ML20049J575
| ML20049J575 | |
| Person / Time | |
|---|---|
| Site: | Diablo Canyon  |
| Issue date: | 12/05/1977 |
| From: | Crews J, Spencer G NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML20049J565 | List: |
| References | |
| FOIA-81-435 NUDOCS 8203180398 | |
| Download: ML20049J575 (30) | |
Text
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MN (Axrs on9n-)
DEC 5 1977 M*j 4
Docket tio. 50-323 4
Diablo Canyon Unit No. 2
.4Ett3RAtiDut! FOR:
File FR0!!:
G. S. Spencer, Chief, Reactor Construction and Engineering Support Branch J. L. Crews, Chief, Reactor Operations and nuclear Support Branch h
SUBJECT:
IE:RV FOLLOWUP 0F GA0 PROGRAF 4 IMPLEMEtiTATI0ri C0!iCER!iS A GA0 consultant vis:ted the Diablo Canyon facilities during the period of June 13-16, 1977 to conduct an audit of the RV implementation of the Inspection and Enforcement program.
Pursuant to this audit, the GA0 conducted an exit interview, at the RV offices, on October 6,1977 during which the GA0 submitted the consultant's handwritten notes identifying the GAO consultant's observations regarding program imple-mentation.
Region V inspectors were assigned to follow up each GA0 observation which related to the cognizant activities of the Reactor Operations and rioclear Support and Reactor Construction and Engineering Support Branches.
The followup inspections were conducted at the Diablo Canyun facilities during the period of October 25-28 and liovember 8-9, 21-23,1977, and required the expenditure of 148.5 inspector-hours in the categories of travel (30.5), in-office preparation and report writing (74) and on-site inspection (43).
The RV followup report details are attached.
r Region V considers that certain conments regarding the GA0 activities are in order and are listed below:
The GA0 allegations and observations lacked in specifics and a.
contained numerous instances of baseless GAO consultant opinions.
The GA0 failed to examine licensee procedures, to detemine specific O
b.
requirements, and failed to conduct their inspection to those requirements. The GA0 consultant inspected to his understand'ng of the Appendix B criteria and failed to realize the acceptability of differing implemantation schemes.
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MEF,0RAfiDUM FOR:
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DEC.519n The GA0 failed to determine and understand the philosophy and im-c.
piementation techniques of the flRC inspection program and did not D
understand the words, impact and s l
Report-ito. 323/77-01.----
'-- - pecificity of IE Inspection 4
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The GAD observation continua 11y. implied that the tiRC was negligent 5
or that conditions at the. licensee facility were in noncompliance without documenting proof. of the impli. cations by specifics and facts:
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The Gh0,'obviously,-iiid not adequately question licensee personnel e.
I because many"of *.the GA0 findings would..have been cleared by licensee O
personnel"and licensee documentation. ^
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G. -S. Spencer, Chief
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Engineering Support Branch
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. J. L. Crews, Chief L L Crews 8
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Reactor Operation and fluclear Support Branch L
Encl osures :._:.
1.
Details I - Reactor Consturction 2.
Details 'II - Rehctor Operations i
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DETAILS I
- c. -e (Reactor Construction and Engineering Support Branch)
If' Prepared By:
D. Kirsch
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Individuals contacted _
a.m x713 Pacific Gas and Electric Company (PG&E)'
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- M. R. Tressler, Project Superintendent E7
- R. D. Etzler, Resident Mechanical Engi6eer
- C. M. Seward, QA Engineer r yqW.
- J. Arnold, Coordinating QC Engineer D.~4; C. Braff, Pipe Support Group Leader
'P' D. Hill, Inspector M
C. Wayne, Field Engineer uMG B. tiolan, Instrument Issue Room Attendant
.T T. tieimi, Field Engineer
"?O R. K. Rhodes, Instrument Supervisor Sk M
M. W. Kelloqq Company (Kellogg)
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- .*Q J. P. Runyon, QA Manager G2 C. Heinzenberger, Design Drafting Supervisor J"-
- 5. Sweet, Field Engineer M. Wilhelm, Receiving QA Engineer 3
D. Geske, level II NDE Technician k$.
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- Denotes those present at exit interview.
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2.
Background _
h A General Accounting Office (GAO) consultant conducted an audit of M
the fiRC inspection program at the Diablo Canyon Unit 2 facility Pursuant to this audit
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during the time period of June 13-16,1c77.
the GA0 notified Region V management of the Region V inspection a"
program implementation audit observations on October 6, 1977 during f.
an exit interview conducted at the RV offices. A Region V inspector J,-g 25, 1977 was dispatched to the Diablo Canyon facilities on OctoberThe following report con M
to followup on the GA0 observations.
F quotations of the GA0 observations related to the Reactor Constructionj and Engineering Support Branch and the associated f1RC findings and comments.
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3.
GAO Item II 50-323/77-01 Dated 1-25-77 states on dM "Ref. IE Inspection Report tio.
two separate occasions that the inspector p::rformed a review of Quality Records and that with two exceptions not addressed in this
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'no other discrepancies were noted, the records appeared tc Jp report; be satisfactory and no anomalies werc noted.'"
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in 11RC Coment
- ,.7 The GA0 statement, above, implies that Inspection Report tio. 77-01 states that the records appeared satisfactory to the NRC, with two exceptions which were not addressed in the report.
The inspection report clearly identifies and summarizes the two anomolies noted (paragraph 4b of Report 77-01) as a result of the NRC record reviews.
a.
GA0 Observation II.a W5 "A review of the licensee's QC Document Control Center records 3
relating to Rec. Insp., Equipment Control History Records, 4
Storage handling, Inspection, Installation, etc., revealed a Jf lack of signatures for inspection events and a lack of followup h
on problems noted during various phases of equipment history."
g NRC Finding
?
IE Inspection Report No. 50-323/77-01 clearly identifies that the quality records reviewed consisted of the receipt inspection,
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storage, handling, identification and installation records for t
(1) certain instrumentation components and equipment listed in
! J the report and (2) cables and terminations, only, for Residual Heat Removal Pump No. 2-2, Reactor Charging Pump No. 2-2, Safety Injection Pump No. 2-1 and Containment Spray Pump No.
[ d 2-1.
The GA0 observations, identified above and below, indicate is that the GA0 consultant apparently did not understand the M
differentiation between cable and termination records, located l @
in the electrical contractor's (H. P. Foley Co.) office, and j t.y the pump mechanical component records, located in the QC td s
document control center.
In addition, the GA0 consultant failed to ascertain that additional equipment surveillance and is installation records were located in the mechanical contractor's (Wismer and Becker) office.
Also, the GA0 consultant sample l';:J included the Safety Injection Pump No. 2-2 and the Boron
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Injection Tank (BI"' which were not included in the NRC sample A
of Inspection Repc 77-01.
4 lj The inspector exam.aed the records of receipt inspection, l..g equipment control history, storage, handling, inspection and y
installation for Reactor Charging Pump No. 2-2, Residual Heat W.;
Removal (RHR) Pump No. 2-2, Safety Injection (SI) Pump No. 2-2 l
and the Boron Injection Tank (BIT).
The Equipment Control History form provides a history and summarizes the documentation W
contained on a particular equipment.
It was noted that the Equipment Control Histo y form (M4), prior to November 20, M
1974 required entry of final alignment, lubrication and record T$
l inspection signatures and that after the November 1974 evision
%i the requirement for these signatures was deleted.
