ML17263A740
| ML17263A740 | |
| Person / Time | |
|---|---|
| Site: | Ginna  |
| Issue date: | 07/15/1994 |
| From: | Finkel A, Eugene Kelly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML17263A738 | List: |
| References | |
| 50-244-94-17, NUDOCS 9407260135 | |
| Download: ML17263A740 (11) | |
See also: IR 05000244/1994017
Text
U.S. NUCLEAR REGULATORY COMMISSION
REGION I
DOCKET/REPORT NO:
50-244/94-17
LICENSEE:
Rochester Gas and Electric Corporation
Rochester, New York 14649
FACILlTY
DATES:
R.E. Ginna Nuclear Power Plant
June 27 through July 1, 1994
INSPECTOR:
Alan Finkel, Se
r Reactor Engineer
Systems Section
Division of Reactor Safety
APPROVED BY:
Eug ne K
y, Chief
Systems
tion
~
~
~
~
~
Division of Reactor Safety
SUh9dARY: The inspector reviewed the procurement program plan including audit reports,
training, procurement engineering, and warehouse storage and stock control.
One violation and two unresolved items were identified. Inventory control personnel in the
plant Level B storage areas were not protecting, cleaning, or reporting nonconforming
equipment conditions as required by the Quality Assurance Manual and related procedures
(94-17-01).
Procedures
do not define an appropriate storage level of safety-related items
which are withdrawn from B Level control but not yet installed (94-17-02).
Quality
Assurance Audit No. 93-33, performed in December 1993, did not evaluate the control or
protection of stored safety-related parts and materials.
Also, the audit inspection did not
evaluate the effectiveness of the documents in the inventory control program (94-17-03).
A procurement program has been implemented as described in Site Procedure A- 405,
"Evaluation of Commercial Grade Items for Safety-Related Applications." The procurement
engineering staff has been trained on program requirements, with additional traiimig in the
areas of parts/materials procurement, root-cause analysis, and parts dedication.
An approved
vendor supplier list is issued and maintained current.
Warehouse personnel have received
basic training courses for their task assignments, 'which has generally improved the storage
and cleanliness of items in the warehouse areas.
A quality assurance
audit of the site
procurement program did not identify the weaknesses
regarding warehouse storage.
Audit
findings are tracked in a system that is monitored by management.
The inspector's review of
procurement open audit findings indicated that they were resolved in a timely manner.
9407260135
9407i5
ADOCK 05000244
8
DETAILS
1 0
INSPECTION SCOPE (38701)
The inspector evaluated the performance of the procurement program for the Ginna site,
using the documentation listed in Attachment 2 of this report. In addition, the inspector
reviewed the site procurement program for compliance with the quality assurance program;
ANSI N45.2.2-1972 and 1978 additions of, "Quality Assurance Requirements for Packaging,
Shipping, Receiving, Storage and Handling of Items for Water-Cooled Nuclear Power
Plants;" ANSI N45.2.3-1976, "Housekeeping Requirements for Water-Cooled Nuclear Power
Plants;" ANSI N45.2.13-1978, "Quality Assurance Requirements for Control of Procurement
of Items and Services for Nuclear Power Plants;" and 10 CFR 21, "Reporting of Defects and
Noncompliance."
2.0
PROC
PROGRAM
The licensee's
site procurement program is described in Procedure
A-401, "Control of
Procurement Documents Prepared for Ginna Station." This procedure provides the licensee's
instruction for preparation, review, and approval of procurement and upgrade documents for
safety-related (SR), safety-related environmentally qualified (SREQ), and safe significant (SS)
materials, parts, components,
and services processed
at the Ginna site.
