IR 05000410/1986022
| ML17055B908 | |
| Person / Time | |
|---|---|
| Site: | Nine Mile Point  |
| Issue date: | 06/11/1986 |
| From: | Eapen P, Hunter J, Winters R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17055B905 | List: |
| References | |
| 50-410-86-22, NUDOCS 8606260343 | |
| Download: ML17055B908 (24) | |
Text
U.S.
NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-410/86-22 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 2 Inspection At:
Scriba New York Inspection Conducted:
A ri 1 30-Ma
1986 Inspectors:
R.
W. Winters, Reactor Engineer date Approved by:
.
G. Hunter III, Reactor Engineer, gA Section, OB, DRS Dr.
P.
K. Eapen, Ch ef, guality Assurance Section, OB, DRS date date Ins ection Summary:
Routine Unannounced Ins ection on A ril 30-Ma
1986 Ins ection Re ort No. 50-410/86-22 Areas Ins ected:
Procurement, Receipt, Storage and Handling, Document Control, and Records Management programs and licensee actions on previous inspection findings.
Results:
No violations were identified.
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DETAILS 1.0 Persons Contacted Nia ara Mohawk Power Cor oration NMPC
- R. B. Abbott, Station Superintendent
- D. H. Balduzzi, Superintendent, Records Management
~C.
G.
Beckham, Manager, Project Quality Assurance (QA)
- G. L. Blackburn, Test Group Manager, Startup
"J. J. Bufis, Test Group Manager
- K. C. Carter, Unit Supervisor, Records Management
- G. J.
Doyle, NQA-OPS
~W. J.
Hanley, Manager, Contracts and Purchasing
- L. D. Kassakath, Test Group Manager, Startup
"R.
G. Matlock, Deputy Project Director
+M. Meehan, Material Control Supervisor
+R. Miller, Assistant Manager, Nuclear Materials Management
- W.
WE Mural, Associate Senior NCU Technician E.
P. Opelski, NQA-OPS J.
Salmon, Lead Project Engineer
~D.
E. Sandwick, Manager, Information Management S. Starowicz, Contract Administrator
~I. Weakley, Special Projects Stone and Webster En ineerin Cor oration
~SWEC
- B.
R. Bulger, Project Engineer C.
Deban, Document Control Coordinator
- J. L. Drake, Jr., Startup Special Projects Supervisor
- B. Kallander, Manager, NMP2 Records Management L. Terry, Project QA Manager General Ph sics Cor oration GP S.
Lessard, Project Engineer T. Mogsen, Project Manager Public Service Commission
~PSC
- P.
D. Eddy, Site Representative U.
S. Nuclear Re ulator Commission
~USNRC
+"R. A. Gramm, Senior Resident Inspector
"J. Stair, Reactor Engineer
- Attended Exit meeting May 9, 1986
+Attended Exit meeting May 7, 1986 The inspectors also contacted other administrative and technical licensee personnel during the course of the inspectio ~, ~
2.0 Followu of Previousl Identified Items (Closed) Violation 83-18-86:
Ineffective corrective action program for contractor and subcontractor activities.
The licensee required the prime contractor (Stone and Webster Engineering Corporation) to revise their procedure to strengthen the requirements for closing deficiency reports in a timely manner.
In addition, the licensee instituted a Quality Performance Management Program (QPMP) to provide qua-lity trends and timely corrective action.
This program provided trending on a weekly basis.
Through this program trends were identified early and'orrective actions were taken before major problems developed.
The Inspector reviewed reports of the QPMP as well as the followup on Mas-ter Tracking System program used in Startup and preoperational testing.
The Master Tracking System reports are published weekly and they identify all deficiencies as well as items opened and closed in the preceeding weeks.
These reports also provide information by systems in a manner to facilitate easy trending.
Based on the above review, the inspector concluded that the licensee's actions were adequate to resolve the concern identified in this violation.
This violation is closed.
Closed Unresolved Item 80-09-01:
Pertaining to the development of a program to insure that parts subject to deterioration are identified and inspected to determine that the component will perform its intended func-tion satisfactorily.
The licensee has developed such a program to inspect parts subject to deterioration.
