ML17139A231
| ML17139A231 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/29/1981 |
| From: | Martin T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17139A230 | List: |
| References | |
| 50-387-81-08, 50-387-81-8, 50-388-81-04, 50-388-81-4, NUDOCS 8106160517 | |
| Download: ML17139A231 (11) | |
Text
APPENDIX A NOTICE OF VIOLATION Pennsylvania Power and Light Company Susquehanna Units 1 and 2
License No s.
CPP R-101 CPPR-102 Docket Nos.
50-387 50-388 As a result of the inspection conducted on March 23-April 4, 1981 and in accordance with the Interim Enforcement Policy, 45 FR 66754 (October 6, 1980),
the following violations were identified.
10 CFR 50.55a(g)(2) states in part that, "For a boiling or pressurized water-cooled nuclear power facility whose construction permit was issued on or after January 1,
1971, but before July 1,
- 1974, components (including supports) which are classified as ASME Code Class 1 and Class 2 shall be designed and be provided with access to enable the performance of (i) inservice examination. of such components (including supports)...".
Contrary to this requirement, there was no objective evidence available to indicate that measures had been applied during design to provide for accessibility for performance of preservice or inservice examinations.
Access to several welds-for preservice/inservice inspection in Class 1
systems such as the reactor water cleanup, feedwater, core spray and RHR systems will be impractical, and in some cases impossible short of major dismantling of the plant.
This is a Severity Level IV Violation (Supplement II) applicable to Docket Nos.
50-387 and 50-388.
2.
10 CFR, Appendix B, Criterion II, states, in part, that "The quality assurance program shall provide control over activities affecting quality of identified structures;...".
and "Activities affecting quality shall be accomplished under suitably controlled conditions."
PSAR Section D.2.2 of Appendix D states',
in part, that:
"The guality Assurance Program for the Susquehanna Steam Electric Station, Units 1 and 2, will be responsive to, and meet the intent of 10 CFR 50, Appendix B."
Contrary to the above, on March 24, 1981 the inspector observed workmen in the lower cable spreading room, elevation 714, performing random
'installation of Hilti Power Driven Fasteners to safety related structural steel for the purpose of attachment of non-safety related metal lathe for fireproofing material support without instructions, direction or acceptance criteria for this activity.
This is a Severity Level IV Violation (Supplement II) applicable to Docket No. 50-387.
ti
Appendix A 3.
10 CFR 50, Appendix B, Criterion III, states, in-part, that "Measures shall be established to assure that...the design basis...for those struc-
- tures, systems, and components...are correctly translated into specifica-tions, drawings, procedures and instructions."
PSAR Section D.3.3. 1 of Appendix D, states, in part, that:
"The project engineering team employs several documents to establish requirements...
These documents include...project criteria...standard specifications and data sheets."
Contrary to the above, on March 26, 1981 the inspector observed that the Hydrogen Analyzer small pipe drawing SP-HCB-108-1 through 3, for the atmosphere sample return line, does not conform to the requirements in vendor installation instructions,'hich specify a maximum total vertical run of thirty (30) feet.
The subject drawing indicates a total vertical run in excess of fifty (50) feet.
This is a Severity Level IV Violation (Supplement II) applicable to Docket Nos.
50-387 and 50-388.
10 CFR 50, Appendix B, Criterion VII, states, in part, that:
"...Docu-mentary evidence that material and equipment conform to procurement requirements shall be available...".
and "...shall be sufficient to identify the specific requirements...met by the purchased material and equipment."
PSAR Section D3.3.5 of Appendix D, states, in part, that:
"The Bechtel quality assurance program includes a comprehensive system to assure that purchased
- material, equipment and services conform to the procurement documents".
Paragraph 6.3 of Purchase Specification 8856-J-27 requires Certified Performance Data for the Reactor Coolant Radiation Leak Detection System.
Such data is used to establish minimum instrument capability.
Contrary to the above, on March 25, 1981 the inspector reviewed Isotopic Calibration Results data which had been accepted by the licensee as Certified Performance Data.
Purchase Specification requirements include Isotopic Calibration Results (paragraph
- 10. 13) as well as Certified Performance Data.
