ML20054F197
| ML20054F197 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/27/1982 |
| From: | Blumberg N, Caphton D, Eapen P, Meyer G, Napuda G, Shaub E, Shaub T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20054F190 | List: |
| References | |
| 50-387-82-09, 50-387-82-9, NUDOCS 8206150304 | |
| Download: ML20054F197 (52) | |
See also: IR 05000387/1982009
Text
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U.S. NUCLEAR REGULATORY COMMISSION
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REGION I
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Report No. 82-09
Docket No. 50-387 _
License No. CPPR-101
Priority
Category
B
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Licensee: Pennsylvania Power & Light Com any
>
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2 North Ninth Street
Allentowr., Pennsylvania- 18101
Facility Name: Susquehanna Steam Electric Station, Unit 1
Inspection At: Allentown and Berwick, Pennsylvania
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Inspection Conduc d:
March 22-26, 29-31 and April 1-2, 1982
Inspectors:
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G.Napuda, R4 actor Inspec4.or
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['T Yk
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@ N. Blumberg, Reactor Inspector
date
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P. K. Eapen, Reactor Inspector
date
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G. Meyer, Reactor Inspector
date
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7. Shaub', Reactor Inspector
date
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~D. Caphton, Ctfief, Management Programs
/date'
ection En inepring Inspection Branch
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Approved by:
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D. Ca'pht6nf Chief, Management Programs
date'
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Section, Engineering Inspection Branch
Inspection Summary:
Inspection on March 22-26, 29-31 and April 1-2, 1982
(Inspection Report No. 50-387/82-09)
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Areas Inspected:
Routine, announced inspection by region based inspectors of 1)
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the Pre-operations Quality Assurance Program implementation, and 2) the readiness
of the Quality Assurance Program for operations in the areas of design changes /
modifications and engineering; maintenance; plant surveillance testing and
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C206150304 820528
PDR ADOCK 05000387
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calibration control; test and measurement equipment; onsite and offsite. safety
committees; non-licensed training; document control; records; procurement;
receipt, storage and handling of items; audits; plant procedures,; and, previously
identified items. The inspection involved 46 inspector hours in-office by five
inspectors, 361 inspector-hours onsite by five region bassd inspectors and one
supervisor, and 131 inspector-hours at the corporate offices by four region
based inspectors.
,
Results: Of the thirteen areas inspected, two 1.tems of noncompliance were
identified in one area (violation - failure to obtain proper authorization prior
to work on a safety-related system, paragraph 4'.1; violation - failure'to conduct
comprehensive audits of pre-operational testing, paragraph 4.1).
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DETAILS
1.
Persons Contacted
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A: -Pennsylvania Power & Light Company (PP&L), Allentown, Pa.
- W. Barlserich, Supervisor-Nuclear Licensing .
A.' Butt, Consultant Engineer (Quadrex Corp.)
- J. Calhoun, Senior Vice President - Nuclear
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- S. Cantone, Manager - Nuclear Support
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L. Clark, Quality Engineer
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- A. Craven, Senior Information Specialist - Nuclear Administration
- N. Curtis, Vice President - Engineering
- R. Featenby, Assistant Project Director - Site
J. Gutshall, Senior Project Engineer
R. Harris, Licensing
W. Heske, Manager - Nuclear Administration
- P. Henrikson, Manager Licensing
C. Kalter, Assistant to Manager - Nuclear Support
- B. Kenyon, Vice President - Nuclear Operations
W. Lurch, Manager - Education and. Training
,
- A. Male, Manager - Nuclear Design
- C. McVicker, Assistant Manager - Nuclear Quality Assurance (Operations)-
- J. Medeiros, Supervisor - Nuclear Records
- J. Miltenberger, Manager - Nuclear Safety Assessment
- K. Neddenien, Information Specialist - Nuclear Administration-
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H. 0heim, Group Supervisor - Electrical Design
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- A. Sabol, Manager - Nuclear Quality Assurance
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O. Sattar, Senior Project Engineer
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N. Schwan, Assistant Manager - Nuclear Quality Assurance (Engineering /
Procurement)
R. Shovlin, Assistant Project Director
B. Skoras, Engineer - Electrical Design
- J. Stefanko, Manager - Nuclear Fuels
J. Spadotto, Supervisor - Management Development
- W. Ward, Manager - Training
H. Webb, Supervisor - Nuclear Maintenance Support
B.
Susquehanna Steam Electric Station, Berwyck, Pa.
L. Adans, Supervisor of Operations
F. Butler, Instrument and Control / Computer (I&C/C) Supervisor
R. Byram, Acting Supervisor of Operations
,
P. Cape:osto, Acting Resident Nuclear QA Engineer
D. Cassel, Group Supervisor - Nuclear Site Engineering
N. Covington, Assistant ISG Supervisor
J. Edwards, Personnel and Administrative Supervisor
F. Eisenhuth, Senior Compliance Engineer
C. Figard, ISG Supervisor (Bechtel)
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F. Graber, Operations Consultant
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J. Graham, Staff Assistant
J. Green, Operations QA Supervisor
E. Gorski, QC Supervisor
M. Johnson, ISG Quality Engineer (Bechtel)
- H. Keiser, Superintendent - Susquehanna Steam Electric Station
G. Kuczynski, Electrical Maintenance Supervisor
D. Lauer, ISG Coordinator
B. Lloyd, Maintenance Engineer
W. Lowthert, Supervisor - Technical Training
T. Nork, Acting Supervisor - Maintenance
A. Piemontese, Power Production Engineer
A. Reasin, Test Director - ISG
G. Robinson, I&C Foreman
M. Rutkoskie, Assistant (I&C) Foreman
J. Skrocki, Project Engineer (Spare Parts Analysis)
M. Sherman, Assistant Electrical Foreman
D. Sitler, Senior Results Engineer
NRC Personnel
- S. Ebneter, Chief, Engineering Inspection Branch, Division of
Engineering and Technical Programs
- J. McCann, Resident Inspector
- G. Rhoads, Senior Resident Inspector
2.
Licensee Action on Previous Inspection Findings
(0 pen) Inspector Follow Item (387/81-24-08):
No procedure existed which
addressed system cleaning.
The inspector observed that new procedure AD-
QA-503 provided instructions for determining grades of system cleanliness
in accordance with ANSI N45.2.1 but contained no procedures for system
cleaning and flushing. The licensee stated that these procedures were
contained in corporate engineering procedure M-1039, " Cleanliness of Piping
and Associated Components". The inspector determined that M-1039 did
conform to ANSI N45.2.1.
The licensee agreed to revise AD-QA-503 specify
that M-1039 was to be used whenever system cleaning or flushing was
required. This item remains open pending completion of licensee action.
(Closed) Inspector Follow Item (387/81-24-04):
Procedure AD-QA-502, " Work
Authorization System", to be revised to further define the makeup of the
final work package.
The inspector verified that AD-QA-502 has been revised
to specify the necessary documents to be part of a completed work package.
Based on the above, this item is closed.
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(Closed) Inspector Follow Item (.187/81-24-07) Cleanliness zones as specified
in Procedure AD-00-48 did not appear to completely conform to those specified
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in ANSI N45.2.3.
The inspector verified that AD-00-48 has been reissued as
AD-QA-503, " Housekeeping / Cleanliness Control", a,d has been revised to
incorporate the requirements of ANSI N45.2.3.
Based on the above, this
item is closed.
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3.
General
The primary intent of this inspection was to ascertain the readiness of the
applicant for operation of the plant in the specific areas inspected.
Procedures were reviewed to verify they were consistent with commitments
and clearly detailed the particular activity.
Employees were interviewed
to determine that thay were aware of their authorities and responsibilities,
and knowledgeable in applicable procedures.
Records of activities that had
taken place were reviewed to determine the effectiveness of the established
program. Personnel and training records of selected interviewed employees
were also reviewed to verify that job incumbents had adequate education /
experience or proper supplemental training for their positions. When
possible, ongoing activities were observed to assure they were accomplished
in accordance with established procedures.
These areas are discussed in
paragraphs 5 -16.
Those items that must be corrected / resolved prior to the issuance of an
Operating License (0L) or fuel loading are so identified and this action
will be verified as appropria+e during a subsequent inspection (s). Those
concerns / minor items that must be corrected / resolved prior to or when an
activity occurs (other than OL or fuel load) will be examined during sub-
sequent routine inspections.
4.
