IR 05000423/1985021

Insp Rept 50-423/85-21 on 850513-17.No Violation Noted.Major Areas Inspected:Maint Programs,Instrumentation & Control Program & Qa/Qc Interfaces

ML20127G938
Person / Time
Site:	Millstone
Issue date:	05/31/1985
From:	Bettenhausen L, Blumberg N NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20127G908	List: IR 05000423/1985021 ML20127G902
References
50-423-85-21, NUDOCS 8506260141
Download: ML20127G938 (12)

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L U.S. NUCLEAR REGULATORY COMMISSION f

REGION I

Report N /85-21 Docket N License No. CPPR-113 Priority --

Category B Licensee: Northeast Nuclear Energy Company P. O. Box 270

Hartford, Connecticut 06141 Facility Name

Millstone Nuclear Energy Station, Unit 3 Inspection At: Waterford, Connecticut Inspection Conducted: May 13-17, 1985 Inspectors:

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.h, kv Blumberg, Lead Reactor End4neer

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Approved by: d[t L'.

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tw /n, H. Bettenhausen, Chief, l " ~

Operations Branch, DRS f/5//P[

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Inspection Summary:

Inspection on May 13-17,1985 (Inspection Report No. 50-423/85-21)

Areas Inspected: Routine, unannounced inspection of maintenance programs, I&C program and QA/CC interfaces. The inspection involved 30 hours3.472222e-4 days <br />0.00833 hours <br />4.960317e-5 weeks <br />1.1415e-5 months <br /> onsite by one region-based inspecto Results: No violations were identifie ,,

8506260141 850613 PDR ADOCK 05000423 0 PDR l

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DETAILS i Persons Contacted D. Blumenthal,-NUSCO QA Engineer M. Brown, I & C Supervisor C. Clemont, Maintenance Supervisor J. Crockett , Unit 3, Superindentent K. Gray, NCQA Staff Assistant

• E. La Ware, Group Lead Startup Engineer NUSCO Construction QA

"D. Miller, NNECO Startup

• L. Nadeau, NUSCO Assistant Project Engineer

• P. 0'Connell, Assistant Scientist, NUSCO Construction QA

• M. Pearson, Operations Assistant

• T. Rogers, I & C Planner R. Rothgeb, Staff Engineer U.S. Nuclear Regulatory Commission D. Lipinski, Resident Inspector, Millstone Units 1 and 2

• T. Rebelowski, Senior Resident Inspector, Millstone Unit 3

• Denotes those present at the exit intervie . Inspection Scope The following programs which the applicant must have established for operations subsequent to receiving an operating license, were reviewed:

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Corrective Maintenance Program

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Preventive Maintenance Program

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Technical Specification Surveillance Test Program

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Instrument and Control Program

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Inservice Test Program - Pumps and Valves

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Quality Assurance / Quality Control Programs The above programs were reviewed for conformance to the requirements and guidelines of the following:

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10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants

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Final Safety Analysis Reports (FSAR), Section 13, Conduct of Operations

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Technical Specifications, Section 6, Administrative Controls

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FSAR Section 17, Quality Assurance During the Operations Phase

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Reg. Guide 1.33 - 1978, Quality Assurance Program Requirements (Operation)

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ANSI N18.7 - 1976, Administrative Controls and Operational Quality Assurance for the Operational Phase of Nuclear Power Plants

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ANSI N45.2.1 - 1973, Cleaning of Fluid Systems and Components

