IR 05000423/1985049

Insp Rept 50-423/85-49 on 850819-23.No Violations Identified.Major Areas Inspected:Licensee Action to Address Operational QA Program for Design Changes & Mods,Test & Experiments & Safety Committee Activities

ML20133C099
Person / Time
Site:	Millstone
Issue date:	09/19/1985
From:	Dev M, Jerrica Johnson, Oliveira W, Prell J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20133C061	List: IR 05000423/1985049 ML20133C058
References
50-423-85-49, NUDOCS 8510070225
Download: ML20133C099 (15)

Text

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O O U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-49

. Docket N License No. CPPR-113 Licensee: Northeast Nuclear Energy Company Post Office Box 270 Hartford, Connecticut 06101 Facility Name: Millstone Nuclear Power Station, Unit 3

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Inspection At: Waterford and Berlin, Connecticut Inspection Conducted: August 19-23, 1985 Inspectors: '

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U. Prell, Reac' tor En ineer '

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'W 7011veira, Reactor Engineer ffs'

4 ate hl W M. Dev, React 6r Engineer

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[ date Approved by: b( )M ***

J, Jbfinson, Ch ef, Operational Programs T//1/r5'

date Section, Operation Branch, DRS Inspection Summary: Routine Unannounced inspection conducted on August 19-23, 1985 (Inspection Report No. 50-423/85-49)

Areas Inspected: Licensee's action to address Operational Quality Assurance Program for Design Changes and Modifications, Test and Experiments, Measuring and Test Equipment and Safety Committee Activities. The inspection involved )

107 inspection hours by three Region I based inspector Results: No violations were identified, o01 0 l 0.

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1.0 Persons Contacted Northeast Utilities M. Brown, Supervisor, Instrumentation and Control, (I&C) MP-3 l J. Crockett, Superintendent, MP-3 G. Closius, Supervisor, Quality Assurance / Quality Control (QA/QC)

J..Coleman, Supervisor, Construction QC C. Drane, Maintenance Technician E. Fetterman, Shift Supervisor MP-3 R. Fraser, Assistant Supervisor, I&C

• K. Gray, Staff Assistant, Construction QA G. Johnson, Director, Generator Engineering and Design T. Kulterman, Coordinating Engineer MP-3 R. Langer, Assistant Supervisor, Chemistry J. LaWare, QA Engineer Technologist O. Moore, Operation Assistant MP-3

• W. Nadeau, Assistant Project Engineer D. Nordquist, QA Manager C. Opelnik, Maintenance Foreman

• S. Orefice, Project Engineer H. Peterson, Plant Equipment Operator J. Regan, Supervisor, Generation Electrical Engineering J. Ruttar, Shift Supervisor, MP-3 R. Sachatello, Supervisor, Radiation Protection

• Denotes those present at the exit meeting on August 23, 1985.

2.0 Licensee's Actions on Previous Inspection Findings P

(Closed) Open Item (423/84-04-02). Northeast Utilities uses the Joint Utilities Management Audit (JUMA) to satisfy the requirement for an annual review of the QA Program. The JUMA is conducted in less than a week's time period and encompasses all three Millstone Nuclear Power Plants and Connecticut Yankee Nuclear Power Plant. Because this audit is too broad in scope and too short in duration, it is considered a weakness of the management audit progra . In addition to the JUMA, Northeast Utilities upper management reviews the results of audits conducted by the Corporate QA group and the Site QA groups. A review of the program indicated that:

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Copies of all audit reports are sent to the Senior Vice President -

Nuclear Engineering and Operations Group for his review

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Quarterly and annual reports on the QA Program are prepared and sent by the QA Manager to upper management

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Upper management participates in many of the monthly QA Progress Meetings held on site The NRC inspector verified that either the President, Senior Vice President or Vice President attended these QA Progress Meetings by reviewing the meeting minutes for meetings held between January and April, 198 Based on the above this item is close .0 Design Changes and Modifications 3.1 References / Requirements

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10 CFR 50.59, Changes, Tests and Experiments

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Final Safety Analysis Report, Section 13.5, Plant Procedures, and Section 17.2, Quality Assurance During the Operation Phase

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Technical Specification Section 6, Administ ative Controls (Draft)

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Northeast Utilities Quality Assurance Program Topical Report, Rev. 7

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ANSI N45'.2.11 - 1974 (Reg. Guide 1.64-1976), Quality Assurance Requirements for the Design of Nuclear Power Plants

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ANSI N18.7_- 1976 (Reg. Guide 1.33 - 1972), Quality Assurance Program Requirements (Operation)

