ML17244A359

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IE Insp Rept 50-244/78-24 on 781113-16.Noncompliance Noted: Single Type Records Stored in Locations Which Did Not Meet Storage Facility Physical Feature Requirements.Records Involved Were Radiographs & Operations Recorder Charts
ML17244A359
Person / Time
Site: Ginna Constellation icon.png
Issue date: 12/05/1978
From: Kister H, Markowski R, Napuda G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML17244A355 List:
References
50-244-78-24, NUDOCS 7902080091
Download: ML17244A359 (28)


See also: IR 05000244/1978024

Text

Report

No.

50-244 78-24

U.S.

NUCLEAR REGULATORY COMMISSION

OFFICE

OF INSPECTION

AND ENFORCEMENT

Region I

Docket No.

50-244

License

No.

DPR-18

Priority

Licensee:

Rochester

Gas

and Electric

Com an

Category

C

89 East Avenue

Rochester,

New York

14649

PZ-5: 78

Inspectors:

date signed

ate signed

2

,5-2Z'ate

signed

Facility Name:

R

E

Ginna Nuclear

Power Plant, Unit No.

1

Ontario,

New York; and

RG&E Corporate Offices and

the Andrews Building, Rochester,

New York

Inspection

conducted:

November 13-16,

1978

R. S.

Mar owski, Reactor Inspector

s4

G

puda,

Reactor

n

ector

D.

Ke o,

eactor

Inspector

Approved by:

. Kister, Chief, Nuclear Support Section

No. 2,

RO

8

NS Branch

a-~ -7F

date

signed

Ins ection

Summar

Ins ection

on November 13-16

1978

Re ort No. 50-244 78-24

~AI d:,

dd

b

by

dd

bb

dd

d

y

b

accepted

Quality Assurance

Program

(QAP) implementation including:

QAP changes;

design

change/modification control; procurement/material

control; records

management;

and,

audits.

The inspection also included followup on previously identified unresolved

items.

The inspection involved 39 inspector-hours

on site

and 54.5 inspector-hours

at corporate

- offices by three

NRC regional

based

inspectors.

Results:

Of .the six areas

inspected,

no items of noncompliance

were identified in five

areas;

one item of noncompliance

was identified in one area (Infraction - fai lure to

store nonduplicated

recorder charts

and

radiographs

in compliance with ANSI N45.2.9,

Section 5.6, Paragraph 6.b.(l)).

7 9 0 2 0 8 0 0

f l

Region I Form 12

(Rev. April 77)

~

)

0

Jf

4I

DETAILS

Persons

Contacted

  • C. Anderson,

QA Manager

  • J. Arthur, Chief Engineer

S. Bullock, Site

QC Engineer

G. Daniels, Electrical Discipline Manager

G. Davis, Mechanical

Engineer

  • K. Easterbrook,

QA Engineer

D. Gannon, Assistant to Drafting Supervisor

  • K. Gregory, Project

QC Engineer

  • L. Lang, Superintendent

- Nuclear Production

H. Hack,

Document Control Supervisor

  • R. Morse, Drafting Supervisor

G. Paris,

I8C Supervisor

  • W. Schulze,

Purchasing,

Buyer

  • B. Snow, Plant Superintendent

J. St. Martin, Project Liason Engineer

  • D. Woodward, Quality Engineering Co-ordinator
  • R. Vanderwheel,

Project Manager

Other Accom an in

NRC Personnel

  • J. Johnson,

Reactor Inspector

  • denotes

those present at exit interview.

Followu

on Previousl

Identified Items

(Closed} Unresolved

Item (244/77-08-01):

Establish correct/preferred

method for making corrections

to quality records.

The inspector

reviewed the revisions to the Quality Assurance

Manual - Section

17, Procedure

QE-1701GS,

and Procedure

QC-1701 that specify the

correct/perferred,metho'd-'for"making:corrections

to quality records

and observed

the established

method to be

a single line through the

error, initialed, with the correction

above.

This item is resolved.

(Closed)

Unresolved

Item (244/77-08-02):

Revise

Procedure

QE-401GS.

The inspector reviewed Revision

4 to QE-401GS

and observed that the

revision eliminated the engineering

department

requirement for the

QA department

to initial the purchase requisition

as part of engineering's

review of the purchase

requisition.

The inspector

reviewed Procedure

gA-402GS

and verified that the appropriate

documentation of QA

review of purchasing

documents

is specified therein.