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ANSI N45.2.3 - 1978, Housekeeping for the Construction Phase of Nuclear Power Plants The above programs are defined in station and department procedures which are listed in Attachment (1) to this repor Department procedures define in more detail each department's implementation of a station procedur However, departments are not required to establish an implementing procedure for each station procedure as they can use the station procedure directly if they desire. Most program procedures have been issue Review of program procedures and discussions with plant representatives indicated that corrective maintenance, preventive maintenance, and instru-ment control programs were in place and being implemented in support of pre-operational testing and system turnover. Maintenance is controlled by a computerized system called the Production Maintenance Management System (PMMS). This system is used by all Northeast Utilities Companies and can be universally accessed within the company. Each department has a PMMS planner who is trained to make entries to the syste All work is controlled by an automated work order (AWO) system whie generates each work order as a computer printout. There is a manual back up system for when the computer is down or for emergency maintenanc Preventive maintenance and calibrations are automatically scheduled on an AW Personnel Noting problems in the plant can generate a trouble report directly into a computer terminal which in turn will directly issue an AWO for work performance. At completion of a job all manual entries made on an AWO are also entered into the computer so that the computer maintains a complete maintenance history. This allows the PMMS system to provide virtually any kind of computer sort concerning plant maintenanc Although for the most part, program procedures are in place, implementing procedures have not yet been issued. Discussions with plant personnel indicate that there is large backlog of operating, surveillance test, inservice test, maintenance, preventive maintenance, and plant instrument calibration procedures. Plant representatives stated extra personnel are being assigned to assure that procedures are issued by September, 198 Preliminary inspection and discussions with plant representatives indi-cated that the surveillance test programs and inservice test programs are not yet at a level which would warrant pre-license inspection by the NR Master test indices'have not yet been established; and department respon-

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sibilities for surveillance tests have not yet completely been assigne There is no overall surveillance test coordinator, and each department is responsible for developing its own program. Although significant computer capability exists on the PMMS, the inspector was informed by the applicant that except for I & C Department, present plans call for manual scheduling of surveillance tests and maintenance of test status. Surveillance and inservice-test programs will be reviewed during a subsequent NRC:RI inspectio . Maintenance program Corrective and preventive maintenance for mechanical and electrical, in general, will be performed by the Maintenance Department. I & C Depart-ment which is discussed in paragraph 4, will perform instrument corrective and preventive maintenance. Other groups which perform maintenance at the plant are a Northeast Utilities (NU) Interplant Maintenance force (IMF),

Production Test Group (PTG), NU Construction Backfit and Betterment Group which currently uses the C. M. Flagg Company as permanent contractor, to perform their assigned work and other contractors used for case basis maintenance. IMF is an NU group which performs work at all NU facilities; PTG performs maintenance on electrical protective devices and Millstone Units 1, 2 and 3; and C. M. Flagg performs modification work for NU con-struction. The applicant stated that IMF, PTG, and any contractors work under plant systems and QA; while, C. M. Flagg works under the NU con-struction QC syste Maintenance Department is currently performing maintenance related to turned over systems and systems under test. Approximately 50 out of 250 projected maintenance procedures have been issued with A" gust, 1985 as the projected date for issuing all maintenance procedures. There are approximately 50 mechanics and electricians in the Mainterance Department and it is fully staffed based on current manning projection .2 Area Reviewed The maintenance program was reviewed to assure that the following areas were incorporated into program procedures:

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A work permit system has been established for initiating and controlling maintenance activities ,

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Criteria and responsibilities have established for review and approval of maintenance work requests

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Responsibilities of maintenance personnel are defined

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Methods have been established for defining safety-related maintenance

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Methods have been developed for the preparation of maintenance procedures and their proper approval

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A program has been estabitsbed for the definition and perfor-mance of preventive maintenance activities

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Systems have been established for the trending and evaluation of component failures

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Methods have been established for the evaluation of applica-bility of component failures at other nuclear power plants

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Responsibilities and method have been established to assure adequate post-maintenance testing will be accomplished prior to return to service

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Provisions and responsibilities have been established for the identification of appropriate inspection hold points

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QA/QC interfaces are defined

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Procedures are in place for the review and storage of mainte-nance records 3.3 The following procedures listed in attachment (1) were reviewed to ensure that the above areas were incorporated.into the maintenance i program:

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ACP-QA-1.02 --

ACP-QA-8.25

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ACP-QA-2.028 --

ACP-QA-9.02

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ACP-QA-2.02C --

ACP-QA-9.04

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ACP-QA-2.06A --

MP 3701A

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ACP-QA-2.068 --

MP 3702A

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ACP-QA-2.06C --

MP 3702B

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ACP-QA-2.07 --

MP 3704A

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ACP-QA-2.12 --

MP 3708/.

