IR 05000410/1981008
| ML17053C843 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 09/03/1981 |
| From: | Feil R, Kister H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17053C842 | List: |
| References | |
| 50-410-81-08, 50-410-81-8, NUDOCS 8109240534 | |
| Download: ML17053C843 (22) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT Region I Report No. 50-410/81-08 Docket No. 50-410 License No.
CPPR-112 Pr'iority Licensee:
Nia ara Mohawk Power Cor oration 300 Erie Boulevard West S racuse New York 13202 Category B
Facility Name:
Nine Mile Point Unit 2 Inspection At:
Scriba, New York-0 Inspection Conducted:
Inspectors:
Feil, August 4-6, 1981 tor Inspec r
dat s'gned Approved By:
.B. Kist
, Chief, Reactor Projects Section 1C, Division of Resident and Project Inspection date signed
~w s/
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gned Ins ection Summar
Ins ection on Au ust 4-6 1981 Re ort No. 50-410/81-08 Areas Ins ected:
Routine unannounced inspection by one regional based inspector of unresolved items, facility status and licensee's qA program.
The inspection consisted of 24 inspector-hours onsite and 7 inspector-hours in office by one regional based inspector.
Results:
No items of noncompliance were identified.
Region I Form
(Rev. April 77)
8109240534 8l0904 I PDR ADOCK 05000410
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DETAILS Persons Contacted Nia ara Mohawk Power Cor oration NMPC W.M.
R.C.
- S E
- J G.J.
- L.H.
- E.J.
R.A.
R.L.
- J.R.
Bryant, QA Manager Clancy, Senior Vice President Czuba, QA Engineer Dillon, QA Engineer, Site Lead Doyle, QA Technician Fenton, Senior QA Technician Manning, Senior QA Engineer Norman, QA Supervisor Patch, QA Technician Saurini, Senior Lead Engineer Stone and Webster En ineerin Cor oration SWEC
- S.W. Crowe, Assistant Superintendent, FQC
- E.P. Eichen, Assistant Superintendent, Engineer
"C.E. Hilton, Superintendent of Construction R.J.
Huggons, QC Engineer
"M.G. Pace, Project QA Manager
- G.W. Pierce, Site QA Supervisor
- H.J. Pierre, Chief, Engineering Office
- L. Shea, Superintendent, Engineering ITT-Grinnell D. Giguere, Superintendent L. Pela, Documentation Supervisor
- Denotes those present at exit meeting.
The inspector conferred with other licensee and contractor personnel during the course of the inspection.
Licensee Action on Previous Ins ection Items (Closed)
Unresolved Item (78-88-01):
Ensure licensee is aware and has taken any needed action regarding Byron Jackson pump seal piping not adequately hydrotested;
CFR 21 Report No.
77 012000.
The inspector reviewed the records relating to the hydrotesting of the pump seal
cooling water piping to verify it meets ASME specifications for the RHR pumps and the HPCS pump.
Shipping and receiving records were verified.
The Non-Destructive Inspection reports for the HPCS seal flange stated that the unit was hydrotested to 900 psi for 45 minutes.
A Certificate of Conformance dated February 8, 1979 attested to the re-hydrotesting of the seal flange to conform to Byron Jackson Pro-cedure 1T-5715, Revision F.
The Non-Destructive Test Reports for the RHR Seal Flanges stated that the units were hydrotested to 750 psi for 45 minutes.
Certificates of Conformance for the three units, dated February 8, 1979 attested to the re-hydrotesting of the seal flange to conform to Byron Jackson Procedure 1T-5715 Revision F.
The inspector had no further questions on this item.
This item is considered closed.
(Closed)
Unresolved Item (81-05-03):
Adequacy of site quality staffing.
NMPC has contracted with Universal Testing Laboratories, Inc. for additional site quality assurance personnel.
Six (6) persons reported for work on August 3, 1981; 2 additional persons will report for work on August 10, 1981.