The Inspector reviewed a representative sample of the evaluations made in this area and determined that the program was adequate.
This unresolved item is closed.
Closed Unresolved Item 50-410/84-18-09:
This item pertains to the effectiveness of the licensee's corrective action and trend analysis program.
The licensee did not have adequate measures to consolidate the corrective action requests (CARs) involving generic problems; disposition and im-plement corrective action in a timely fashion; and update inspection plans and procedures.
The licensee reviewed and consolidated seven corrective action requests involving generic problems and one audit findings report in one correc-tive action request, CAR ¹84.0177.
The CAR was properly dispositioned.
Also, through formal and informal meetings, and implementation of the
management actions the number of overdue CARs were significantly reduced from 112 to a manageable number of 35 duri"ng the review period.
The licensee tracked the overdue responses to the corrective action requests as a Quality Performance Indicator.
A review of the licensee'
Quality Performance Management Program Trend Analysis Graph (period June 27, 1984 to April 12, 1985)
and letter NMQA 1315, dated February 13, 1985 indicated that the licensee's action was adequate.
The licensee also updated the inspection procedures, dispositioned CAR 84-0158 and implemented the required corrective action.
In addition, the licensee's agent, Stone 8 Webster Engineering Corporation, reviewed the QA program of vendors, such as Reactor Control, Inc., ITT-Grinnel, and Johnson Controls, Inc.,
and revised the applicable procedures, as neces-sary.
Based on the review of the licensee documentation the inspector determined that the licensee adequately resolved this item.
The item is closed.
Closed Construction Deficienc Re ort 50-410/83-00-10
This item pertains to potential
CFR 50.55(e concern regarding uncertified elec-trical inspector (SWEC) performing quality control activities.
The licensee investigated the matter of certification and qualification of the QC inspector identified through the licensee's QA Surveillance at NMP-2.
The licensee reviewed the inspector',s certification and qualifi-cation documentation as well as SWEC's QC Inspector qualification pro-cedures and methodology.
The licensee verified that the inspector was properly certified to perform the assigned inspections in accordance with the SWEC QA program and ANSI N45.2.6-1978 requirements since August 19, 1982.
Based on the findings the licensee concluded that a
CFR 50.55(e) report need not be made for this concern, as indicated in the licensee's final report to the.NRC dated June 3,
1983.
Based on the review of the licensee's disposition, the inspector deter-mined that the licensee has adequately resolved the item.
This item is closed.
Closed Construction Deficienc Re ort 50-410/83-00-12:
This item pertains to potential
CFR 50.55(e)
concerning uncertified SWEC QA inspectors performing quality control activities.
The licensee's corrective action was reviewed during the previous NRC inspection (50-410/85-27).
The licensee provided additional supporting information for:
The qualifications, educational background, experience, and the site specific training associated with each uncertified inspector at the time the suspect inspection was performed;
The type of inspections performed by the QC inspectors in question; and The results of the reinspections performed on the accessible hardware.
The inspector reviewed the above additional information provided by the licensee and concluded that this information adequately addresses the con-cerns identified in NRC inspection 50-410/85-27.
Based on the review of the above information, the inspector determined that the licensee's corrective action is adequate.
This item is closed.
3.0 Procurement Material Recei t, Ins ection and Stora e
To assure the effectiveness of the licensee's program for Procurement dur-ing the operations phase, the Inspector reviewed the "Procedure for Control of Materials and Services",
AP 7.0, Revision 1, effective August 9, 1985 and the implementation of this procedure.
The details of the review are given below:
3.1 Procurement Activities The inspector reviewed purchase orders placed directly by the Licen-see and by General Physics, a contractor hired by the licensee to purchase spare and replacement parts.
For nondestructive testing and inspection services the contract was awarded to that vendor who was determined to be the best qualified vendor by the Quality Assurance organization and not to the lowest bidder.
General Physics (GP)
has been contracted to purchase spare and re-placement parts.
To accomplish thi s GP is using lists of recommended spare parts furnished by Stone
& Webster Corporation (SWEC).
The quantities recommended have been determined either by the original suppliers or SWEC.
SWEC developed the spare parts lists for each plant system.
GP as part of the contract searches these lists to identify identical parts used in different systems and to optimize spares while assuring adequate availability for operation.