3.2 Program Review The inspector reviewed Millstone Plant (MP)-3 Operation QA program to verify that the applicant has:

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Established procedures for control of design changes and modifica-tions, including modifications such as lifted leads and jumper These procedures establish methods for initiation, reviews, safety evaluations, incorporation of fire protection guidelines and final approval prior to implementing the proposed changes

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Established responsibility for design changes and modification These procedures establish organization responsibilities for perfor-ming design work; conducting safety evaluations; identifying, reviewing, and approving design input requirements; performing inde-pendent design verifications; establishing design interfaces between responsible design organizations; approving design documents; reviewing final design changes against original design requirements; l

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and assuring that appropriate fire protection requirements are addressed in the design change or modification

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Established administrative controls for controlling changes to approved design change documents, recalling obsolete design change documents, and releasing and distributing approved design change documents

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Established responsibility and administrative controls to assure timely incorporation of design changes and modifications into plant procedures, plant drawings and operator training programs

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Established controls that define the channels of communication and interface between the various design organizations and individuals performing design changes and modifications

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Established administrative controls for collecting and transmitting design change and review documents to the records storage facility

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Established administrative controls for implementing in accordance with approved procedures design changes, post-modification acceptance testing and testing results evaluations

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Established responsibility and methods for identifying post-modifi-cation testing requirements and acceptance criteria, as well as, reporting design changes and modifications to the NRC in accordance with 10 CFR 50.59 requirements

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Established controls for periodic reviews of lifted lead and jumper records, including checks of outstanding entrie The inspector reviewed the following Nuclear Engineering and Operations (NEO), Generation Engineering and Construction (GE&C) Administrative Control Procedures (ACP), Quality Assurance Procedures (QAP), and a MP-3 Policy Statement:

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NEO 2.14, Nuclear Plant Fire Protection Program, Rev. 0

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NEO 3.03, Preparation, Review, and Disposition of Plant Design Change Requests (PDCRs), Rev. 4A

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NE0 3.04, Preparation, Issuance and Control of Project Assignments, Rev 0

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NE0 3.12, Safety Evaluation, Rev. 1

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NEO 5.03, Controlled Distribution of Design Documents, Rev. NE0 5.05, Design Inputs and Design Verification, Rev. O

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NE0 5.06,. Preparation, Review and Approval of Design Analyses and Calculations, Rev 0

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NE0 5.11, Design Change Notices for Design Documents, Rev. 0

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NE0 5.12, Performance of Fire Protection Review, Rev. 0

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NE0 7.01,= Construction Implementation of Operating Plant Modifica-tions, Rev. 0 ,

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.NEO 7.03, Preoperational Testing of Plant Modifications, Rev. 0

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NE0 8.01, Jumper, Lifted Lead and Bypass Control, Rev. 1

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Northeast Utilities QA Program (NVQAP) Topical Report QAP-3.0, Design Control, Rev. 7

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NUQAP Topical Report QAP-5.0, Procedures, Instructions and Drawings,

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NUQAP Topical Report QAP-11.0, Test Control, Rev. 7

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Administrative Control Procedure (ACP)-QA-2.06B, Station Bypass / Jumper Control, Rev. 5

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ACP-QA-3.04A, Design Change Control . Design Phase, Rev. 0

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-ACP-QA-3.10, Preparation, Revies, and Disposition of Plant Design Change Requests (PDCRs), Rev. O i- --

ACP-QA-3.12, Design Inputs and Design' Verifications, Rev. 0

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ACP-QA-3.14, Design Change Notices for Design Documents, Rev. 0

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Generation Engineering and Construction (GE&C) Division - 3.06, '

Preparation, Review, and Approval of Drawing change Requests (DCRs)

and Drawing Submittal Requests (DSRs) for Inservice Nuclear Plants, Rev. 0

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GE&C - 3.07, Processing and Control of Drawing Change Requests-(DCRs) and Drawing Submittal Requests (DSRs) by Generation Engineering Design, Rev. 0

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NEO Policy Statement Policy No. 24, Millstone Unit 3 Project

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Procedures and Design Control / Design Document Control Transition,

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q Upon receipt of the operating license, the Design Change and Modification- :

program will be implemented. The program implementation for Millstone '

