IR 05000387/1989032
| ML17156B486 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 11/14/1989 |
| From: | Blumberg N, Oliveira W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17156B485 | List: |
| References | |
| 50-387-89-32, 50-388-89-30, NUDOCS 8911280481 | |
| Download: ML17156B486 (8) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report Nos.:
50-387/89-32 50-388/89-20 Docket Nos.:
50-387 50-388 License Nos.:
NPF-14 NPF-22 Licensee:
Pennsylvania Power 8 Light Company 2 North Ninth Street Allentown, Pennsylvania 18101 Facility Name:
Susquehanna Steam Electric Station Inspection at: Allentown, Pennsylvania Inspection Dates:
September 25 - 27, 1989 Inspector:
'H. Oliveira, Reactor Engi e r Operational Programs Se io Operations Branch, DRS
~i I/ ~7 Date
/,g~
Norman J.
Blumberg,
.Chi Operational Programs Section Operations Branch, DRS (i/(s rg Date Ins ection Summar
- Routine, announced inspection on September
27, 1989 (Report Nos.
50-387/89-32 and 50-388/89-30).
Areas Ins ected:
Follow-up of an allegation regarding the status of the General Office (GO) drawing stick files (stick files) at the corporate office.
The allegation stated that for a ten month period, the stick file clerk was discarding instead of incoporating the changes required to maintain the stick files current.
>den repl Results:
The allegation was substantiated, that is, the GO stick files were not being properly maintained by the stick file clerk.
The problem had been tified by the licensee who took immediate corrective actions that included:
acing the stick file clerk; determining the status of the stick files by a
89ii28048i 891ii6 PDR ADOCK 05O0038'7
quality assurance (gA) surveillance andperforming a
100K audit of the stick files.
Subsequent corrective and preventive actions were to divide the stick file clerk responsibilities among three clerks, perform monthly sample audits and gA survei llances, and add the stick file area to the gA audit scheduled in August 1990.
The corrective actions taken and planned appear to be adequate to preclude recurrence of the stick file problem.
Because design engineers routinely used the licensee's Design Document Management System to verify proper drawing revisions, the stick file problem did not appear to have caused any design change errors.
No violations or deviations were identified.
This occurence was not a
reportable even DETAILS 1.0 Persons Contacted G. Bast, Senior Project Engineer, Electrical
- W. Brown, Project Engineer, Nuclear Quality Assurance (NQA)
"S. Cantone, Manager, Nuclear Services T. Gorman, Supervisory Engineer, Civil, Design and Analysis
- W. Gulliver, Supervisory Engineer, NQA
"R. Harris, Senior Licensing Specialist W. Heske, Manager, Nuclear Administration
"J.
Kenny, Supervisor, Licensing Group R. Kickline, Project Licensing Specialist
"J. Medeiros, Manager, Nuclear Records J. Miltonberger, Manager, Nuclear Safety Assessment
"Denotes those attending the September 27, 1989 exit meeting.
The inspector also contacted other administrative and technical personnel during the inspection.
2.0 Follow-u Ins ection of Alle ation No. RI-89-A-0086 Unreliable General Office Stick Files 2. 1 Back round An allegation was received by the-NRC on July 14, 1989, and assigned a
Control No. RI-89-A-0086.
The allegation stated that the individual (stick file clerk) responsible for the General Office (GO) Stick Files (drawing stick files) in the Corporate Office was discarding the changes required to maintain the stick files current.
The individual's actions placed the stick file in an uncontrolled status for use by engineering and corporate personnel.
The problem was discovered when the stick file clerk on June 1,
1989 admitted to the Susquehanna Records Management System (SRMS) Manager that he had been discarding since August 1988, the changes required to maintain the stick files current.
His admission might have been prompted by mounting complaints from users that the stick files were in an uncontrolled state.
