IR 05000410/1986015
| ML17055B721 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 05/23/1986 |
| From: | Briggs L, Dev M, Jerrica Johnson, Petrone C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17055B720 | List: |
| References | |
| 50-410-86-15, NUDOCS 8606030121 | |
| Download: ML17055B721 (28) | |
Text
U.S.
NUCLEAR REGUIATORY COMMISSION
REGION I
Repor t No.
50-410/86-15 Docket No.
50-410 License No.
CPPR-112 Licensee:
Nia ara Mohawk Power Cor oration 300 Erie Boulevard West S racuse New York 13202 Facility Name:
Nine Mile Point Unit No.
Inspection At:
Scriba New York Inspection Conducted:
A ri 1 7-11 and 21-25 1986 Inspectors:
C.
P t one, e
Reactor Engineer date L. Briggs, Le Reactor Enginee date M. Dev, Reactor Engineer date Approved by:
Q.
J. Johnson, Chief Operational Programs Section, OB, DRS Ins ection Summar
- Ins ection on A ril 7-11 and 21-25 1986 Ins ection Re ort Number 50-410/86-15 date Areas Ins ected:
Routine, unannounced inspection by three region-based inspectors of administrative procedures, operations procedures, design changes and modifications, and preoperational testing.
Results:
No violations were identified.
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DETAILS 1.0 Persons Contacted Nia ara Mohawk Power Cor oration
"T. J. Perkins, General Superintendent, NMPC
~R.
B. Abbott, Unit 2 Station Superintendent, NMPC R. Randall, Supervisor, Technical Support, NMPC
"T. B. Lee, Special Projects, NMPC G. J.
Doyle, Supervisor, Quality Engineering, NMPC M. J.
Ray, Manager, Special Projects, NMPC J.
L. Drake, Startup Special Projects Supervisor, SWEC
"W. R. Yaeger, Manager of Engineering, NMPC
- L. Weakly, Special Projects, NMPC
"M. Jones, Superintendent of Operations, NMPC J.
Dominy, QA Operations, NMPC A. Anderson, Station Shift Supervisor, NMPC M. Colomb, Station Shift Supervisor, NMPC J.
Bufus, Test Group Manager, NMPC US Nuclear Re ulator Commission R.
Gramm, Senior Resident Inspector, NMP Unit 2 S. Kucharski, Resident Inspector, Limerick
"S. Hudson, Senior Resident Inspector, NMP Unit 2
~Denotes those who attended the exit meeting on April 22, 1986.
2.0 Plant Procedures Administrative control procedures were reviewed to verify the adequacy and scope of plant procedures and the management con-trols established to implement and maintain them.
2. 1 References
CFR 50, Appendix B, Quality Assurance Criteria for Nuclear for Nuclear Power Plants, Criteria V, VI, XIV, XVII, and XVIII; ANSI N18.7 (Regulatory Guide 1.33 1978), Administrative Control and Quality Assurance Program Requirements (Operations)
Technical Specifications, Section 6 (Proof and Review)
ANSI/ANS 3. 2-1982
I
Nine Mile Point Unit 2 FSAR Nine Mile Point Units 1 and 2 guality Assurance Program Topical Report NMPC-gATR-1 Rev.
1.