Site Nuclear Qi911ty Assurance (NQA) Staff for the Preoperational Testing
Prngram
4.1 The NQA site staff responsibilities covers both preoperational testing
and operations. As of April 1,1982 the site staff consisted of one
QA supervisor, two technical engineers plus one technical contractor.
The licensee's representative stated that one senior NQA analyst was
recently (3/29/82) transferred to the plant staff.
It was further
stated that attempts were underway to fill this vacancy.
The licensee's
representative stated that the NQA site staff utilization had been
approximately 60% of available time involved with QA review of pro-
cedures.
QA Audits are scheduled and preplanned. A review of the audits scheduled
indicated some slippage relative to the established schedule. A
review of the audits performed and completed in the preoperations
testing area identified 8 audits (see paragraph 15.3) of the ISG
(Integrated Startup Group) controlled preoperational testing work over
an approximate 18 month period, June 16, 1980 through March 9, 1982.
An inspection was made of the QA audits performed on the ISG conducted
preoperational testing program to determine audit overall coverage,
comprehensiveness and degree of periodicity. The eight QA audits when
placed on a matrix to analyze coverage, except in the area of preopera-
tional test implementation and test witness, provided essentially a
one time audit of some aspects of the ISG controlled run preoperational
test program.
The audit coverage noticably lacked evidence of periodi-
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city. No reaudits of deficient areas was evident. 'All aspects of the
ISG preoperational testing program was not covered by the audits.
For
example, there were no comprehensive audits of ISG handling and pro-
cessing into the ISG program the turned over system packages from
construction; and, many Q listed systems lacked evidence of having any
aspects audited. A comparison made of the eight audits performed by
QA against the Q-list showed there were no planned and periodic QA
Audits of, e.g. Q Listed Systems Nos. 4.0, 5.0, 6.0, 9.0, 11.0, 11.0,
17.0, 45.0, 54.0, 55.0, 58.0, 60.0, 61.0,-62.0, 64.0, 69.0, 70.0,
71.0, 73.0, 75.0, 76.0 and 81.0.
A review of the QA audits that were conducted appeared to provide
meaningful coverage within the limits of their scope; however, 10 CFR 50 Appendix B Criterion XVIII, Audits, states that a comprehensive
system of planned and periodic audits shall be carried out to verify
compliance with all aspects of the (preoperational testing) quality
assurance program and to determine the effectiveness of the program,
and Criterion II Quality Assurance Program, states that the "...
program shall provide control over activities ... consistent with
their importance to safety".
The licensee's QA audits appear not to
meet the intent of Criteria XVIII and II in that only some aspects of
the preoperational testing program had been audited and many activities
regarding Q listed systems important to safety had either no audit
coverage or only one time audit coverage (lacked periodicity). This
is a violation (387/82-09-01).
The construction turnover over package to ISG for Core Spray System
No. 51A was selectively sample reviewed.
Twenty items from the construc-
tion turnover exception list were examined to determine how they were
incorporated into the ISG system. All twenty items had been placed on
the ISG Startup Work List (SWL). One item entered on the list on May
16, 1980 was followed up since it was still open and the core spray
preoperational pump test had been essentially completed. This item
was titled " Install Core Spray Strainers IF 404 A,C on HBB 104-1 after
flush." There was also a similar entry on the SWL for Strainers IF
404 B and D.
The flush was completed prior to the core spray pump
test. Bechtel Drawing M152, Rev. 15 showed the strainers installation
to be two each on the 'A and C' and 'B and D' Core spray pump suction
lines inside the suppression pool area. A visual inspection was made
inside the suppression pool on April 1, 1982 to determine whether or
not the strainers were installed.
Strainers were visually observed to
be installed on the top side of each core spray pump suction line Tee.
The suppression pool had been filled with water, howeve- visual clarity
through the water was excellent when aided with light. A blind flange
(handle) tab could be seen projecting from the flange at the bottom of
the Tee however no strainer was installed on the bottom side of the
Tee.
A review made of ISG Startup Work Authori:ations (SWA) identified one
written to cover installation of blind flanges for the system 51A Core
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Spray pump suction line, however no SWA was identified by ISG personnel
to cover the installation of the strainers found to be installed on
the top side of the Tee.
AD 6.4 Rev. 9, Startup Work Authorization, states that"... all hardware-
identified under PP&L Quality Assurance Program will require an SWA
"and" work is considered to be any activity that requires a
...
craftman to perform that activity." The installation of the Q listed
core spray pump suction line strainers without an SWA is in violation
of the AD 6.4, Rev. 9 procedure.
This is a violation (387/82-09-02).
In addition to the two violations identified above, the existing QA
staff was found to be inadequate to provide auditing and surveillance
coverage for preoperational testing activities and station oparational
activities. This concern will be communicated to the licensee by NRC
RI management.
The adequacy of licensee management overview (i.e. audits, etc.) of
preoperational testing activities and the readiness of the plant for
initial OL activities will be reviewed during a subsequent NRC-RI
Inspection.
(IFI 387/82-09-28).
4.2 Quality Control
4.2.1
References
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Regulatory Guide 1.33, Rev. 2, " Quality Assurance
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Program Requirements (Operation)", February,1978
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ANSI N 18.7 - 1976, " Administrative Controls and Quality
Assurance for the Operational Phase of Nuclear Power
Plants"
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ANSI N 45.2.6 - 1978, " Qualifications of Inspection,
Examination, and Testing Personnel ... of Nuclear Power
Plants"
4.2.2
Program Review
The inspector reviewed the quality control program, as
described in the following licensee administrative documents.
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OPS-14, Control of Inspection and Testing, Rev. 1,
April 1, 1982
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NQAP 11.1, Quality Control Program, Rev. O, January 18,
1982
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QCP-10, Training, Qualification, and Certification of
Inspection and Test Personnel, Rev. O, April 28, 1981
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QCP-20, Inspection of Maintenance,-Modifications, and
Testing Activities, Rev. O, November 8, 1981
QCP-21, Establishing Inspection Points, Rev. O, November
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8, 1981
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QCP-50, Quality Control Checklists, Rev. O, June 8,
1981.
4.2.3
Implementation
The inspector reviewed the implementation of the audit
program in the following areas:
-- . Organization Chart of NQA-Quality Control;
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1982 QC Inspection Log;
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1982 QC Call Number Log; and,
Quality Control Inspection Reports (QCIR's), including
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QCIR's #82-982, 82-1098, 82-1101, 82-1123, 82-1124
During the review of the quality control program, the inspector
verified the following.
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Inspections are performed by qualified inspectors who
are independent of the work being inspected
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The inspectors are notified of the work being performed
(e.g., hold points, notification points, sign-off on
work authorizations, etc.) and the inspectors utilize
importance to safety as a criteria in evaluating which
inspections to perform
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The inspections utilize a checklist or procedure covering
the areas inspected to ensure a thorough inspection
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Deficiencies identified during inspection are formally
entered into a non-conformance/ corrective action system
and tracked until resolution
4.2.4
Findings
The inspector found no violations or open items relative to
Quality Control.
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5.
Design Changes, Modifications, Tests and Experiments
5.1 References
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ANSI N45.2.8 - 1975, Mechanical Installation, Inspection and
Testing
-- ~ ANSI N18.7 - 1976, Administrative Controls and Operational QA
--
--
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Proposed Technical Specifications
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FSAR Sections 13 and 17
5.2 Program Review
The inspector reviewed the licensee's programs for design changes,
facility modifications, and conduct of tests and experiments to verify
the following
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Required QA programs have been developed in accordance with the
regulatory requirements, industry standards and licensee's commit-
ments
-. Procedures have been established for control of design changes,
modifications, and tests and experiments
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Appropriate responsibilities have been established and assigned
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Administrative controls have been established to preclude unautho-
rized activities; assure prompt recall of obsolete documents; and
facilitate distribution of approved documents
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Administrative control procedures have been established to revise
the plant procedures, the training program and the facility
drawings as necessary to reflect any facility changes as described
in this section
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Proper communication channels have been established among partici-
pating organizations
Provisions have been established to transfer the records to the
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records storage facility
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Provisions have been established to assure that activities are
conducted using approved procedures, whenever applicable
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Post implementation testing and acceptance criteria are established
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Responsibility and the method for reporting activities to the
Nuclear Regulatory Commission have been established
The following documents were reviewed to assure the program complies
with the above requirements.