The inspector b
observed that the alignment, lubrication and record review p$
signatures were not entered on the M4 forms for Reactor Nk$
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Changing Pump ffo. 2-2, SI Pump flo. 2-2 and the BIT, but that F
the M4 form for RHR Pump tio. 2-2 was a revised form and was p
satisfactorily completed.
Further inspection revealed that j
the activities of equipment retrieval identification, storage, 2
alignment and lubrication were completed satisfactorily and I
included within the equipment document package for each of the
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GA0 sampled equipments.
It is the fiRC position that the 1
absence of a signature on a summary document does not constitute i
a matter of substance when technical documentation is included
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to verify completion of an activity to acceptable specifications.
3 m
[3 The inspector examined the minor variation and deviation reports associated with each of the GAO sampled items of equipment and observed that equipment problems were adequately b
documented and resolved.
The inspector did not find substance
'd to the GA0 findings of lack of problem followup.
ft4 b.
GA0 Observation II.b 5
" Reactor Charging Pump tio. 2-2.
Licensee Report tio. 670 i
History Record indicates that item was received 2-3-71 and 5
stored until 4/10/72 when it was Rough-Set in the plant by 3
Wismer & Becker.
The " Initial Alignment Insp." was performed 8/2/72 and recorded j
on the Equipment Control History record.
This was the last w
recorded inspection on this record.
Final Alignment Insp.,
Q Lubrication Requirements Insp., Records Complete & Inspection d
- 9 and QC Record Audit complete by QCE are all functions identified to be performed and recorded on this form.
flone of these Q
events are recorded as having been completed since 8/2/72."
hh flRC Finding 4
W As stated previously, the Equipment Control History is essentially 4
a summary statement of records contained in a package and the d
use of the old and revised forms is discussed in paragraph 3a, 6
above.
An examination of inspection records contained in the j
Reactor Charging Pump tio. 2-2 data package disclosed that (1) gt initial alignment inspections were performed on 8-2-72 and on
'I 4-9-73 (following installation of a repaired gear case), the hot alignment check was performed on 2-26-76 and the final hot alignment inspection was performed on 5-27-77; and (2) turbine g
oil was added to the gear case on receipt (2-3-71) and that g
lubrication verifications were performed on 9-17-76 and 5 M 77.
Licensee representatives stated that the document package would not be complete until the mechanical contractor (Hismer 9
and Becker) submits the installation and inspection records at project completion.
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The inspec:or examined the Wismer and Becker installation traveller and equipment surveillance records for charging pump
[5 flo. 2-2.
The records were satisfactory and no deficiencies r
were noted.
The inspector could find no substance for the GA0
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finding that inspection events had not been recorded since 9
8-2-72.
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c.
GA0 Observation II.c
" Reactor Charging Pump fio. 2-2.
The Licensee's Equipment dd Surveillance Report for this same item " Sheet 1" dated 2-3-71
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instructs inspection personnel to rotate pump shaft 41/4 turns monthly during storage.
This was accomplished for five
@Y inspector reported that rubbing was detected during the 41/4 _
"g months by one inspector.
On the sixth month a different turn rotation, that the problem was reported to Westinghouse, 4
that dry mechanical seals were suspected as the problem, that by it should be tested again in one week and an Engineer was
@N assigned to investigate.
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That is where the records of this problem stop.
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record of re-inspection and no record of followup.
The next
'd month storage inspection report just states that the item is y
in good condition.
This inspection was performed by the original inspector of the first five months, not by the in-spector that recorded the finding in the sixth month of storage."
j
$m flRC Finding The Equipment Surveillance records indicate that on 7-9-71 M
rubbing was detected on Reactor Charging Pumps 2-1 and 2-2 and f'
the original licensee inspector stated that this is a normal conditions for pumps in storage with dry mechanical seals.
j Further investigation revealed that Westinghouse provided resolution, which was entered on the Reactor Charging Pump fio.
p 2-1 equipment surveillance record, on 7-28-71, which indicated
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that such rubbing of dry mechanical seals was normal.
The
,f rota, tion within one week was performed and recorded for
[e,p Charging Pump tio. 2-1.
4 Licensee representativesr stated that information regarding the
%j rubbing resolution and rotation within one week was inad-vertently left off of the Charging Pump tio. 2-2 equipment surveillance record.
The f4RC considers the licensee's reso-M lution and documentation of such a normal condition adequate.
M dl d.
GA0 Observation II.d j
" Reactor Charging Pump rio. 2-2 Equipment Control liistory d
record mentioned in the above items II,b and c revealed further complications which should have been evaluated by tiRC; i.e.,
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-D "The remarks section of this form indicated that on 8/2/72
[$y (the date that " Initial Alignment Insp." was performed) a An oil leak x
Deviation Report #102 was filed by the licensee.The gear case housing og was discovered in the gear case housing.
was removed and returned to Westinghouse for repair.
3 Field Discrepancy Report flo. PEG 10030 identifies this item as Iden. f CV-58017-1 Catalog f5645D35G01 and recommends that the y
This info was hole be drilled, tapped and plugged 8/1/72.
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later crossed out by the Investigation Field Engineer and the 2
new disposition assigned was " Receiving tiew Unit" and dated
..~Z Several letters of communications between the 12/15/72.
licensee Project Superintendent and Westinghouse followed from April 3, 73 and April 24, 1974 which revealed the following:
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'M A new unit was not received.
Unit ID CY-58017-1. Cat. flo.
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5645035G01 was certified and returned around 3/28/73.
second gear case housing on Charging Pump 1-1 was also found
,y 13, 1973.
Cause and corrective action g
to leak, around April to prevent recurrence was requested by the licensee around M.
and after repeated attempts to acquire positive j
April 13, 1973 action from Westinghouse, the subject appears to have been "g
dropped around April 7,1974, a year af ter the original request
, L 's and was two years'after the discovery of the problem."
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f4RC Finding QfE Deviation Report tio.102 was initiated by the licensee on 8-2-72 and identified a gear case oil leak on Charging Pump
- g for repair and was returned to the site and receipt inspected
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The gear case was reaned to the pump manufacturer lio. 2-2.
Receipt inspection documentation reveals that the on 2-26-73.
The fact that a
- pgi, repaired unit was received and accepted.
t field engineer wrote that a new unit would be received on 12-h 15-72 is inconsequential.
The gear box for Reactor Charging Pump tio.1-1 was likewise found to have an oil leak as a g
result of an inspection of other pump gear boxes, was returned-to the pump manufacturer for repair and was inspected upon return to the site following repair.
PG&E records were in-spected a*.d found to reflect the current status of both gear 4.,
The installation records of the returned gear boxes were examined and found to be satisfactory.
In response to 9
boxes.
4 PG&E questions regardincj corrective action, a Westinghouse 3
letter of 4-24-74 stated that specification changes would be made to require additional testing, by the manufacturer, to
$g This letter was filed with Deviation prevent recurrence.The fact that action to prevent recurrence y
7 Report flo. 102.
was not provided until two years after discovery of the original b
problem is not seen as substantial in light of the minorratur actions resolved the problems.
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The GA0 consultant also states "It should be noted that the i,
lack of reported inspection events and signatures reported in item II.b of this report was also found to be true during our j
review of the Residual Heat Removal Pump t{o. 2-2, the Safety i
Inspection Pump flo. 2-2 and the Baron Injection Tank."