2.2 Pro The following procedures were reviewed:
AP-1.0 AP-1.1 AP-1.2 AP-1.3 AP-2.0 AP-3.0 AP-3. 1 AP-3.2 AP3.2. 1 AP-3.2.2 AP-3.3. 1 AP-3.3.2 AP-3.4. 1 AP-3.4.2 AP-3.4.3 AP-3.5 AP-3.6 AP-3.7 AP-4.0 AP-4.1 AP-5.0 AP-5. 1 AP-6.0 AP-7.0 AP-7. 1 AP-8.0 AP-8. 1 AP-8.2 AP-8.3 Procedur e for Administrative Control Composition and Responsibility of Site Organization Composition and Responsibility of Unit Organization Personnel Responsibilities and Authority Start-Up Test Phase Production and Control of Procedures Assurance of Safety Control of Access Industrial and Radiological Safety Maintaining Occupation Exposure to Radiation and Radioactive Materials ALARA Asbestos Removal and Handling Control of Equipment (Markups for Personnel Safety)
Control of Equipment (Placement of Jumpers or Blocks or Lifting of Leads)
Administration of Technical and Safety Reviews (Site Operations Review Committee)
Administration of Technical and Safety Reviews (Operations Experience Assessment)
Administration of Technical and Safety Reviews (Safety Engineering Review Panel)
Station Fire Protection Program Special Nuclear Material Control Program Process Control Program Administration of Operations Communications System Procedure for Repair Site blelding Program Procedure for Modification and Addition Procedure for Control of Material and Services Procedure for the Control of the Use and transfer of Organic Materials Assurance of Equipment Integrity Procedure for Service and Preventive Maintenance Surveillance Testing and Inspection Program Inservice Inspection and Test Program
,%>r
AP-8.4 AP-8 '
AP-8.6 AP-8.7 AP-9.0 AP-10. 1 AP-10-2.1 AP-10.2.2 Control and Calibration of Equipment Used in Tests and Inspections Housekeeping and Cleanliness Control Procedure for Pre-Operational Tests Startup Test Procedures Training Management of Station Records Production, Distribution and Maintenance of Operating Reports and Responses to NRC Requests.
Reporting Variations from Normal Plant Operations, Defects and Noncompliance 2.3 Procedure Review The 2.2 inspector reviewed the licensee's procedures listed in paragraph and determined that:
The licensee has established administrative controls for review, approval and periodic updating of administrative, general plant operations, startup, operation and shutdown of safety-related systems, and night order or standing order procedures.
Responsibilities for review, update and approval of plant procedures, including incorporation of changes per
CFR 50.59 and temporary changes, have been established.
Preparation of station procedures including format and contents are controlled.
Issuance of new and revised procedures and disposition of outdated procedures are controlled.
Plant procedures, including night orders, are periodically reviewed by cognizant individuals.
Shift turnover activities and review of the operating logs are conducted in accordance with written procedures.
The procedures in use in the control room were the latest revision.
The operating staff turnover checklists had been completed as required.
The inspector verified that the administrative control procedures specified in Table 13.5-3 of the FSAR had been issued.
The inspector also reviewed a sample of recently issued plant procedures to verify that:
Review, approval, and updating has been made in accordance with the licensee's administrative control procedures; Issue of new procedures and control of superseded procedures has been in accordance with the licensee's administrative control procedures; and, The working copy is the same revision as the current approved revision in the master file.
The following procedures were reviewed:
OI-8, Occurrence Reports, Revision 1, dated March 31, 1986; TOP-8, Post. Maintenance Testing Criteria, Revision 0, dated February 28, 1986; N2-FP-2 Nuclear Fuel Receipt and Storage Fire Match/Fire Fighting Procedure, Revision 1, dated December 4,
1985; N2-MMP-1. 10, Maintenance of Main Steam Isolation Valves, Revision 0, dated March 18, 1986; N2-MMP-29.6, Replacement of Recirculation Pump Seals, Revision 0, dated September 4,
1985; N2-RAP-5, Operation of Bucle, Revision 0, dated March 5, 1986; N2-IOP-13, Reactor Building Closed Loop Cooling, Revision 2, dated April 2, 1986; N2-IOP-39, Fuel Handling and Reactor Service Equipment, Revision 0, dated March 11, 1985; N2-IOP-33, High Pressure Core Spray System, Change 8, dated December 12, 1985; and, N2-IOP-32, Low Pressure Core Spray, Revision 1, dated March 24, 1986; The inspector's review did not identify any discrepancies.
The procedures were generally well written and clear.
However, it was noted that the IOPs (Interim Operating Procedures)
were all approved but were marked "not to be used after initial fuel load".