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OPS-9, Control of modifications and design activities, Rev. 0
NDI-QA-2.2.3, Design Responsibility Delegation (Draft)
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NDI-QA-14.2.2, Safety Evlauations, Rev. 0
DC 010.0, Review Verification and approved of design documents
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Rev. 0
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DC 040, Design Change Mechanism, Rev. 0
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DC 110.0, Design calculation control, Rev. 0
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AD-QA-410, Plant Modification program, Rev. 1
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AD-QA-411, Plant modification design control, Rev. 1
5.3 Implementation
The programs discussed in this Section are not required until the
facility license is issued.
Currently, programs for design changes,
modifications, and tests and experiments are conducted for the licensee
by the Architect Engineer.
The licensee representatives advised the
inspector that licensee personnel have not completed any safety related
activity covered by the programs discussed in this section. However
at the time of the inspection, several projects were in progress in
this area and the licensee intends to use these activities to determine
the effectiveness of established procedures and administrative controls.
The licensee representatives discussed their on going projects with
the inspector and demonstrated how the applicable portions of the
program were implemented for these projects.
5.4 Findings
5.4.1
The licensee has no specific procedures that address the
conduct of Tests and Experiments under the provisions of 10 CFR 50.59.
During discussions with corporate and plant
staff, the inspector learned that the licensee intends to
conduct these tests and experiments under the provisions of
procedure AD-QA-101, Procedure Program. The inspector
stated that additional guidance and instructions needed to
be developed to aid individuals in performing tests and
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experiments prior.to the issuance of the Operating License
and the licensee acknowledged the inspectors statement. The
effectiveness of the licensee's tests and experiments program
will be followed in future NRC:RI inspections.
(IFI 50-
387/82-09-03).
5.4.2
The procedure for delegating design responsibilities had not
been issued prior to the completion of this inspection. The
licensee's representative told the inspector that the required
procedure was being drafted and it would be issued prior to
the issuance of the Operating License.
The licensee's
design change and modification program allows both the
corporate and plant staff to perform the modifications.
The plant staff told the inspector that limitations in
manpower, expertise and other resources would allow them to
undertake only relatively simple design modifications.
The
inspector stated that the scope of the modifications carried
out by the plant staff should be well defined; the plant
procedures should be adequate to perform the delegated
responsibility; and, the plant staff should be adequately
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trained to perform the delegated responsibility. The licensee
representatives told the inspector that the above items
would be completed prior to delegating any design respon-
sibility to the plant staff. This will be followed in a
future NRC:RI inspection (s).
(IFI 50-387/82-09-04)
5.4.3
As noted in Section 5.3 above, the licensee has not yet
completed a safety related project using established pro-
cedures. The inspector discussed the need for management
controls (Management review. QA review, verification by the
Independent Safety Assessmt ,t Group, etc.) of the projects
during the trial use of the procedures, to assess the effective-
ness of the program and to implement corrective actions.
The licenste representatives agreed to institute the necessary
management controls.
The effectiveness of these actions
will be followed in future NRC:RI inspections (IFI 50-
387/82-09-05)
Except for the weaknesses cited above, the licensee's programs
for design changes, modifications, and tests and experiments
appear to meet the requirements of the references listed in
Section 5.1 above.
6.
Maintenance Programs
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6.1 References
,
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ANSI N18.7 - 1976, Administrative Controls and Operational QA
. - .
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11.
ANSI N45.2.6 - 1973, Qualifications of Inspection, Examination,
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and Testing Personnel
AN5I N45.2.1 - 1973, Cleaning Fluid Systems and Components
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Proposed Technical Specifications
--
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Section 13 and 17 of the FSAR
6.2 Program Review
The inspector reviewed the licensee's maintenance program to verify
the following.
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Written procedures have been established for initiating requests
for routine and emergency maintenance
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Criteria and responsibilities have been established for review
and approval of all maintenance requests
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Criteria and responsibilities have been established to identify-
safety and non-safety related maintenance activities
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Criteria and responsibilities have been established for verifying
work classification and the use of industry accepted procedures
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Criteria and responsibilities have been established for designating
hold points and for performing work inspections
Administrative controls have been established to prepare, assemble,
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review and store the maintenance records
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A preventive maintenance and a corrective maintenance program
have been established
A program has been established to review the corrective maintenance
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program, to assess the adequacy of the preventive maintenance
program, to identify repetitive failures of parts and components
and to identify design deficiencies
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Work control procedures have been established for special process,
fire protection, radiation protection, physical security, clean-
liness and housekeeping
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Provisions have been established for the Coordination of maintenance
activities and interface controls among participating organization
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Methods and responsibilities for equipment control have been
established
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Personnel are trained and qualified to perform maintenance
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The inspector reviewed the following documents to assure that the
requirements of the references cited in section 6.1 above are met.
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OPS-13, Maintenance, Installation of modifications and related
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activities, Rev. 0
AD-QA-500, Conduct of Maintenance, Rev. 0
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AD-QA-502, Work Authorization System, Rev. 2
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AD-QA-503, Housekeeping / Cleanliness, Rev. 1
AD-QA-520, Station Welding Program, Rev. 0
--
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AD-QA-521, Brazing and Iiller Metal Control, Rev. 0
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AD-00-540, Computerized Preventive Maintenance System (Draft),
Rev.
AD-00-504, Preventive Maintenance Program Prior to Full Load,
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Rev. 0
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NDI-14.1.2,, Work Process Maintenance, Rev.
OPS-13, Maintenance, Installation of Modifications and Related
--
Activities, Rev. 0
--
MT-GE-001, Motor Inspection and Maintenance, Rev. 0
MT-GE-011, Chiller Maintenance and Inspection, Rev. 0
--
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MT-GE-013, 480 kV Load Center Inspection and Breaker Maintenance,
Rev. 0
MT-GE-015, Advanced Control Room (ACR) Electrical Maintenance,
--
Rev. 0
MT-64-003, Recirculation Pump Seal Removal and Replacement, Rev.
--
1
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MT-64-004, Reactor Recirculating Pump Seal Rebuild and Test, Rev.
2
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MT-62-007, Steam Dryer Removal and Installation, Rev.1
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MT-53-001, Standby liquid Control Pump Disassembly and Reassembly,
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Rev. 1
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MT-49-001, RHR Pump Disassembly and Reassembly, Rev. 1
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IC-DC-100, Transmitter / Converted Calibration / Calibration Check
Procedure, Rev. 2
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IC-DC-200, Indicator / Receiver Calibration / Calibration Check
Procedure, Rev. 1
--
IC-DC-400, Switch / Bistable / Calibration / Calibration Check Procedure,
Rev. 1
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IC-DC-600,-Temperature Element and Wiring Check Procedure, Rev. 1
6.3 Implementation
The inspector reviewed maintenance activities authorized under the
following Work Authorizations to assess the effectiveness of the
program implementation.
--
U-14666 - Investigate and Rework RBCCW Pump for high vibration
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U-14649 - Clean and Inspect 024 Standby Diesel Generator
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P-10940 - Preventive Maintenance for the control structure emergency
supply fan.
U-27120 - Maintenance for FT 01109 A&B transmitter system
--
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U-27071 - Check control loop of HPCI
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U-27075 - Wiring change to APRM/RBM channels
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U-27175 - RHR Sample line repair
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U-24300 - Adjust valve position indicator for HV-1F020 (15112)
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U-24225 - HPCI Turbine Exhaust check valve maintenance
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U-24251 - Removal of drywell head
U-24291 - Gas leak replacement for valves on ADS, MSRV air header
--
6.4 Findings
6.4.1
The inspector noted that the licensee has not establisNd
the required procedures to implement planning and scheduling
of maintenance as described in Section 5.2 of OPS-13. The
licensee representatives told the inspector that the planning
and scheduling of maintenance activities would be the respon-
sibility of the Unit Co-ordinator; and, the Unit Coordinator's
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procedures were being developed to address safety consequences,
co-ordination, interface control among participating organi-
zations, and methods of acquiring resources for maintenance
activities.
The inspector told the licensee that the effective-
ness of the Unit Coordinator's procedures for planning and
scheduling of Safety-Related maintenance activities would be
followed it, future NRC:RI: inspections and the licensee
acknowledged the inspector's statement.
(IFI 387/82-09-06)
6.4.2
The inspector noted that the licensee's maintenance procedures
do not address the fire protection requirements adequately.
The licensee representatives informed the inspector that
they were finalizing the fire protection program for the
facility; and upon issuance of the fire protection program
the maintenance procedures would be revised to include
requirements for a fire watch, control of combustibles and
other fire protection aspects.
The inspector informed the licensee's representative that
this item would be followed in a future NRC:RI inspection
and the licensee's representative acknowledged the inspector's
statement.
