IR 05000387/1980014
| ML17138B706 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 08/18/1980 |
| From: | Gallo R, Mccabe E, Rhoads G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17138B702 | List: |
| References | |
| 50-387-80-14, NUDOCS 8101090869 | |
| Download: ML17138B706 (12) | |
Text
3
N U.S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I
1
~33
N
. 3~10
Licensee:
enn Priority Category 2 No th N nth St e Allentown Penns
'
Facility Name:
Sus uehanna Steam Elect 'c Station Inspection at:
Salem Township, Pennsylvania Inspection conducted:
June 2 - June 27, 1980 Inspectors:
. M. Gallo, Senior Resident Inspector
.G.
G. Rhoads, Resident Inspector date signed 1I11lYo date signed Approved by:
Ebe C. McCabe, Chief, eactor ProjectsSection II, R08NS Branch date signed 8'-J8-K'ate signed Ins ection Summar
Areas'ns ducted:
Routine inspection by the Resident Inspector s of:
preopera-tlona test program implementation, preoperational test quality assurance program, tag permit system, and preoperational test witnessing.
The inspectors also per-formed plant tours and reviewed licensee actions on previously identified items; The"inspection involved 88 inspector-hours by the NRC Resident Inspectors.
'esults:
Of the five areas inspected, no items of noncompliance were identified
~sn t ree areas; two apparent items of noncompliance were identified.
(Infraction-failure to use properly approved procedures
- Paragraph 4.c; Infraction - failure to follow approved procedures for reporting non-conforming items - Paragraph 7).
Region I Form 12 (Rev. April 77)
DETAILS 1.
Persons Contacted Penns lvania'Power'and'Li ht Com an L. Adams, Plant Supervisor of Operations R. Beckley, Site gAE R. Byram, Plant Supervisor of Maintenance S. Cantone, Superintendent of Plant E. Carroll, Site gAE T. Clymer, Site gAE T. Dalpiaz, Startup and Test Group Supervisor D. Dunn, Resident Engineer J.
Edwards, Plant Personnel and Administrative Supervisor J. Everett, ISG guality Engineer R. Featenby, Assistant Project Director E. Figard, Assistant ISG Supervisor E. Gorski, Plant guality Supervisor M. Gorski, Resident Engineer D. Hattersley, Startup and Test Field Engineer D. Housenick, Startup and Test Group Supervisor G. Lazarowitz, Resident Engineer W. Lowthert, Plant Training Supervisor L. O'eill, Plant Technical Supervisor D. Potocik, Plant Health Physics~Supervisor R. Prego, Site gAE (
J.
Rimsky, Plant I8C/Computer St, ivisor R. Stotler, Plant Security Supervisor R. Webster, ISG Supervisor Bechtel Cor oration M. A. Drucker, Electrical gAE H. Lilligh, Project gAE T. Minor, Project Field Engineer J. O'ullivan, Assistant Project Field Engineer FMEA 2.
W.
R. Rogers, ANII The inspectors also interviewed other PP&L employees, as well as employees of Bechtel, and General Electric Company; Plant Tours a.
During the course of the inspections, the inspector made observations
\\
and conducted multiple tours of plant areas, including the following:
Control Room (2 Reactor Building (3 Turbine Building (4 Containment (5 Diesel Generator Rooms (6) Yard Areas b.
The following determinations were made:
-Plant Housekeeping Conditions.
Observations relative to plant house-keeping identified no unsatisfactory conditions.
Equipment Tagging.
The inspector selected plant components for which valid tagging requests were in effect and verified that the tags were in place and the equipment in the condition specified.
Fire Protection.
The inspector verified that selected fire extinguishers were accessible and inspected on schedule.
During a tour of the Control Building the inspector observed welding in the C-600 Battery Room..
The inspector observed that the associated battery charger was on float charge.
The inspector determined that the work had been authorized by Startup Work Authorization 1326.
The work required welding to structural steel beams inside each of the Unit 1 Battery Rooms.
The inspector stated that it appeared that the battery could'e put into a charge or discharge condition with no operator action.
The inspector did, observe that precautions including increased battery room ventila-tion, a fire watch and covered battery cells had been taken.
The inspector, reviewed applicable industry and NRC Documents regarding battery installation and welding safety precautions.
While no specific guidance regarding necessary construction work, such as
.