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The i1RC inspector examined the Equipment Control History Records (See tiRC Finding of this report paragraph 3a), the i
identification and receival records, storage records, the equipment surveillance records of both PG&E and Wismer and M
Becker, alignment records, lubrication records and installation 3*
records, for the above named pumps, and found that the records were satisfactory and as required by procedures.
It is the i;
ilRC inspector's conclusion that licensee systems for insuring completion and documentation of quality related activities S
were operating satisfactorily for the GA0 examined components.
4.
GA0 Item III i
"Ref. IE Inspection Report flo. 50-323/77-01 Dated 1-25-77.
Detailed j
e report item tio. 8 states in brief 'A special test program was developed and conducted to analyze potential weaknesses in Concrete p
The inspector (!{RC) reviewed the test procedure j
Expansion Anchors.
and the anchors were tested in 3000 and 5000 psi strength concrete.'
l The inspector did not review any of the reinspection data but the a
licensee advised him that several unacceptable anchors had been g-found; however, they did not believe that the hangers involved I
would have been rendered incapable of performing its intended e
function."
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itRC Comment The statement of IE Inspection Report tio. 50-323/77-01 that anchors I
"were tested in both 3000 and 5000 psi design strength concrete" I
was recognized as being in error and corrected and clarified in IE Inspection Report flo. 50-323/77-06 covering the Unit 2 inspection l
7-10, 1977.
The Inspection Report !{o. 77-01 also clearly E
of June identifies that the unacceptable anchors had been found in Unit 1.
p The inspection program had not been started on Unit 2 in January of f
1977.
Because the inspection report covered a Unit 2 inspection, the reinspection data was not reviewed.
This item is carried as an open item by the itRC since the Unit 2 reinspection and rework program has not yet been completed.
I a.
GAO Observation III.a I
i "The report does not identify who developed the special test program, who performed it, who approved it, who witnessed it, I'
how the potential problem was discovered and the basis for acceptance."
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NRC Finding u.
<j It is not normal NRC practice to formally identify, in IE il inspection reports, individuals or groups who would develop, The NRC function is to 4
approve, perform or witness tests.
11 insure that a test program had been developed and performed utilizing responsible technical expertise and the requisite j
degree of quality assurance and control.
The NRC has been cognizant of the program for reinspection, testing and repair j
of concrete anchors and has documented this cognizance in IE lc Inspection Report Nos. 50-275/76-14, 77-03, 77-11, 77-17 and ij Nos. 50-323/76-05, 77-01, 77-03, 77-06 and 77-07.
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In deference to the GA0 observation, the test program was q
developed, approved and witnessed by PG&E General Construction g
JV personnel onsite under the direction of the Resident Mechanical Ii Engineer. The tests were performed by contractor personnel
!y under PG&E direction.
$a
,f The problem was discovered about 9-23-76 and documented by j*
Minor Variation Report M-2298 which identified that of 55 anchors inspected,18 were noted to have some type of discrepancy.
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This problem was subsequently escalated to Deviation Report J
No. 202 and as such, the test program, acceptance criteria, i
test data and reinspection program were approved by the licensee j
Engineering Department letter of 2-Engineering Department.
25-77 provide acceptance criteria for anchors not fully driven, anchors with angular misalignment, anchors which were overembedded,
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anchors with part of the threaded end or expansion end removed q {e and the minimum thread engagement required to develop design load strength.
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b.
GA0 Observation III.b ii "The unacceptable anchors were not identified as to location
,g or final disposition.
il[g NRC Finding Licensee personnel stated that identification of anchors to be The
?e reinspected was made by reviewing all hanger drawings.
l' status of the reinspection and repair program was tracked by' jl keeping a record of all hangers, marking the base plates and a,
keeping a current anchor inspection checklist. Unacceptable anchors were identified on the anchor inspecion checklists as 5(
to location of the specific hanger and anchor.
The NRC finds that unacceptable anchors were identified as to location and r;
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final disposition by means of this status keeping system.
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a3 GA0 Observation III.c.
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"The inspector states that he did not review a t[
he had i
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M witnessed any of the tests.he would have taken credit for tha
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!iRC _ Find _ing The fiRC did not witness testing to develop acceptance cr 3
76 and this time Z.
as testing was performed in late fiovember,19 tion schedule.
4 period did not coincide with the inspector's in d this 4
50-323/77-06.
fact in IE Inspection Report tio.
GA0 Observation III.d T
d.
it was "During our review of this act vity at the plant,xiliary buildingW i
h observed that a vacated floor section of t e au One of the had been used as a test floor for the program
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i tests simulating a variety of conditions,We were later advised flush, too deep, shallow mounting, etc.
had conducted the
'by the licensee management that the licenseeHowe M--
d the licensee area, we observed that both the contractor an ly 3400 psi.
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tests.
advised that the concrete strength was approximate tioned in When we inquired about the second test condition m 4
ditions and did not know of any tests performed under those con the f1RC report, h re were no tests run m.
the licensee specifically stated that t e in 5000 psi strength concrete."
r flRC Finding, h statement As previously stated in paragraph 4 of this report, t e sts were run 50-323/77-01 that te i d in IE Inspection of IE Inspection Report flo.on 5000 psi concrete f
50-323/77-06.
referred to is a design strength value and th Report flo.
h based l
(p d the apparently upon cylinder compressive test data.
by contractor personnel under PG&E direct t r of semantics and not of substance.
w 5.
GA0 Item IV It addresses documentation Q.f This is a general observation.
ifically; the appearance A
of construction events in general, but specof a v i
XVI as it relates
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to identification of defects, cause an df
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.w tiRC Comment 4-10 CFR 50, Appendix B, Criterian XVI requires, in part, that measures 1
shall be established for the control of conditions adverse to quality and that "The identification of the significant condition if adverse to quality, the cause of the condition, and the corrective g
action taken shall be documented and reported to appropriate levels 3
of management," and also that, "In the case of significant conditions j
adverse to quality, the measures shall assum'e that the cause of the condition is determined and corrective action taken to preclude repetition."
The licensee had established measures in the form of fd Quality Assurance Procedure tio. PRC-12 (On-site Discrepancies) which, since the inception, had been revised such that the current
>y revision is flo. 4 dated May 23, 1977.
M The Resident Engineers are charged, by PRC-12, with the responsibility 3
for determining whether discrepancies are Minor Variations or Deviations and with writing recommended disposition of the discrepant g*
item as well as the justification for recommending this disposition.
The determination of an items significance is highly subjective in
(*j The licensee classifies a discrepancy as a Minor Variation gc or as a Deviation (to which steps to prevent recurrence are assigned) ff nature.
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and has implemented procedural requirements which require reporting the discrepancy to appropriate levels of management.
Therefore, the f1RC does not consider the licensee procedures and practices for M;-
documenting and correcting defects to be in violation of 10 CFR 50,
.f i;
Appendix B, Criterian XVI.
3 a.
GAO Observation'IV.a by b
"There have been approximately 3,400 plus Minor Variation Reports generated on Units 1 and 2 by the licensee during the s
construction phase of these plants beginning Janrary 27, 1970 f
and continuing as of this writing."
sh f1RC Finding The f4RC concurs with this observation.
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b.
GA0 Observation IV.b I
"There have been approximately 275 Deviation Reports generated j
cn the same units for approximately the same period of time.
g Some of these are extensions of Minor Variations."
gW f4RC Finding py EE The liRC concurs with this observation.