(IFI 387/80-09-07)
6.4.3
The inspector noted that the program to review, approve and
adopt vendor documents for maintenance activities have not
been completed. The inspector told the licensee's repre-
sentative thit the completion of the review and approval of
Vendor documents under the "IOM Program" would be followed
.
during a future NRC:RI inspection and the licensee's repre-
sentative acknowledged the inspector's statement.
(IFI
387/82-09-08)
6.4.4
The inspector noted that the procedure for Work Authorization
(AD-QA-502) did not provide measures to verify classification
of maintenance activities as safety-related or non-safety
related. The inspector identified this concern to the
licensee representatives.
Prior to the conclusion of the
inspection the licensee representatives issued Temporary
Change No.82-084 to Procedure No. AD-QA-502 to incorporate
a means for verification of the above Work Classification.
The inspector told the licensee's representative that the
effectiveness of the licensee's actions, including the above
temporary change, would be followed in a future NRC:RI
inspection and the licensee's representative acknowledged
the Inspector's statement.
(IFI 387/82-09-09)
6.4.5
The inspector noted that the procedure for trending and
corrective actions, AD-QA-541, was being developed. The
inspector told the licensee's representative that the issuance
and implementation of AD-QA-541 would be followed in a
i
1
15
future NRC:RI inspection and the licensee's representative
acknowledged the inspector's statement.
(IFI 387/82-09-10)
\\
6.4.6
The inspector noted that the licensee conducted two audits
-
in the maintenance area in 1981. The first audit, No. 0-11,
was closed out on January 14, 1982. One of the findings,
III.A.2, of the second audit (No. 0-21, completed on August
5, 1931) was not resolved at the time of the inspection.
The inspector noted that the corrective action response was
repeatedly granted extensions.
Subsequent to the inspector's
discussions with licensee representatives and prior to the
conclusion of the inspection, the maintenance department
responded to the unresolved item. Closure of this item and
the effectiveness of the licensee's management control
program in the audit area will be followed in future NRC:RI
inspections.
(IFI 387/82-09-11).
6.4.7
In the areas discussed in Section 5 and 6 of this report,
the inspector noticed a lack of communication between the
corporate office and the plant, and between levels of manage-
ment at each establishment. The inspector discussed this
matter with the Plant Superintendent and the Vice President
of Operations. These licensee representatives acknowledged
the inspector's statements and stated that licensee management
was aware of this concern and were diligently pursuing a
means to improve communications. The inspector had no
1
further questions.
6.4'.8
Other than the weaknesses cited above, the inspector found
the licensee's maintenance program to be in compliance with
the requirements of the documents stated in Section 6.1
above.
7.
Plant Surveillance Testing and Calibration Program
7.1 References
--
Technical Specifications (Proposed), Sections 4 and 6
--
Regulatory Guide 1.33-1978, Quality Assurance Program Requirements
(Operation)
ANSI N18.7-1976, Administrative Controls and Quality Assurance
--
for ... Nuclear Power Plants
--
SSES Quality Assurance Manual (QAM), SP-3, Control of Testing and
Inspection activities, Rev. 2, September 26, 1980
~
16
SSES QAM, Procedure 12.0, Test control, Rev. 5, August 28, 1981
--
AD-QA-422, Surveillance Test Program, (Not Issued)
--
AD-TY-602, I&C Surveillance Draft Procedure Verification Program,
--
Rev. O, August 6, 1981
AD-QA-605, Maintenance and Calibration of Installed Plant Instru-
--
meatation, Rev. O, December 21, 1981
7.2 Program Review
The inspector reviewed the program for surveillance tests, calibrations,
calibration checks, and instrument functional tests required by the
Technical Specifications; and calibration of plant installed instru-
mentation which are used to verify satisfactory performance of Technical
Specification Surveillance Testing or Inservice Testing (Pumps and
Valves).
The program and its administrative procedures were inspected
for conformance to the above referenced requirements. The following
areas were verified.
--
A master schedule has been established for surveillance and.
calibration testing
--
Responsibilities have been assigned for performance of tests and
to assure that test schedules are satisfied
--
Methods and responsibilities have been established for review and
evaluation of data, for reporting deficiencies and failures, and
for verification that LCO requirements have been satisfied
Adequate manpower was available to perform required testing
--
--
Interfaces with other organizations were defined
--
Responsibilities for training and qualification of test personnel
were defined
Implementing procedures for performance of tests have been esta-
--
blished
7.3 Implementation Review
The program as defined in paragraph 7.2 has not been completely
implemented.
Implementing surveillance operating procedures issued, were
i
reviewed. The results of this review is further detailed
in paragraph 16.
1
17
s
7,4 Findings
7.4.1
The licensee has established a program for calibration
of "Q" system instruments. Calibration frequencies are
determined by I&C personnel and data sheets are approved by
the I&C supervisor. The inspector informed the licensee
that ANSI N18.7-1976, Paragraph 5.2.8, requires that control
procedures be instituted for safety related components to
assure timely surveillance tests and appropriate documentation,
reporting, and evaluation of their results. Moreover, pro-
cedures are required for calibration of plant installed
instruments used to verify operability of components identified
in the Technical Specifications or Inservice Test Program.
Additionally, these procedures and the established frequency
of calibration must be reviewed by the PORC and approved by
the Station Superintendent as required by the Technical
Specifications.
The licensee's representative stated that appropriate pro-
cedures would be prepared and approved for the calibration
of plant installed instruments used to verify Technical
Specification Surveillances and Inservice Tests.
This item is required by OL and is open pending completion
of-licensee action and subsequent NRC:RI inspection.
(IFI
387/82-09-12)
8.
Plant Test and Measurement Equipment Calibration and Control Program
8.1 References
Technical Specifications (Proposed), Section 6
--
--
Regulatory Guide 1.33-1978, Quality Assurance Program Requirements
(Operation)
--
ANSI N18.7-1976, Administrative Controls and Quality Assurance
for ... Nuclear Power Plants
--
ANSI N45.2.4-1972, Installation, Inspection and Testing Requirements
for Instrumentation . . . of Nuclear Power . . . Stations
SESQAM, Procedure 13.0, Control of Measuring and Test Equipment,
--
Rev. 5
8.1.6 AD-QA-615, Control and Calibration of Plant Measuring and
--
Test Equipment, Rev. O, February 3, 1982.
.
}
l
1
18
8.2 Program Review
The adequacy of the program for calibration and control of test and
measurement equipment was inspected. The program and its administrative
procedure (reference 8.1.6) were examined for conformance to the' above
referenced requirements.
The following areas _were verified to be
established:
--
Responsibilities for control of test equipment
Maintenance of a master test equipment list
--
--
A calibration schedule
8.3
Implementation Review
Implementation of the test and measurement equipment program was
reviewed for conformance to the referenced requirements in paragraph-
8.1.
The following areas were verified.
--
Calibration schedule was adhered to
--
Test equipment was in calibration when in use
--
Calibration data was adequate, accurate and within specified
tolerances
--
Standards used for calibration of test equipment are traceable to
the National Bureau of Standards or other testing organization
--
Test equipment custody control records were adequate
--
Storage and labeling of test equipment was proper
--
Primary standardr used for test equipment calibration were in
calibration
--
Usage was traceable for out of calibration test equipment
8.4 Findings
8.4.1
The inspector observed that IC-227 (Mensor Mecury Manometer
Controller) was used to calibrate IC-247 (Absolute Pressure
Gage) on September 23, 1981; and IC-116 (Dead Weight Tester)
was used to calibrate IC-275 (Torque Wrench) on September 9,
1981.
In each instance the useage logs for IC-227 and IC-
,
!
116 did not reflect the respective calibrations of IC-247
'
and IC-275. These appeared to be isolated cases and not
i
part of a general problem.
,
t
19
The licensee's_ representative stated that all records would
be reviewed against usage logs for the latest calibration
period for each piece of test equipment used to calibrate
other pieces of test equipment to ensure accuracy. Addition-
ally, usage logs for test equipment used by the Calibration
Laboratory would be transferred from the I&C Shop to the
Calibration Laboratory.
Further, clerical personnel would
be provided to maintain the logs. The inspector had no
further questions concerning this matter.
9.