This item is

resolved,

(Closed)

Unresolved

Item (244/77-08-03):

Revise Procedure

QE-

1701GS.

The inspector

reviewed Revision

4 to QE-1701GS which

contains

a specific method for indexing records.

The inspector

reviewed the records

index and storage

area

and found both to be

consistent with the requirements of QE-1701GS,

Revision 4.

This

item is resolved.

(Closed)

Unresolved

Item (244/77-17-07):

Followup action associated

with CAR 77-2.

The inspector

reviewed revised

drawings transmitted

for installation associated

with supports

SW-69,

SW-70,

SW-73,

SW-

78,.and

SW-83; and, audit report 77-32-CA.

The drawings associated

with SW-69,

SW-73,

SW-78,

and

SW-83 indicated that the support load

values

had

been recalculated.

The drawing associated

with SW-70

indicated that the support

had

been redesianed.

The

RGSE audit

report indicated that the

AE had performed

a review (by audit)

and

additional training in design interface control

and concluded that

no other design interfaces

had been missed.

This item is resolved.

3. ~PCh

The inspectors

reviewed

a sample of revisions

made to the Quality

Assurance

Manual

(0AM), and implementing procedures

of the Quality

Assurance

Department

(QA), Engineering

Department

(QE), Purchasing

'epartment

(QP),. and the Site

(QC) subsequent

to the last

NRC

QA

inspection

during May 1977.

These revisions

were reviewed for

consistency with the licensee's

accepted

Quality Assurance description.

These

procedures

also served

as the basis for inspection of the

areas

discussed

in this report.

During the conduct of this inspection,

discussions

with licensee

personnel

indicated that they were aware

of the, procedural

changes.

The procedures

reviewed were:

  • QAM Section 3, Design Control, Revision

7

  • QAM Section

6,

Document Control, Revision

5

QAM Section

17, Records,

Revision

6

  • QA103GS, Management

Review of the Quality Assurance

Program,

'Revision

4

QA201GS, Quality Assurance

Group Organization

and Responsi-

bilities, Revision

7

QA502GS, Preparation,

Review and Approval of Quality Assur-

ance Procedures,

Revision

4

QA601GS, Quality Assurance

Review of Departmental

Quality

Assurance

Procedures,

Revision

2

QA602GS, Preparation,

Review and Approval of Procedure

Deviation Requests

by Quality Assurance,

Revision

2

  • QA1603S, Preparation,

Review and Processing

of Corrective

Action Reports

by Quality Assurance,

Revision

3

QA1801GS, Qualification of Auditing Personnel,

Revision

5

QA1803GS,

Performance of Quality Assurance Audits, Revision

3

  • QA1804GS, Reporting

and Follow-up of RG&E Audit Findings,

Revision

5

  • QA1806GS, Review of Audit Program,

Revision

2

  • QE602GS, Control of Documents

by the List of Current Revisions

Method, Revision

3

QE604GS, Distribution and Control of Documents

by Project

Correspondence

Procedures,

Revision

1

  • QE606GS, Receipt,

Control

and Distribution of Drawings

and

Aperture Cards,

Revision

0

QE1701GS,

Records,

Revision

4

QP101GS,

Periodic

Review of Purchasing

Procedures,

Revision

4

QP210GS,

Purchasing

Department Organization

and Responsi-

bilities, Revision

3

  • QP401GS, Preparation,

Review, Approval and Issuance of

Purchase

Orders

and Changes

to Purchase

Orders,

Revision

4

  • QP701GS, Supplier Evaluation,

Revision

5

  • QP702GS,

Establishment

and Maintenance of Qualified Suppliers

List, Revision

5

+QP703GS,

Biennial

Review of Qualified Suppliers,

Revision

1

QP1701GS,

Purchasing

Records,

Revision

3

  • QC202, Modification Project Organization,

Revision

0

gC301,

Work

S tart Authorization,

Revi si on 4

qC303, Control of System Modification Activities, Revision

3

gC304, Control of Modification Activities by the Modifi-

'ation

Project,

Revision

0

gC601, guality Control Procedure

Document Control,

Re-

vision

3

gC602, Plant Procedure

Document Control, Revision

12

qC1001,

Inspection

and Surveillance Activities, Revision

6

gC1102,

Performance of Tests,

Revision

3

gC1501,

Control

and Disposition of Deficient Materials,

Revision

3

  • gC1701, guality Assurance

Records,

Revision ll

gC1703,

Record Storage Facility and Equipment,

Revision

3

  • revised since previous

NRC inspection.