'welding, near batteries was identified the inspector discussed his concerns and stated that batteries should be placed on op'n circuit while any such work was in progress.,
The licensee concurred and the battery where the welding was in progress was subsequently placed on open circuit and provisions were made by the licensee to place subsequent batteries on open circuit as the work progresse Documents reviewed by the inspector relative to the above in-cluded:
Regulatory Guide 1. 128 and 1.129 IEEE 450-1975
'IEEE 484-1975 ANSI N45.2.4 FSAR Section 3.13 NFPA Standard 51B PPSL Fire Protection Review Report (PLA-211)
The inspector expressed his concern to Plant Management for the apparent lack of safety precautions for this evolution.
Maintenance.
The inspector selected maintenance activities observed during the tour, and verified they are in accordance with established procedures except as noted in paragraph 4.c.
3.
Status of Previous Ins ection Items a 0 (Closed)
Inspector Followup Item (387/79-29-01):
The inspector had expressed a concern about the lack of a procedure covering the reactor pressure vessel internals vibration testing.
The ISG Supervisor had agreed with the concern and stated a procedure would be developed.
Technical Procedure 2. 16, Revision 1, has been developed and was issued on March 31, 1980.
The inspector had no further questions at this time, and this item is closed.
b.
(Open)
Unresolved Item (387/80-10-03):
Reactor Protection System Power Supplies.
The inspector reviewed appropriate General Electric Drawings regarding the main steam line radiation monitor.
The inspector determined that the loss of power from a Reactor Protection System (RPS) Motor-Generator (MG) Set would cause the main steam line radiation monitor re-lays to deenergize thus opening contacts which deenergize one Main Steam Isolation Valve (MSIY) Pilot Solenoid for each MSIV.
As a result the loss of one RPS MG Set and the alternate power supply would provide one half of the shut signal for each MSIV.
Loss of the other RPS power supply would complete the shut signal and shut all eight MSIV's.
Bechtel Drawing Nos. for the General Electric drawings reviewed are:
M1-B21-131(1)-5 Ml-B21-131(6)-2 M1-B21-131 7)-4 M1-B21-131 12)-1 M1-B21-131 16 -2
The inspector stated that clarification was still required regarding design consideration of the Operating Basis Earthquake (OBE).
FSAR Section 3.7a defines the OBE as "that earthquake which produces the vibratory ground motion for which these features of the Nuclear Power Plant necessary for continued operation without undue risk to the health and safety of the public are designed to remain functional." '
The inspector stated additional review of the design and installation of the RPS power supplies was required.
This matter remains unresolved pending further review by the licensee and the NRC.
II 4.
'Preb erational'Testin "-"'alit 'Assurance a. Station'alit Certification'Records and'Trainin
'Pro ram The inspector reviewed Station guality personnel certification records, to verify compliance with NRC requirements, licensee commitments and plant procedures.
FSAR Section 17.2.2 coomits the licensee to ANS1 45.2.6-1973 for certification of personnel who are performing inspection, examination and testing.
FSAR Section 17.2.1.1.1.4.1.1.1 commits the licensee to Paragraph 4.4.5 of ANSI/ANS 3. 1-1978 regarding the qualifi-cations of the Station guality Supervisor.
FSAR Table 17.2-1 commits the licensee to Regulatory Guide 1.58 which endorses ANSI N45.2.6-1973.
The inspector reviewed the following licensee procedures relative to this inspection:
'I
Plant Administrative'Procedures-AD-00-017, Revision
AD-00-051, Revision
ualit 'Assurance'Procedure-SP-7, Revision
The inspector determined that AD-00-051 does not completely incorporate the FSAR Table 17.2-1 commitment to Regulatory Guide 1.58.
The Regula-tory Guide 1.58, Regulatory Position C,3. states that the basis u'sed for certification be documented.
The basis should include general education and experience requirements and specific technical requirements.
It further states that the specific technical abilities of the person being cer tified
should be related to the specific assigned tasks, e.g., electrical in-spection.
AD-00-051 Paragraph 6,2.specifies the disciplines a person may be certified in, e.g., electrica'l and Paragraph 7.0 specifies the documentation required to support Personnel gualifications and Certifi-cations.
However, the procedure does not specify what specific technical requirements must be completed and documented for any particular discipline, The licensee committed to review and revise AD-00-051, as necessary to incorporate Regulatory Position C.3.
This matter is unresolved pending review by the NRC.
(387/80-14-0j.)
The inspector found that AD-00-051 Paragraph 7.0 specified a Reading List as part of the personnel qualification documentation.
The inspector reviewed the current Reading List which did not include all documents addressed in FSAR Table 17.2-1 "Operational guality Assurance Program Compliance Matrix."
The inspector stated that these references should be included in the'nspector Reading List or otherwise addressed in the Training Program.
The licensee committed to review and revise the Reading List as necessary to include appropriate FSAR Table 17.2-1 items.