~2.2 Sco e
The inspector reviewed the status of the allegation, determined the follow-up actions necessary to address the concern raised, and determined by an onsite inspection whether the licensee's corrective and preventive actions taken or planned are adequat.3 Ins ection Review
. The inspector reviewed the SRMS Manager's memorandum of June 2,
1989, and revised September 25, 1989.-
The SRMS Manager's memorandum briefly dis-cussed the events regarding the GO stick file discrepancies and corrective actions taken and planned.
The events discussed in the memorandum'ncluded the admission of the stick file clerk to discarding the stick file changes, and the corrective actions taken such as notifying-management of the problem, replacing the clerk, placing the files in a "Temporarily Uncon-trolled" status while a 1004 audit was conducted, and requesting Nuclear Quality Assurance's (NQA) assistance.
Key documents reviewed included:
Technical. Procedure (TP) 1.4, Nuclear Quality Assurance Procedure (NQAP)
12. 1', Nuclear Department Instruction's (NDIs) NDI-QA-15.2.3, and Engineering Procedures Manual (EPM) EPM-QA-209.
Other documents reviewed are listed in Attachment A.
The inspector verified the implementation of corrective actions stated in SRMS Manager's memorandum and of the program procedures by observing SRMS work in progress.
After the observations and interviews with engineering and SRMS personnel, the inspector selected a sample of the drawings from the work observed and verified that th'- requirements of the stick files program had been implemented.
2.4 Ins ection Findin s
2.4. 1 Alle ation Substantiated The SRMS Manager's memorandum and QA Surveillance Record (QASR)89-095 substantiated the allegation.
The GO stick file clerk on June 1,
1989, admitted to the SRMS Manager that he had not been "posting" (attaching changes)
to all of the respective stick files from August 1988 through May 1989 and that he discarded some of the changes.
2.4.2 Monitorin Actions'rior to the Discover of the Stick File Problem Nuclear Quality Assurance (NQA) conducted nine QA surveillances in the stick file ar ea between June 1986 and May 1988.
A QA surveill-ance is an assessment of designated activities by direct observation or records review to determine if they conform to established criteria and/or identify trends adverse to quality.
The survei ll-ances were satisfactorily performed in accordance with NQAP 12. 1 and all the findings were minor and corrected in a timely manner.
The inspector reviewed the QASRs and did. not find any evidence of a potential stick file problem.
In the same time period, two QA audits that included the review of GO stick files were conducted and the stick files were found to be adequately controlled and maintained current.
The QA audits were detailed and all findings were adequately correcte From August 1988 through May 1989, the period that the stick file problem existed, there was no QA,audit or QA surveillance activity in the stick file area.
NQA supervision believed the QASRs and QA audits indicated an improving trend; and, therefore, the monitoring period could be extended.
The next QA audit in this area would have been scheduled around August 1990 (2 year audit cycle).
2.4.3 Immediate Corrective Action SRMS Manager's immediate corrective action was to replace the stick file clerk, personally inform management and Engineering Group headers of the problem, and conduct 100%
SRMS audits in accordance with TP 1.4.
On June 2,
1989, the SRMS Manager is-sued a memorandum explaining the problem and corrective actions being taken.
The stick files were also labelled "Temporarily Uncontrolled."
The SRMS Manager also met with NQA and a
QA surveillance was initiated on June 2,
1989 a
QA Surveillance Record QASR No.89-095.
The QA, surveillance was completed and the QASR was issued on June 22, 1989.
The licensee's 'Corrective Action Tracking/Trending System indicated that a followup svrvei llance (QASR 89-133, started on September 19, 1989) would be completed on October 9,
1989.
2.4.4 Current Corrective Actions Three monthly SRMS sample audits followed the 100%
SRMS audits.
The inspector observed the audit of.75 Electrical Stick File drawings.
Also observed was the use of the Design Document Management System (DDMS) and stick files by engineering personnel as they performed tasks for Design Change Packages (DCPs)
Nos. 87-9090, 87-9209, 87-9117, 88-3054, and 89-30001A.