This procedure is in
accordance with the Rochester Gas and Electric Station Quality Assurance Manual,
encompassing
the following aspects:
~
Procurement Engineering
~
Warehouse Storage and Stock Control
~
Training
~
Supplier Audit Program
~
Quality Assurance Audit
~
Nuclear Records Retention
3.0
PROC
ENGINEERING
The procurement engineering (PE) organization is responsible for ensuring that replacement
parts and materials are evaluated so that the use of these replacement items does not degrade
the operation or function of the original design safety systems or equipment.
The PE
requirements for using commercial grade items are described as, "when a replacement part
or material can no longer be purchased from a supplier qualified to the requirements of
10 CFR 50, Appendix B." The licensee's site program for parts and material dedication is
described in Procedure A-405, "Evaluation of Commercial Grade Items for Safety-Related
Applications.
To determine the acceptability of a commercial grade item, the PE completes
'The parenthetical
notation foHowing the paragraph
title denotes
the NRC inspection
procedure that was used by the inspector in conducting this inspection.
The procedure title is
"Procurement Program."
2
an engineering evaluation form that considers such areas as traceability, shelf life application,
safety function, equipment qualification (EQ), seismic requirements,
and materials.
To
determine ifthe procurement engineers were performing evaluations on the items approved
for dedication, th'e inspector selected the following approved commercial grade dedication
packages for review:
~
.
Technical Evaluation No.94-529, "Valcor Solenoid Valve 0-Ring Replacement"
~
Technical Evaluation No.90-046, "E-7000 Agastate Timer Relay Series"
~
Technical Evaluation No.94-528, "Crane Model.47-1/2 N Gate Valve"
The inspector verified that the above commercial grade dedication packages
had supporting
documentation and was complete and adequate to justify the use of the specific item
evaluated.
The inspector also verified that'the engineering evaluations considered
system
requirements
as part of their evaluation program.
The inspector only reviewed the
procurement dedication process associated with the above three selected components,
and did
not evaluate the licensee's entire dedication program.
The licensee requires their suppliers to comply to ANSI N45.2.2-1978, "Packaging,
Shipping, Receiving, Storage,
and Handling of Items For Nuclear Power Plants," however,
the site program endorses
the addition of ANSI N45.2.2-1972.
Section 6, "Storage" of both
the 1972 and the 1978 issue of ANSI N45.2.2, appears to require the same level of
protection, therefore, there does not appear'to be any conflicts in this area of the documents.
4.0
WARIHXOUSESTORAGE AND STOCK CONTROL
During a tour of the warehouse and receiving areas, the inspector noted that:
(1) the area
was clean; (2) parts and materials were protected; (3) shelf life requirements were identified
on the purchase orders; and (4) cabinets for storing hazardous
materials were located
throughout the areas.
However, the inspector identified several stored parts missing port and
connector plugs.
Also, the inspector identified instruments that were returned to B Level
storage without cleaning dust that had accumulated around the electrical terminations.
An
inspection of various B Level storage areas by the inspector indicated that missing connector
and port protection was noted throughout the storage facility. The inspector also identified
seven Limitorque SMB-000 geared limitswitches, in Level B storage that were leaking
oil/grease while in their protective packaging material.
No nonconformance report (NCR)
was written on the leaking switches, as required by licensee's Procedure A-1502,
"Nonconformance Reports," Section 3.1.1.
Discussions with the inventory control
personnel indicated that they were aware of the leaking Limitorque switches, however, an
NCR was written on the condition.
Verbal communication between the inventory control
supervisor and the procurement engineer on the condition of the Limitorque switches were
held.
During a licensee's surveillance inspection of the Level B storeroom (Report No. 90-
049, August 21, 1990) the surveillance inspector identified that three Limitorque spare limit
switches were leahng grease.
The surveillance report stated that whenever the ambient
temperature rises above 90 degrees F, these items leaked.
However, no NCR was written,
and no root cause analysis had been performed to identify the cause of the leaking grease.
Failure to provide adequate protection for safety-related equipment in B Level storage and
failure to issue nonconformance Reports (NCRs) on identified deficient materials in B Level
storage is considered a violation (50-244/94-17-01).
