ML18116A164

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IE Insp Repts 50-280/79-08 & 50-281/79-09 on 790213-16. Noncompliance Noted:Failure to Maintain Records,Failure to Provide Identification & Control of Matl,Parts & Components & Failure to Provide Care of Items in Storage
ML18116A164
Person / Time
Site: Surry  Dominion icon.png
Issue date: 04/26/1979
From: Ashenden M, Brownlee V, Kellogg P
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML18116A153 List:
References
50-280-79-08, 50-280-79-8, 50-281-79-09, 50-281-79-9, NUDOCS 7907190078
Download: ML18116A164 (11)


See also: IR 05000280/1979008

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Report Nos.

UNITED STATES

NUCLEAR REGULATORY COMMISSION

REGION II

101 MARIETTA STREET, N.W.

ATLANTA, GEORGIA 30303

50-280/79-08 and 50-281/79-09

Licensee: Virginia Electric and Power Company

Post Office Box 26666

Richmond, Virginia 23261

Facility Name:

Surry, Units 1 and 2

Docket Nos.

50-280 and 50-281

License Nos.

DPR-32 and DPR-37

Inspection at Surry Site near Richmond, Virginia

Inspectors: ~~

V. L. Brownlee

~UMMARY

Inspection on February 13-16, 1979

Areas Inspected

Date Signed

,-Date Signed

<-(/74/-,c;

Date Signed

This routine, unannounced inspection involved 54 inspector-hours onsite in

the areas of procurement, steam generator replacement QA program, independent

inspection effort.

Results

Of the three areas inspected, no apparent items of noncompliance or deviations

were identified in one area; three apparent items of noncompliance were found

in two areas (deficiency - failure to maintain records-Detail 6.b; infraction-

failure to provide identification and control of materials, parts and

components-Detail 5; deficiency-failure to provide care of items in storage-

Detail 6.c and 6.h).

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DETAILS

1.

Persons Contacted

Licensee Employees

  • R.
  • J.
  • W.
  • E.
  • J.
  • E.
  • T.
  • T.
  • Y.
  • J.
  • P.
  • A.
  • J.
  • F.
  • C.
  • R.
  • R.
  • W.
  • B.
  • M.
  • J.

L. Baldwin, Supervisor, Administrative Services

Bolin, Engineering Technician

W. Cameron, System Superintendent, Technical Services

P. DeWandel, Staff Assistant

Goodson, SGRP QC Supervisor

Reiland, Engineering Technician

J. Hronec, Safety/Security Coordinator

J. Kenny, Outage Coordinator

P. Mangum, Resident Engineer, Project Control

W. Martin, Jr., Supervisor, QA

P. Nottingham, Assistant H.P. Supervisor

L. Parrish, SGRP Manager

Pickworth, Senior Engineering Technician, Q/C

L. Rentz, Resident Q/C Engineer

W. Rhodes, Resident Engineer, Construction

F. Saunders, Superintendent, Maintenance

M. Smith, H.P. Supervisor

L. Stewart, Station Manager

R. Sylvia, Director, Nuclear Operations

Terrier, System Fire Protection Engineer

L. Wilson, Superintendent, OPS

Other licensee employees contacted during this inspection included

two construction craftsmen, two technicians, two engineers and six

office personnel.

Other Organizations

  • M. Randolph, Stone and Webster

NRC Resident Inspector

  • D. J. Burke
  • Attended exit interview .

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2.

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Exit Interview

The inspection scope and findings of this inspection were summarized on

February 16, 1979, with those persons indicated in Paragraph 1 above.

The licensee acknowledged the findings of this inspection.

3.

Licensee Action on Previous Inspection Findings

Not inspected.

4.

Unresolved Items

5.

Unresolved items are matters about which more information is required to

determine whether they are acceptable or may involve noncompliance or

deviations.

New unresolved items identified during this inspection are

discussed in Paragraph 6.d.

Independent Inspection Effort

The inspectors performed a walk-through inspection of the operating

plant and steam generator repair project warehousing and laydown yards.

Additionally, the inspectors inspected the storage conditions of the two

lower steam generator sections that have arrived on-site and the automated

welder qualification area.

During the walk-through inspection of the west end of the operating

plant warehouse, the inspectors identified large amounts of materials,

components and parts that were not part of the warehouse inventory

stock. These items consisted in part of spare control rod drive mechanisms,

current transformers, large and small motors, stainless steel pipe

fittings and elbows, etc.

The licensee informed the inspectors that

these items were not a part of warehouse stock and they belonged to the

maintenance department.