The inspector noted that the engineers do rely on DDMS, as required by NDI-QA-15. 2.3, rather than the stick files.
DDMS is an automated system that contains information about.
modifications, design documents, and design changes.
Activities observed included:
requesting the DDMS to place the engineer on
'istribution for all the postings for a specific drawing; searching for closed out design changes; and requesting the latest postings for several drawings and searching the discipline group files for these postings.
The engineers were knowledgeable of the use of DDMS and the, stick files.
Based on discussions with engineers an'd their use of the DDMS, there was no indication that th~ stick file problem caused any design change errors.
The problem apparently caused only some inconvenience to design engineers.
The inspector requested SRMS personnel to provide selected drawings and postings from the above DCPs.
The inspector also visited the areas where these documents are maintained.
The files are properly organized, retrievable, and maintained in accordance with Regulatory Guide 1.88, Collection, Storage and Maintenance of Nuclear Power P
P 1 ant Qual ity Assurance Records."
2.4.5 Preventive Actions Licensee actions taken to preclude recurrence included: reassigning the previous stick file clerk to handling non design-rel'ated corre-spondence; dividing the GO stick file clerk responsibilities among three clerks; conducting monthly SRMS sample audits with SRMS auditors; and conducting a follow-up QA surveillance to ensure that actions taken do preclude recurrence.
Planned future preventive actions include continuing the SRMS sample audits and the QA survei llances, as well as adding the stick file area in the QA audit scheduled in August 1990.
2.5 Conclusion The allegation was substantiated.
However, the problem had been discovered by the licensee and corrective actions were quickly implemented.
Preven-tive actions should preclude recurrence of the problem.
The drawing control problem was restricted to t>>e corporate offices and had no effect on drawing control at the 'licensees'uclear facilities.
This occurence was not a reportable even ATTACHMENT A Procedures (Paragraphs 2.3 and 2.4)
EPM-QA-209, Modification Package, Rev.
7.
EPM-QA-604, Modification Package Closeout, Rev.
NDI-QA-2.2. 1, Susquehanna Steam Electric Station Records, Rev.
5.
NDI-QA-5.2. 1, Significant Operating Occurrence Reports, Rev.
3.
NDI-QA-8.1.7, Reporting of Significant Conditions Adverse to Quality, Rev. 3.
NDI-QA-8.1. 11, Quality 'Assurance Surveillance Program, Rev.
NDI-QA-15.2.3, Configuration Control Program, Rev.
3.
NDI-QA-15.2.4, As-Built Drawing Requirements, Rev.
3.
NQAP 12. 1, QA Surveillance Program, Rev.
SRMS TP 1.4, Drawing Stick File Establishment and Maintenance, Rev.
9.
SRMS TP 14. 11, Controlled Stick File Maintenance SSES, Rev.
13."'esi n Chan e Packa es DCPs (Paragraph 2.4)
DCPs 87-9090, 87-9117, 87-9209, 88-3054, 89-3001A
~Drawin s
(Paragraph 2.4)
Electrical E-9, E-28-1, E-28-4, E-152, E-153, E-159, E-184, E-281-1 E-,351-38 Mechanical M141, M146 Instrument and Control J-26-1, J-149, J-161, J-451, J-461, Civil C-293, C-1193, C-1948 QA Surveillance Records (QASRs)
Nos.86-046, 86-112,86-114, 87-078,87-131, 87-132,88-106, 88-138,89-095, and 89-133.
Corrective Action Tracking/Trending System of September 26, 1989 QA Audit Report Nos.86-021, 87-042,88-078 Miscellaneous (Paragraph 2.3 and 2.4)
Regulatory Guide 1.88, Collection, Storage, and Maintenance of Nuclear Power Plant Quality Assurance Records.
Rev.
2, October 1976 Memorandums PLI 58039, 59044, 61424.
Memorandum of June 2, 1989,
"Summary of Events Regarding General Office Stick File Discrepancies; June
8 2, 1989"