The site quality assurance staff will consist of 14 technical persons and 1 administrative person.
These 14 persons provide surveillance in the areas of Structural, Mechanical, Piping/NSSS, Electrical and I&C/Building Service/Program.
The inspector reviewed the qualification records for the new personnel and verified that they were qualified to ANSI N45.2.6.
The inspector had erroneously reported in Report No. 50-410/81-05 that the site quality control staff would be increased to 11 persons under the reorganization reporting through the Manager, Project guality to the Project Manager.
The present site quality assurance organization consists of 14 technical persons and l,administrative person.
A description of the organization structure and group and individual responsibilities is as follows:
The activities of each Group are directed by a ~Grou Leader who assures that surveillance plans, schedules and assignments within his areas of>>-
responsibility are carried out, and performs any additional surveillance he may deem necessary.
He assigns surveillance activities to contracted gA staff members in his Group, and supervises their performance of these surveillances.
Surveillance Reports generated by contracted gA staff members are reviewed by the Group Leader, who initials and dates the Reports, and submits them to the Site gA Engineer (Lead)
when he is satisfied with their content and validity.
The Group Leader performs all work preparatory to conducting scheduled procedure verification survei llances, including review of applicable procedures and preparation of checklists, and generally conducts these survei llances, with the assistance of contracted gA staff members as he deems appropriate.
When contracted gA staff members identify negative findings or concerns, the Group Leader closely monitors their efforts to resolve the concerns, advises them as to appropriate actions, and initiates any necessary Action Sheets or Nonconformance Reports.
Finally, the Group Leader
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interfaces regularly with the Site QA Engineer (Lead),
keeping him fully apprised of the status of surveillance activity and adverse findings.
The planned 'Site Quality Assurance Organization includes eight con-tracted QA staff members employed by Universal Testing Laboratories.
These gA Ins ector/Technicians are assigned to work in the various Groups under the functional direction of the Group Leaders.
They perform and document surveillance activities assigned by the Group Leader.
They interface closely with the Group Leader on any negative findings or concerns, pursue resolution of concerns through normal channels, and inform the Group Leader when those channels appear to be ineffective or insufficient and an Action Sheet or Nonconformance Report seems to be warranted.
Administrative Or anization Administrative functions include time and expense reporting, approval of vacations and holidays, reporting of sickness or other job absence, and other related areas.
and all the NMPC Group Leaders report administratively to the Unit P2 QA Supervisor.
Since the Site QA d)
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e2 OA that individual retains full authority to give functional direction to, the Site QA staff through the Site QA Engineer (Lead),
and can in addition make direct functional assignments to any member of the Site QA staff relating to special off-site or audit activities.
The contracted QA site staff members (Universal Testing Laboratories)
report administratively to the designated UTL administrative supervisor, who in turn reports to the NMPC Site QA Engineer (Lead)
on all administrative matters.
Represented members of the Site QA staff report administratively to the Administrative Assistant to the QA Manager.
Functional Or anization The function of NNPC Site ~ualit Assurance is to assure, by surveillance of Stone 5. Webster and subcontractor activities and programs, that site work conforms to quality requirements as defined in the Project Safety Analysis Report, regulatory requirements, approved QA programs and procedures, and applicable design drawings and specifications.
This includes verification that the various quality programs at the site are being implemented, as well as assessment of the adequacy of those programs.
Site QA surveillance activities, and the status of any adverse findings, are regularly reported to Niagara Mohawk management through the Unit 82 Quality Assurance Superviso The NNPC.Site gA En<nineer ~Lead has overall responsibility for directing and administering the Site Surveillance Program, and in this capacity acts as functional supervisor for the site staff, including contracted staff.
He plans, schedules, and directs the performance and documentation of site surveillance activities to assure implemenation of adequate quality programs at the site, and to assure that site conditions adverse to quality are identified and resolved.
