IR 05000387/1979013
| ML17138A666 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 04/12/1979 |
| From: | Kister H, Markowski R, Napuda G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17138A665 | List: |
| References | |
| 50-387-79-13, NUDOCS 7907130238 | |
| Download: ML17138A666 (10) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT R
Region I Docket No.
50-387 License No.
CPPR-101 Priority Category Licensee:
Penns lvania Power and Li ht Company 2 North Ninth Street Allentown, Penns lvania Facility Name:
Sus uehanna Steam Electric Station, Unit
Inspection at:
Berwick, Pennsylvania Inspection conducted:
March 13-16, 1979 Inspectors:
R.
S. Markowski, Reactor Inspector J
~4AM G. Napuda, Reactor Inspector
<8zl~
date signed
<Prz /7 date signed Approved by:
. Kis er, Chief, Nuclear Support Section No.
2, R08NS Branch date signed at signed Ins ection Summar
Ins ection on March 13-16 1979 Re ort No. 50-387 79-13 d:
R
1 b
by Rf
b df f
procedures which document the guality Assurance Program to be implemented during
'reoperational Testing in the areas of organization, insoection/surveillance,t cor-rectivee action, audits and gA/gC personnel training.
This inspection also included
,the review of corrective action associated with suspect ANPP-2 carbon test cells and cannisters.
The inspection involved 55 inspector-hours onsite by two NRC regional based inspectors.
Results:
No items of noncompliance were identified.
Region I Form 12 (Rev. April 77)
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DETAILS 1.
Persons Contacted
- J. Bradford, Quality Supervisor
- R. Dunn, Superintendent of Plant SSES E. Elyard, Specialist-NQA
- J.
Green, Resident NQA Engineer C, McVicker, Operations Supervising Engineer-NQA T. Oldenhage, Resident Engineer
- A. Sabol, Manager-Nuclear Quality Assurance (NQA)
Other Accom an in NRC Personnel
- R. Gallo, Resident Inspector
- T. Szymanski, Nuclear Eng. (Instructor)-NRC Headquarters The inspectors also interviewed other licensee emplovees who are members of the Plant Quality, Onsite Nuclear Quality Assurance and Integrated Startup Group staffs.
- denotes those who attended the March 16 exit meeting.
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2.
Prep erational ualit Assurance Pro ram Review a.
References
-- 'usquehanna Quality Assurance Program Pennsylvania Power and Light Quality Assurance Manual Startup Administrative Manual Station Administrative Procedures Manual Plant Quality Procedures Nuclear Quality Assurance Work Instructions b.
Program Review The inspectors performed a selective review of the Pennsylvania Power and Light (PP&L) Quality Assurance Manual (OAM) and Supplemental Procedures (SP) for conformance to the require-ments of 10 CFR 50, Appendix B, and FSAR Chapters 14 and 17.
The specific areas reviewed were organization, control of
services, inspection, nonconforming material control, cor-rective action control, audits, and qualification require-ments for RA/gC personnel.
The inspectors further reviewed applicable procedures developed by the Resident Nuclear guality Assurance staff, the Plant guality staff and the Integrated Startup Group which imple-ment the PPSL JAM requirements.
No items of noncompliance were identified.
However, unresolved items were identified as discussed below.
o~t'uring the review of Procedures 8.2, AO 10.2 and AD-00-055, the inspector determined that the responsibilities for performance of quality verification activities (i.e.,
surveillance/inspection/monitoring)
associated with Phases
and 2 (collectively called preoperational testing) of the Initial Test Program needed further clarification in that these appeared to be conflicting responsibilities for verifying/monitoring vendor/con-tractor activities.
FSAR Section 14.2.2.2.8 identifies the responsibilities of the Integrated Startup Group.
FSAR Section 14.2.4 states that the procedures to perform these functions collectively form the Startup Administrative Manual (SAM).
Two of the responsibilities assigned are to "ensure" that vendors perform in accordance with project procedures, and "monitoring" rework, repair and maintenance durinq preoperational testing.
SAM Procedure AD 10.2 states that the guality Supervisor (gS),
who reports to the Superintendent-Plant, is responsible for the above men-tioned ISG functions.
Also, Station Administrative Pro-cedure AD-00-055 describes the plant quality program for monitoring of contractors.
The inspector further determined that FSAR Section 17.2.2 states that safety-related activities (i.e., repairing, modifying, maintaining, etc.) will be controlled as de-scribed in the PPSL (AM.
Procedure 8.2 of the JAM assigns the responsibility for quality verification of contractors to the Resident N(}A Engineer who reports to the Manager-Ng The Manager-N(A acknowledged the inspector's findings regarding the conflicts in responsibilities.
He further stated that the appropriate procedures of the (AM will be revised to provide clarification of the responsibilities for the performance of quality verification activities associated with preoperational testing and issued by May 15, 1979.
The Superintendent-Plant also acknowledged the inspector 's findings.
He further stated that the appropriate SAM procedures, Station Administrative procedures and/or Plant guality procedures would be reviewed and revised as necessary, to clarify responsibilities, and issued by July 1, 1979 or prior to commencement of Phase 1 activities (whichever is earlier).
Pending review of the issued procedures by,RI, this item is unresolved (387/79-13-01).
(2)
Nonconformin Conditions and Corrective. Action The inspector reviewed Procedure 16.0, 16.1 and SP-ll and noted that they addressed the basic requirements for documenting nonconforming conditions and described two different corrective action systems, each with it s own distinctive form.
