IR 05000387/1984040
| ML17139C859 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 01/10/1985 |
| From: | Alba A, Eapen P, Kelly G, Prell J, Shaub E NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17139C857 | List: |
| References | |
| 50-387-84-40, 50-388-84-50, NUDOCS 8502050480 | |
| Download: ML17139C859 (18) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
50-387/84-40 Report No.
50-388/84-50 50-387 Docket No.
50-388 NPF" 14 License No.
NPF-22 Licensee:
Pennsylvania Power 6 Light Company 2-North Ninth Street Al 1 entown, Pennsyl vani a 18101 Facility Name:
Susquehanna Steam Electric Station Unit 1 and
Inspection At:
Berwick and Allentown, Pennsylvania Inspection Conducted:
December 10-14, 1984 Inspectors 1 a, Reactor Engineer Kell
, Pr ct Engineer
. Prell, Reactor Engineer E.
Shaub, React r Engineer Approved by:
P.
K. Eapen, Acti g Ch>ef, Management Program Section, DETP
-/0-date
/-lg tu date
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/'/0 gM date IE date Ins ection Summar:
Ins ection conducted December 10-14 1984 Combined Re ort Nos.
SO-387/84-40 and 50-388/84-SO R
of the Quality Assurance Program including design and modification control, pro-curement, and receipt and storage of safety related systems, structures and components.
The inspection involved 96 hours0.00111 days <br />0.0267 hours <br />1.587302e-4 weeks <br />3.6528e-5 months <br /> onsite and 43 hours4.976852e-4 days <br />0.0119 hours <br />7.109788e-5 weeks <br />1.63615e-5 months <br /> at the corpor-ate offices.
Results:
No violations were identified.
$502050 o
000S87 850130 pDR ADO pDR W
DETAILS Persons Contacted T.
R.
K.
D.
C.
P.
T.
F.
- A.
- S M.
A.
J.
J.
RJ W.
J.
J.
- H I.
A.
R.
W.
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RR C.
D.
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B.
H.
- D AD C.
R.
Abbatiello, Supervisor QA Modifications, NQA Baker, Technical Procurement Supervisor Blakslee, Operations Supervisor Bockstanz, Project Engineer, Nuclear Power Engineering (NPE)
Brown, Project Engineer Mechanical NPE Burns, Senior Project Engineer, NQA Capotone, Senior Project Engineer - NPE Crimmons, Manager NPE Czysz, Senior Project Engineer - Mechanical NPE Derkacs, Senior Quality Engineer NPE Denson, Assistant Manager, Nuclear Quality Assurance Detamove, Supervisor, System Engineering NPE Dominquez, Senior Project Engineer Plant Engneering Edwards, Personnel andAdministrative Supervisor Everett, Senior Results Engineer Operations Frittzen, Group Supervisor, Resident Engineering Gulliver, Supervising Engineer NQA Hober, Project Engineer, Mechanical NPE Hubis, Senior Peoject Engineer, Installation Engineering Keiser, Plant Superintendent Keister, Manager, Nuclear Operations - NPE Male, Manager, Nuclear Design NPE Mathews, Senior NQA Analyst Metgzer, Group Supervisor, Engineering Planning NPE O'Donnell, Senior Project Engineer NQA Prego, NQA Operations Supervisor Purcell, Warehouse Supervisor Satter, Group Leader, Engineering Mechanics and Welding Codes NPE Sees, Material Support Service Supervisor Stitt, Senior Simulator Instructor Training Stokes, Senior Project Engineer, QA Modifications NQA Sutton, Materials Supervisor Thompson, Assi stant Plant Super vintendent Tucker, Supervisor, Engineering Support NPE Whirl, Senior NQA Project Engineer Whitmayer, Senior QC Specialist USNRC L. Plisco, Resident Inspector
- Denotes those present at the exit interview on December 14, 1984.
The inspectors also interviewed other personnel including engineers, technical and administrative personne.