GP then prepares a Request for Quotation (RFQ) and submits this RFQ to the Licensee's Quality Assurance and Materials Management Section for review and approval.
When approved, GP submits the RFQ to vendors for Quotations.
For Safety Related equipment only vendors on the licensee's
"Qualified Suppliers List" receive copies of the RFQ.
Returned RFQ's are sent to the licensee's Quality Assurance organization and the Materials Management Section
I I'
for review.
From these reviews a vendor is chosen and the quotation from the chosen vendor is returned to GP for preparation of the Pur-chase Order.
When the purchase order is prepared it is sent to the licensee for management and budget approval, and returned to GP for placement.
The Inspector reviewed a representative sample of Res and purchase orders in various stages of preparation.
A subset of the above sample was used to verify the adequacy of receipt inspection, documentation, storage, and retrievability.
The Staffing was adequate to accomplish the issuance of the purchase order without excessive delays.
No violations were observed.
The inspector found the procurement activities to be adequate to support operation of Nine Mile Point Unit 2.
3.2 Material Recei t Ins ection and Stora e
Materials are received onsite in the materials storage building or at the offsite warehouse.
Both facilities are part of the Materials Management Organization and have full time guality Control Receiving Inspectors.
Attributes and acceptance criteria used during receipt inspection are as requi red by the purchase order.
Results are re-corded on a Materials Receipt Report (MRR).
Acceptable material is clearly identified and stored, unacceptable or indeterminate items are clearly tagged and placed in a segregated area.
Shelf life is as specified by the product manufacturer, or as required in the appro-priate Military Handbook.
'In the absence of manufacturing data the licensee requires vendors to guarantee that a minimum of 70% of the shelf life remains when the material is received.
The inspector reviewed the offsite warehouse and the onsite materials storage facility.
Both facilities met the requirements of ANSI N45.2.2 for level 8 storage.
Inspection reports, documentation in-cluding certificates of conformance, manufacturing data such as cure date used for shelf life determination, and MRRs, were readily retrie-vable and complete for those purchase orders previously identified (in paragraph 3. 1 above).
Storage locations are provided to the user from a computer.
In all cases observed the material was in the loca-tion as recorded in the computer.
All material were observed to have the shelf life expiration date clearly marked on the material or its container.
In addition, the shelf life expiration dates are tracked in the computer system.
The Inspector requested the expiration date information from the computer
and the licensee furnished two reports.
The first report indicated the materials that would expire on or before the date requested (by the Inspector)
and the second had the same basic information along with the reorder date to remind the user of the lead time for such repla'cement purchases.
Staffing in both locations was adequate to complete receipt inspec-tion without excessive backlogs.
No violations were observed.
The inspector found the licensee's material receipt, inspection and storage activities to be adequate to support operation of Nine Mile Point Unit 2.
4.0 Records Mana ement Pro ram The basic requirements and guidelines for collection, storage and main-tenance of Quality Assurance records are described in:
CFR 50, Appendix B, Criteria XVII.
Proposed Technical Specifications, Section 6, Administrative Controls.
Final Safety Analysis Report (FSAR), Section 17.1
~ 17.
ANSI N45.2.9-1975, Requirements for Collection, Storage, and Mainten-ance of Quality Assurance Records for Nuclear Power Plants.
Regulatory Guide 1.88, Rev.
2, Collection, Storage and Maintenance of Nuclear Power Plant Quality Assurance Records.
ANSI 18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants.
ANSI N45.2-1977, Quality Assurance Program Requirements.
4.1 The requirements and guidelines found in the reference documents of paragraph 4.0 are implemented by the licensee's Quality Assurance Pro-gram by utilizing Site Administrative procedures, Quality Assurance procedures, and Document Control procedures.
The inspector reviewed the following procedures:
QAP 17.10, Nuclear QA Records, Rev.
2, May 17, 1985 AP 10.1, Management of Station Records, Rev.
2, April 29, 1986 DCI 1, Station Incoming/Outgoing Correspondence Control Instru-mentation, Rev.
2, April 25, 1985 DCI 2, Central Files Internal Processing, Rev.