This matter is unresolved pending review by the NRC.
(387/80-14-02)
The inspector reviewed the certification records for the seven presently assigned Station guality Inspectors for compliance with the education, experience and qualification requirements of Administrative Procedure AD-00-051.
The inspector identified the following discrepancies; The inspector found that the personal work/experience history record, for the guality Supervisor, required by AD-00-051, indicated different dates for previous work experience (Military Service)
from the dates found in the training record, Form AD-00-017'-1, required by Procedure AD-00-017.
The licensee committed to revise these documents as necessary.
This matter is unresolved pending review by the NRC.
(387/80-14-03)
The inspector found that the personal work/experience history form for one additional inspector did not completely document the basis for certification in that the Level II Requirement for a High School Education was not included.
The licensee committed to revise this
.
document as necessary..
This matter is unresolved pending review by the NRC.
(387/80-14-04)
Review of Audit Re orts The inspector reviewed NgA Audit Reports regarding the Preoperational Testing Program to certify compliance with NRC requirements and licensee
'commitments and procedures.
Licensee commitments reviewed by the in-spector included FSAR Section 17.2. 18 and PSAR Appendix D, Section D.2.18; licensee procedures reviewed included guality Assurance Procedure 19.0, Revision 2 and Work Instruction No. 2, Revision 6.
The inspector reviewed documentation including corrective actions for the following audits:
0-1, documented on PLI-3616 dated September 11, 1978 0-2, documented on PLI-6729 dated December 21, 1979 Site Audit No. 80 documented on PLI-5586 dated July 24, 1979 The inspector found that the last correspondence regarding Site Audit No.
80 was PPSL internal letter PLI-5972 dated September 24, 1979.
Several items remained open from this audit and were appropriately tracked but it did not appear that the items were being actively pursued.
The licensee committed to immediately review the status of these audit findings.
This action was initiated during the inspection period.
This matter is considered unresolved pending further review by the NRC.
(387/80-14-05)
ualit Surveillance Activities The inspector observed station quality surveillance activities in pro-gress to verify compliance with NRC requirements, licensee'ommitments and plant procedures.
FSAR Section 17.2. 1.1. 1.4.1.1. 1 commits the li'censee to inspection of activities such as maintenance.
Plant Admin-istrative Procedure AD-00-054, Revision 1, "Inspection of Maintenance Modifications and Testing Activities," provides implementing instructions for Station guality Inspectors.
Administrative Procedure AD-00-046, Revision 0, provides the Plant Staff with instructions regarding the Work Authorization System.
The inspector observed work activities in progress in two areas and verified station quality inspector activities.
On June 25, 1980, the inspector observed work in progress on the recirculation system pump seal removal and the repacking of a recirculation system pump discharge gate valve.
The inspector observed that the two maintenance procedures in use at the work location were marked,
"PORC Approved 6/20/80."
The pro-cedures MT-64-003 for pump seal removal and MT-GM-011 for the valve packing had been signed by the appropriate Plant Section Head, but had not been approved by the Superintendent of Plant prior to the work com-mencemen The inspector observed that.the Work Authorization for the valve repacking 1-64-M-80-4 did not refer to an attached Work Instruction.
In addition copies of the Work Instruction and the Maintenance Procedure MT-GM-Oll in use at one work location were marked "For Info Only."
The inspector reviewed Plant Administrative Procedure AD-00-001, Revision 2, titled
"Procedure Program" which states that the Superintendent of Plant is re-sponsible for the final approval of all plant procedures.
The inspector also reviewed Plant Administrative Procedure AD-00-003, titled "PORC Pro-cedure" which states that the PORC shall recommend in writing, to the Superintendent of Plant, approval or disapproval of all items reviewed.
The inspector stated that the use of unapproved procedures and the use of procedures marked for information only was contrary to the requirements of 10 CFR 50, Appendix 8, Criterion V.
(387/80-14-06)
The licensee took the following immediate corrective actions.
Maintenance Procedures MT-GM-Oll and MT-64-003 were approved on June 25, 1980.
The Work Authorization Package 64-M-80-4 was revised to include the applicable Work Instructions.
During review of Administrative Procedure AD-00-054 the inspector determined that the procedures did not provide specific instructions to Station guality Personnel regarding what was to be reviewed prior to signing a Work Authorization.
The Station guality Supervisor acknow-ledged the inspector's comments and committed to review this procedure and revise it as necessary.
This is considered unresolved pending review by the NRC.
(387/80-14-07)
jl Station ual it Control The inspector was informed that the Station guality Control Organization now reported to the Manager-Nuclear guality Assurance and not the Super-intendent of Plant as described in FSAR Section 17.2.1.1.1.4.1.