5.0
lVlhJÃIXNANCECONTROL OF SAFETY-RELATEDPARTS
Maintenance personnel withdraw materials and equipment for storeroom areas which are
controlled by the inventory control personnel.
The control and handling of safety-related
items are maintained and controlled by maintenance personnel,
as described in Procedure A-
801, "Control of Accepted Material, Parts, and Components," however, this procedure does
not provide accountability and storage direction for. safety-related items that are delayed in
installing them into their assigned location.
The licensee stated that the procedure willbe
corrected to concur with the requirements of the Ginna Quality Assurance Manual, Section
13, "Handling, Storage,
and Shipping."
This is considered an unresolved item and the
program and procedure changes willbe reviewed by the NRC (50-244/94-17-02).
6.0
TRAINING
Warehouse personnel have had training for handling chemical-based
materials, and they also
understood the storage requirements for these materials.
The inspector reviewed the training
program, history and records for the procurement engineering, and inventory control
personnel.
The procurement engineering staff has completed a basic procurement training
program and is receiving special training in the areas of parts and material dedication.
The
inventory control personnel have completed their basic training program.
An updated
training program has been approved, but has not been scheduled
as yet.
The present training
the inventory control personnel have received should not prevent them from complying with
their present site documentation requirements.
7.'0
QUALITYASSURANCE AUDIT
A quality assurance
audit of the Ginna Material, Procurement,
and Budget Program, Audit
No. 93-33:HMG, was issued on December 20, 1993; The audit of the procurement program
concentrated primarily on the portion of the cycle that begins with receiving items through
issuing the items for use and/or installation.
The audit, performed between
October 18, 1993, and November 8, 1993, did not identify part storage problems, not
preparing NCRs on nonconforming items in storage, nor identify that safety-related items not
installed are not protected in B Level areas until installed in their assigned location.
The
inspector s evaluation of Audit 93-33:HMG indicated that the audit team did not perform a
performance-based
evaluation of the procurement'rogram
but rather a compliance-type of
evaluation of the program.
The audit report did identif'y that a safety-related valve actuator
was stored in the Butler Building, which did not meet Level B criteria.
However, no
investigation was initiated as to why the valve actuator was placed in the Butler Building,
which was not an approved Level B storage area at that time. The inspector's evaluation of
F
the audit inspection attribute that sheets indicated that the audit was weak in the area of parts
and materials storage requirements verification. The licensee stated that they were
developing an audit checklist with more performance-based-
inspection criteria. This area is
considered
an unresolved item pending NRC review of the licensee's revised
performance-based
inspection program. (50-244/94-17')
8.0
SUPPLIER AUDITPROGRAM
The Ginna site supplier audit program is described in Procedure QA-702, "Supplier
Surveillance," QA-705, "Procurement Evaluation Requests,"
and A-401, "Control of
Procurement Documents Prepared for Ginna Station."
These procedures describe the
requirements for planning and conducting supplier audits, establish the approved supplier list,
and initiate and follow-up issued corrective action findings identified during a supplier audit.
The quality assurance
procurement organization is responsible for establishing, implementing,
and maintaining the site supplier audit program.
This audit program consists of a
combination of licensee's
scheduled supplier audits, and audits that are received as part of
the licensee s participation in the industry-wide utilityprogram called NUPIC. The inspector
verified that the approved supplier listing, which is maintained as a computer-based
program,
is updated on a regularly scheduled time frame, and that updated information is added on a
daily basis, ifrequired.
The licensee performs both an annual and a triennial inspection of
their suppliers based on site procedure requirements.
The QA audit personnel are certified in
accordance with the requirements of Regulatory Guide 1.146,
Qualification of Quality
Assurance Program Audit Personnel for Nuclear Power Plants," which endorses ANSI
N45.2.23Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.23" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
The inspector reviewed the following vendor audits:
93-18:ARP, GTS Duratekis; 94-089:JB,
HT Engineering Valves; and, 94-01:GRA, Tioga Pipe.