He reports regularly to the Unit ¹2 QA Supervisor on the activities and findings of Site Quality Assurance.
The NMPC Site Quality Assurance Organization consists of five major
~Grou s, each of which monitors work, inspection, and testing activities and procedural compliance in their assigned areas, to assure that appropriate quality requirements are established and implemented.
The five Groups are as follows:
1.
Structural Grou
Monitors civil and structural activities and programs, including concrete, steel, structural welding, buildings (siding, roofing, decking, etc.),
masonry, protective coatings, earthwork, tunnels, and geology.
2.
Mechanical Grou
Monitors site activities related to maintenance, handling and installation of equipment, and field fabrication and erection of welded components including the primary containment liner, fuel pool liners, and biological shield wall.
3.
Pi in /NSSS Grou:
Monitors, site fabrication/installation of piping components and systems, including valves, restraints and supports.
Also monitors site activities relating to the Nuclear Steam Supply System, including the Reactor Pressure Vessel and related equipment, piping systems and appurtenances.
4.
Electrical Grou
Monitors handling and installation of electrical equipment and components, raceway and supports, cable installation and termination, and related storage and maintenance activities.
5.
?EC/Bui ldin Services/Pro rams Grou
Monitors activites in in-strumentation and controls (not active at this time), building services (including heating, ventilation and air conditioning, fire protection, plumbing, drainage, and other plant service systems),
and various site program areas (including field procurement, receiving, general storage, material control, rigging, METE control, document and document change control, records management, nonconformance systems, audits and training).
The inspector examined records of the increase in staffing for the Field Quality Control (FQC) for Stone and Webster.
The inspector had previously expressed concern that the site quality staffing might not keep pace with the increase in construction manual and non-manual personnel.
The SEW FQC staff has increased by 21 persons since May 21,
1981, to the current level of 73 with an additional proposed increase to 79. This has increased from a total of 30 persons as of January 1,
1981.
The FgC staffing appears to have kept pace with the increase in manual site construction personnel.
The inspector had no further questions regarding FgC staffing at this time.
Faci 1 it
- Tour The inspector observed work activities in progress, completed work and plant status in several areas of the plant during a general inspection of the plant.
The inspector examined work for any obvious defects or noncompliance with regulatory requirements or license conditions.
Particular note was taken of presence of quality control inspectors and quality control evidence such as inspection records, material identification, nonconforming material identification, housekeeping and equipment preservation, and quality inspection personnel as they were available in the work areas.
The inspector observed the continued welding of the overlay on the biological shield wall.
The inspector noted that the Reactor Building had been cleaned up somewhat; however, additional effort is needed in this area in order to insure satisfactory cleanliness and storage of components in the Reactor Building.
No items of noncompliance were observed.
Faci lit Status The licensee informed the inspector that the facility is 31% complete as of July 15, 1981.
Manpower has increased to 1989 manual and 601 non-manual.
Construction activity included, but was not.limited t'o',;
electrical cable tray installation, rebar i'nstallation on primary containment wall, secondary containment and deck placement, control building construction,- electric tunnel wall construction, pipe erection of RHR, service water, HPCS and CCS and piping in turbine building, containment penetrations, repair of primary containment liner, fit up and welding on biological shield wall, continued effort on lake tunnels, structural steel in turbine, control, and service building, reactor building structural steel erection,'xcavation for Radwaste Building foundations, cooling tower and fuel pool liner fabrication.
Licensee Audits of Contractor Activities Audits by the licensee of contractor activities are conducted quarterly.
The inspector reviewed the last six audits conducted by the licensee.
These audits covered activities of Stone and Webster, CBI, ITT-Grinnell, Johnson Controls, and Schneider Comstock.
Areas audited included but were not limited to compliance with the gA program, surveillance activities, corrective actions, application of procedures and instructions
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to contractor activities, effectiveness of surveillance activities, personnel qualification, document control, records management and follow-up on audit findings.
The inspector noted that in general details of area audits were well documented regarding the activity.