Desi n Chan e and Modification 2.1 References ANSI N45.2. 11 1974, Quality Assurance Requirements for the Design of Nuclear Power Plants ANSI N1, Quality Assurance for the Operational Phase of Nuclear Power Plants Final Safety Analysis Report Operational Quality Assurance Program (OPS 9, 13,
& 14)
Nuclear Department Instruction (NDI)-QA-15.1.1, Communication Interfaces with Nuclear Power Engineering (NPE), Revision
NDI-QA-15.2. 1, Delegation of Design Authority to Plant staff, Revision
NDI-QA-15.2.3, Configuration Control Program, Revision
NDI-QA-15.2.4, As Built Drawing Requirements, Revision
NDI-QA-15.2.7, Drawing Change Control AD-QA-410, Plant Modification Program, Revision
AD-QA-414, Installation Engineering Activities, Revision
AD-QA-900, Conduct of Insallation Engineering Group, Revision
NDI 8.2.6 QA Requirements for Safety Impact Items, Revision
NDI 9. 1, Safety Evaluations, Revision
Engineering Department Manual
~
DC-010.0 Design and Approval of Design Documents, Revision
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DC-10. 1 Design Yerification, Revision
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DC-30.0 Design Control Package, Revision
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DC-40.0 Design Change Mechanisms, Revision
2. ~PII The procedures references in Section 2. 1 were reviewed to determine that the licensee has established a program for control of design changes and modifications to plant systems structures and components which included the following:
Mechanisms for assuring that proposed changes do not involve an unreviewed safety question as described in 10 CFR 50.59 Definition of responsibilities for identifying, reviewing and approving design changes, including independent design verifica-tion Definition of design organization interfaces Control of changes to design documents including distribution, approval and revisions Definition of post modification testing requirements and acceptance criteria Either the plant staff or corporate organization may identify the need for a modification by initiating a Request for Modification (RFM) which, after processing by the Nuclear Support Group (NSG)
and if approved by the Resource Management Review Group (Keiser, Greminons, Cantone),
is assigned a Plant Modification Record (PMR)
number.
That assignment, keys the PP&L corporate design organization, Nuclear Plant Engineering (NPE), into creation of an Engineering Work Request (EWR) which will initiate and track design and engineering activity.
NPE's methods of design, review and safety analysis of plant modifications are governed by the Engineering Procedures Manual (EPM), which provides those written instruction'hat in turn imple-ment the requirements of ANSI N45.2. 11-1974, "guality Assurance Requirements for the Design of Nuclear Power Plants".
The documentation and control of PP5L's design processes are accom-plished through and implemented by the Design Change Package (DCP).
This document is the integral part of any PMR, and principally con-tains design inputs, a safety evaluation, records of review, and approved design output for a specific plant modification.
The DCP is evidence of the development, review and approval of a design change by NPE, from initiation of an EWR through issuance to and installation by the field, and eventual update of as-built design documents.
There has been considerable design activity at Susquehanna in the past 12-15 months, associated with the December 1983 February 1984 tie-in outage of both units, the Unit 2 precommercial outage of October-December 1984, and the upcoming Unit 1 first refueling outage scheduled to commence in February 1985.
Over 100 DCP's were issued for work during the inter-tie outage, and approximately 150 packages have been issued (since October 1984) for work during the Unit 1 refueling outag e
~
Implementation of design changes and facility modifications were reviewed at the corporate office and on site to verify the following:
Changes were reviewed and approved in. accordance with Technical Specification
CFR 50;59 and established QA/QC controls.
Adequate post modification testing was required and implemented, including review of test results.
Applicable documents (i.e., operating and surveillance proce-dures, FSAR and system descriptions)
were updated to reflect the modification.
As-built drawings were changed to reflect the modification.
Design input and verification was adequately performed.
Modification training was given to applicable personnel (ice.,
operation, engineering, etc).
Ten (10) DCP's were reviewed for NDI and EPM procedural adherence, as well as for the technical content and adequacy of safety evaluations, independent verification and other reviews such as NQA, safety impact, compliance and Design Review Board.
Both properly prescribed design input and appropriate design output were evaluated, and finally, each DCP's responsible NPE engineer was interviewed to assess his training, qualifications, knowledge, and ability to defend his DCP.
The DCPs reviewed were:
DCP 82-0051, Unit
RHR Throttle Valve DCP 83-05920, Unit 2 ESW Loop A Waterhammer OCP 84-3109, Unit 2 LPCI Injection Valve Wear Strips OCP 82-0761, Diesel Generator Air Dryers DCP 83-0474, Unit 1 Vacuum Breaker Limit Switch Support OCP 84-3014, Unit
RHR Pump Seal Cooler DCP 83-0267, Unit
RHR Heat Exchanger Discharge Temperature Indicator DCP 83-0189, Unit 1 Containment Purge Valves DCP 82-0578, Unit 1 Scram Discharge Instrument Volume DCP 84-3119B, Unit 2 Moisture Separator Check Valve Discussions were held with the licensee group involved in modifica-tions and determined that the licensee personnel were aware of their duties and responsibilities.
The modification process was walked through with the Plant Engineer, Installation Engineering, Quality Control,'Quality Assurance, and Operations and assured that licensee personnel were aware of their
duties and responsibilities associated with modifications.
Work authorizing documents, testing requirements, and inspection require-ments associated with the DCP listed above were reviewed.