The inspectors discussed the practice of storing uncontrolled material,

parts and components in a fashion where they could be inadvertently

introduced into a safety-relat~d system without proper identification,

qualification and traceability as required by 10 CFR 50, Appendix B,

Criterion VIII, which requires measures be established for the identifi-

cation and control of materials, parts and components.

The Accepted

Quality Assurance Program, Section 17.2.8 requires replacement parts,

materials and components be identified to allow control.

This failure to provide identification and control of materials, parts

and components is an item of noncompliance (280/79-08-01 and 281/79-09-01).

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6.

Procurement

References:

a)

VEPCO Nuclear Power Station Quality Assurance Manual

(NPSQAM), Section 4, "Procurement Document Control",

Revision 2, January 24, 1978

a.

b)

NPSQAM, Section 7, "Control of Purchased Material,

Equipment and Services", Revision 2, February 21,

1978

c)

NPSQAM, Section 8, "Identification and Control of

Materials, Parts and Components", Revision 2, January 24,

1978

d)

NPSQAM, Section 13, "Handling, Storage and Shipping",

~evision 2, May 11, 1978

e)

NPSQAM, Section 16, "Corrective Action", Revision 8,

March 30, 1978

Inspection Items

The inspectors reviewed the procurement area to verify that the

procurement documents used in the purchase of components and material

from selected safety-related systems included proper approval,

quality control inspection requirements and quality record require-

ments.

Components were selected from the reactor coolant, safety

injection and electrical distribution systems.

The specific items

selected were:

(1)

Safety Injection Pump Shaft Bushings, Purchase Order No. 54605

(6/1/78)

(2) Retainer Rings for Shaft Sleeve and Bushing, Purchase Order

No. 53920 (5/23/78)

(3)

Stainless Steel Pipe ..Plugs, Purchase Order No. 21980, Stock

No. 3865544

(4)

(5)

(6)

Safety Injection System Motor Operated Valve, Purchase Order

No. 52096 (4/27/78) A)

Reactor Coolant\\Pum~s (C) Seal Assembly, Purchase Order No.

49773 (10/3/78) 1/'

Reactor Coolant)*System Valve Diaphragm, Purchase Order No.

93127 (1/12/77) ;

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(7) Reactor Coolant Pump (B) Seal Assembly, Purchase Order No.

27982 (4/2/74)

(8) Safety Injection Pump Seal, Purchase Order 59607 (7/19/78)

(9) Maintenance Report Nos. 1804, 91540, 2801300122 and 1801300123

For the items selected with the exception of item.a.(9) above, the

inspectors verified that documentary evidence was available on-site

to support their conformance to procurement requirements.

In

reviewing activities to assure that these items were inspected upon

delivery and that they were handled in accordance with established

controls in addition to being supplied by an approved vendor, the

inspectors reviewed the warehouse and related activities.

The inspectors identified two items of noncompliance with respect

to traceability of materials, storage and care of materials and

equipment in storage.

These are documented in paragraphs 6.b and

6.c and 6.h combined below. Additionally, one unresolved item and

three items were identified with respect to tape materials, local

purchases, review and placing under the QA program certain expendable/

consumables, and review of spare parts, materials and components

inventory to determine which items require level A storage. These

are documented in paragraphs 6.d, 6.e, 6 .. f and 6.g below.

Material Traceability, Record Failure

The inspectors selected the below listed maintenance reports from

three safety-related systems to verify technical and quality assurance

requirements of purchased documents and the traceability of the

materials to approved vendors. The method of selection was random

from a computer listing of completed maintenance during the year

1978.

MR Number

Component

Parts Used

2807051512

Sl Pump

Bushings

2807301525

Sl Pump

Seal

1806120743

MOV1860A

Pipe Plug

1805160900

MOV1869B

Valve

1804191250

RC Pump

Seal

1804191251

RC Pump

Seals

1805191355

RC Pump

Diaphragm

  • 1804191540

Diesel Gen

Valve

  • 2801300122

Diesel Gen

Valve

  • 2801300123

Diesel Gen

Valve

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The inspectors were informed that the maintenance record system

computer printout would provide a listing of the parts and materials

used to complete maintenance reports and provide the traceability

back to the purchase documents. It was noted that the computer did

not provide any data requested. The traceability of the parts used

had to be accomplished by manual means and took over two days to

provide the inspectors with the required documentation of parts

used on seven of the ten maintenance reports listed above.

The

records of parts used in completing maintenance reports indicated

by asterisks above could not be provided the inspectors.

The

inspectors verified by direct observation that three relief valves

had been installed of a type different than originally installed.