The inspector was informed that the reorganization of PPSL would be described in a future amendment to the FSAR.
The Manager-NgA issued a
Memo dated June 24, 1980 endorsing the existing Plant guality Procedures until a Manual of Nuclear guality Assurance Procedures can be developed.
The PPSL NgA reorganization will be examined during a future NRC inspection.
.(387/80-14-08)
5.
Preo erational Test Witnessin The inspector witnessed a portion of P88.1, Revision 1, Preoperational Test of the 250 VDC Battery.
The test observed was the service test of battery number 10660, Section 8.3.5 of P88.1.
The inspector noted that the only thermometer in use to measure battery temperature was not calibrated.
This thermometer was designated EM134."
A Nonconformance Report (NCR) had been issued by Plant guality against this thermometer and a.second:uncalibrated thermometer used in the battery testing.
The second thermometer had also been designated EM134, and had broken while in use during testing.
A test change notice was issued which permitted the test to continue using the uncali-brated thermometer.
The validity of the test results will be determined by the calibration/reje'ction of the thermometer.
The NRC will review the dis-position of the NCR and the acceptance of the P88. 1 test in a future inspec-tion., (387/80-14-09)
6.
S stem Ta out Procedure References:
(a)
AD-00-30 Revision 0, Functional Unit Procedure Protective Permit and Tag System (b)
AD-00-26Revision 0, Conduct of Operations The inspector reviewed references (a)
and (b) to determine if system lineup changes were authorized to be accomplished without the use of the Tag System.
References (a)
and (b) do not authorize systems to be placed in an abnormal configuration without the use of the Permit and Tag System.
The inspector discussed this situation with the Plant Supervisor of Operations.
He confirmed that the Tag System was used for all cases where systems were placed in an abnormal configuration not covered by the normal operating procedures, and that the Shift Supervision was not authorized by the Tag Procedure to effect, line-up changes without the formal tagout.
The inspector had no further questions at this time.
No items of noncompliance were discovered.
7.
Prep erational Test Pro ram - Im lementation Controls The inspector reviewed licensee activities relative to the identification of cracks in the valve yokes of Anchor Darling Manual Valves 1F034C and D in the Residual Heat Removal System.
The inspector determined that work had been initiated by the PPSL Integrated Startup Group by issuing Startup Work Re-quest (SWR) No.
1112 on tune 9, '1980 to Bechtel to replace the valve yokes from Unit 2.
Bechtel guality Control issued Nonconformance Report No.
5980 to document this conditio The inspector reviewed the following PPSL gA Program Documents relative to this matter:
gA Procedure 8.2, Revision'7, SSES Site guality Assurance Function gA Procedure 16.0, Revision 5, Reporting, Control and Disposition of Non-conforming Conditions gA Procedure SP-11, 'Revision 3, Control of Nonconformances gA Procedure SP-13, Revision 0, Preoperational Testing Inspection Function Plant Administrative Procedure AD-00-033, Revision 2, Nonconformance Control Startup Administrative Procedure AD-10.2, Revision 0, Startup guality Program The inspector determined that the aforementioned procedures did not describe the method used for documenting the nonconforming valve yokes and subsequent replacement.
The inspector was informed that the SWR was addressed in Start-up Administrative Procedure AD 6.6, Revision 4.
The inspector stated that the use of the SWR alone was contrary to the established gA Program require-ments for identification of nonconforming conditions.
Specifically, AD-00-033 Attachment A requires the Technical Supervisor to evaluate nonconforming con-ditions, to determine reportability to the NRC.
Attachment A also requires the signature of the Section Supervisor who is authorizing and approving the disposition.
AD-00-033 Section 7.3 describes the method of processing Non-conformance Reports for Conditional Release, which is required to remove an item from the hold status, and therefore permit work to proceed on that item.
The Plant guality organization issued Nonconformance Report No.80-126 on June 12, 1980 after the valve yokes had been replaced by Bechtel.
The failure to follow documented procedures regarding the identification and disposition of nonconforming items is contrary to
CFR 50, Appendix B, Criterion XV.
(387/80-14-10)
8.
Unresolved Items Unresolved items are matters about which more information is required to as-certain whether they are acceptable items, items of noncompliance, or deviation.
Unresolved items disclosed during the inspection are discussed in paragraphs 4.a (four items), 4.b, 4.c.
9.
Exit Interviews At periodic intervals during the course of this inspection, meetings were held with facility management (dates and attendees are denoted in Details 1)
to discuss inspection scope and findings.