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Unit 3 is the extension of the approved program used by Millstone Units 1 and 2. The NRC inspector reviewed the Plant Design Change Request (PDCR)

program used by Units 1 and 2. The inspector also reviewed implementation of Units 3's temporary modification progra . PDCR Program PDCR #1-46-85, " Gas Turbine Battery Replacement" for Millstone Plant Unit I and PDCR #2-20-85, " Terminal Blocks Inside Containment Used for Instrumentation Circuits" for Millstone Plant Unit 2 were reviewe Based on this review the following was determined:

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The design change was reviewed and approved as require Design input requirements were specified, reviewed and approve Independent design verification was performe Personnel responsible for designating safety related/non-safety related classification were cognizant of the QA program classification requirement . Temporary Modification, Lifted Leads and Jumpers The inspector reviewed the MP-3 Control Room temporary modification log and verified that:

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The log reflected the actual status of items involved in the temporary modificatio Approved updated procedures which covered the modification were availabl Independent verification of installation and removal of temporary modifications, lifted leads and jumpers was performed, wherever applicabl The inspector also verified that the documentation, review and approval process for the following installation of jumpers or lifting of leads pertaining to the Reactor Protection System, Emergency Safety Features System and Emergency Diesel Generators Systems were complete and adequat Reactor Protection System:

385-76, Reactor Head Vent Valve - Lifted Leads 385-93, Pressurizer Pressure Safety Injection Block - Lifted Leads

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. Emergency Safety Features:

385-46, Reactor Coolant Loop I - Lifted Leads 385-92, Level Transmitter on Recirculating Sump -

Lifted Leads Emergency Diesel Generators:

385-59, Emergency Generator Fuel Pump IC - Jumper

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Installation 385-79, Bypass A Diesel Startup - Jumper Installation The inspector verified that the log entries were complete and correct, the temporary modifications were properly reviewed and evaluated and a monthly audit was conducted which reflected the actual status of the items involve .4 Findings No violations were identifie .0 Test and Experiments 4.1 References / Requirements

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10 CFR 50 Appendix B, Criteria I and XI

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Final Safety Analysis Report (FSAR) Section 13, Plant Procedures, and Section 17, Quality Assurance

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Technical Specification, Section 6, Administrative Controls

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ANSI N45.2.8 - 1975 (Reg. Guide 1.116 - 1976), Quality Assurance Requirements for Installation, Inspection, and Testing of Mechanical Equipment and Systems

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ANSI N18.7 - 1976 (Reg. Guide 1.33 - 1978), Quality Assurance Requirements (operation)

4.2 Program Review The inspector reviewed Millstone Unit 3 Operation QA program to verify that the applicant has:

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Established formal methods for conducting tests and experiments involving safety-related structures, systems and components, or modes of operation different from those described in the FSAR

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Developed written procedures for conducting tests and experiments

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Established responsibilities for reviewing and approving tests and experiments procedures

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Established responsibilities for controlling implementation of the conduct of tests and experiments and the governing procedures

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Established a formal system, including assignment of responsibilities, for reviewing all proposed tests and experiments

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Assigned responsibilities for developing a written safety evaluation pursuant to 10 CFR 50.59 for each te and experiment not described in the FSAR to assure that it does not involve an unreviewed safety question or a change in the Technical Specificatio The inspector reviewed the following Millstone Units 1 and 2 operating plants' approved procedures which will be utilized for Millstone Unit 3 tests and experiments programs:

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ACP-QA-9.02, Station surveillance program, Rev. 12

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ACP-QA-9.03, Inservice Plant Testing, Rev. 5 and SF-314, Inservice Station Procedure Change Form, Rev. 1

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Northeast Utilities QAP Topical Report QAP-11, Test Control, Rev. 7 4.3 Program Implementation The tests and experiments program will not be implemented until issuance of the Plant Operating Licens . 4 Findings No violations were identifie .0 Measurement and Test Equipment (M&TE)

5.1 Program References / Requirements

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Final Safety Analysis Report (FSAR) Chapter 17

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

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Yankee Atomic Electric Company (YAEC) Quality Assurance Manual, YOQAP-1A, QAP 12 and Section XII, Control of Measurement and Test Equipment, Revision 15

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5.2 Program Review The inspector reviewed the M&TE program and determined that the applicant has:

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Established responsibilities for establishing and implementing procedures

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Developed an equipment inventory list which allows for the addition of new equipment as well as:

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identifying M&TE used on safety related structures, systems or components

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identifying the calibration and adjustment frequency

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listing the calibration standard and procedure

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Established a recall system which includes the calibration and adjustment frequency and provides assurance that the equipment will be submitted on or before due date

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Established out-of-calibration controls including cause and traceability to previously tested or measured items