Drawings in the control room and Technical Support Center were review-ed and ensured that the as-built plant. conditions were posted to=the applicable drawing after DCP closeout.
The training provided to the operation department for these DCP was reviewed with senior operations staff and the training department.
Training is provided for each DCP's via required reading, shift briefings, or a formal presentation in the requalification program for operations.
The method of training is based on the operational impact of the modification, 2.4 A/
C Involvement with Desi n Chan e and Modification Quality Assurane provides inline review and approval of all safety related OCP's, surveillance and audit of the modification program.
Quality control (modification) provides inspections for the safety-related work associated with modification.
The inspectors discussed the inline review and approval with Quality Assurance engineering and determined the adequacy of their reviews.
QC inspection reports (i.e.,
GIR V4392-H, V43974-H, C44425-28-M and GIR C40886-E)
were reviewed and discussed with QC personnel.
This ensured that the inspection plans were detailed and acceptance criteria were estab-lished.
The QA surveillance program.was discussed with QA supervision and determined that the level of QA coverage for modifications was ade-quate.
Several QA surveillance reports were reviewed (QSAR's83-159, 203, 84-54, 75 and 22)
and verified the initiation of prompt and adequate corrective action for identified problems.
2.5
~Findin n
No violations were identified.
3.0 Procurement 3. 1 References/Re uirements Susquehanna Steam Electric Station (SSES)
Final Safety Analysis Report (FSAR) Units 1 and 2, Chapter
Administrative Directive (AD) - Quality Assurance (QA)-210, Revision 3, Procurement Control Activities Nuclear Department Instruction (NDI)-QA-2.4', Revision 1,
Evaluation and Approval of Suppliers of Quality Material and Service NDI-QA-2.4.7, Revision 0, Procurement of Quality Materials and Services
NDO-QA-2.4.4, Revision 1, Quality Consideration Lists Defective Device List, Revision
Approved Supplier Quality List (ASQL)
Nuclear Quality Assurance Procedure (NQAP)-4. 1, Revision 2, Procurement Document Review NQAP-6. 1, Revision 1, Evaluation and Approval of Suppliers for SSES Operational Policy Statement (OPS)-10, Revision 0, Procurement Control Regulatory Guide 1. 123, Revision 1, Quality Assurance Require-ments for Control of Procurement of Items and Services for Nuclear Power Plants, endorses ANSI N45.2. 13 The inspector reviewed the documents listed in Section 3. 1 and determined that the licensee had established a procurement program of safety-related replacement items which included the following:
Only approved and qualified suppliers were used for supplying safety-related items.
Procurement procedures were developed in accordance with Regulatory Guide 1.123.
Procurement activities were in accordance with established procedures.
Purchase and receipt records for safety-related items were retained and maintained in accordance with established require-ments.
QA/QC performed an overview of the above activities.
3.3 Im lementation Review The inspector selected the following plant purchase requisitions (PPRs) for safety related items to ascertain whether procurement activities were conducted in accordance with programmatic and QA/QC requirements.
PPR M-4-351, 8/13/84, Reactor Vessel Flanges PPR M-4-251, 6/21/84, RCIC Oil Drain
PPR E-4-0259, 6/27/84, Hydromotor Actuator PPR E-4-0354, 9/4/84, Carrier Chiller PPR C-4-1378, Welding Procedure Qualification The inspector verified that the vendors for the above PPRs were on the ASQL; that QA/Engineering 'had performed an evaluation/reevalua-tion of the vendors according to procedures; that the PPR's had received the necessary technical and quality control review and documentation; and, that the PPR's references the appropriate codes, standards, Part 21, shelf-life/preventive maintenance, and Certifi-cate of Conformance requirements.
A gAA/
The inspector discussed with site QC personnel, their program for procurement review and receipt inspection.
Site QA was also inter-viewed and the following audit was examined:
SSES Audit No.
1A-84-06, April 1984, Procurement Activities.
The checklist for this audit was reviewed and found adequate.
The 1984 and 1985 audit schedule was examined and procurement audits were scheduled annually.
The inspector also reviewed the QA vendor evaluation program with PP&L Headquarter s personnel.
Supplier Evaluation Forms for the following vendors were reviewed for timeliness and adequacy; Carrier Corporation, Hub Incorporated, Pittsburg Testing Laboratory and Johnson Controls, Inc.
In addition to performing their own evalua-tions, PP&L is a member of CASE and uses these evaluations as well as Bechtel vendor evaluations.
Based upon the above review the inspector found PP&L QA/QC procure-ment activities adequate in all areas.
3.3
~indin<is No violations were identified.
