paragraph 3.B. (3) of Thatcher's QC procedure 12-1 will be revised to clearly indicate the significance of Ceritificates of Calibration that are received from manufacturer (4) Thatcher QA Manual Section 18 Revision 1 does not clearly prescribe the qualification requirements for audit personne Also, Section 18 does not detail the methods to be used by Thatcher audit personnel to assure that audits are scheduled, conducted and documented per ANSI N45.2, Section 19. The inspector discussed this concern with Braun QA/QC representatives. The inspector was informed that Thatcher will be required to procedurally re-address audits and audit personnel, using ANSI N45.2.12 for guidanc This matter was identified by the inspector previously as an unresolved item (367/78-02-09) in IE report 50-367/78-02; this item remains ope No items of noncompliance were identifie . Other Areas - Thatcher Engineering Corporation The inspector discussed with the licensee the responsibilities which have been delegated to Thatcher. The inspector was informed that Thatcher is not responsible for any design functions relative to
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permanent plant components, parts or structures being purchased !
or installed at BGSN-1.
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No items of noncompliance were identifie .
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of non-compliance, or deviations. Unresolved items disclosed during the inspection are discussed in Section I, Paragraph 3.
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Exit Interview The inspector met with site staff representatives (denoted in the Persons Contacted paragraph) at the conclusion of the inspection on October 6, 1978. The inspectors summarized the scope and findings of the inspectio Subsequent telephone conversations between the inspector and licensee representative on October 17 and 18 provided supplemental information concerning the vertical load test as related to the subject inspectio This matter was upgraded from unresolved to an item of noncompliance based on the additional information. The inspector was advised that a second test would be conducted during the week of October 23-27, 197 I
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