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ACP-QA-2.13 --

MP 3710AA

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ACP-QA-3.01 --

MP 3710BA

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ACP-QA-3.02 --

MP 3719MB

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ACP-QA-3.03

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ACP-QA-3.05

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ACP-QA-3.07

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ACP-QA-4.01

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ACP-QA-5.02 3.4 Findings Although a maintenance training procedure exists, a plant repre-sentative stated that a maintenance training program was still being developed. This training will include administrative controls, a

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systems course, and pump and valve maintenance trainin The applicants action in this area will be reviewed during a subsequent NRC:RI inspection. This is IFI (423/85-21-01). Instrument and Control Program l 4.1 Program Review Corrective and preventive maintenance of plant instruments will be

accomplished by the I&C Department. I&C Department is currently fully staffed. There are 24 contract I&C technicians working in I&C;

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however, they are fully integrated with the plant staff. I&C Depart ,

ment gives a comprehensive written test to all contract technicians prior to hiring and does not rely completely on vendor certification of qualification There appears to be in place a comprehensive program for instrument maintenance. A loop folder has been prepared for each instrument which contains such information as a loop diagram, calibration data sheets, valve lineups for taking the instrument out of service and placing back into service, and an instrument history card. Instru-ment calibration procedures will be developed, either specific or generic, for each instrument in the plant. Most calibration proce-dures are being written and have not*yet been issue I&C stated that all calibrations and technical specification sur-veillance tests will be scheduled using'the PMMS computer (as opposed to the manual system). Surveillance tests required to be performed by I&C have been identified and proceduras are being written. The development of the surveillance test program appeared to be ahead of that of other department .2 Independent Verification TheI&Cbepartmentstatedthattheyrequiredtheirtechniciansto lockwire all instrument valves after us During plant tours, the inspector observed numerous instrument valves which were lockwire Each valve was lockwired firmly with heavy duty lockwire in such a manner that the lockwire would preclude operation of the valve unless a

physically cut and remove A small sampling of instrument loop folders were reviewed and the inspector observed that they contained the appropriate informatio In addition, the PMMS system was tested. The inspector noted that work on the system could be checked in many different ways. Infor-mation sorts were available such as components, technicians perform-ing work, procedures used, measuring and test equipment used, et These sorts would be valuable in tracing specific maintenance his-tories.

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4.3 Areas Reviewed

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cThe I&C program was reviewed to assure that the following areas were incorporated into program procedures:

[ Note: Mafntenance areas listed in paragraph 3.2 are also applicable Items listed below are those which are unique to I&C.)

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Responsibilities of I&C personnel are defined I l --

Methods have' been developed for the preparation of I&C procedures

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and their proper approval

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A program has been established for the calibration of technical specification related instruments

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A program has been estabitsbed for the calibration of balance-of-

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plant instruments

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Training programs have been estabitshed for I&C personnel

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4.4 The following procedures listed in attachment (1) were reviewed to

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, ensure that the above areas were incorporated into t.he I&C program:

ACP-QA-2.028j! , ACP-QA-3.03

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ACP-QA-2.02C' ACP-QA-3.07

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ACP-QA-2.06A #

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ACP-QA-2.06B ACP-QA-9.02 ,

ACP-QA-2.06C' ACP-QA-9.04 ,

ACP-QA-2.12 ,

IC-3401 ACP-QA-2.BA IC-3402 ACP-QA-2.138 <

IC-3403 f ,

ACP-QA-3.0 IC-3404 (

ACP-QP-3.02 ,

IC-3405 <

4.5' findings

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No violations or other discrepancies were observe ,

$ .- QA/QC Interfaces

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There are currently two QA groups onsite, concerned with operational QA-corporate-(NUSCO) QA and site QA (NNECO). Site QA is a line organization which works under the Station' Services Superintendent who in turn reports directly to the Station Superintendent, and does not report to any of the three site, superintendents. Site QA provides QA/QC services to all three units. This includes audits, QA surveillance, and specific QC inspec-tions of on going work. NUSCO QA also maintains an onsite QA' group which reports directly to the corporate organization. They perform overview audits and QA surveillances of all site activities including'those of site j .

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Q In some instances, NUSCO and site QA perform joint audit activities The inspector held discussions with NUSCO QA representatives who stated that all NUSCO and NNECO QA programs and procedures were in place and being implemented. QA/QC activities will be inspected for operating license activities during a future NRC:RI inspectio . Management Meetings Licensee management was informed of the scope and purpose of the inspec-tion at an entrance interview conducted on May 13, 1985. The findings of the inspection were periodically discussed with licensee representatives during the course of the inspection. An exit interview was conducted on May 17,1985 (see paragraph I for attendees) at which time the findings of the inspection were presente At no time during this inspection was written material provided to the applicant by the inspector.