No items of noncompliance

were identified.

4.

Design

Chan es/Modifications

References

ll

Applicable procedures

listed in paragraph

3.

Review

The inspector selected

and reviewed the Station Modifications

(SM) listed below to verify, as applicable,

that they were

accomplished

in accordance

with 10 CFR 50.59

and the licensee's

accepted

gA program description.

The review was conducted

to verify that documentary

evidence

was available to establish

that the following activities were

performed:

technical

and quality verification provisions

specified in engineering

documents

were incorporated into the

modification procedures;

quality verification activities

(inspection and/or testing)

were conducted

concurrent with

and/or subsequent

to installation;

reviews of required records

were conducted

and the installation was accepted prior to

placing the affected

system in operation;

and, prints/drawings

and operating

procedures

were revised.

The station modifications reviewed were:

SM 75-39,

Main Steam Isolation Valves

SM 75-58,. Spent

Fuel

Pool Cooling Discharge

Pipe Rerouting

SM 76-24, Air Ejector Radiation Monitor Modification

SM 77-08, Full Length Control

Rod Sampling Resistor

Modification

SM 77-1836,

Pressure

Shielding Steel

Diaphram in the

Turbine Building (work in progress)

No items of noncompliance

were identified.

However, during

this review, the inspector identified the

two items discussed

below.

(1)

During the review of the calibration

(performed August

1977} of the rate meter drawer replaced

during the per-

formance of SM 76-24,

the inspector observed that the

specific test equipment utilized was not identified (e.g.

by serial

number}.

The inspector

reviewed the results of calibrations per-

formed subsequent

to the initial calibration and, cali-

bration records

associated

with the test equipment utilized.

These

documents identified the specific test equipment

.used;

and the acceptability of the rate meter.

Based

on

this review of these

supplementary

documents,

no item of

noncompliance

was identified.

(2)

The below listed inspection/examination

records

were not

retrieved prior to the completion of the inspection:

NDE report 1520, Penetrant

Test of MSIV Seat

(SM 75-

39)

NDE report 132, Ultrasonic Test of MSIV Cover Studs

(SM 75-39)

Radiography reports for welds AC-1008-E2-E20

(SM 75-

58)

Pending retrieval of these

records;

and,

review by RI,

this item is unresolved.

Refer to paragraph

6.b.(2) for

further details.

5.

Procurement .Material Control

a.

Reference

Applicable procedures

listed in paragraph

3.

b.

Procurement

Document

Review

The Purchase

Orders

(PO) listed below were selected for accepted

items which were stored in the station warehouse

area.

The Purchase

Orders

were reviewed to verify that proper approvals

had been obtained, quality control inspection

requirements

were specified,

and traceability from the item to the purchase

order and receipt inspection

records

was established.

The

Purchase

Orders

so reviewed were:

Shock

and

Sway Suppressors,

P.O.

NEG-84686-78-2

(on hold)

Welding Rod,

P.O.

NEG-87493-78-2 (rejected)

Stationary Motor Varidisc for Charging

Pumps,

P.O.

NEG-

87493-78-10

Shifting Motor Varidisc for Charging

Pumps,

P.O.

NGMDNR-

1748

fluke 343A Calibration,

P.O.

NEG-85751-78-1

SS Schedule

40 Pipe,

P.O.

NASC-16133

Heise Pressure

Gage Calibration,

P.O.

NEG-85749

4020-8 Resistor Calibration,

P.O.

NEG-85753

3450A Digital Voltmeter Calibration,

P.O.

NEG-85752

The inspector

reviewed the inspection

records

documenting

the

receipt inspection of the selected

items

and confirmed that:

the inspections

had

been

conducted

and reported

as required;

the items were procured

from vendors

included

on the licensee's

list of approved suppliers;

and, the items were stored

as

required.

No items of noncompliance

were identified, however,

an unre-

solved record item is discussed

in Paragraph

6 and two unre-

solved items are discussed

in Paragraphs

c and

d below.

C.

Stora

e Area Tour

The inspector toured the station warehouse

area,

observing

general

storage conditions,

conforming and nonconforming

material identification and segregation,

and general

house-

keeping practices.

The inspector observed

several

unacceptable

conditions at the

Warehouse

storage location such

as accessability,

pipe protec-

tion and general

cleanliness.

These

and other similar observed

conditions

were identified previously by the licensee

during

a

routine surveillance

and corrective action was initiated.