The Deficiency Report (DR) system and form is to be utilized by licensee personnel (including Nuclear equality Assurance)
other than plant staff.
The Nonconformance Report (NCR) system is to be used exclusively by plant staff (including Plant guality).
However, the inspector noted that Procedure 16. 1, which describes the details of processing, issuing and dispositioning DR', addresses
.situations associated only with con-tractors/subcontractors and not situations where site Nuclear guality Assurance personnel would be required to issue DR's to plant or other PP&L internal organizations during the Initial Test Phas The licensee acknowledged the inspector's comment and stated that the procedure would be reviewed,
'revised as appropriate and issued by May 16, 1979.
Pending review of the issued procedure by RI, this item is unresolved (387/79-13-02).
The inspector further noted that =Procedure SP-ll, which describes the details of processing, issuing and dispositioning of NCR's, does not address the actions/responsibilities associated with.the pro-.
cessing/dispositioning of DR's should they be issued to plant personnel during the Initial Test Phase.
The licensee acknowledged the inspector's comment and stated that the area would be reviewed and appropriate instructions/procedures would be developed/revised as necessary by May 16, 1979.
Pending the review of the licensee's completed action(s)
by RI, this item is unresolved (387/
79-13-03).
Plant guality Procedure OL-OP-002 delineates the method to be used to assure that the conditions adverse to quality which do not require the initia-tion of a nonconformance report are promptly iden-tified and corrected.
Such items are defined as Corrective Action Items (CAI) and are documented in a status log maintained by the guality Super-vlsol (gS)
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The inspector determined that the critieria to be used to classify a given discrepancy as a CAI, the time frame for completion of corrective action associated with a CAI, and the basis to be used by the gS in his review of the CAI status log were not
'delineate The guality Supervisor acknowledged the inspector's statement.,
Further, he stated that gL-OP-002 would be revised to address the above referenced items and issued by May 15, 1979.
Pending review of the issued procedur e by RI, this item is unresolved (387/79-13-04).
Station Administrative Procedure AD-00-033 defines a Class B nonconformance as a trend adverse to quality.
However, the procedure does not describe the specific method utilized to detect such trends.
-The Ouality Supervisor acknowledged the inspector's finding and stated that the appropriate station administrative procedure(s)
would be revised to delineate a method and issued by May 15, 1979.
Pending review of the issued procedure(s)
by RI, this item is unresolved (387/79-13-05).
(3)
Audits The inspector determined that there is a Supervising Engineer-Operations position within the Nuclear guality Assurance (NgA) organization that is currently occupied.
The licensee stated that this individual would be re-sponsible for the conduct of audits with respect to plant staff activities.
The inspector noted that Procedure 19.0, which describes the authorities and responsibilities of NOA auditing personnel,
'does not address the subject position.
The inspector further noted that other supporting procedures also do not address this position.
The licensee acknowledged the inspector's comments and stated that Procedure 19.0 would be reviewed and revised as appropriate and issued by April 16, 1979.
Pending the'eview of the issued procedure, by RI, this item is unresolved (387/79-13-06).
(4) 'rainin and gualifications'of Plant ualit Staff The licensee stated that all Plant guality Staff would be qualified and certified in accordance with Station Administrative Procedure A0-00-051,,
and that this pro-cedure was written to be consistent with the require-ments of ANSI N45.2.6-1973, gualifications of Ihspec-tion, Examination, and Testing Personnel for the Con-struction Phase of Nuclear Power Plants.
The inspector reviewed the resumes, training and other documents of three randomly selected Plant Ouality per,-
sonnel and determined that each met or exceeded the minimum requirements of both the ANSI standard and the subject procedure.
However, the inspector noted that the detailed provisions of the procedure were delineated in such a way that once an individual was certified to Level I, that individual could progress to Level II and then Level III and not necessarily possess the minimum experience requirements for these.levels as stipulated by ANSI N45.2.6.
The licensee acknowledged the inspector's comment and stated the Procedure AD-00-051 would "be reviewed, re-vised as 'appropriate and issued by May 15, 1979.
Pending review of this issued procedure by RI, this item is unresolved (387/79-13-07).
3.
Sus ect ANPP-2 Carbon Cells On October 19, 1978, the FARR Company submitted a 10 CFR 21 report to NRC:Region V.
This report stated that some ANPP-2 carbon cells supplied to Bechtel Corporation for use at the Susquehanna Steam Electric Station were suspect.
The inspector reviewed the correc-tive actions taken with respect to this report as discussed below.
In a letter dated November 2, 1978, Farr Company notified Bechtel Corporation that 23 ANPP-2 carbon cells and 180 test cannisters supplied under Bechtel Purchase Order No. 8856-M-325-AC were suspect.
The letter recommended testing prior to installation or at the time of installation to establish the acceptability of the items for us The inspector reviewed Bechtel NCR No. 3389 and Shipping'Notice No. 8856-5468 (dated December 20, 1978) which documented the review of the Farr Company letter and subsequent shipment of 23 ANPP-2 carbon cells and 180 test cannisters back to Farr Co.
for retesting.
No items of noncompliance were identified.
4.
Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance, or deviations.
Unresolved i ems identified during this inspection are discussed in Paragraph 2.
5.
Exit Interview The inspectors met with licensee representatives (denoted in Para-graph 1)
on March 16, 1979 at the conclusion of the inspection.
The scope and findings of this inspection as stated in this re-port were presented.
The committed completion dates as stated in this report were confirmed by the Manager-NgA or Superintendent of Plant-SSES during this meetin,