Review Committees
9.1 References
(TS) Sections 6.2.3, 6.5.1 and 6.5.2
--
Proposed TS Sections 6.2.3 and 6.5.3
--
Regulatory Guide 1.33, Rev. 2 and ANSI N18.7-1976, Administrative
--
Controls and Operational QA
NUREG-0737, Clarification of TMI Action Plan Requirements, Item
--
I.B.1.2
SECY-80-242, Independent Safety and Engineering Group, May 6,
--
1980
FSAR Section 13.4.3
--
9.2 Onsite Review Committee
9.2.1
Program Review
Written procedures addressing the Plant Operations Review
Committee (PORC) activities were reviewed to verify that
administrative controls have been established for:
--
Independent review authority and responsibility
--
Manner by which TS Section 6 reviews will be accomplished
--
Membership, alternate member, and quorum requirements
--
Meeting frequency, maintenance and distribution of
minutes / records
--
Lines of communication and interface with other groups
such as the offsite review committee
l
20
Procedures reviewed were:
Nuclear Department Instruction (NDI) - 1.4.2, Charter-
--
Plant Operations Review Committee, Rev. 0
--
NDI-QA-2.1.3, Nuclear Department Open Items Tracking,
Rev. 1
AD-QA-101, Procedure Program, Rev. 4 with temporary
---
changes82-046, 048 and 049, and a draft revision
--
AD-QA-102, Plant Operations Review Committee, Rev. 2
and a draft revision
--
AD-QA-130, Open Items Tracking, Rev. 0
9.2.2
Findings
The committee has been established; procedures addressing
committee activities have been developed; and the committee
is functioning with respect to its current responsibilities.
The inspector reviewed a number of meeting minutes, interviewed
the chairman and another member, and determined the committee
is fulfilling its current responsibilities other than the
examples discussed in IE Inspection Reports 50-387/81-24 and
82-08.
The applicant was aware that a significant increase in the
demand on each member's time will occur as review responsi-
bilities become greater.
Therefore an alternate approach to
procedure review has been developed and is described in a
proposed change to the TS.
Should the proposed TS change be
approved by the NRC the applicant has revised applicable
procedures which are being held in a final draft form for
expeditious review and approval if and when needed.
The
inspector reviewed the draft procedures and determined that
the alternate review could be implemented with a minimum
amount of effort and time.
I
No violations or concerns were identified.
9.3 Offsite Review Committee
!
!
9.3.1
Program Review
Written procedures addressing the Safety Review Committee
(SRC) activities were reviewed to verify that administrative
controls have been established for:
l
.
21
Independent review and audit authority and responsibility
--
Manner by which TS Section 6 reviews and audits will be
--
accomplished
Membership, alternate member, and quorum requirements
--
--
Meeting frequency, maintenance and distribution of
minutes / records
Lines of communication and interface with other groups
--
such as the onsite review committee
Procedures reviewed were:
--
Nuclear Department Instruction (NDI) - QA-1.4.4, Charter-
Susquehanna Review Committee, Rev. 1
NDI-QA-2.1.3, Nuclear Department Open Items Tracking,
--
Rev. 1
--
AP-001-001, SRC Rules of Conduct, Rev. 0
--
AP-002-001, SRC Review Procedure, Rev. 0
9.3.2
Findings
Procedures detailing committee activities have been esta-
blished; meetings have been held since May, 1981; the committee
has been appointed and is functioning relative to its present
level of responsibilities. The inspector reviewed a number
of meeting minutes and other records and noted that the
committee has conducted meetings on an almost monthly
basis. The SRC discussed / reviewed subjects such as:
the
annual QA audit schedule; documents that will be reviewed;
establishment of two standing subcommittees; manner in which
reviews are to be accomplished; NRC inspection reports,
including those of PAB on other utilities; Cooperative
Utility Management audit reports; and, internal audit reports.
The two sub-committees have been established and have conducted
meetings. One sub-committee intends to tour the site annually
while the other plans two annual visits. Based on document
reviews and an interview with the chairman and secretary of
tile committee the inspector determined that the committee
should fulfill its increased responsibilities as they occur.
A concern with respect to review of QA audits is addressed
in paragraph 15.4.1.
.
i
22
No violations or other concerns were identified.
9.4 Nuclear Safety Assessment Group (NSAG)
9.4.2
Program Review
The Nuclear Safety Assessment Group (NSAG) program described
in the following licensee administrative documents was
reviewed.
NDI-9.1.1, " Charter - Nuclear Safety Assessment Group",
--
Rev. O, November 11, 1980
--
Nuclear Safety Assessment Procedure NSAG-1, Rev. O,
January 4, 1982
The program consists of five dedicated engineers responsible
for independently assessing the effectiveness and quality of
the licensee's nuclear operations and related safety and
environinental programs. The NSAG is structured to have
three on-site engineers, two corporate office engineers, and
a corporate office manager reporting directly to the Senior
V.P.-Nuclear.
9.4.3
Implementation
The inspector reviewed the following areas to ascertain the
effectiveness and compliance of NSAG.
--
Organization Chart, January 1, 1982
--
Qualifications of assigned personnel
--
NSAG Project Report 1-81, September 30, 1981, Circulating
Water Pump House Flooding
--
NSAG Project Report 2-81, November 17, 1981, Potential
Safety Hazard Due to Gas Line
NSAG Project Report 1-82, January 19, 1982, Failure to
--
Trip Remotely of Circulating Water Pump
--
Follow-up actions resulting from the above NSAG Project
Reports
9.4.4
Findings
The inspector's findings are discussed below.
i
l
23
9.4.4.1
The Technical Specification requires the NSAG to be composed
of "five dedicated, full-time engineers." Currently NSAG
has three engineers plus one manager; there are two assigned
positions (one onsite and one offsite) that are unfilled.
Before issuance of an operating license, the licensee must
staff NSAG to meet the Technical Specifications. This item
(IFI 387/82-09-13) will be reviewed during a subsequent NRC
inspection.
9.4.4.2
To maximize NSAG effectiveness in evaluating nuclear
safety, NSAG should evaluate nuclear safety issues from many
sources.
However, there is no established program to inform
all Nuclear Department personnel of the NSAG and their
ability to assess the safety of licensee nuclear operations.
The licensee should establish 1) policy for referal of
nuclear safety employee concerns to NSAG, including anonymous
reporting of such concerns, and ; a continuing means (e.g.,
procedures, employee training, employee publications, etc.)
to inform licensee personnel of this policy.
This item (IFI
387/82-09-14) will be reviewed during a subsequent NRC
inspection.
9.4.4.3
Section 6.4 of NSAO-1 describes follow-up action on NSAG
Project Report recommendations, including issuing Open Items
in the Nuclear Department Open Items system. The inspector
found:
--
NSAG Project Report 1-81 recommended to the Vice President-
Operations that eight items be declared open items.
Contrary to this no open items were declared.
The
eight items were resolved and documented in a memo by
the Plant Superintendent in a timely manner.
--
On NSAG Project Report 1-82, the V.P.-Operations, at
NSAG suggestion, requested the Plant Superintendent to
respond to NSAG recommendations by February 12, 1982.
On April 1, 1982, no response had been made and no open
items had been issued.
The above examples demonstrate the absence of an effective
tracking system to provide follow-up action on NSAG recommenda-
tions.
The licensee should establish an effective tracking
system and specify it in administrative procedures.
This
item (IFI 387/82-09-15) will be reviewed during a subsequent
NRC inspection.
__.
.
.
I
.
24
10. Non-Licensed Training
10.1 References
--
Proposed Technical Specifications Section 6.2
Regulatory Guide (RG) 1.8, Rev. I and ANS 3.1-1978, Personnel
--
Selection and Training-
RG 1.33, Rev. 2 and ANSI N18.7-1976, Administrative Controls'and
--
Operational QA
--
RG 1.58, Rev. 1 and ANSI N45.2.6-1978, Qualifications of Inspection,
Examination and Testing Personnel
FSAR Section 17.2
--
10.2 Program Review
Selected por+ ions of the written' training program were reviewed to
verify con
'ency with the above requirements in the following areas.
--
General Employee training / indoctrination (GET) in subjects such
as quality assurance, emergency plan, administrative controls,
radiological. safety and prenatal exposure, controlled access and
security, and fire / industrial safety
Formal and on-the-job (0JT) training for personnel such as crafts-
--
men, technicians, QA/QC, engineers, operators and other plant
support workers
--
Qualification / certification of personnel as applicable
--
Guicclines such as job analyses, testing methods and position
descriptions for use in determining an individuals qualifications
and supplementary training needs
--
Facility equipment such as workshops, classrooms, lesson plans,
course material, and visual aids (including mock-ups, items and
'
parts similar to those in plant, etc.)
--
Delineation of training organization, assignment of responsibilities
i
and identification of objectives
i
--
Training of instructors, training program evaluation and making
of needed change, and management involvement
Documentation of training and retention of required records
--
i
,
I
i
/
'
.