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- CE GAO Observations IV.c, IV.d, and IV.f_
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_Since these observations are similar in nature, they will be fg listed together and addressed as a unit.
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4W GA0 Observation IV.c_
M f
"The figures used in a and b above do not include thousands M
d other reported nonconformances from other subcontractors anOu contractors working on this project.
y facility did not permit an in depth review of these m d
The licensee's form used 119 numbers.
as " Deviation" or " Minor Variation."to record such ev QA-1 (Rev.
and previously Rev.6-18-73).
' ' ^ ^ -
12-16-76 The Discrepancy Report form block titled "Classii cation a Od Disposition" contains a block titled " Minor Varia W
'?d b
members of the Material Review Board conc
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" Deviation."
i signature required)."
d$
GA0 Observa_ tion IV.d
" A substantial number of the Discrepancy Reports reviewed id i
during this inspection have been identified as Minor Variat o i
which we believe should have been classified as D T
GA0 Observation IV.f_
?-M "While many items were observed to be improperly classi d
the following is a list of a few that were note.
l DR # M-254 Hangers and restraints insta t
i 1.
found to leak and subsequently removed ang replaced.
t 2.
out of position.
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DR # M-237 Pump Motor Mount anchor bolts 45 DR # M-288 Meld repairs made to prima I YE 3.
j an approved weld procedure and without contractor 4.
+
DR # M-3378 All Grinnel Hydraulic Shock and Sway Su documentation.
pi (snubbers), to be inspected, removed, repaired, re-
'4 5.
calibrated and reinstalled (Approx 230 units).
- T NRC Findinq PRC-12 (0nsite Discrepancies) requires that a PGSE disc h
l discrepancy report be initiated when a supplier or contra ih
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violates PG5E. quality requirements.
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stated that the Resident Engineer receives all contractor M[t generated discrepancy reports and signs each signifying approval of the contractor specified corrective actions, as is required j;
by the contractor QA Manuals.
Licensee representatives further f
stated that a PG&E discrepancy report is generated for all
$p contractor discrepancy reports unless the report is of such a f$)}
minor nature that PG&E reinspection is deemed unnecessary (for g
cxample: a failure of a contractor employee to sign an inspection y.-
block on an inspection form).
Therefore, the statement that y
"the figures used in a and b above do not include thousands of other reported nonconformances from other subcontractors and 1
I contractors working on this project" is quite erroneous, f,
With regard to the classification of discrepancies as minor t rA variations or deviations, the itRC recognizes that a strict l$
literal interpretation of the definitions of a minor variation Tf and deviation, as contained in PRC-12 (0nsite Discrepancies),
'g would result in a preponderance of deviations and not the
- O observed preponderance of minor variations.
It nas been itRC policy with regard to Diablo Canyon te insure that discrepancies, both minor variations and deviations, are resolved in a manner A
comensurate with the significance and extent of the discrepancy
' 4.W and to accomplish this end, the itRC inspection reports throughout Eid the construction period make frequent mention of the itRC gi if inspector's review of the Minor Variation Reports.
s
@jf During the initial development of the PG&E QA program, the system for controlling discrepant or nonconforming conditions -
qw i,of" was built on the requirement that prior engineering approval was required before the disposition of major or significant h
discrepancies.
Such discrepancies are called " deviations."
While the original system has been modified, the basic criteria for engineering involvement has not been changed from that F
described in the Unit 2 PSAR.
- g iJ This PG&E system is in contrast to systems in general use o
today that require prior engineering approval of disposition actions whenever the requested disposition for a discrepant 1 3 item is either " accept as is" or " repair". In these generally '
g f
used systems, if the product is to be rejected or reworked to
%g specifications, no engineering involvement is required.
N Thus, the PG&E system is based on engineering involvement when 4
the discrepancy _ is significant, while the commonly used system is based on engineering involvement when the disposition is frg) f*
significant.
h(d The PG&E system was conceived at a time when the benefits of the later system were not perceived, and the problems associated
'N with subjective judgements in the use of the PG&E system were 3sy Td?
__ Q
I 3
f.
/
C O -4
$h e
.not fully, appreciated.
However, once the system was in place and had been imposed on' contractors it was generally deemed inadvisat>1e to make najor changes.
The forms were changed to
,y;p help facilitate u.1e, but the basic structure of the system iy remained. unchanged.
',"y' Over the years, i1RC: inspectors have recognized the problems
. associated with use of the PG&E system., Minor variations have
'(
been reviewed on numerous occasions and their classification Y l as minor was often questioned.
However, because of the sub-jective judgements involved, the more normal course of events 3
has been for the tiRC :to assure the treatment of questionable 1
minor variations as deviations requiring engineering involvement; i4 particularly when it appeared that such an action was warranted
(-
by the nature of the proposed disposition.
In any event, all c;
discrepancies have been sent to engineering for review although j
in the case of minor variations, this review usually takes M
place af ter the disposition is complete.
o Iicensee personnel stated that a revised procedure for handling on-site discrepancies was currently in the review process and
).40 was expected to be issued in final form about late November, s
- (
1977.
This revised procedure would~ eliminate the bi-level discrepancy classification system and standarize the review, disposition and approval processes.
This procedure and.its implementacion will, be examined during future itRC inspections.
3 d.
GAO Observa tion IV.e s
"As stated above,'the' Minor Vartnion category items do not appear to receive a minor degree of the attention applied to the Deviation category items, i.e., a single engineer can sign off on a Minor Variation and does not have to concern himself l
with QA'ra3 ews, QA/QC inspection.- corrective action and steps i
to prevent recurrence, Vendor notification, material review a
i board meeting, '.etc."i b
t.
f1RC Finding As discussed in the f4RC. finding of paragraph 5.c above, the
[
tiRC concurs with the~ statement that "the Minor Variation a
i category items do' not appear to receive a minor degree of the
(*
l attention applied to the Deviation category items."
.f Whereas the Resident Engineer alone may constitute the Material h,k Raview Board for minor variations, procedure PRC-12 (On-site TQ Discrepancies) requires that (1) for all cases involving N
rework the work must be inspected and accepted by an Inspector 7
who signifies acceptance by his signature in the Disposition J
Accomplished section of the discrepancy report and (2) in all
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cases the discrepancy corrective action and justification must 3
/
be entered in the Disposition section.
The implication that i
QA/QC inspection and corrective actions are not required or M
documented is erroneous.
.j A
It is true that steps to prevent recurrence ano a material review board meeting are only required in the event that a
'N discrepancy is classified as a deviation.
PRC-12 does not i
require vendor notification.
i 6.
GA0 Item V bj a
st "Ref: IE Inspection Report No. 50-323/77-01 Dated 1/25/77 item 3 of j,
the detailed report casually mentions that the licensee is taking
.I advantage of the reinspection program for Pipe Hangers and Supports 2
to verify that pipe snubbers are installed with the acceptable
)
limits on angular orientation."
3 v.t a.
GAO Observation V.a
$n "The observation mado in Item IV-f-5 on sheet 8 ot this report (GA0 notes) applies to this item.
This item involves E
approximately 230 significient pieces of functional equipment,
-e extensive removal, rework, recalibr'ation, testing, new handling 23 inspection and reinstallation activities and it is not only
?
recorded in a casual manner by NRC but is also classified as a Minor Violation by the licensee."
f n
,@h b.