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Established the requirement to prohibit use of out-of-calibration M&TE

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Established a program which provides the calibration status of M&TE 5.3 Program Implementation Implementation of the' M&TE Program was verified in accordance with the approved procedures ACP-QA-9.04, ACP-QA-9.04A, GE&C 5.01, GE&C 5.04 and IC3401. Controls identified in paragraph 5.2 were verified by randomly selecting 16 M&TE that were being used in the field. Each piece of equipment was:

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properly identified including calibration status

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calibrated by working and reference standards traceable to National Bureau of Standards (NBS) in accordance with a specific calibration procedure and calibration schedule

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stored, issued and returned in accordance with the approved procedure The M&TE equipment selected for examination included 3 pressure gauges, 3 Digital Voltmeters, 2 Dead Weight Testers (Primary Standards), a pico-ammeter, a thermocouple thermometer, 2 torque wrenches, a dial indicator (primary standard), a dual trace memory oscilloscope, a micrometer, and a digital _ calibrator. In addition, the Instrumentation and Control (I&C)

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Department Head, the I&C foreman and the Maintenance Department technician responsible for the M&TE Program were interviewed. They were knowledge-

- able of the criteria in paragraph Twelve users of the M&TE (craftsmen and technicians) were interviewed at the work site. They were knowledgeable of the use and care of the M&T They also knew the procedure to follow when a M&TE is damaged, out-of-calibration, or providing questionable data. The training records of three I&C. technicians interviewed were reviewed and found to be in

. conformance with IC 340 The fellowing documents were reviewed:

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ACP-QA-9.04, Revision 16, Control and Calibration of Measurement &

Test Equipment

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ACP-QA-9.04A (Revision 0 Draft), Use of Quality Assurance Measurement & Test Equipment Control Program

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1.1C 3401, Revision 2, Unit 3 Instrument and Control Department Training

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GE&C Quality Control Procedure QC-G-5.01, Revision 3, Control of Measuring and Test Equipment

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Department calibration records (history and usage folders) and the Calibration Laboratory logs and procedures for the following M&TE

• Digital Calibrator QA 5155

• Digital Voltmeters QA 5215,- 5166, 5060

• Dual Trace Memory Oscilloscope QA 5196

Dial Indicator QA 17539

• Inches of Water Gauge QA 5182

Micrometer QA 5794

Picoammeter QA 5055

• Pressure Gauges QA 5088, 5324, 5326

• Thermocouple Thermometer QA 5721

• Torque Wrenches QA 5753, 5870

• Primary Standard Dead Weight Testers QA-174 and 5057

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• Primary Standard Torque Master Calibration System QA-5839 with

• Digital Torque Readout QA 5838

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Calibration records for level /and flow transmitter 3FW-LT-47

and MSS-FT-542

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M&TE List (M&TEL) for Instrumentation and Control (I&C)

Department and Maintenance Department

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Automated Work Order (AWO) M3-85-20115 for repair of M&TE QA 5077

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Quality Assurance (QA) Monitor Report (SF-921) Nos. 183-09 and 283-11

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Instrument Nonconformance Report (INCR, SF-902) Nos. 653, 844, 847, and 862

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Training and Qualification record of three I&C technicians

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Nuclear Construction QA Audit Report A-40963 Control and Calibration of M&TE The inspector also witnessed the following activities:

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AWO Nos. M3-84-00148 (Scheduled Loop Calibration); M3-85-12408 (Repair and Test of Relief Valve CHS-RV-8570B); M3-85-24954 (Corrective Maintenance of MSS Loop 75 Radiation Monitor); and M3-85-25197 (Install Prissure Indicator)

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Primary Standard QA 5057 Red Tagged for INCR

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Level and Flow Transmitter 3FW-LT-547 and M85-FT-5&2 with questionable calibration label (stickers) problems 5.4 Findings No violations were identifie .5 QA and QC Interface Quality control (QC) activities reviewed for conformance to program requirements were: Processing of Instrument Nonconformance Reports (INCRs) to assure adequate corrective action Observing a QC inspector checking the calibration status of a test gauge (QA 5324) prior to start of acceptance tests for the repair of

- the CHS-RV-8570B relief valve

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Quality assurance (QA) activities reviewed for conformance to program requirements were: Processing QA Monitor Report Nos. 183-09 (Unit 1) and 283-11 (Unit 2) regarding maintenance Department Torque Wrench Calibration Progra Nuclear Construction QA Audit A-40963, Control and Calibration of M&TE, conducted November 8, 1984 through December 7, 1984 and issued December 26, 1984. The audit checklist was thorough and was followe .0 Safety Committee Activity 6.1 Requirements / References