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ATTAC!iMENT (1) ,

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STATION AND DEPARTMENT PROCEDURES REVIEE D 1

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Station Administrative Contrp1 Procedures i

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ACP-QA-1.02 Organization and Responsibilities,, Revision 16, 04/17/85 l

ACP-QA-1.04 PlantOperation}JAeviewCommittee, Revhion 19, 06/13/84 '

ACP-QA-1.05 Site Operations Review Committee, ,' , Revision 13, 06/13/84

.y ACP-QA-1.06 Quality Assurance / Quality Contro'e', ^

Program ' b Revision 8, 12/24/84 1 t, '

ACP-QA-2.01 QA Program Boundary, >

Revision 5, 05/17/84 ACP-QA-2.02B Retests, , Revision 10, 11/13/84 ACP-QA-2.02C Work Orders, ,

, Revision 2, 02/25/85 ACP-QA-2.06A Station Tagging', ,.

Revision 8, 03/11/85

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ACP-QA-2.06B Station Bypass / Jumper Control (NEO 8.01) Revision 5, 02/01/85 g \

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ACP-QA-2.06C Station Bypass /Ju"fper Control for Trouble Shooting, l Red Lining and Cafibration, Revision 1, 10/26/84 ACP-QA-2.07 Control of Special Processes Revision 14, 05/13/85 ACP-AQ-2.12 System Valve Alignment Controlf Revision 6, 10/09/84 ( '

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l ACP-QA-2.13A Computer Software Implementation, Revision 0, 03/05/85

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ACP-QA-2.13B Maintenance and Control of Site Computer Systems, Revision 0, 03/05/85 ACP-QA-3.01 ACP's and Station Form Revision 14, 12/03/84 ACP-QA-3.02 Station Procedures and Forms, Revision 32, 05/07/85 ACP-QA-3.03 Document Control, Revision 25, 05/09/82 ACP-QA-3.05 Review and Approval of Vendor Procedures, Revision 6, 11/17/82 ACP-QA-3.07 Maintenance of Station Implementing Procedures in Accordance with NUSCO Governing Documents Revision 4, 12/01/82 ACP-QA-4.01 Plant Housekeeping, Revision 11, 11/13/84

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ACP-QA-5.02 Trend Analysis From Quality-Related Documents, Revision 0, 02/25/85 ACP-QA-8.07 QA Training Program, Revision 3,66/04/82 ACP-QA-8.15 Technical Training Program, Revision 0, 01/17/83 ACP-QA-9.02 Station Surveillance Program Revision 12, 11/13/84 ACP-QA-9.03 Inservice Plant Testing, Revision 5, 11/02/82 ACP-QA-9.04 Control and Calibration of Measuring and Test Equipment, Revision 16, 09/14/84 ACP-QA-9.05 Monitoring of QA Activities, Revision 12, 02/28/83 ACP-QA-9.06 Inservice Inspection Program, Revision 8, 02/01/85

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ACP-QA-9.07 Quality Assurance Surveillance Program, Revision 0, 02/01/85 ACP-QA-10.06 NRC Commitment Follow Program, Revision 5, 03/02/84

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'I&C Department Procedures IC 3401 Unit 3 Instrument and Control Department Training, Revision 2, 02/20/85 IC 3402 Assembly and Maintenance of Instrument Loop Folders, Revision 2, 03/28/84 IC 3403 Unit 3 Preventive Maintenance (PM) Program, Revision 2, 03/28/84 IC 3404 Unit 3 I&C Department Installation Verification, Revision 2, 06/24/83 IC 3405 EEQ Maintenance, Revision 0, 05/14/83

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Maintenance Department Procedures MP 3701A Maintenance Procedures and Forms, Revision 0, 05/31/83 MP 3702A EEQ Maintenance Program, Revision 0, 01/14/85 MP 37028 EEQ Closecut Requirements, Revision 0, 01/14/85 MP 3704A Preventive Maintenance Program, Revision 1, 05/17/85 MP 3708A Unit 3 Maintenance Training, Revision 0, 10/13/83 MP 3710AA Lubrication Program, Revision 1, 03/15/85 MP 3710BA Preventive Maintenance Program Application, Revision 0, 05/03/84 MP 3719MB Mechanical Equipment General Inspections, Revision 0, 04/15/85

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