The

unacceptable

conditions

and request for corrective action are

documented

on PAR-.78.

This item is unresolved

pending review

of the completed

requested

corrective action by RI during

a

subsequent

inspection(s).

(50-244/78-24-01)

Inter-Divisional Services

The inspector noted that the General

Maintenance, Division

performed quality related services

under P.O.

GMDWR-1748.

The

inspector identified a number of interface areas

that were not

clearly described

in governing procedures

such

as what instructions,

records,

inspection

documentation,

etc.

were required.

The

Maintenance

Foreman

provided sketches

and other documents

that

enabled

the inspector to determine that the quality affecting

activities were performed

and inspected

as required.

The

inspector

expressed

concern

about the apparent

weaknesses

in

this area of interface control.

The licensee

stated that'he

.

manner of interface control with respect

to services

provided

by the General

Maintenance

Division would be reviewed

and

appropriate

action taken.

Pending

RI review of completed

action(s)

during

a subsequent

inspection(s)

this item is

unresolved.

(50-244/78-24-02)

6.

Records

and Drawin

s

a ~

Reference

Applicable procedures

listed in paragraph

3.

b.

Record Stora

e and Retention

The inspector selected

the following records in order to

'etermine

the licensee's

capability to store,

control

and

retrieve operating records:

-.--""-<'Reco'rde'r:Char't"-';,".Ooop",Hot'iL'eg:.Pressurizer

Level-

Control

Room (June

1975)

Recorder Chart - Pressurizer

Pressure

(March 1975}

Surveillance Test PT-17.1,

Radiation Monitoring System

(January

through

December

1975)

Flux Map Raw Data

(1976)

I

Daily Generation

Log (May 1978)

Surveillance Test PT-2.1, Safety Injection

Pump Test

(1977}

HEPA Filter Banks

DOP Test Reports

(1975)

Plant Heatups at 100'F/HR (January

1977 through July

1977) (Plant Transient

Log}

~ The inspector

reviewed the following files at the Corporate

Office:

Closed

Out Car's

Superceeded

Engineering

Procedures

OA Procedures

and Manual

Chapters

Design Analysis

The inspectors

also requested

the records listed below at

various times during this inspection

and verified that they

were retrievable

and they were maintained

as required.

Audit Reports Listed in Paragraph

7

Procurement

Records Listed in Paragraph

5

Modification Packages

and Related

Records Listed in Para-

graph

4

In the area of records

storage

and retention

one item of

noncompliance

and two unresolved

items were identified.

These

items are discussed

below.

(1)

The inspector identified that oriainal radiographs of

safety related

systems

(dating to 1968)

such

as Reactor

Coolant and Chemical

Yolume Control were stored within

five cardboard

fi=ling boxes in the Andrews Building.

The

inspector also identified that operations

type recorder

charts,

required to be retained

by Technical Specifications,

were stored within steel filing cabinets

in a vacant

warehouse office.

Neither storage facility meets

the

10

minimum physical

requirements

described

in Paragraph

5.6

of ANSI N45.2.9 for the storage of single type records.

These

two examples constitute

an infraction level item of

noncompliance.

(50-244/78-24-03)

(2}

During the inspection,

the inspectors

requested

the

following records

which were not retrieved prior to the

completion of this inspection.

P,O.

NASC-16633 (duplicate copy,

Andrews Building)

P.O.

GMDWR-1748,(duplicate copy, Andrews 8uilding)

NDE Report

1520 (microfilm}

NDE Report

132 (microfilm}.

Radiographic Test Reports for Welds AC-1008-E2

through

20 - not necessarily

complete numerically

(microfilm}

Pending the retrieval of these

records

and their review

by RI during a subsequent

inspection(s),

this item is

unresolved.

(50-244/78-24-04)

(3).

The microfilm of calibration data sheets

associated

with

P.O.'s

NEG-85751

and

53 were not entirely legible.

The

I8C foreman

had retained

the original documents

in the

respective instruments'History

Files" and the inspector

reviewed

documents

indicating that subject copies of the

data sheets

fiad been

forwarded to the Andrews Building

for duplicate storage.

Therefore,

duplicate storage of

the required records

had been

accomplished.

The inspector

expressed

concern

about the reliability of

the record duplication process

and verification of legi-

bility prior to retention,

The licensee

stated that this

area

and associated

activities would be reviewed

and

appropriate action taken to assure

that microfilm of

records

are legible.