4. 0 Rece i t S tora e and Handl in 4.1 References/Re uirements Susquehanna Steam Electric Station (SSES)
Final Safety Analysis Report (FSAR), Chapte}
Non-Conformance Report (NCR)-83-559, Agastat Timing Relay Quality Assurance Action Request (QAAR) 83-1833, Agastat Timing Relay Receipt Inspection Report (RIR)-83-670, Agastat Timing Relay
r
RIR-82-1057, Pressure Switch RIR-82-471, Hex Bolts RIR-83-653, Mode Switch RIR-83-650, Weld Rod PP&L Nuclear Quality Assurance Procedure (NQAP) 11.2, Revision 1,
Receiving Inspection AD-QA-200, Revision 4, Material Control Activities Regulatory Guide 1.38, Quality Assurance Requirements for Pack-aging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants, which endorses ANSI N45.2.2-1972 Nuclear Department Instructions (NDI) 8. 1.5, Revision 1, Noncon-formance Control and Processing NOI 8. 1.9, Revision 0, Receipt, Non-Conformance Control and Processing
.2
~P The inspector reviewed the documents listed in Section 4. 1 and deter-mined that the licensee had.established a receipt, storage and hand-ling program for safety-related material which:
Provided for receipt inspection of all incoming safety-related materials and supplies Identified qualified vendors who may supply safety-related items which are supported solely by a certification of conformance Required that received materials be examined for conformance with requirements specified in the purchase order Provided for documentation of receipt inspection and storage of receipt inspection records Provided controls for tagging/marking of acceptable and noncon-forming items Established controls for the disposition and documentation of nonconforming items Established controls for the conditional release of nonconform-ing items Established responsibilities for each aspect of the program
Established controls for components having a shelf-life or requiring preventive maintenance Provided for periodic inspections of the storage areas 4.3 Im lementation Review Implementation of the program was determined by the following:
A tour of the warehouse and outside storage area.
Segregation of safety-related items from non-safety related items was accom-plished through the use of colored tags attached to or with each item. All items inspected were properly stored, identified and segregated.
In addition, the inspector found no indication of water leakage or rodent damage.
Inspection of acceptance tags.
It was found that the acceptance tags allowed tracing each item to the purchase order.
Verification that access controls exist which limit entrance to the warehouse and outdoor -storage arear'erification that hazardous materials were stored away from safety-related items.
Verification that safety-related items were stored at their proper storage level or better.
In addition, the inspector witnessed a
QC receipt inspection being performed for steel piping and the generation of the corresponding Receipt Inspection Report (RIR). The NRC inspector verified that the following items were examined during the receipt inspection; heat numbers, dimensions, interior/exterior surface conditions, preserva-tives, capping, and purchase order numbers.
The inspector reviewed the licensee's program for handling non-con-forming material and verified its proper implementation.
Verification that the licensee was properly implementing his shelf-life and pre-ventive maintenance program was made by inspecting several items requiring shelf-life or preventive maintenance controls.
'I. 0 ~/
The site procur ement QC gr oup is responsible for reviewing al 1 PPR'
and inspecting all received safety related items.
A nonconformance identified during receipt inspection results is one of two types of reports being written.
A Quality Assurance Action Request (QAAR) is issued if the nonconformance is with the receipt documentation.
Cor-rective action for QAAR's is the responsibility of the Procurements and Contracts groups.
A Receipt Discrepancy Report (RDR) is issued for all other receipt non-conformances.
All RDRs are reviewed and
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addressed by the Technical Procurement Group.
An automated tracking system of RDRs is being developed by the QC group to replace a manual system now in use.
An RDR that has been issued against an item to be conditionally released is converted to an NCR and then tracked by the site maintenance or engineering QC group.
The inspector reviewed the trending RDR log, examined several RORs and QAARs and verified that proper corrective action had been taken, and reviewed five RIRs for compliance with appropriate procedures, standards and regulations.
The inspector also reviewed two Material Control and Identification audit reports, Audit numbers 0-83-02 and 0-84-23, and verified that NQA is maintaining and scheduling an active audit program over material control.
Based on the above the inspector found PP8 L QA/QC material control program adequate in all areas.
4.5
~Findin s
No violations were identified.
5.
Mana ement Meetin s
Licensee Management was informed of the scope and purpose of the inspec-tion at the entrance interview conducted on December 10, 1984.
The find-ings of the inspection were periodically discussed with licensee represen-tatives during the course of the inspections An exit interview was con-ducted on December 14, 1984, see Detail 1 for attendees, at which time the findings of the inspection were presented.
At no time during the inspection was written material provided to the licensee by the inspector t