GA0 Observation V.b "Our inspection of several areas of the plant revealed that many of the snubbers which had not yet been removed for rework
!g still display a green Acceptance inspection tag from tha
- g original inspection of a year or two ago.
4
'P4 tionconforming items installed in the plant should be identified j4 and segregated ASAP per 10 CFR 50, Appendix B, Criterion XV.
h!
The problem is at least 3 months old.
There has been ample
- ,j time to identify."
y a
GA0 observations V.a and b will be addressed as a unit since
.~5 they address a singular minor variation report.
'W NRC Finding 3
The licensee had not determined that a generic problem existed h-on ITT Grinnell seismic limiters until about March 1977 and on March 29, 1977 wrote Minor Variation Report No. M3378 which
'W documented that of 13 surplus snubbers checked 5 were suspected 3
of having entrapped air and of 15 installed Unit 1 snubbers
$$A sf:MP a
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59
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4 Therefore, x
checked, 8 were suspected of having air entrapped.
J$$
during the inspection period which IE Inspection Report flo.
50-323/77-01 covered (January 4-7,1977), seismic limiters had tts 4"
Minor Variation not yet been determined to be a problem.
24, 1977 which h
Report flo. M3378 Rev.1 was issued on June specified the program for reinspection, overhaul and reinstallation
- 3 Subsequent to the oetermination 3
of ITT Grinnell seismic limiters.
M of a seismic limiter problem, the status and progress of the 3
problem and disposition has been addressed by IE Inspection 50-275/77-03, 77-11, 77-17 and 50-323/77-03, 77-f Report flos.
It can, therefore, be stated that this 3
e 05, 77-06, 77-07.
problem has not been addressed in a " casual" manner by the The licensee Engineering Department has been aware of 3
p:i tiRC.
the status and progress of this problem since its discovery 4
and the high level of licensee effort expended on its resolution indicates that the problem has received attention commensurate 3
7t; 9}
i with the importance.
Licensee representatives stated that the contractor (Kellogg) d was requested to identify all snubbers that had been removed for testing or rework and that an Accepted Support Work Request tyj was attached to each snubber that was removed for testing M
An Incomplete specifying the installed location of the snubber.
Support Work tag was attached at the snubber location for all Licensee snubbers which required rework following testing.
- 4 representatives further stated that the original green acceptance h
tag was removed when a snubber was removed for testing and d
that the acceptance tag was not removed prior to snubber removal because, until the snubber was proven unacceptable f
it was considered to be acceptable.
The licensee 0;
2 maintained a list of all ITT grinnell snubbers and the testing / rework j
under test, status of each to insure that all had been tested and or repaired.
7.
GA0 Item VIII "Ref: IE Inspection Report tio. 50-323/77-01 Dated 1-25-77.
Detailed y
report section item #7 states in part; The qualifications records
[?
of 11DE personnel were examined and found to be in order and no y
discrepancies were noted in regards to equipment calibration."
b NRC Comment H
u 50-323/77-01 is clearly p
Paragraph 7 of IE Inspection Report flo.
titled "Preservice Inspection" and clearly references preservice t
inspection, ASME Code Section XI and nondestructive examination f
The test equipment trailer inspected by the GA0 consultant i
throughout.
contains test equipment which is used for instrument and component test and calibration and is not used for preservice inspection or The itRC can only conclude that the GA0 3
consultant was unfamiliar with the Preservice Inspection terminology i
or did not adequately question the licensee.
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8 6
ri GAO Observation VIII.a 6
a.
"An inspection of test equipment calibration located in jp laboratory trailer tio. 4/3616 issue room was conducted, h
Approximately one hundred (100) instruments were evaluated with the following results:
t 5
Temperature Potentiometer - four inspected - four out of p
1.
calibration by five to eight days.
Equip. Ser.
L itas. 113.217.1,
.2,.3 and.4.
i3 Volumeter Mod. tio.14321, one inspected - one out of 2.
calibration by five days.
Equip. Ser. tio. 101
~
Tachometer - one inspected - This item did not have 3.
a calibration label applied, however, the licensee 1:
employee acknowledged that one was required."
O t
ftRC Finding _
- w Interviews with licensee personnel and examination of calibration procedures and records disclosed that prior to instrument recali-Since none of bration a pre-calibration set of readings is taken.
h the instruments identified were out-of-tolerance during the pre-r calibration checks, the GA0 observation that the instruments were
~
Because an instrument is due "out-of-calibration" is erroneous.
for recalibratior, does not necessarily imply that the instrument is s
out-of-calibration.
i The licensee records of Equipment Calibration History and Equipment 9
Withdrawal were examined for each of the above instruments and the l N findings are as follows:
l The licensee has established Temperature Potentiometers:
1.
a three month recalibration frequency for these instruments.
, g 113.217.1 was recalibrated on 3-8-77 and l q Equipment Serial fio.
! g 6-14-77 and records indicated that it was not used for any Equipment
!g tests during the interval of 6-8-77 ano 6-14-77.were recalibrated I(J 113.217.2,113.217.3 and 113.217.4 on 3-5-77 and 6-9-77 and records indicated that they were not l3 Serial llos.
l It used for any tests durino the interval of 6-5-77 and 6-9-77.
IIG Volumeter Model flo.14321 Serial fio.101 is a leak raa
'N 2.
The monitor and was recalibrated on 12-8-76 and 6-24-77.
k licensee has established a six month recalibration frequency The records of equipment use were not for this instrument.
available at the issue room and will be examined during a b
action to verify that the instrument was subsequent ftRC in:
N aring the period of 6-8-77 and 6-24-77.
ib not used for test Ie
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Tachometer:
Since the equipment serial number is not identified the records for this instrument could not be reviewed.
The observation that a niibration sticker is required is correct.
l An examination of tachometers in the Dry Run Test Equipment
{
storage area disclosed that all had properly completed cali-bration stickers attached and that none were overdue for recalibration.
The licensee had noved the test equipment storage and issue area into permanent structures and has established in each a segregated location for placement of equipment oue for recalibration.
6 b.
GA0 Observation VIII.b
" Inspection of the calibration laboratory, equipment issuance area and dry run test group equipment storage area and issuance area has brought the question of adequate separation control t
to surface.
Equipment which has been calibrated, equipment i
awaiting calibration and equipment which has been damaged or f
awaiting repair is being stored in the same areas.
The fact i
that one category equipment is on the top shelf of a storage
(
bin and another category is on the second and third shelf does
,g not constitute adequate assurance that uncalibrated equipment g
l will not be issued in the place of calibrated equipment.
The potential of this happening is not remote it is very probably.
l
- Positive segregation of test equipment status by category should be incorporated at the earliest opportunity.
b
- A survey of all active test equipment in this facility should k
be performed to cetermine status.
7 k
- The equipment we found to be out of calibration and that which may be identified by the survey mentioned above should
?
be traced back to the most recent usage to determine the possible need for re-evaluation of tests which may have been performed using this out of date equipment.
- Personnel working in these areas of importance should be h
I indoctrinated as to the significance of maintaing calibration j
l and issuance controls."
y flRC Finding f
The IIRC inspector examined the calibration laboratory instrument storage and issue area nd the Dry Run Test group equipment L3 storage and issue area.
It was observed that both areas have
[
space set aside and marked for equipment that is due for T
recalibra tion.