The Isotopic Calibration Results data does not meet the same requirements as Certified Performance Data which is used to establish minimum detectable sensitivities within defined parameters (i.e., flow, temperatures, sample line, size and configuration, response time) necessary for detecting the 1
gpm leak rate included in Regulatory Guide 1.45.
This is a Severity Level IV Violation (Supplement II) applicable to Docket Nos.
50-387 and 50-388.
,l
Appendix A 5.
10 CFR 50, Appendix B, Criterion V states in part:
"Activities affecting quality shal.l be prescribed by documented instructions, procedures, or drawings,...and shall be accomplished in accordance with these instruc-
- tions, procedures, or drawings."
PP&L QA Manual Procedure 2.2, Section 5.2. 1 states:
"For new procedures and revisions, other than minor changes (such as typographical errors, organization name changes, and position title changes) and updating, the Manager-NQA issues the procedure as a
"DRAFT" and formally distributes the procedure for review and comment to personnel and organizat'ions which are affected."
Procedure SP-8, Section 4.2 states in part:
"Functional unit managers responsible for controlling specif'ic documents...shall initiate, coordinate and document reviews of such documents in accordance with the applicable
'requirements...".
Section 4.4 of the same procedure states:
"The Manager-NQA is responsible for verifying compliance with the requirements of this procedure."
Contrary to the above, Procedures 16.0, Revision 6;
- 16. 1, Revision 4;
16.2, Revision 4; and SP-4, Revi son 2 were not subjected to the review and comment process before their approval and issuance despite major changes effected in the above procedures, and th'e Manager-NQA transmitted these procedures to the QA Manual holders for retention.
This is a Severity Level V Violation (Supplement II) applicable to Docket Nos.
50-387 and 50-388.
6.
10 CFR 50 Appendix B, Criterion V, states, in part:
"Activities affecting quality shall be prescribed by documented instructions, procedures or drawings, of a type appropriate to the circumstances...".
The Susquehanna PSAR, Appendix D, Paragraph D.25 states in part:
"Activities affecting quality will be prescribed by documented instructions, procedures, or drawings appropriate to the circumstances."
The PP&L Quality Assurance
- Manual, Supplemental Procedure SP-ll, Revision 5, Section
- 7. 1 states in part that:
"Functional unit procedures shall describe the processing of Nonconformance Reports (NCRs) from inception to closeout.
This description may be literal or in the form of a flow chart.
This flow shall assure that NCRs are routed to allow proper,...,
trend analysis of NCR's."
Contrary to the above, no functional unit procedure exists which describes the processing of NCR's for trend analysis.
This is a Severity Level V Violation (Supplement II) applicable to Docket
'No. 50-387.
E q
I
Appendix A 7.
10 CFR 50, Appendix B, Criterion V states in part:
"Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings,...and shall be accomplished in accordance with these instruc-tions, procedures or drawings."
PP&L Susquehanna QA Manual, Procedure 1.0, Section 6.2. 1 states in part:
"Supplemental Procedures (SP) are issued to augment QA Manual Procedures.
in order to introduce additional direction for PP&L personnel and organi-zations performing activities during the transition from the construction phase to the operating phase."
Contrary to the above, Procedure SP-8 was issued to replace an existing approved QA procedure
- 5. 1 in its entirety from the QA Manual.
This is a Severity Level VI Violation (Supplement II) applicable to Docket Nos.
50-387 and 50-388.
8.
10 CFR 50, Appendix B, Criterion V states in part:
"Activities affecting quality shall be prescribed by documented instructions, procedures, or drawings,...and shall be accomplished in accordance with these instructions, procedures, or drawings."
PP&L Work Instruction No.
10, Rev.
1, Section
- 5. 1.3 states:
"Qualified Auditorany person to be designated at this level shall have:
5.1.3.2 Accumulated a minimum of ten (10) points on QA Form AQ-1."
Attachment I, Rev.
1,Section I.B of the same work.instruction further states:
"Bachelor's degree from an accredited institution in Engineering, Physical
- Sciences, Mathematics, or Quality Assurance score (3) points; other type degrees score (2) points."
Contrary to the above, one qualified auditor's certification disclosed that the person was certified improperly by having been awarded four (4) points for a Bachelor's degree..