Therefore, these procedures will need to be reviewed and re-issued prior to plant operation.
3.0 0 eratin Procedures 3. 1 The inspector performed a review to confirm that the plant operating-procedures met applicable regulatory requirements and were adequate to.
control safety related operations.
This review was made against the
references specified in paragraph 2. 1 and the administrative control requirements specified in paragraph 2.2.
In addition to the operating procedures specified in paragraph 2.3, the following operating procedures were reviewed to verify that each was in the appropriate format as specified in the administrative control procedures and that they appeared technically adequate to accomplish its stated purpose.
N2-IOP-29, Reactor Recirculation System, Revision 1, dated 7/16/85; N2-IOP-53A, Control Room Ventilation System, Revision 1, dated 3/24/86; N2-IOP-101A, Plant Startup, Revision 2, dated 6/21/85; N2-IOP-101B, Plant Startup to that Standby, Revision 0, dated 4/22/86; N2-IOP-101C, Plant Shutdown, Revision 0, dated 4/18/85; N2-IOP-ll, Service Water Systems, Revision 0, dated 3/10/85; and, N2-IOP-30, Control Rod Drive, Revision 2, dated 9/13/85.
3.2 During this review the inspector verified that appropriate operating limits, prerequisites, precautions, plant conditions, limitations and actions, reactivitity control instructions, acceptance criteria, and sequence of operations had been incorporated.
The IOPs are interim operating procedures and will be used during testing and converted to plant operating procedures.
The licensee has identified those procedures which are safety related and has labeled them to indicate that they cannot be used after initial fuel load.
Of the 115 IOPs approved, 55 have been identified as required to be reissued as operating procedures (OPs) prior to fuel load.
Thirty-one of these fifty-five OPs have been issued as of April 24, 1986.
4.0 Overall Status of Procedures As of April 24, 1986 the licensee had approved the following numbers of procedures.
Total Required Number for Fuel Load A
roved Percent A
roved Power Ascension 115 70/'hemistry
15 27%
Reactor Analyst
23 49%
Inservice Inspection
29 97%
Computer Total Required for Fuel Load Number A
roved Percent A
roved 33%
Instrument 5 Control
22 88%
Electrical 126 / 83 119 / 82 94% / 99%
Mechanical Piping - Preop/
Power Ascension VIB 180 / 180 180 / 180 100% / 100%
17%
Surveillance 492 / 181 309 / 105 63% / 58%,
Administrati ve
69 100%
Training
100%
Document Control
53%
Operation Interim 115 114 99%
Operati on Final 131 / 55 33 / 31 25% / 56%
22%
Radiation Protection
52 32%
Environmental
13 50%
Fire Protection
17 94%
Waste Handling
15 100%
Total 1596 1054 66%
The inspector noted that approximately four hundred and forty additional procedures in draft form were under review.
The remaining one hundred (approx.)
procedures were not yet, completely written.
These incomplete draft's include twenty surveillance and seventy operations procedures.
Based on this review the inspector concluded that although the majority of procedures had been approved, a substantial amount of work remained before the remaining procedures could be approved, especially operations and surveillance procedures.
The inspector will continue to monitor the completion of procedures during future inspections.
5.0 Plant Tours The inspectors toured the reactor building and control room and observed the following:
Plant construction appeared to be essentially complete with some pipe support modification work, pipe insulation installation, and painting ongoing.
The housekeeping appeared to be generally satisfactory at this stage of construction.
A substantial cleanup effort is planned during the transition from construction to operation.
The plant personnel who accompanied the inspector on the tour, and the other operations personnel contacted during the tour were very knowledgeable of the plant systems and equipment.
During tours of the reactor building one of the inspectors observed two instances where portable weld rod containers (ov'ens)
had not been plugged-in to energize the heaters.
Mhen questioned by the inspector both welders plugged in the ovens.
Later review of welding requirements by the inspector and the licensee's gA Manager identified that in one case the weld was a non-safety related weld and in the other case the type of weld rod used could be stored unheated for up to four hours.