Segregation of equipment by bin or shelf is y
l satisfactory if the areas are plainly marked, equipment issue p
and calibration personnel are knowledgeable regarding the f
,;,r u-
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0 ii W m
5 calibration and storage requirements and direct inspection of
,.i the licensee's instrument issue, recalibration and storage M
system demonstrates that the controls are adequate and operating Y
satisfactorily to prevent use of due for calibration equipment.
,(
Interviews with licensee personnel responsible for test equipment
.?
issue disclosed that each calibration label is checked prior
'i to issue to ensure that the equipment is within the calibration d
period.
It is, therefore, a remote possibility that test 3,
equipment which is due for recalibration would be issued.
is.
The licensee requires that a pre-calibration check be performed on each instrument prior to recalibration and if an out-of-Y tolerance condition is noted, it is so recorded on the Equipment y
Calibration History and an Out-of-Tolerance flotification is
.j issued to all users of the instrument since the last calibration j
who then determine if a test performed with the instrument is y
to be repeated.
The Quality Control Department is required to E
follow up on any Out-of-Tolerance flotification which is not resolved and returned to the Instrumentation Supervisor.
The 4
licensee system for followup of out-of-tolerance instruments Q
appear to provide adequate assurance that out-of-calibration y)N instruments would not be used for tests.
The NRC direct inspection of the GA0 identified instruments disclosed that those instruments were not out-of-tolerance during pre-calibration checks.
9j A
The inspector examined al'out 100 instruments in the test equipment storage area.
It was noted that two Weston Model 3
904 voltmeters and one Chart Recorder were due for recalibration.
rs Interviews with licensee personnel disclosed that these con-ditions had been previously identified and, due to low usage rates for these instruments, action was being taken to remove u
the instruments from the calibration cycle and calibrate nnly if the instrument was to be used.
L4 Interviews with licensee personnel disclosed that instrument 5
issue personnel are given about two weeks of on-the-job training, P
under supervision of an experienced individual, in the systems h
h@
and practices utilized to control calibration and issue of measurement and test equipment.
v:
8.
GA0 Item IX II
'" General:
A cursory inspection of the plant and several out of plant storage areas was conducted during the audit.
Several items M
of a curious nature were observed and are here-in noted as a matter R
of record."
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GA0 Observation IX.b s
a.
"It was noted that the Steam Generator support structures and h
the support pads for the Reactor Head Laydown area in Unit 1 g
It was further noted W
had been welded and secured with epoxy.
that these areas had not been completed in Unit 2 and that c
several mounting studs were tilted off the vertical and had p
not been tightened down to a flush position with the bolt These items were discussed briefly with the licensee's AM TS heads.
site management personnel.
We were advised that Unit 2 had not reached this stage of final' setting, cleaning and lock j
welding at this time.
We were unable to pursue the observation v3 45 any further due to a lack of +.ime."
M
'?S NRC Finding i
The inspector examined the upper and lower support structure d
for all Unit 1 and 2 steam generators.
No instances of out-
?-
of-alignment mounting studs were noted and no instances were
.k observed wherein epoxy had been used to secure support structures Licensee personnel stated that the steam generator or pads.
i support structure for both units were in the process of final l
- i
- L shimming.
! be.
The reactor head laydown structure is not classified as safety related and, therefore, is not subject to 10 CFR 50, Appendix
! 9 8 criteria.
These areas were examined and noted to consist of iL steel pedestals embedded in concrete.
The examination did not
!f disclose any areas where epoxy had been used to secure component I;
i-parts.
P
[
It should be r.oted that the licensee uses epoxy or resin base r
coatings on concrete surfaces as an aid in housekeeping to minimize dust formation and facilitate cleanup.
N b.
GA0 Observation IX.c U-Gt "During a brief inspection of the storage building in Area 10 used for storage of valves, motor operators, snubbers, weld rod and other items, it,was observed that identification and S@
status of materials in this area was less than desirable.
f.e., several skids of can stored weld rod in several locations jq i pi of this small building were not identified as to their acceptable or rejected status, several cans of weld rod were damaged, fd j7 dented and isolated from the main weld rod storage skid but again not identified accepted or reject although there were qh accept / reject labels in the area; the only floor in this y
storage area between the products and the ground are slatted
'yd skids; and in general the care of storage and identification 9
of material status was not in keeping with good construction k'
practices."
04, e
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,J f1RC Finding f'
i The inspector examined the Area 10 storage building for certain
!)
Class 1 material and, although motor operators and weld rod were not stored herein, licensee personnel noted that the area
- T M had been used as a repository for unopened weld rod cans 71 (prior to transfer to rod issue areas) and air actuated valve s
operators.
Licensee personnel indicated that because tne
?
damaged weld rod cans had been isolated from the main weld rod E
skid, they were most probably awaiting return to the supplier, y
as required by procedure.
Investigation of procedures utilized 9s to control storage conditions in the Area 10 building disclosed M
that the acceptability of items is required to be documented i'
on the receiving inspection forms.
A holding area was observed to be set aside for material that was rejectable or questionable.
The procedures appeared to provide adequate control of acceptable
- ;. pd or rejectable material.
1 'M The NRC inspector noted that the Area 10 building environmental h
storage conditions appeared satisfactory in that the material was stored inside an enclosed area and was, as noted by the
. $.,d GAO, stored on pallets to preclude ground contact.
h5 q
c.
GA0 Obse vation IX.d J
"During our general in plant inspection of Unit 2, it was
^
observed that a valve had been subjected to considerable
-r grinding on one port and on the body sfde.
The valve was a Y
h 10" Velan Valve SN.0067 located at 305 on the 91' elevation.
A It would appe'ar that the wall thickness of this valve has been altered considerably by this grinding."
^} :i; f 4 NRC Finding
)l. -@.]4y The valve in question is the motor operated discharge isolation valve for Safety Injection System Accumulator No. 2-1.
The NRC inspector examined the discharge isolation valves for all f ' @N.2 Unit 1 and 2 safety injection accumulators.
While grinding marks were observed on the other valves, it was noted that the (j.
]%
Accumulator 2-1 discharge valve appeared to be the only one 4
which had been subjected to extensive grinding. Further examination b
i--
of the valve disclosed that the texture and appearance of the f fi2 grinding marks appeared uniform indicating that the grinding 7
had most probably been done by the valve mar.ufacturer at the 3
manufacturcrs plant.
This conclusion was reached with the m
I knowledge that all of tne valves were forged and ground, 1
subsequent to forging, to obtain a smooth contour suitable for liquid penetrant examination.
The Westinghouse Quality Release 1
documentation for the valve disclosed that ultrasonic and M
nondestuctive examinations performed were acceptable.
In I
Y addition, the valve manufacturers ultrasonic test record for hN the valve was telecopied from the manufacturer's facility and L
p' i i
disclosed that the ultrasonic test results were acceptable.
f4
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Q R
ZR DETAILS II_
T (Reactor Operations and Nuclear Support Branch) na Tc ;'[
1.
Individuals Contacted Vf..
.W
- M. Tressler, Project Superintendent
- M. Norem, Resident Startup Engineer
?;
)
- R. Taylor, QA Engineer
(
C. Seward, QA Engineer 4
J. Townsend, Resident Electrical Engineer
.1 J. Arnold, Coordinating QC Engineer J. Booth, Senior Chemical and Radiation Protection Engineer 4
- J. Diamonon, QC Supervisor
- Denotes those present at Exit Interview.
2.