It was further verified that the valves had the same settings as

the original valves.

The Station Manager was contacted and was

notified that no records could be found on the valves. Therefore a

safety evaluation would be required to consider the valves in

question.

The safety evaluation was conducted on February 20, 1979 and the

valves were found to be acceptable and documentation of this review

is available at the Surry Power Station.

This matter of failure to maintain records of activities affecting

quality is an item of noncompliance (280/79-08-02) and 381/79-09-02).

c.

Failure to Establish a Maintenance Program for Items

in Storage

d.

The inspectors noted that there existed no program for the care of

items in storage in that motors were not tested for insulation

resistance and also rotating equipment in storage was not being

rotated as required by ANSI N-45.2-2, Section 6.4.2. This example

of a failure to establish controlling procedures is combined with a simil

failure documented in Paragraph 6.h and collectively constitutes an

item of noncompliance (280/79-08-03 and 281/79-09-03).

Gummed Labels and Tape

The inspectors observed that stores personnel were affixing gummed

labels to stainless steel fittings with a transparent tape.

The

inspectors asked if the labels and the tape met the requirements of

ANSI N.45.2.2, Appendix A3.S.2.

The licensee stated that a study

would be conducted to determine if the tape and labels contain less

than 0.10 percent by wejght of halogen and sulfur. Until such time

as a study is conducted to determine the quality of the gummed

labels and tape this item is unresolved (280/79-08-04 and

281/79-09-04).

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e.

Expendables/Consumables

During the IE inspection of procurement activities at the North

Anna site, see IE Report 338/79-08, it was identified that expen-

dables/consumables were not under the licensee's current QA program.

The licensee committed to and is actively engaged in activities to

review expendable/consumable items for both the North Anna and

Surry sites to determine which items would effect safety-related

functions of safety-related systems, structures and components.

The items requiring special controls, as determined by the review,

will be placed under the QA program controls to the degree required

to ensure that safety is not degraded.

Until the review has been completed and controls have been implemented,

this item is designated (280/79-08-05 and 281/79-09-05).

£.

Level A Storage

g.

During . the inspection, the inspectors noted that only a small

number of electronic cards had been designated as requiring level A

storage .

Both North Anna and Surry Power Station are committed to the same

QA program requirements relative to storage of materials, parts and

components.

The inspectors noted that there is considerable incon-

sistency between the storage program implemented at North Anna and

the program at Surry regarding the materials, components and equipment

requiring level A storage.

It was further determined that the

licensee had not completed a meaningful review of stocked items to

determine level A storage requirements. The licensee committed to

perform a review of stocked items to determine which items will

require level A storage conditions. A target date of July 1, 1979

to prepare the level A storage list and January 1, 1980 for full

program implementation.

Until the review has been completed and the storage program

implemented, this item is designated (280/79-08-06 and 281/79-09-06).

Local Purchase Order Book and Change Orders

During the IE inspection of procurement activities at the North

Anna site, see IE Report 338/79-08, it was identified that there

existed no administrative controls to assure that Category I items

could not be locally purchased without proper technical and QA

review.

The licensee c9mmitted to and is actively engaged in

activities to develop both short-term and long-term controlling

measures for both North Anna and Surry to prevent local procurement

of Category I items without proper technical and QA review.

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Until these measures have been established and implemented, this

item is designated (280/79-08-07 and 281/79-09-07).

Pipe Capping

During the inspection of warehousing and storage, the inspectors

identified that capping of pipe ends at the operating plant ware-

house, steam generator repair project (SGRP) warehouse and laydown

yards was not being accomplished as required by the controlling

standard (ANSI N45.2.2-1972) and NPSQAM Section 13, Paragraph 5.5.2(3).

Additionally, the inspectors determined that inspections in this

area had not been performed as required by NPSQAM Section 13,

Paragraph 5.2.5. This matter was discussed with warehouse, station

and SGRP QC and management personnel.

VEPCO concurred with the

findings and committed to look into the matter at the exit interview.

This failure to cap pipes and perform the required inspections is

identified as an item of noncompliance (280/79-08-03 and 281/79-09-03).

This item is combined with a noncompliance item documented in

Paragraph 6.c.