In this case the oven had only been unplugged for approximately one hour.
The inspector discussed these incidents with the gA Manager, the Construction Superintendent, and the licensee management at the exit meeting.
They assured the in-spector that the welders involved had been re-instructed about the heating requirements of the weld rods during storage.
They also in-dicated that gC coverage of welding activities was in progress.
The inspector had no further concerns.
6.0 Desi n Chan es and Modifications 6. 1 Pro ram Review Im lementation and Findin s
The inspector reviewed the licensee's Administrative Procedures for design changes and plant modifications, AP-6.0 and AP-6. 1, and related
t sr
interface departmental procedures and instructions (listed in Attachment 1)
such as, quality assurance, procurement, nonconformance reporting, and mainte-nance.
At the time of this inspection the licensee acknowledged that
systems have been turned over to the Operation Group.
Any modifications to plant systems, structures and components are under the control of the Niagara Mohawk Power Corporation (NMPC) Administrative Procedures and changes are processed in accordance with the requirements contained therein.
Administra-tive Procedure AP-6. 1 describes the mechanisms for the initiation and control of replacements, additions, or modifications (temporary or permanent)
of plant systems or equipment.
It delineates the persons and groups and their respon-sibilities and prescribes the methods to be employed for documenting these changes.
This procedure is effective from fuel load through commercial opera-tion, for all systems turned over to the plant Operations Group.
Administrative Procedure AP-6.0 covers the changes and additions to the station process systems, structures, or components when they are completely turned over to the Nuclear Generation Department for commercial operation and maintenance.
The procedure requires that cognizant site Technical Department staff or Nuclear Engineering Department staff to prepare a plant modification or addi-tion request.
After review and approval of the modification request by the plant Superintendent, the Nuclear Engineering Department or the Technical Department as the case may be, develops a functional specification and concep-tual engineering package.
The package includes ( 1)
a Functional Specification, (2)
a Conceptual Safety Evaluation, (3)
a Fire Protection Review and, (4)
a ALARA Review.
For systems as described in the criteria of Appendix A,
CFR 50, the licensee is committed to conduct the design change and modification in accordance with ANSI/ASME NQA-1 and NQA-2-1983.
The licensee has established procedures for the procurement and control of modification related materials.
The cognizant modification group is responsible for ensuring that special processes shall be performed in accordance with applicable codes.
Procedures NT-110.A and NT-180 define the licensee methodology to report material defects and noncompliance reportable in accordance with 10 CFR 21.
The station modification implementation process is initiated with the. issuance of the Modification Work Request (MWR) and activities tracked by the Work Tracking Systems (WTS) for planning for each MWR.
The Administration Procedure AP-6.0 requires that the installation procedures be developed and reviewed prior to installation.
The related tests and inspections are integrated with the installation plan along with the identification of QA witness and hold points.
The procedure also requires that any ALARA and radiation protection concerns are resolved during planning and scheduling stage of the plant modifi-cations.
Any changes to the modification that affect the original safety evaluation are processed through the same procedures as the original modifica-tion and are reviewed and approved by the SORC in accordance with 10 CFR 50.59
requirements.
It is the responsibility of the Operations Group to develop operating, preoperational testing and surveillance procedures and conduct interface coordination with other groups to identify the impact of the modifi-cation work on the safety and integrity of other station systems.
The proce-dure also requires that all safety-related plant modifications and design changes be conducted by qualified and trained personnel.
The Superintendent of Training, or his designee, has responsibilities to develop training curricula, prepare schedule and conduct training for the individuals performing quality control activities of the design changes and modifications.
The inspector also reviewed the licensee's procedure N2-SAP-118.
Presently, the licensee conducts station temporary modifications, lifted leads and jumpers and blocking activities in accordance with this procedure.
The procedure provides methods and responsibilities for controlling these ac-tivities.
In addition, the procedure also provides instructions for the generation and maintenance of records relating to the temporary modifica-tions.