GA0 Item I_
IE Inspection Report No. 50-323/77-01 dated January 25, rg "Ref:
Sumary Item #7 states
'A review of the licensee's site
', $9 1977.
audit reports and minor deviation reports issued since the previous insoection disclosed no items of particular interest.'"
g NRC Coment 50-323/77-01 is a construction branch report;
,j' Inspection Report No.
therefore, the statement in that report refers to audits of
}:
The Audit Report No. DE 76-1 is an construction activities.
iL l
audit of preoperaticns and would be repo'rted (if examined) in an j
l operations branch inspection report because of the separation of i
8 responsibilities between the two branches.
].
A.
5A0ObservatlonI.a l 'D Licensee Site Audit Report fDe 76-1 dated December 27, 1976, g
page one, stated that four (4) flush tests were performed f'
per Startup Test Procedure #16.2, that the water pH and chloride quality were not per spec, and that the Resident Startup Engineer would revise the Test Procedure,#1.2 by January 11.,1977 to prevent a recurrence of this problem.
g NRC Coment An examination of records, reports and discussions with the rl c plant chemist and a licensee's QA Engineer revealed that the chemistry report of the flush water examined by the
,Ir li V
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m
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h licensee's OA Engineer was for a sample made on tiovember 17, j&
At that time, the C1' content was 1,2 ppm and the pli (The acceptance limits were Cl,1.0 ppm, maximum
~
1976.
jp/
The IE. inspector exanined the chemistry d
was 5.8.
i 30,1976 (the date of actual flushing) 3$
and pli, 6.0-8.0).
which revealed the Cl content to be 0.27 ppm and the pli to y
report of !(ovember The be 7.1 (which is within the acceptance limits). licen M
ME d
water in the flush tank to be out of limits at times, an i$
that when this is the case the water is recirculated through M
demineralizers and brought back within specifications prior h
^
to use.
- g
~
.unt GA0 Observation I.b_
'l B.
A review of the records in the QC Document Control Cen h
revealed that Startup Test Procedure #16.2 had not been J
.g; performed as of June 6,1977.
pq flRC Finding _
y Completed startup tests (SUT) are not placed in the QC d
Document Control Center until every item of the tes Gyg 15 primary system, was still in the field on flovember completed.
4 because of an outstanding problem report on the primaryA tiy water makeup pumps.
two (2) steps of a test having fifty (50) steps.
H
?l I
I GAO Observation I.c_
. L C.
A7eview of the records in the QC Document Control Cen revealed that Startup Test Procedure #1.2 for U
- y
!g
!q not identify what change was made.
i@
l @
flRC Coment_
l".
11, 1977. The change SUT Procedure 1.2 was revised on January They 1-noted by our inspector was to the pil acceptance limits.
were changed from a range of 6-8 to 5.5-8 which is consistentThe
(
with the limits of AtlSI Standard fl45.2.1.is f.
The required to know what changes are made in procf i
Startup Engineer who is required to authorize changes in p4 startup test procedures.
mh 5
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3.
GA0 Item VI i
hit "Ref:- IE Inspection Report No.- 50-323/77-02 dated March.2, 1977.
,y Detailed section of report, item 2, states in essence:
Diesel W
generator (DG) testing was started on January 27, 1977; records
,f J~
and discussions with plant personnel revealed to the inspector that speed governor prublems stopped all testing on February 7,
'm 1977.
Toning and adjustments allowed testing to resume Mj, February 10, 1977 until February 14, 1977, when the inspector was IFq advised by telephone that various problems resulted in the suspension of all testing till vibration and governor problems can be resolved. Problem reports were made out."
"Our evaluation of.this problem on si revealed the following infomation: A total of six (6) Startup Problem Reports (SPR's) had been generated as a result of this test."
rMQ NRC Coment i
OA procedures require that if a system or component does not function as required, the deficiency will be documented and resolved by the use of the Startup Problem Report (SPR).-
Problem reports are initiated by the Resident Startup Engineer Cjj and sent to the Project Superintendent who takes the necessary g
action to resolve the problem.
3g A.
GA0 Observation III:a SPR-618 identified lube oil supply check valve leaking.
Instruction stated:
Corrective action requested - ASAP
-i dated May.13,1977.?
~
NRC Finding- -
l Valve on order; probl'em still has not been resolved.
B.
GA0 Observation VI.b SPR-614 not filed in QC Document Control Center; could not L
be located.and. Startup Engineer did not recall the problem.
g
?
N2C Finding Damaged gauge movement and glass replaced on May 17, 1977.
Resolved.
l4-r,m
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IIRC Finding An SPR must go through its full administrative process before it can be recorded as resolved in the OC Document Control Center.
The Resident Startup Engineer does keep a working copy of each SPR and a current status is maintained in his office.
H.
GA0 Observation VI, flote 2 There are no records and there was no verbal response to indicate that the licensee QA or QC departments were involved in the proposed resolution, vendor communications, problem research, corrective action or anything about this extensive and involved problem.
flRC Finding There are no QA requirements for the QA/QC departments to be involved in the proposed resolution, vendor comunications, i
problem research or corrective action. The QA/QC departments lJ are, however, on the distribution of initiated SPR's and i
again when the SPR is resolved. The QA/QC departments may
!yW
' y and can audit at any time.
f4RC Coments on GA0 Item VI 1
0 Diesel generator testing on Unit 2 is one of tests chosen to j
be witnessed by Region V inspectors. An inspector was on site during part of the testing. Testing-has been suspended q
and all the problems that would affect testing must be r
resolved prior.to resumption of testing. When DG testing is d
resumed, an inspector will witness portions of the tests and i
examine the status of the SPR's and the adequacy of their i
resolutions.
1 4.
GA0 Item VII (Parts a through d)-
f "Ref:
IE Inspection Report flo. 50-323/77-02 dated March 2, 1977'.
Item 4(c) states:
'A partial review of selected procedures was completed.
These procedure reviews will be completed during a q
i future inspection.'"
" Observation:- The principal inspector provided a list of nine (9) i procedures which were in various stages of review. Of the nine, five were concerning the reactor coolant leak detection system h
2
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GA0 Observation III.c SPR-522 automatic voltage regulator does not regulate.
Resolve as manpower pemits.
Dated February 12, 1977.-
5 I
3' NRC Findina
- M 5
Cables found incorrectly wired on regulator.
Resolved on
.J. $. c,1 n
September 29, 1977.
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GA0 Observation VI.d
.El c
Cl SPR-521 DG tack-packs do not operate properly.
Resolve
.9 i ASAP, dated February ll,1977.
4 HRC Finding Tack-packs repaired and calibrated on May 6, 1977.
Resolved.
.{.
E.
GA0 Observation VI.e 3
SPR-520 DG electric governors do not operate properly.
Resolve ASAP, dated February 28, 1977.
f ies
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]
NRC Findino i
Failed zener diode found July 12, 1977.
Resolved.
i F.
GAO Observation VI.f L
r SPR-517 0G 21 and 22 both have high vibration, 7.6 mils, t
6.2 mils and 8.5 mils. Resolve ASAP - Test in process, f-dated February 9,1977.
1 NRC Finding k
t Grouting of base pads essentially resolvd the problem, but the problem report is still held open.
?
G.
GA0 Observation VI, Note 1 a.
l None of the six SPR's recorded on this problem had been recorded as resolved or the status of resolution as of
(
May 31, 1977.
No SPR record or progress.