2, April 1, 1985
OCI 2.1, Document Preparation Instruction, Rev. 2, April 12, 1985 DCI 2.4, Document Indexing, Rev.
5, March 25, 1986 DCI 5.0, Control and Disposition of Active Files, Rev.
2, November 14, 1985 DCI 9.0, Control of Station Archives, Rev.
2, November 8,
1985 DCI 13.0, Methods for Correcting, Changing, Supplementing or Superseding Permanent Plant File Records, Rev.
0, March 4, 1986 DCI 14.0, Final Disposition of Site Records, Rev.
0, March 4, 1986 NMP2 Project Manual, Volume II, Section 3'. 1, NMP2 Records Management Plan, June 28, 1985 The above procedures were reviewed to verify compliance with the re-quirements and guidelines of the referenced documents in paragraph 4.0 and to assure that the licensee's procedures adequately esta-blished the following:
Requirements to maintain and retain records required by the licensee's quality assurance program; Responsibilities to identify and maintain QA records; Responsibilities to transfer and retain construction and pre-operational phase records',
Record storage controls to identify record storage facility, designate custodian(s)
in charge of storage facilities, file and retrieve records, verify that the records received are in agree-ment with pre-established checklists or transmittal documents, control access to the files, maintain traceabi lity when files are removed from storage, correct files and dispose superseded records; and Authorities and responsibilities are specified for authorizing the disposal of records no longer required to be maintained.
The inspector~ selected a random sample of construction project re-cords to determine thei r retrievability.
The records consisted of SORC meeting minutes, personnel qualifications, procurement documen-tation and calibration records.
The inspector verified that the re-cords sampled were processed according to procedures, listed on the master computer index, properly stored and readily retrievable.
The effectiveness of the implementation of the licensee's records management program during the operational phase of Unit 2 will be reviewed in a future NRC inspectio.3 Fi~din<is Based on the above review and discussions with cognizant personnel, the inspector determined the following:
Site Administrative procedure AP 10. 1,
"Management of Station Records" and supplemental document control procedures outline the responsibilities and provisions for the access control, col-lection, disposition, removal, retention, retrieval, storage and maintenance of site records and technical information.
The pro-cedures are in effect for Unit 1 and apply to Unit 2 records generated by the Nuclear Generation Department for equipment that has been turned over to NMPC for operations and/or main-tenance.
Permanent Plant File records generated from the construction project are processed in accordance with project records man-agement procedures.
The licensee will continue to process con-struction project related records under the current system until all such records are processed.
Any records generated from work performed on systems turned over to operations but completed by project personnel will also be processed in accordance with the project records management procedures.
Although construction project and operations records are process-ed in accordance with different procedures they are both entered into a similar computer aided document retrieval index system intended for general use by station personnel.
The Records Management organization is currently conducting classes to train operation and construction personnel in the use of the records management retrieval system.
The responsibility of determining who receives the training is up to the various station supervisors.
The Records Management personnel are responsible for maintaining attendance records of the training.
The inspector obtained a training manual and reviewed a sample of the training given to licensee personnel.
The training pro-vided adequate guidance to personnel in the use of the computer aided record retrieval system.
Through discussions with the Superintendent of Records Management and a review of the current staffing, the inspector determined that the licensee is adequately staffed to manage the present records workload.
The Records Management Superintendent has temporarily hired eight employees to help process the increased records workload due to the Unit 1 outage.
There are also pro-visions to hire six more employees as Unit 2 nears commercial operatio The licensee is currently incorporating some attributes of the construction Records Management Instructions (RMIs) with the operations Document Control Instructions (DCIs) and generating Nuclear Records Management Instructions (NRMIs) for the station operations records management program covering units 1 and 2.
The NRMIs will be reviewed in a subsequent inspection.
The attributes of the records management program reviewed were ade-quate.
No violations were identified.
From this review the inspec-tor concluded that the licensee's records management program is ade-quate to support Unit 2 operation.
5.0 Document Control Pro ram The basic guidelines and requirements of a document control program are contained in:
CFR 50, App. B, Criteria II, V, VI Proposed Tech Specs, Section 6, Administrative Control Final Safety Analysis Report (FSAR) 17. 1.6 ANSI N45.2 - 1977, Quality Assurance Program Requirements ANSI N18.7 - 1976, Administrative Controls and Operational Quality Assurance for the Operational Phase of Nuclear Power Plants Regulatory Guide 1.33, Rev.