However in the area of follow-up of audit findings, there was very little follow-up documented.
The licensee recognized this deficiency in the audit report and has documented all outstanding follow-up actions which have=not been closed out.
The site QA representative has been detailed the responsibility of verifying closeout action on outstanding follow-up actions for audits 1 through 20.
The inspector verified that the licensee has a program for ensuring that all audit findings and actions are documented and action initiated to closeout the audit findings.
The inspector had no further questions in this area.
ualit Assurance Manual Review-Reactor Controls Inc.
The inspector reviewed correspondence and meeting minutes of Stone and Webster's review of the Quality Assurance Manual for Reactor Controls, Inc.
Reactor Controls, Inc.
has been contracted to install the remaining reactor internals, design, fabricate and erect the CRD Hydraulic System and erect the Reactor Coolant Recirculation system.
By letter dated May 21, 1981, Stone and Webster stated that their review of the Reactor Controls, Inc.
QA Manual was complete and found acceptable for use at NMP-Unit 2.
ualification of Persons Performin ualit Assurance Activities Contractors The inspector reviewed survei-llance reports by Stone and Webster of ITT-Grinnell and CBI training and qualification records of persons performing field inspections.
(NDE personnel were certified to SNT-TC-lA requirements.)
The reports indicated that these persons were qualified to their respective QA manuals but were not qualified to ANSI N45.2.6-78 as required by S&W Specification P275C (Equipment Setting Contract).
The contracts between S&W/ITT-Grinnell and S&W/CBI did not specify that persons performing field inspections be qualified to ANSI N45.2.6-78.
The surveillance reports recommended that the subcontractors upgrade their Training, Qualification and Certification Program to meet the requirements of ANSI N45.2.6-78.
The reports indicated that qualification records of persons performing field inspections were evaluated and that the persons performing surveillance had the qualifications to be certified to Level I or Level II in accordance with ANSI N45.2.6-78 based on education and experience or capability testing.
The inspector independently selected qualification records and verified that the persons were qualified to meet the stated requirements.
The inspector also noted that the subcontractors are upgrading their training and qualification program to meet the S&W specification requirements.
The training and records are expected to
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be completed and updated by August 31, 1981.
The licensee has issued a Nonconformance Report to S&M to ensure that all requirements are met and that the requirements in ANSI N45.2.6-78 are invoked on all vendors and site contractors and that all vendor and site contractor QA manuals be reviewed against the requirements of ANSI N45.2.6-78.
The inspector had no further questions on this matter.
Pro osed A Function Reor anization On January 26, 1981, NMPC met with the Division of Licensing, Office of Nuclear Reactor Regulation (DL, ONRR) to discuss the reorganization of the NMPC management structure as it affects the QA organization for NMP2.
NMPC proposed to reorganize its QA function into two organizations:
(I) a Project Quality Organization, which reports to NMP2, Project Manager and (2)
a Corporate Quality Assurance Department, which reports to a senior vice president.
The licensee submitted a description of the Project Quality Organization to DL, ONRR on March 25, 1981.
The new proposed Project Quality Organization, reporting to the Project Manager, will perform the day to day quality functions of the project.
The Corporate Quality Assurance Department, which is completely independent of the project, will continue to perform the required audits and advise Corporate senior management whether the project is in compliance with the Quality Assurance Program for Nine Mile Point Unit 2.
The Project Quality Organization, when implemented, will comply with the established Quality Assurance Program as described in the Niagara Mohawk Quality Assurance Manual for Nuclear Reactors-Design and Con-struction Phase.
It will also comply with Appendix D of the Pre-liminary Safety Analysis Report except for the organizational changes.
The Project Quality Organization will continue to function in accordance with the existing Corporate Quality Assurance procedures until such time as its own procedures are finalized.
The function of the Project Quality Assurance Program are divided into 2 groups as follows:
Project ualit Or anization This group reports to the Project Manager.