The inspector reviewed the licensee temporary modification.and jumper log, and related restoration documentation on a sample basis, and found them adequate.
A minor di screpancy was noted in the work related to the removal of six Feedwater Pump Motor Bearing Thermocouples.
Only two of the six single element thermocouples were replaced by dual elements thermocouples.
The remaining did not have tags on the components delinea-ting their status.
The operations issued a
new temporary modification order (86-04-233) for the missing ones and properly dispositioned the old modification order (85-04-176).
Temporary Modification Orders reviewed include the following:
85-01-113, 85-03-225, 85-04-135, 85-04-176, 85-05-307, 85-09-029, 85-10-090, 86-01-008, 86-02-050, 86-03-156, 86-04-168, 86-04-233, System System System System System System System System, System System System System 72.002, 2NNS-SWG 011-9 100. A05, 2ENS "SWG-101" 1 15.001, Hydro/Flush, Plastic Tie-in 6.001, Feedwater Motor Bearing Thermocouples 103.001, Rosemount Back Cover Removal 43.005,
~~ -inch Union Installation Testing 66.0026, LS130 5 LS131 Removal 66.009, 2DTM-AOV6A Lead Removal 43.007, 2FPW-PS158,205,243,244 Removal 85.001, Temporary Power WCS Loop 53.001, 2HVCFS9A, Flow Switch 6.001, Feedwater Motor Bearing Thermocouples The inspector discussed the licensee's training program for the individuals performing quality control activities of design changes and modifications with the Assistant Superintendent-Nuclear Training.
A training descrip-tion survey has been distributed to the cognizant station groups to review, evaluate and comment on the training requirements relative to the station design changes and modifications.
The inspector also participated in the licensee introductory session on the implementation of the Administrative Procedure AP-6. 1, Procedure for Modifications and Additions (NMP) Unit The indoctrination discussed the requirements, responsibilities and the administrative controls related to the station design changes and modifi-cation as delineated in the procedure.
No violations were identified.
6.2 A/
C Interface Administrative Procedure AP-6.0 requires that guality Control examine materials, installation, progress testing, and installation documenta-tion and conduct an inspection of the installation as required by the MWR.
These inspections are in accordance with the licensee commit-ments to the requirements of ANSI N45
~ 2.8 and ANSI N45.2.4, and other standards as established by the engineering group.
In addition, any nonconforming situation is resolved using a gA nonconformance per guality Assurance Procedures.
The inspector reviewed the following licensee Operations guality Assurance surveillance reports for the station operation's compliance to the station temporary modification procedure, N2-SAP-118.
25-0018-85, System 103.001, Procedure N2-SAP-118 25-092-85, System 37.001, Procedure N2-SAP-118 25-167-85, System 100.A01, Procedure N2-SAP-118 SR-85-10014, Procedure N2-SAP-118, Programatic SR-85-10063, System 100AKB, Procedure N2-SAP-118 SR-85-10089, Procedure N2-SAP-118, Training 85-1018, Rev.
1, Procedure N2-SAP-118, Corrective Action Report No violations were identified.
However, it is determined that the licensee is planning to develop a comprehensive audit schedule to cover the station design changes and modifications activities.
The effectiveness of such audits will be reviewed in future NRC inspec-tions.
7.0 Preo erational Test Witnessin Testing witnessed by the inspector included the following observations of overall crew performance:
Approved procedure with latest revision available and in use by test personnel; A designated person in charge and conducting the test; Minimum test personnel requirements met; gualified personnel performing the test; Test precautions followed and prerequisites met;
,J
QA/QC hold and witness requirements met (QA engineer present if required);
Proper plant supporting systems in service; Special test and measuring equipment required by the test procedure, its calibration and use; Procedure is technically adequate for the test; Test personnel actions appeared to be correct and timely during performance of the test.
The inspector observed a portion of the performance of Preoperational Test (POT)-100A-1, Division I Diesel Generator, Revision 3.