2, Quality Assurance Program Requirements (Operation)
The requirements and guidelines established in the reference documents in paragraph 5.0 are implemented by the licensee's Quality Assurance Program by utilizing Quality Assur ance Procedures, Site Administrative Procedures, Nuclear Engineering Procedures and Nuclear Engineering and Licensing procedures.
The inspector reviewed the following procedures:
QAP-6.01, Review and Control of NMPC QA Documents, Rev.
3, February 19, 1986 AP-6.0, Procedure for Modification and Addition, Rev.
1, April 1, 1986 NEL-014, Document Control and Distribution, Rev.
0, August 25, 1985 ND-014.C, Controls and Distribution of Drawings, Rev.
0, August 22, 1985 ND-160, Drawing Change Control, Rev.
0, August 29, 1985 ND-160.B, NMP2 Drawing Revision and Issuance, Rev.
0, February 11, 1986
DCI-ll, Control and Distribution of Technical Specifications, Rev.
1, September 19, 1985 CSI 11. 13, Controlled Document Processing, Rev.
10, March 27, 1986 The above procedures for document control were reviewed to verify that the program is consistent with the requirements and guidelines of the referenced documents in paragraph 5.0 and to assure that the program contains the following attributes:
Require that current as-built drawings, including piping and instrument drawings (P8 ID's), will be provided to the plant site in a timely manner; Require that proposed drawing changes and the revised drawings receive the same level of management review as originals;
. Provide provisions for identifying and marking drawings with outstanding revisions; Establish control of obsolete drawings; Require that discrepancies found between as-built drawings and the as constructed facility are handled as design changes; Require master indices to be maintained for drawings, manuals, technical specifications and, procedures that indicate the latest revision; and Provide a mechanism for document issuance, distribution, use and periodic review.
The responsibilities for controlled documents at the site are present-ly delineated in project guidelines and instructions for the Project Document Control Organization.
The verification of the operational phase document control program implementation will be performed in a subsequent inspection.
5.3
~Findin n
Based on the above review and discussions with cognizant personnel, the inspector determined the following:
Responsibilities and administrative controls have been estab-lished to describe methods by which the Nuclear Engineering and
Licensing Department will control and distribute documents and their revisions.
Documents generated by the Nuclear Engineering and Licensing Department and those received from other groups are controlled through implementation of applicable procedures.
Nuclear Engineering and Licensing is responsible for providing controlled documents to the site for distribution.
The attrib-utes of the document control program reviewed were adequate.
The responsibilities for controlled document distribution on site are presently delineated to the Project Document Control Organization through certain procedures.
A computer index is maintained of the latest revisions or changes to controlled doc-uments and utilized to ensure effective distribution and track-ing of controlled copies.
Prior to commercial operations, the licensee plans to transfer the responsibilities of the Project Document Control Organiza-tion from construction to operations.
However, the licensee has not yet developed the required operations procedure or instruc-tion to delineate the methods and responsibilities for receiving and processing controlled documents, ensuring that the latest applicable controlled documents are distributed to identified controlled copy stations or holders, and preventing the use of voided, superseded or cancelled documents.
The licensee's re-presentatives stated that the requ'ired procedure would be devel-oped and implemented to establish an adequate document control program for the operation phase of Unit 2.
This item remains unresolved (50-410/86-22-01)
pending licensee development and implementation of the required procedure or instruction to pro-vide adequate control for the operational phase document control program.
No violations were identified.
6.0 Unresolved Items Unresolved items are matters which require additional information in order to determine if they are acceptable, violations or deviations.
The unre-solved items identified during this inspection are discussed in Paragraph 5.3 of this report.
7.0 Exit Interview A mini-exit meeting Hay 7, 1986 and a final management meeting May 9, 1986 were held to discuss the scope and findings of the inspection as detailed in this report (see Paragraph 1.0 for attendees).
The licensee did not indicate that any proprietary material was contained within the scope of this inspection.
At no time during this inspection was written material provided to the license l~
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