..
_ _ . -
_
-,
. . _ . .
. . _ .
25
Staffing and qualifications of selected training department'
--
personnel
The inspector toured the on-site Nuclear Training Center and the
corporate Training and Development Center; interviewed management,
supervision and instructors; and, reviewed the following documents and
procedures.
--
Training records of five I&C technicians, four QA auditors, four
QC inspectors, seven maintenance craftsmen, and nine plant operators
--
OJT records for several on-site warehouse employees
--
Curriculum Committee Report-Electrical Maintenance
Job Analyses for Supervisor of Maintenance, Maintenance Foreman,
--
Mechanic, and Nuclear Quality Assurance
--
Indices of required and recommended training courses for various
selected positions
--
Nuclear Training Manual (selected portions)
--
Nuclear Department Instruction (NDI)-QA-10.8.1, Nuclear Department
Qualification and Training, Rev. 1
--
NDI-10.1.7, Verification of. Applicant's Qualifications and
. Experience, Rev. 0
NDI-QA-4.1.5, Curriculum Planning, Rev. 0
--
NDI-QA-4.1.4, Instructor Certification, Rev. 0
--
10.3 Findings
The Susquehanna Training Center has developed a series of procedures
detailing their activities and the training program has been implemented.
The classrooms are well lighted, equipped and sound insulated. Several
trailer rooms are being equipped with items such as pump shaft alignment
fixtures, valves, and relays for hands-on training of crafts and
trades people. An effort to obtain items similar to in plant equipment
is evident.
The training staff appears to be qualified and adequate
for the current level of training effort. A licensee representative
stated that the one unfilled instructor position is due to be filled
in the near future.
During the exit interview the inspector stated
i
that requests for additional equipment for craft / trade training should
receive management support because this would enhance this aspect of
training. The inspector also stated that the overall level of training
i
effort will increase in the future.
Licensee management acknowledged
i
both statements.
!
,
_-
-
-
26
Lesson Plans have been developed and the inspector noted evidence that
they are being used.
The mechanical maintenance and GET Lesson Plans
that were sampled for review appeared adequate for their intended
purpose. The inspector noted that Job Evaluations have been developed
for positions in areas such as Maintenance, Operations, Nuclear Quality
Assurance, In Service Group, Instruments and Controls, Health Physics,
Nuclear Safety Assessment Group, Construction, Nuclear Training Group,
and Technical.
Indices of required and recommended training courses
for specific positions have been developed for approximately fifty
percent of the plant staff. The development of the remainder is
ongoing.
Supervisors and management are to use the indices' guidance
to determine any supplementary training needs of an individual.
The
inspector noted evidence that these determinations and evaluations are
being accomplished.
The Supervisor-Technical Training stated that the
remaining training indices are scheduled to be completed in the near
future so that any identified needed training can be completed prior
to fuel load.
During a subsequent interview the inspector learned
that licensee management had directed this same individual to concentrate
full time effort on completing the remaining indices. This is evidence.
of continued management support in this area.
The corporate Training and Development Center provides support company
wide in the areas of educational services, management development,
supervisor training, training design, and craft / trade training for
conventional power stations. These facilities provided well equipped
workshops, classrooms, and visual aids.
The inspector noted that the
capability existed for producing TV training tapes. The center was
fully staffed and four individuals who were interviewed appeared well
qualified for their positions.
No violations or concerns were identified.
11. QA Record Program
11.1 References
--
Proposed Technical Specifications, Section 6 Administrative
Controls
--
Final Safety Analysis Report (FSAR), Section 17.2.17
--
ANSI N45.2.9-1974, Requirements for Collection, Storage, and
Maintenance of Quality Assurance Records for Nuclear Power Plants
--
Regulatory Guide 1.88, Rev. 2
--
ANSI N18.7-1976, Administrative controls and quality assurance
for the operational phase of nuclear power plants
-
27
--
ANSI N45.2-1977 Quality Assurance Program Requirements
11.2 Program Review
The licensee's QA program for records management was reviewed for
conformance with references in paragraph 11.1 for:
.
Requirements to maintain and retain Quality Assurance type records
--
--
Responsibilities are assigned to ensure QA records' identified
will be maintained;
--
Responsibilities are assigned and controls established to assure
transfer and retention of construction and preoperational phase
records;
--
Record storage controls are established which identify the record
storage facility, designated custodian (s) in-charge of storage
facilities, the filing system for record retrieval, a method for
verifying records received are in agreement with preestablished
checklists, access control to files and accountability maintained
when files are removed from storage, and a method for correcting
files and disposing of superceded records;
--
Responsibili. ties assigned to establish retention periods for
records not covered by the FSAR, Technical Specifications or 10
CFR; and,
,
Authority and respcnsibility for authorizing disposal of records
--
assigned.
Procedures reviewed were:
--
OPS-3, Control and Issuance of Documents, Rev. 1, April 1, 1981
--
OPS-8, The Collection, Storage and Maintenance of Quality Assurance
Records, Rev. 1, April 1, 1982
--
QA-18.1, Quality Assurance Records, Rev. 5, August 18, 1980
--
OPS-1, Operational Quality Assurance Program, Rev. 1, April 1,
1982
--
NDI-QA-1.1.2, Nuclear Department Instruction System, Rev. 3,
March 25, 1981
--
NDI-QA 1.2.1, Nuclear Department Correspondence Control, Rev. 1,
January 25, 1982
__
-
!
28
--
NDI-QA-1.2.2, Susquehanna SES Records Management System,-Rev. 0,-
-
December 23, 1981
NOI-QA-1.2.3, Organization and Administration of the Susquehanna
--
-SES Records Management System, Rev, 0, May 21, 1981
--
NDI-QA-1.1.3, Nuclear Department Open Item Tracking, Rev.1,-
March 31, 1981
--
Susquehanna SES Records Management System (SRMS) Manual, Procedures
P-1 through P-15, Index Rev. 10, March 10, 1982
--
AD-TY-193, Release of System from Test Status, Rev. O, January
18, 1982
--
IP-020.0, Engineering Turnover Documentation Procedure, Rev. 1,
February 1, 1982
--
AD 6.1, System / Component Turnover to PP&L, Rev. 9, November 16,
~
1981
--
System Power and Engineering Department, Correspondence File -
Procedure, February 5, 1982
--
RD 00-007, Receipt and Processing of System Turnover files from
ISG. December 15, 1981
11.3 Implementation
11.3.1
The inspector reviewed the following documents, records,
and instructions to verify implementation of established QA
records system.
SRMS Training Matrix (draft)
--
--
Records type list (draft)
--
Susquehanna SES QA document list, Rev. 10, December 14,
1981
--
SRMS work instructions (corporate office and site)
11.3.2
The inspector selectively sampled various QA records to
verify that the record:
--
Was listed on a records checklist or index;
--
Was readily retrievable from its designated file or
microfilm storage location as applicable;
l '<
,
,
.
.
,
,
, .
L
29
Was provided suitable protection and stored inifile
--
cabinets or container in a predetermined'lecation; and,
ll.
When received by Document Control Center, was processed
--
in accordance with the SRMS manual and work instructions.
The following record types were examined.
Various PP&L General Correspor.dence
--
,
--
SRMS personnel training records for three clerks and
one supervisor
Fi.ceen receipt inspection reports including,80-076,-- 80-284, 81-459 and 81-180
Twenty Work Authorizations including U 12078, E-80-A
--
and S 10156
,
--
Eight Procurement Documents (Purchase orders) including
500442, 500C23 and 500070
--
Audit SESS, Records Management System (May 1981) and
NGA Audit. SRMS (August 1981)
--
System Turnover Packages P2.1 125 Vdc Battery, P88.1
250 Vdc Battery, and P76.1 Leak Detection System
^
Various plant procedures and manuals
--
11.3.3
The inspector toured the licensee's document control centers
(DCC) both at the site and corporate office to verify that
file room access was being controlled, microfilming and
record processing was being performed as described in work
instructions, and records were being transmitted to the DCC
with the required transmittal forms.
In addition interviews were conducted with record management
system supervisors and personnt.1 to determine if the current
staffing level and training was adequate.
11.4 Findings
No violations were identified, however the following minor deficiencies
were identified by the inspector.
11.4.1
FSAR Table 17.2-1 commits the licensee to full compliance
with ANSI N45.2.9-1974, " Requirements for Collection Storage,
and Maintenance of Quality Assurance Records for Nuclear
Power Plants."