Each audit had a defined scope audit
checklist and inspection finding associated with each checklist., The checklists were tailored
to inspect areas that were applicable for the product produced by the vendor.
A review of
each audit checklist indicated that the audit inspections complied with the scope of the audit.
The inspector concurred with the audit team certifications assigned to these vendors based on
the results of the audit documents reviewed.
The inspector verified that the three safety-
related vendor audits were listed on the licensee's current approved vendor supplier listing
and that this listing was updated by QA personnel during the m*onth of June 1994.
9.0
NUCLEARRECORDS RETF22ION
Nuclear records are maintained in accordance with the requirements described in Procedure
A-1701, Ginna Records.
The inspector reviewed the procurement records of the packages
described in Paragraph
1.3.
The data within the packages were signed, legible, and
complied with the program requirement for record documentation retention.
'
5
10.0
E$'FZX:TlVENESS OF LICENSEE CONTROLS
The licensee has supported training in the areas of corrective action systems and root cause
analysis.
However, not issuing nonconformance reports on items in B Level storage
indicates that there may be a lack of understanding of their basic nonconforming program
described in Procedure A-1502, "Nonconformance Reports."
The lack of adequate air
conditioning design in one B Level storeroom was identified in Surveillance Report 90-
049:LED, August 21, 1990, as a possible reason for the leaking of grease in three
Limitorque spare limitswitches.
However, as of July 1, 1994, the Level B storeroom
temperature control is still a problem.
The storage procedure requirement of 120 degrees F
for a maximum storage temperature is within the requirement of ANSI N45.2.2-1972,
Paragraph 6.1.2 (2), however, the Level B storage temperature is required to be controlled
for the requirements of the stored equipment.
Temperature/humidity control of Level B
storage areas is subject to be evaluated by the licensee in relationship to stored equipment
and material requirements.
The generic temperature range of their procedure of 40 to 120
degrees F may not be adequate for all safety-related Level B stored items.
11.0
CONCLUSION
The inspector determined that the engineering procurement program is defined and
implemented as described in Procedure A-401, "Control of Procurement Documents Prepared
for Ginna Station."
The vendor supplier pxogram approved list is maintained in an updated
configuration with vendor audits performed on a scheduled
bases.
A quality audit of the site
procurement function was weak in the areas of storage and protection of
safety-related materials and equipment in the B Level storage areas.
Also, the audit
inspection attribute list was weak in performance-based
type of inspection criteria.
The
licensee 's present procedures do not define their B Level method for handling issued
safety-related material and equipment that is not installed as planned by the maintenance
organization.
The inventory control personnel have been trained in their inspection, storage,
and handling procedures,
however, the use of NCRs to identify storage nonconformances
is a
weakness.
12.0
MANAGE1VHWTMEETINGS
Licensee representative were informed of the scope and purpose of the inspection at an
entrance meeting conducted on June 28, 1994.
Findings were periodically discussed with
licensee personnel during the course of this inspection.
The inspector met with the
individuals noted below at the conclusion of the inspection on July 1, 1994, and summarized
the preliminary findings.
~ )Q
M. Burchell, Mechanical Procurement Engineer
C. Edgar, Manager, Electrical and I and C
R. Graham, Jr., Supervisor, Inventory Control
A. Harhay, Manager RP and Chemistry
R. Jaquin, Lead Nuclear Safety and Licensing Engineer
T. Kirpatrick, Quality Procurement Coordinator
R. Marchionda, Superintendent,
Ginna Production
M. Shaw, Manager Materials and Procurement
T. Moslak, NRC Senior Resident Inspector
The licensee acknowledged the findings and conclusions, with no exceptions taken.
Further,
the bases for the preliminary conclusions did not involve proprietary information, nor was
any such information discussed or expected to be included as part of the written inspection
report.