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'WC which directly) relates to this item of the IE Inspection Report.
g Of the five (5 procedures, this observer elected to review the 4
status of Procedure 37.18 RC, ' Systems 1.cakage Test,' at the
.@y site. This procedure was recorded by NRC as ' partially done.'
The following resulted:
sh "a.
There is no copy of Procedure 37.18 in the QC Document
- c'fy Control Center. There is a folder, no out-card in the file and no procedure.
y <
"b.
The site QC Coordinator stated that he did not believe it 2 S..
' d,p@a has been written yet.
"c.
The Startup Engineer did not believe it had been written
.[
r yet.
"d.
The Resident Startup Engineer stated that this procedure i :.
had not been written for Unit 2 at that time and that he may elect to.use the same procedure he had used on Unit 1.
- g,g He had not decided yet.
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" Note: Licensee files do not appear to be up-to-date with the NRC files or probably the inspector is reviewing the
$.h same procedure twice assuming that this procedure was reviewed prior to the preops of Unit 1."
M Ip.
NRC Coc:nent l p' The GA0 observation is correct in.that Procedure 37.18 had not k
been issued in final form for Unit 2..
The licensee initially i
issued a series of preoperational test procedures for." Units 1 and 2."
After final approval, these procedures were used for Unit 1 preoperational tests.
For Unit 2 preoperational tests, the licensee reviews and reapproves each " Units 1 and 2" procedure, i
incroparates any necessary changes, and reissues it as a " Unit 2" li preoperational test procedure. The " Units 1 and 2" procedure is, i
in other words, a final draft of the " Unit 2" procedure. This D
" Units 1 and 2" version, or final. draft procedure, was the basis
!i R for the partial review conducted during the inspection. The NRC i kk inspector's. review of a Unit.2 procedure.will not be completed h
4 until the procedure is approved and issued in final fonn. The j' W GAO auditor apparently looked only for a Unit 2 procedure and
,[
I did not observe the " Units 1 and 2" procedure which had been previously issued and used for perfonnance of the Unit 1 test.
?
Procedure 37.18 has still not been issued in final fann for Unit 2.
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _. ___ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ __________________________________________3
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e-Ms v:f3'M th respect to the auditor's note, the ilRC Regional Office Q.4
.W does not maintain a file of the licensee's preoperational test
. Try C~
The orecise meaning of the note is not clear, but
, M.T5 procedures.
no assumptions about possible previous reviews were made during
!1%s the conduct of our inspection of Unit 2 preoperational test y
procedures.
'f.
5.
GA0 Item VII (part e)
L'
" Test Procedure #23.0, ' Main Control Room Heating Ventilation
,r and Air Conditioning Systems,' (HVAC) was reviewed during this audit at the site.
- - t "1.
Problem Report #329 identified a test problem with the control room ventilation system. An attachment to Problem b
Report #329 written on standard tablet paper to describe
((#jg 4.;;
three lengthy detailed aspects of the problem is titled
' Attachment to Problem Report i
_. ' Should this. document become separated from the original problem report there could be a problem identifying its parent document and origin.
"2.
There is no record to indicate that site QC Startup _
Engineer becomes involved in the review, followup or W-corrective action taken to resolve the problem.
In all cases, Problem Re 1
Test Procedure (TP 23.1) ports 1329, 399 and 460, and the "3.
which was written up as being in F
violation (the TP no.) was added in the top right corner of the form or bottom left as an afterthought.
The C
Form S-7 (Rev. 7-7-75) does not provide a place to record identificatien of the item to which the problem report is addressed.
~
The records indicate that approximately eleven (11) changes "4.
had been made to TP 23.1 in recent weeks. Many of these
-:. I changes were initiated on licensee Test Procedure Change
~~
Fonn S-10 (8/12/76). The Test Procedure change is signed i;.
There by the Startup Engineer and a person from operations.
F is no place for QA/QC involvement a'nd as a matter of. fact QA & QC is not even on the distribution."
f flRC Connerit
~. '. ' '.
- T It should be noted that the inspector was conducting a procedure l
j review (IE Inspection Procedure 703408, Group C), which does not
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include review of test results. An extra (blank) copy of
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~
M test had previously been perfomed.
This procedure was.
y perfomed somewhat earlier than most Unit 2. tests,. haying,,
3p
.t been dor.e concurrently with the Unit I con ~ trol room ventilation 9M.q test (Units 1 and 2 share a cormon contro.1 room). Although the ~
inspector's review did not include ~the problem reports referenced W
by the GA0 auditor,r the following remarksrelale' to his corrnentsr J,
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q5kf The referenced attachment was foun'd to.be~ stapled to.
(if i.
M Problem Report i329.
Both the
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attachment'were secured in titie' problem report and the' M@
~related file' folder for M-Test Procedure' 23.lmwith. a two-pror)ged -(ACCO type):
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...h s item is. not considered to be of concern. '<
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,The' licensee's.. procedures do not require.QC f avolvement e..u.... u
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4 e; in the resolution.of. individual problem reports ~.
- The e,-
- c problem report.fom is picyided td d0cument unacceptable
~
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, conditions or results experienced du, ring the performance of preoperational 'or startup tests..' Both the QC Supervisor.-
.- e- ' I: ' - ' and. the QA Engineer receive a'. copy "of each problem rep'or.t*'
~ ' rg'n7 d'J when initiated. When the priblem is ' resolved,.the QC
. M.
~ ~ '
P Supervisor receives the~ original 'and ordcopy' of the
- 1. -
resolution, and the QA Engi A co~py.
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of each problem report also,neer ' receives a copy'.'
goes.into the working copy of by the Plant Staff. Review CoFmitteeibefore the' system is ~i i,
' thh related test procedure; which is.rev.iewed and. approved',
~
4 q turned 'over to the' plant staff. :The QC' Supervisor.is.~a f'.A
~~
~
. member of the Plant Staff' Review Comittee. ~ It therefore... '. -
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.l,. appears that there' is adequati opportunity'd p$.;. '
'd
.for QA/QC.
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' i.Jinvolvesent in the.resolutfon of:-identific roblems. '.
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,a indicat' ion. 6f iti e test procedur5 number on. each SPR..f * ~~~M #c-'(' %
The < licensee recognized-s.ome t'ime' ago.the ifeed for
~,.
.3 1
M.
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'
- Fom S:-7 was revised on A~pril:.23; c1976 to include-a blank '.....-
-F al.-- b c. for identi fying the r;elat.ed. t.e., st. 'proce' dure. J,
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.A's the' GAO auditor!.s' comiient points out, each test. " ".* g.. ',h 2r 5 P
h '.:- :'* " procedure change is approved bf'.the.Startup; Enginee
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u an authorlied. representative of' the plant op'e'rhtions staff...
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procedures, which do' not' require'QA or QC approva,1? pf.A'W :';C s J. _,
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, individual procedure changes.. Such overinvolvement.~of QA ff.. 's Gsl.? :
g.
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'.M).. changes would partially' compromise the:independe~nce whichi l,t-(.',F
..e. - i
- c..and QC personnel tri.the approval of. individual 1 procedure
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- eethey must maintain,from' actual. conifuct of the. test program... >S... T.C
.., Additionally, as. noted in Item 2'aboy'e,' e'ach. completed A.
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~
' test procedure' ('W1th.ch'angesT and ielated-tes't tesults'are"
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.'~V' reviewed by~the Plant Staff Review Comittee of. which the.
.. I.~<;.M.. ;:.,::. QC S6pe.,'rvisor 15' a memb.er @ V~~
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