ANSI N45.2.9, Section 5.6, states that QA
. .
-
1
30
records discussed in the standard should be afforded the
equivalent protection of a NFPA Class A, four hour minimum
rated facility.
Currently the licensee does not have an approved storage
facility onsite or at the corporate office. Without approved
storage facilities, completed Q.A. records, transmitted to
the Document Control Center for interior storage prior to
microfilming, duplication, and distribution are not provided
adequate fire protection.
This records storage problem was previously identified in
SESS QA audits performed on the Records Management System in
-'
May 1981 at the site and August 1981 at the. corporate office.
The following corrective action has been planned or is
ongoing as a result of these audits.
--
A vault type room will be constructed in the new corporate
office complex scheduled for completion in the fall of
1982.
--
A vault type room will be construction at the site in
conjunction with the expansion of the Service and
Administration Building.
--
As an ir,terim measure the licensee is procuring approved
_
offsite storage for completed QA records and, archival
>
storage for aperture cards of design drawing and prints.
Additionally, microfilming of QA records is being
performed as soon as possible to reduce the time a QA
/
record must be stored without adequate fire protection.
,
The corrective action, as discussed above will be reviewed
during a subsequent inspection (IFI 387/82-09-16).
11.4.2
ANSI N45 2.9 Section 5.3 requires that storage procedures be
prepared and include the rules governing access to and
control of the files.
The inspector identified that access control to the QA
records file room at the site is not adequately defined.
Currently the licensee has several clerks working in the
file room and access into the rocm is controlled only by a
sign that allows access to " authorized personnel" only.
The licensee's representatives acknowledged the inspectors
concern and stated that:
'
.
31
The Document Control Center (DCC) and records file room
--
is to be relocated to the Service and Administration
Building in June 1982. This move will establish a
separate QA record file room; and,
The procedure for access control to the file room is to
--
be revised and issued concurrently with the planned DCC
move.
This item will be reviewed in a subsequent NRC:RI inspection
(IFI 387/82-09-17).
11.4.3
The inspector determined that no formal control exists for
Records Management System Work Instructions at the corporate
office. The existing work instructions do not have an index
and many pen and ink change are unofficially incorporated
into the work instructions.
The licensee's representatives' acknot:1 edged the inspectors
concern and stated that:
P.6., " Preparation, Review and Distribution of New or
--
Revised Susquehanna SES Records Management System
Procedures" would be revised to include adn,inistrative
control of work instructions or a new work instruction
would be developed to provide administrative control;
and,
~
All current work instruction would be reviewed and
--
reissued in accordance with the new procedure or instruc-
tion.
The inspector had no further questions in this area.
11.4.4
The inspector determined that Records Management System
(RMS) personnel both at the site and the corporate office
were receiving training, but that:
Only a draft instruction exists to delineate the
--
required training for RMS personnel at the corpprate
office; and
--
TM training matrix for RMS personnel at the corporate
office should be expanded to include QA/QC indoctrination.
The licensee's representative acknowledged the inspector's
concerns and stated that the draft work instruction and
training matrix would be revised to include QA/QC indoctrina-
tion and then be formally issued.
!
I
,
32
The inspector had no further questions in this area.
11.4.5
Through discussions with RMS supervisor staff and review
of current organizational charts the inspector determined
that the licensee is adequately staffed to effectively
manage the QA records program present workload.
4
The inspector also verified that the licensee had projected
future staff requirement for the growth of the QA records
program.
12. Document Control Program
12.1 References
Proposed Technical Specifications, Section 6, Administrative
--
Control
Final Safety Analysis Report (FSAR) Sections 17.2.5 and 17.2.6
--
1
ANSI N45.2-1977, Quality Assurance Program Requirements
--
ANSI N18.7-1976, Administrative Contrels and Operational Quality
--
Assurance for the Operational Phase of Waclear Power
--
Reg. Guide 1.33, Rev. 2, February 1978, Quality Assurance Program
Requirements
12.2 Program Review
.
The licensee's program for document control was reviewed to verify
that the program is consistent with the requirements of the references
in paragraph 12.1 above and to determine that the program:
3
Requires that current as-built drawings, including piping and
--
instrument drawings (P&ID's) be provided to the plant in a timely
manner;
--
Requires that proposed drawing changes and the revised drawings
receive the same level of management review required of the
original drawings;
4
--
Provides provisions for identifying and marking of drawings that
have outstanding revisions;
--
Establishes control of obsolete drawings;
--
Requires that discrepancies found between as-built drawings and
the as constructed facility are handled as design changes;
-
. .
!
E
33
l
Requires master indicies to be maintained for drawings, manuals,
--
technical specifications, procedures that indicate the current
revision; and,
Provides a mechanism for document issuance, distribution, use,
--
and periodic review.
I
The following procedures, which describe the administrativa controls
for document control were reviewed by the inspector.
OPS-3, Control and Issuance of Documents Rev.1, April 1,1982
--
OPS-4, Document Review, Rev. 1, April 1, 1982
--
NDI-QA-2.2.6, As-built Drawing Requirements, Rev. O, January 4,
--
1982
NDI-QA-8.1.3, Document Review, Rev. O, September 28, 1981
--
AD-QA-101, Procedure Program, Rev. 4, February 18, 1982
--
NQAP 1.1, Preparation and Control of NQA Section Procedures, Rev.
--
1, January 18, 1982
AD-QA-301, Operations Procedure Program, Rev. O, January 7, 1982
l
--
i
AD-QA-500, Conduct of Maintenance, Rev. O, January 6,1982
--
AD-QA-600 Conduct of Instrumentation Rev. O, February 1, 1982
--
l
12.3 Implementation
'
The following documents, indices, and instructions were reviewed to
verify implementation of the established document control program.
Mailing lists for controlled manuals at the corporate office
--
l
l
--
Open items tracking system (corporate office) for tracking procedure
review
l
!
I
Time Sharing Option (TS0) master indices for check-off-lists and
--
data sheets
--
TSO Control Manual list
--
Plant maintenance information system for procedure review tracking
Controlleo procedures master indices for administrative, maintenance,
--
operational surveillance and' operational procedures
34
Advanced Text Management System (ATMS)
--
Storage and Information Retrieval System (STAIRS)
--
Master drawing index and drawing " Stick File" indices
--
Document Control Work Instructions
--
Transmittal forms (SUSA-105) for index distribution
--
Drawings, procedures, manuals, check-off-lists (COL) and surveillance
data sheets were selectively sampled at the site to verify that con-
trolled copies were consistent with the Document Control Center (DCC)
master indices. The following controlled copy locations were checked.
Control room
procedures, COL's, data sheets, and drawing " stick
--
files"
Technical support center (TSC)
procedures, COL's, data sheets
--
and drawing " stick files"
Technical library
procedures and drawing '.' stick files"
--
Mechanical Maintenance Shop procedures, data sheets and drawing
--
" stick files"
--
Permit Office - drawing " stick files"
Document Control Center
procedures C0C's, and data sheets
--
At each location twenty or more administrative, operating, surveillance
maintenance procedures, operational procedure COL's, and P&ID's were
checked against the master indices.
Additionally, the inspector randomly sampled station procedures and
reviewed the Plant Maintenance Information System's (PMIS) weekly
activity worklist to verify completion of the required periodic procedure
review.
12.4 Findings
No violations were identified, however the following minor concerns
and inspector followup items were identified by the inspector.
12.4.1
Revision to controlled copies of manuals and procedures
are issued, distributed and entered by the DCC staff.
Ruisions to check off list (COL) and surveillance data
sheets are issued and distributed by the document control
staff to the applicable functional units.
The actual COL
and data sheet file updating is done by the functional unit
receiving the forms.
l
.
35
1
The inspector determined that revisions to COL's and Surveil-
lance Data Sheets were not all being issued from the DCC
with a transmittal, and the control room file of COL's and
Data sheets was not consistent with the DCC master indices.
The licensee's representative acknowledged the inspector's
finding and stated that:
--
All future revision to COL's and Data sheet would be
issued to the applicable functional units by transmittal;
and,
--
The control room's file of COL's and data sheets would
be completely maintained by the document control staff.
The inspector had no further questions in this area.
12.4.2
Each Functional Unit at the corporate office has issued
procedures.
In addition each unit has established a procedure
to control the writing, distribution, use, revision and
review of these procedures.
The inspector identified that the following corporate office
Functional Unit's procedures did not address a periodic
review as required by ANSI-N18.7 1976.
.