The emergency diesel generator (EDG) was undergoing a 24 hour2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> load test at the time of observation.
The inspector reviewed the completed portions of POT-100A-1 including test exceptions.
The inspector also toured the EDG bay and independently verified that various temperature and pressure readings were normal for the EDG operating condition.
No unacceptable conditions were observed.
~Ei The inspectors presented their findings to the licensee's management at the exit meeting on April 25, 1986.
No written material was given to the licensee at any time during this inspectio References:
ATTACHMENT 1 1.
Site Administrative Procedure, AP-6.0, Procedure for Modification and Addition, Revision 1,
and AP-3.3.2, Placement of Jumpers/Blocks or Lifted Leads 2.
AP-6. 1, Procedure for Modification and Addition, Revision
3.
ND-100, Plant Modification, Revision-1
~
ND-100B, Conceptual Engineering Package Preparation, Revision
5.
ND-100C, Engineering Initiated Hold/Release Orders, Revision
6.
ND-130, Design Input, Revision
7.
ND-140, Minor Design Changes to Modifications, Revision
8.
NT-100, Licensing Input, Revision
9.
NT-100B, Preparation and Control of Safety Evaluations, Revision
,/'
10.
NT-100C, Equipment Qualification, Revision
11.
NT-100D, Fire Protection, Revision
12.
NT-100A, Determination of 10 CFR 50, Appendix B, Applicability, Revision 0 and NT-130A, Technical Specification Change Control, Revision
13.
NT-130, Notification Under
CFR 21, Revision
14.
NEL-014, Document Control and Distribution, Revision
15.
NEL-014D, Control and Distribution of Calculations/Specifications/System Descriptions/Design'erifications, Revision
16.
NEL-014G, Control and Distribution of Vendor Documents, Revision
17.
NEL-014H, Control and Distribution of Procurement Documents, Revision
18.
NEL-015, Procurement of Materials/Services, Revision
19.
NEL-015F, Preparation of Request for Contractor Quality Qualification, Revision
20.
NEL-015J, Test Control, Revision
,W
Attachment
21.
NEL-016, Corrective Action Reports, Revision
22.
NEL-017, Disposition of Nonconforming Items, Revision
23.
NEL-022, Design Calculations Preparation, Revision
24.
NEL-025, Review and Approval of Submittals to NRC, Revision
25.
NEL-026, Engineering Training Program Implementation, Revision
26. 'EL-027, Design Verification, Revision
27.
Startup Administrative Procedure, N2-SAP-104E, Record Transfer, Revision
28.
N2-SAP-113, Safety Tagging and Markups, Revision
29.
N2-SAP-118, Temporary Modifications, Revision
30.
N2-SAP-121A, Deficiency Reporting System, Revision
31.
N2-SAP-121B, Deficiency Tracking System, Revision
32.
PPNM-151,
CFR 50.55(e) Significant Deficiencies -
NMPC Evaluation and Reporting, Revision
33.
PPNM-152,
CFR 21 Submittal Safety Hazard -
NMPC Evaluation and Reporting, Revision
34.
CFR 50.59, Changes, Tests and Experiments 35.
Niagara Mohawk Power Corporation Quality Assurance Topical Report, QATR-1, Section 3, Design Control, Revision
36.
NMPC Quality Assurance Procedure, QAP-6.20, Review of Design Control Activities, Revision
37.
NMP-2 Proposed Technical Specification, Section 6, Administrative Controls 38.
NMP-2, Final Safety Analysis Report (FSAR), Section 17. 1, Quality Assurance Program During Operation 39.
ANSI/ASME NQA-1-1983, Quality Assurance Program Requirements for Nuclear Faci 1 i ties 40.
ANSI/ASME NQA-2-1983, Quality Assurance Requirements for Nuclear Power Plants 41.
ANSI/ASME 3.2-1982, Administrative Controls and Quality Assurance for Operational Phase of Nuclear Power Plants
~