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Technical Specification Section 6.5.1, 2 & 3 (Draft)

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Final Safety Analysis Report (FSAR) Chapter 13

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ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants 6.2 Program Review The inspector reviewed the independent safety review committee programs described in approved procedures ACP-QA-1.04, 1.05 and NE0 2.02, and determined that the applicant has:

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identified responsibilities and authorities for meeting safety committee requirements

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identified membership and the selection of alternates for safety review committees

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established quorums and meeting frequencies as well as the agendas, conduct of, recording and reporting of meetings

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provided for followup action

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established communications and interface with other review group The inspector also determined that the programs require that:

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the subjects identified in Section 6 of the technical specification and Section 13 of the FSAR were reviewed

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mechanisms exist for initiating and conducting the above revie .

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6.3 Program Implementation

' The implementation of the program was verified by the following actions:

A PORC meeting (3-85-143) was observed in progress. The Chairman

conducted the meeting in an efficient manner. The members were knowl-edgeable of the subjects presented and queried the presenters to ensure

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that each agenda item was_ thoroughly developed and evaluate Minutes of 9 PORC meetings, 5 SORC meetings, and 5 NRB meetings were reviewed. The contents of the minutes were found to conform to the program requirements. A QA surveillance report and ACP-QA-1.04 were discussed with-the Plant Superintendent and the NUSCO site coordinato (see Findings)

The following documents and activities were reviewed:

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Administrative Control Procedure (ACP)-QA-1.04, Revision 19, Plant Operations Review Committee (PORC)

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ACP-QA-1.05, Revision 13, Site Operations Review Committee (SORC).

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Nuclear Engineering and Operations Procedure (NE0) 2.02, Revision 1 Charter for Nuclear Review Aoards

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Plant Operations Review Committee (PORC) minutes for meeting No , 60; 66; 67; 71; 74; 107; 118; 119

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Site Operations Review Committee (SORC) minutes for Meeting No ; 22, 21; 20 (agenda included calibration procedures); 1 Unit No. 3 Nuclear Review Board (NRB) minutes for meeting Nos. 85-2; 3; 4; 5; and 6 (Special)

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Quality Assurance (QA) Surveillance No. C-3051A

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Memorandum from Supervisor, Construction QA to Chairman, Millstone 3 ,

Nuclear Review Board (NRB) of June 21, 1985

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Joint Test Group (JTG) and PORC meeting No. 3-85-143 on August 20, 1985 6.4 Findings QA Surveillance Report C-3051A is a follow-up report to C-3051 regarding training of PORC alternates. The Plant Superintendent acknowledged that there were a few " stragglers". requiring training. The training of the last few stragglers will not reduce the effectiveness of the POR The following were noted during the review of PORC procedure ACP-QA.I.0 .

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Section 6.5.12. The ACP will be revised accordingl . Paragraph 6.1.8 does not include the request for Special Reviews by Station Superintendent as required by TS Section 6.5.1.6h. The ACP will be revised accordingl No violations were identifie .5 QA and QC-Interface QA reviewed and signed off on ACP-QA-1.04 and 1.05. QA is monitoring the progress of QA Surveillance Report C-3051A. QA has not conducted any Unit 3 Safety Review Committee Audits. QA did however, conduct an evaluation of Unit 3 Joint Test Group (JTG) from May through June 198 The evaluation was submitted to the Chairman of NRB June 20, 1985. QA is planning to audit the Unit 3 Safety Review Committee .0 Independent Measurements Automated Work Order (AWO) M3-85-12408 scoped the repair and test of CHS-RV-85708 relief valve. The repair was performed in accordance with Crosby Valve and Gage Company procedure 1-11068 Rev. 1. The pressure lift test was conducted in accordance with maintenance procedure MP3762WD Rev. An onsite independent verification of the stud nut torque and relief valve lift setting was conducted on August 20, 1985. Both inspec-

! tions were within the acceptance criteria of the procedures and also witnessed by a licensee Quality Control inspecto .0 Management Meetings Licensee management was informed of the scope and purpose of the

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inspection at an entrance meeting conducted on August 19, 198 The l findings of the inspection were discussed with licensee representatives during the course of the inspection. An exit meeting was conducted on

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l August 23, 1985 at the conclusion of the inspection (see paragraph r for the meeting attendees) to provide the findings to the licensee j- management i

1 At no time during the inspection was written material provided to the

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