An award of three (3) points would have precluded his certification for at least three months.
This is a Severity Level VI Violation (Supplement II) applicable to Docket Nos.
50-387 and 50-388.
Appendix A Pursuant to the provisions of 10 CFR 2.201, Pennsylvania Power and Light Company is hereby required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including (1) the corrective steps which have been taken and the results achieved; (2) corrective steps which will be taken to avoid further violations; and (3) the date when full compliance will be achieved.
Under the authority of Section 182 of the Atomic Energy Act of 1954, as
- amended, this response shall be submitted under oath or affirmation.
Dated MAY 29 ]99i Thomas T. Martin, Acting Director, Division of Engineering and Technical Inspection
APPENDIX B SIGNIFICANT OBSERVATIONS Pennsylvania Power and Light Company License Nos.
CPPR-101 CPPR-102 Docket Nos.
50-387 50-388 As a result of the inspection conducted on March 23-April 3,
- 1981, the follow-ing significant observations were identified in the implementation of your
- design, construction, and preoperational test program.
1.
The status of the Susquehanna Quality Assurance Plan (SQAP) in relation to the Project QA Manual and other procedures is not well defined and understood by the QA Personnel on-site.
There appears to be a great deal of divergent opinion regarding the relationship of these procedures, a
non-uniformi ty in interpretation, and misunderstanding of requi rement amongst the construction, operations, and the home office QA personnel.
This is considered a weakness in the QA program.
(Reference Section
- 2. 1
~ 3. 1 of Report 387/81-08 and 388/81-04 Details.)
2.
The licensee's QA Manual uses a reference system to augment, amplify, and incorporate additional requirements or directions contained in other pro-cedures.
- However, several procedures reference a document that is not irr existence thereby defeating the purpose of the reference.
Also, the QA Manual contains more than one procedure to control the same activity.
There is no clear indication i'n each procedure as to the purpose and application of these different procedures.
The procedures also lack a clear direction to the user as to where, under what circum-
- stances, and by whom these procedures will be used.
The above examples illustrate a weakness in the licensee's QA Manual.
(Reference Section 2.1.3.2 of Report 387/81-08 and 388/81-04 Details.)
3.
The licensee has not established a method to evaluate turned-over equip-ment that is subsequently found to have conditions adverse to quality, to determine if the conditions developed before or after turnover, and, if before turnover, to determine what deficiency in the turnover process permitted an adverse condition to be overlooked.
This is considered to be a weakness in the licensee's corrective action system as applied to system turnover.
(Reference Section 2.1.3.3 of Report 387/81-08 and 388/81-04 Details.)
0 Appendix B
4.
Several areas were identified in the electrical/instrumentation area where accepted/approved design documents did not meet SAR commitments or other specified requirements.
It appears that reviews of such documents lack depth with insufficient comparison between such documents and require-ments and commitments.
Although each of these cases were individually cited elsewhere in this report, this indicates a weakness in the design document review process.
(Reference Sections
- 5. 1.3 and 5.2. 1.5 of Report 387/81-08 and 388/81-04. )
5.
There are no clearly delineated procedures or practices to direct inter-facing activities between on-site organizations that perform work that impacts on surveillance and maintenance of equipment stored in place.
As a consequence, several instances were observed where it appeared that storage/maintenance requirements h'ad not been met during periods such as for modification or additional installation activities, the pre-operational phase and immediately following system/component turnover.
This is a weakness in the program for in-place storage, surveillance and preventative maintenance.
(Reference Sections
- 6. 1.F 1; 6.2.2.2 and 6.2.2.4 of Report 387/81-08 and 388/81-04.)
6.
Site originated design work involving documentation of calculations as well as activities involved in preparing, processing and dispositioning of design related documents such as FCR's and NCR's was found to be well controlled in accordance with existing procedures.
PP&L audits of site design activities were found to be regularly scheduled and comprehensive in nature.
This is considered to'e an area of program strengths (Reference Sections 3.2.2. 1. 1, 3.2.2.2, 3.2.2:5 and 3.2.3. 1 of Report 387/81-08 and 388/81-04.)
b