Steam Generator Replacement Project (SGRP)

References:

a)

NPSQAM, Section lS, "Organization", Revision No. O,

June 16, 1978

b)

NPSQAM, Section 3S, "Design Control", ~evision O,

June 16, 1978

c)

d)

NPSQAM, Section 6S, "Document Control", Revision O,

June 16, 1978

NPSQAM, Section 15S, "Nonconforming Materials, Parts

and Components", Revision No. 0, June 16, 1978

e)

NPSQAM, Section 16S, "Corrective Action", Revision

No. 0, June ... 16, 1978

f)

NPSQAM, Section 17S, "Quality Assurance Records",

Revision No. O, June 16, 1978

g)

NPSQAM,

Section 18S,

"Audi ts", Revision No. 0,

June 16, 1978

b)

Project Operating Procedure 2.8.2, "Drawing Management",

Revision No. 2, December 18, 1978


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Project Operating Procedure 2. 8. 3, "Records Management",

Revision No. 1, July 25, 1978

j)

Project Operating Procedure 2.8.3.1, Revision No. 3,

January 1, 1979

The inspector identified two items with respect to record storage and

design control. These are documented in paragraphs 7. b and 7. c. During

this inspection, items 280/79-06-01 and 281/79-06-01 were closed. This

is identified in paragraph 7.b.

a.

General

b.

The purpose of this inspection was to perform a follow-up inspection

of IE Reports 50-280/79-06 and 50-281/79-06 regarding the SGRP QA

program manual review and the present degree of implementation of

that program consistent with construction in progress. The inspectors

performed a walk-through inspection of facilities provided for the

support of SGRP activities, held numerous discussions with responsible

VEPCO/S&W/QA/QC/Daniel Construction Company (DCC) and craft personnel,

and reviewed controlling procedures .

Review of QA Program

The inspectors performed follow-up inspection efforts with regard

to item (280/79-06-01 and 281/79-06-01).

VEPCO has determined that

the VEPCO nonconformance report will be the mechanism to provide

nonconformance report control, corrective action control, and

written notification requirements of significant conditions by all

contractors and VEPCO personnel associated with the SGRP.

The

VEPCO Resident QC Supervisor has developed an audit schedule and

the implementation of that audit schedule will commence on February 20,

1979.

VEPCO has reviewed and accepted those applicable portions of

the DCC QC manual which are required to control that work which is

presently in progress.

The VEPCO Resident QC Group has presently

assigned two engineers and four technicians with additional personnel

to be added as needed. The.inspectors reviewed the training records

of five of the Resident QC Group personnel. The inspectors reviewed

the area of record retention and maintenance.

The present record

storage facilities as shown to the inspectors do not meet ANSI 45.2.9

requirements.

Discussions with Records management personnel and

SGRP QC personnel confirm that duplicate record storage facilities

will be utilized to meet ANSI N45.2.9 requirements.

Controlling

procedures are presently in process of completion.

VEPCO anticipates that final procedures will be completed and

issued by February 28, 1979 and full implementation will be

accomplished by March 15, 1979.

Until the final procedures are

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completed and issued and full implementation of those procedures

has been completed, this item is designated (280/79-08-08 and

281/79-09-08).

Items 280/79-06-0l and 281/79-06-01 are closed.

c.

QA Program Implementation

(1)

QA Manual-Document Control

The inspectors selected VEPCO NPS QA manuals located in the

VEPCO Resident QC office, Record Management office, and

Engineers offices and verified that the procedures were current.

No items of noncompliance or deviations were identified.

(2)

Organizational/Functional Alignment

The inspectors verified that the SGRP organizational/functional

alignment was manned as described in the VEPCO NPSQA Manual.

No items of noncompliance or deviations were identified.

(3)

Audits

(4)

The inspectors verified that an audit schedule of SGRP

activities has been established and qualified personnel are

available to perform the scheduled audits.

No items of

noncompliance or deviations were identified.

Design Control

The inspectors held discussions with responsible engineers, QC

personnel, records management personnel and construction

personnel to determine that project-originated design control

activities were being accomplished in accordance with established

controlling procedures. The inspectors selected field changes

to ETA's 20010 and 40027 to verify that the design change was

within the authority ""Of the project, the design change was

checked, the proper approvals were received, and distribution

was in accordance with the controlling procedures. During the

inspection, it was noted that the present controlling project

operating procedure~ did not describe how the present system

is functioning wiS,lv.tegard to the sequence of required signatures,

logging and dist.rilfution of field changes.

VEPCO had found

that the field ~l),ange system as initially implemented was

cumbersome and h¥d to control; therefore, changes were being

implemented to mdke the system workable. The inspector verified

that the system Has functioning as verbally described and that

the controlling'~rocedures were being revised.

The licensee

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committed to having the procedure change accepted and issued

by February 23, 1979 and fully implemented by March 2, 1979.

This is identified as item (280/79-08-09 and 281/79-09-09).

No items of noncompliance or deviations were identified.


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