This group will perform the following functions:
a.
Maintenance of a proper Quality Assurance Program.
b.
Review of procurement documents for adequacy of quality conten J
c.
Monitoring the vendor qualification program.
d.
Monitoring the performance of all project participants in the performance and effectiveness of their quality programs.
e.
Managing the project quality budget.
f.
Performing the quality control functions required during start-up and testing.
g.
Reporting to project management on the progress and status of quality on the project.
h.
Initiating quality related corrective actions as necessary.
Staff members are being selected for unique backgrounds which do not necessarily appear on the organization chart or in the personnel qualification descriptions.
The backgrounds include ASME Code knowledge, non-destructive examination, records management, materials storage and warehousing and engineering design experience.
There are two factors which govern the staffing level.
These are:
a.
The amount of work left to be done in a specific area, and b.
The required level of coverage.
The Project guality Organization, will perform audits with teams of at least two people.
One of these will be a qualified lead auditor who will actually lead the audit or will participate in the audit and sign the report.
Where only one person is assigned to a specific area, other Project equality personnel will be used as part of the audit team. guality Assurance Department personnel may also participate.
Cor orate ualit Assurance De artment This department reports separately up the corporate organization to the President of Niagara Mohawk.
This group will perform the following functions:
a.
Reviewing and approving the Project guality Assurance Program.
b.
Auditing the project on its implementation of the Project guality Assurance Program.
c.
Assuring corporate senior management that the project complies with the Project guality Assurance Progra I.
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Inde endence The Project Quality Organization is to have unlimited access to the project, its participants and records for the purpose of verifying quality plans and performance.
Any member of the group has the right and responsibility to recommend a Stop Work action to the Project Manager when conditions are observed which constitute<<.,'
failure to meet quality objectives and are-:either~severe or are. not being corrected through regular channels..
Independence will be further ensured by overview of the Project Quality Organization by the Corporate Quality Assurance Department.
This group is completely independent of the project and wi 11 perform audits on the project.
The Corporate Quality Assurance Department's staffing and coverage will be sufficient to fulfill their responsibilities in the Nine Mile Point Unit 2 Quality Assurance Program at each stage of the project.
Procedures The Project Quality Organization, when fully implemented, will comply with the Quality Assurance Policies of the Comp'any as described in the Niagara Mohawk Quality Assurance Manual for Nuclear Reactors-Design and Construction Phase and Appendix D of the Unit 2 Preliminary Safety Analysis Report.
These policies are designed to meet Appendix 8 to 10 CFR 50.
Additionally, the Project Quality Organization will have its own implementing procedures patterned after the corporate procedures.
These procedures will be reviewed by Corporate Quality Assurance and have the concurrence signature of the Manager, Corporate Quality Assurance.
The Project Quality Organization will continue to use the Corporate Quality Assurance Department procedures until such time as its own procedures are finalized.
The inspector informed the licensee that some functions of the proposed Project Quality Organization were contrary to Criterion 1, Appendix B,
CFR 50 which states in part,
"The persons and organizations per-forming quality assurance functions shall have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend, or provide solutions; and to verify implementation of solutions.
Such persons and organizations.-performing quality assurance functions shall report to a management level such,'that this required authority and organizational freedom, including sufficient independence from cost and schedule when opposed to safety considerations, are provided."
Under the proposed reorganization, the Project Manager directs and controls NMP-2 construction, records management, quality control, cost and scheduling, test and startup and cost accounting.
The inspector informed the licensee that the proposed reorganization does not provide sufficient independence of some quality assurance functions to insure
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that safety considerations would take priority over cost and scheduling when each is controlled and directed by the Project Manager.
9.
Exit Interview The inspector met with the licensee's representatives (denoted in Paragraph 1) at the conclusion of the inspection on August 6, 1981.
The inspector summarized the purpose and scope of the inspection and the findings.
The licensee acknowledged the inspector's finding ~
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