Until the licensee's

action(s) is reviewed during

a sub-

sequent inspection(s}, this 'item is unresolved.

(50-244/

78-24-05)

~

4

~

~

~

~

c ~

Drawin

Control

The inspector selected

the controlled drawings listed below to

determine that the established

controls were implemented

and

that as built drawings are being maintained.

The inspector

compared

the original tracings against

the master

index (station

and corporate}; corporate

central

records

aperture

card deck;

station central. records .aperture

card deck;

and applicable

hard copies distributed to the control

room, test

and results,

the pipe shop,

and station engineering.

~Dnawin

33013-422

33013-424

Revision

33013-425

33013-426

33013-427

- 33013-428.

33013-431

33013-432

33013-433

2

No items of noncompliance

were identified.

However, during

this review, the inspector identified the two items discussed

below.

(1)

The inspector noted that in an isolated instance

(DMG

33013-433 in the pipe shop)

a drawing was not of the

current revision.

During the review of drawing control

and modification document

packages

(paragraph

4) it was

determined that the control of drawings,

drawing revisions

and drawing change

notices

was in accordance

with established

reqpi.rements.'ubsequent

to this inspection it was

verified.'hat the latest- revision of the drawing was

issued to the subject location.

The inspector

had

no further questions.

(2)

The inspector identified that three drawings,

33013-425,

33013-426,

and 33013-433

had

been

stamped

"For Information

Only" prior to issua'nce

to station central

records.

12

These

drawings were subsequently

issued at the station

as

controlled drawings.

The inspector determined that the

drawings were all of the current revision.

The licensee

informed the inspector that

a new revision

to the procedure for issuing the drawings to station

central

records

was forthcoming which would insure that

only drawings identified as

"as built" would be issued to

station central

records.

This item is unresolved

pending implementation of the

new

procedure revision and review by RI (244/78-24-06).

d.

Tests

and

Ex eriments

The licensee

informed the inspector that no tests

or experi-

ments pursuant to 10 CFR 50.59(b)

have

been

conducted

since

May 1977, the date of the last

gA program inspection.

7.

Audits

a.

Reference

Applicable procedures

listed in paragraph

3.

b.

ualit

Assurance

De artment Audits

The inspectors

selected

the sample of reports listed below

from those audits

performed since the last

gA inspection

conducted

during May 1977.

The inspectors

reviewed the audits listed below to verify that

they were conducted

as follows: in accordance

with written

checklists/procedures;

by trained personnel

not having direct

responsibilities

in .the areas

audited; with findings documented

and reviewed

by responsible

management;

with followup actions

initiated/completed;

and, with audit frequencies

and general

audit conduct in accordance

with established

schedules

and

procedures.

77-16, Audit of Ginna

gC Inspection

and Surveillance

77-26, Audit of Ginna Station Handling, Shipping,

and

Storage

77-27, Audit of Engineering

Desizn Control

77-30, Special

Audit of Ginna Modification

77-42,

Ginna Station Modification Project Program

13

77-44, Audit of Ginna Station Modification Control

Activities

78-01, Audit of Catalytic Inc. Design

and Procurement

Services

78-02, Audit of Gilbert/Commonwealth Continuing Services

Activities.

78-03,

Ginna Station Modification Project Organization

78-05, Audit of Engineering

Design Control

78-08, Audit of Bell/Schneider Project Organization

78-13,

Ginna Station Modification Project Organization

78-14, Audit of Bell/Schneider,

A Joint Yenture

78-16, Engineering

Procurement Activities

78-17, Purchasing

Department

Procurement Activities

78-25,

Ginna Handling, Shipping,

and Storage

Control

78-29, Engineering

Design Control

78-30, Audit of Bell/Schneider Project

During the conduct of the above audits,

the licensee identi-

fied 73 items requiring followup action.

The inspector stated that audit reports not reviewed during

this inspection

may be examined during a subsequent

inspection(s).

No items of noncompliance

were tdentified.

8,

Unresolved

Items

Unresolved

items are matters

about which more information is required

in order to ascertain

whether they are acceptable

items,

items of

noncompliance,

or deviations.

Unresolved

items identified during

this inspection

are discussed

in paragraphs

5.c and d, 6.b.(2)

and

(3k, and 6.c.(2),

~

P

14

9.

~tit 9 tt

,

The inspectors

met with licensee

representatives

(denoted in para-

graph

1) at the conclusion of the inspection

on November

16,

1978.

The scope

and findings of the inspection

as stated

-in this report

were presented.