--
Susquehanna Records Management System
--
Nuclear Quality Assurance
--
Nuclear Licensing
--
Nuclear Engineering
The licensee's representatives acknowledged the inspector's
findings and stated that each Functional Unit procedure
would be revised to include a periodic review of their
procedures.
The corrective action as stated above will be reviewed
during a subsequent NRC:RI inspection (IFI 387/82-09-18).
13. Procurement
13.1 References
Regulatory Guide 1.123, Rev. I and ANSI N45.2.13-1976, QA for
--
Procurement of Items and Services
-
-
36
FSAR Section 17.2
--
13.2 Program Review
The written procurement control program was reviewed to verify that
,
administrative controls were established for:
--
The identification of items purchased; identification of tests
and/or special instructions, technical requirements and documenta-
tion to certify the item; assuring that the contractor / supplier
has implemented a QA program consistent with 10 CFR 50, Appendix
B, and where deemed appropriate by the licensee, access to the
supplier's plant or records for purposes of audit.
Accomplishment of an assignment of responsibilities for:
initiation
--
of procurement documents; review and approval of specifications
differing from the original design documents; review and approval
of procurements, including changes thereto; and, the designation
of quality classification of procured items.
Evaluation and approval of bidders / suppliers including assignment
--
of responsibilities for the following functions:
review / update
of the listing of approved suppliers; providing for rights of
access to supplier's facilities and records; and, maintenance of
records of suppliers qualifications and audit.
The following licensee administrative controls / procedures were reviewed.
~ Operational Policy Statement (OPS)-10, Procurement Control, Rev.
--
1 (a draft)
--
Nuclear Department Instruction (NDI)-QA-1.4.2, Procurement of
Quality Materials for SSES, Rev. 0
--
NDI-QA-1.4.3, Procurement of Services for Susquehanna SES, Rev. 0
--
NDI-QA-2.1.4, Production, Maintenance and Control of the Defective
Device List, Rev. B
NDI-QA-2.1.6, Identification, Evaluation, and Tracking of Class
--
IE Components requiring Environmental Qualification, Rev. 0
--
NDI-QA-15.3.2, Identification, Evaluation, and Tracking of Class
IE Components Requiring Environmental Qualification, Rev.1 (a
draft)
--
Plant procedure AD-QA-210, Procurement Control Activities, Rev. 0
--
Procurement Department procedure (PDN)-QA-2.1, Processing of
Orders Requisitioned by SSES Plant Staff, Rev. O
- _ _ _ _ _ _ _ - _ _ _ _ _ _ - .
_
_ _ _ _ __
._._
_ _ _ _
_ _ . _
_
_ _ _ _ .
_ _ _ _ _ _ .
37
PDN-QA-4.1, Approved Supplier Quality Listing Procedure, Rev. 0
--
Power Plant Engineering Nuclear Plant Procedure (PPENPP)-4,
--
Review of Requisitions for Quality Material, Rev. 3
13.3 Findings
Detailed procedures for procurement activities have been developed.
An oasite engineering group has been established and has been reviewing.
requisitions for spare parts.
Items, components, and sub-components
are evaluated as to their intended use and assigned a quality classifi-
cation.
Procedures identify procurment requirements for each classifi-
cation. The item identifier, its classification, procurement require-
ments, and stock inventory are entered into a computerized information
system. Applicable plant personnel have been trained in the retreival
of this information at variously located terminals.
The inspector
conducted an overview of spares purchasing and determined that engineer-
ing evaluations were done; ite 5, devices and sub-components were
classified as to the level of their intended use; this information was
entered into the information system; and, these activities were being
accomplished in accordance with the established procedures.
The
inspector also conducted a detailed review of the manner in which the
onsite engineering group evaluated and classified sub-components of
Limitorque Operators (spares) and identified no inadequacies.
The inspector discussed present and future levels of activities and
staffing with the group supervisor who stated that most spares have
already been purchased and management made a determination that future
activities could be accomplished with the current staffing level. The
inspector acknowledged the supervisor's statements and had no further
questions.
No violations or concerns were identified.
14. Receipt, Handling, and Storage
14.1 References
--
Final Safety Analysis Report (FSAR) Sections 17.2.7, 17.2.13 and
17.2.15
--
ANSI IN45.2-1977, Quality Assurance Program Requirements
--
ANSI N45.2.2-1972, Packaging, Shipping, Receiving, Storage and
l
Handling
!
--
ANSI N45.2.13-1976, Quality Assurance for the Procurement of
Items and Services
!
i
,
._n,_
-.
. - . , _ .
-
. - , - - . .
38
,
14.2 Program Review
The licensee's program for receipt, storage and handling of safety
related equipment and materials were reviewed to verify that the
program is consistent with the requirements of the references in
pagagraph 14.1 above and to determine that administrative controls
established:
Requirements for conducting receipt inspections on all incoming
--
safety related materials and equipment;
Requirements that materials and equipment be examined for confor-
--
mance with requirements specified on orginal procurement documents;
--
Provisions for identification of those materials and equipment
that can be accepted by only a " certification of quality" (C of
C);
Controls for acceptance of items including tagging / marking for
--
storage or immediate use;
Controls for nonconforming items which include:
--
Marking and segregating nonconforming items
.
'
Disposition of nonconforming items (reevaluate, rework,
.
repaired, or return)
Prohibiting use of nonconforming items
.
Documentation required of the noncomforming items
.
Notification of licensee audit group responsible for supplier
.
(vendor) evaluation documentation of nonconforming items;
Methods for conditional release of nonconforming items including
--
justification for use, documentation and authority for conditional
release;
Requirements for providing proper levels of storage and appropriate
--
environmental conditions;
Requirements for specifying storage controls including access,
--
identification, coverings, and preservatives;
Requirements for periodic inspections of the storage areas;
--
'
--
Requirements for specifying maintenance and care of items in
storage including shelf life;
!
-
. .
- _ .
-,
--.
-.-
,
39
Requirements for routine and special handling measures; and,
--
Controls for hoisting equipment.
--
The following procedures were reviewed to verify administrative controls
have been established.
--
OPS-10 Procurement Control, Rev. O, April 1, 1982
OPS-12, Administrative Control of Plant Operations Rev. 1, April
--
-1,
1982
OPS-17, Control of Plant Material, Rev. 1, April 1, 1982
--
--
OPS-5, Deficiency Control System, Rev. 1, April 1, 1982
--
NDI-QA-2.1.6, Identification, Evaluation, and Tracking of Class
IE Components Requiring Environmental Qualifications, Rev. O,
March 26, 1981
--
NDI-QA-2.4.2, Procurement of Quality Materials for SESS, Rev. O
November 17, 1980
--
NDI-QA-8.1.2, Reportable defects and noncompliance, Rev. 1,
October 19,,1982
--
AD-QA-200, Material Control Activities, Rev.1, February 3,1982
--
AD-TY-190, Preoperational Phase Housekeeping and Protection
Program for Safety Related Equipment, Rev. O, February 16, 1982
AD-QA-109, Nonconforman.ce Control Program, Rev. 0
--
--
NQAP 4.1, Procurement Document and Specification Review, Rev. O,
March 13, 1981
--
QCP-30, Receiving Inspections, Rev. O, May 27, 1981
--
QCP-31, Periodic Inspection of storage facilities, Rev. O December
23, 1981
--
Specification P1003, Technical Requirements for the procurement
of spare parts, Rev. B
14.3 Implementation
14.3.1
The inspector selectively sampled safety related materials
and equipment received on site to verify:
L
40
Receipt inspections were conducted in accordance with
--
administrative controls
Disposition of the item was in accordance with admini-
--
strative controls
Storage of items including packaging, presevatives,
--
covering and environmental conditions were in accordance
with manufacturers' recommendations
--
Tagging / marking allowed tracing the item back to procure-
ment documents, receipt documents and " quality certifi-
cation" documents
--
Nonconforming items were clearly marked ar.d segregated
from other safety related items
--
Documentation of nonconforming items was transmitted to
affected organization for them to determine final item
disposition
The following safety related items were selected for review.
--
Shaft Sleeve Catagory No. 8625, P. O. 500109, Receipt
--
Pump Gasket, Catalogue No. 1463, P. O. 500009, RIR 80-
075
--
Weld Rod, Catalogue No. 022005, P. O. 600170, RIR 81-
222
--
Fan, Catalogue No. 8645, P. O. 500085, RIR 81-114
--
Pivot Pins, Catalogue No. 22028, P. G. 500442, RIR 81-
073
--
Globe Valves, Catalogue No. 8164, P. O. 500070, RIR 80-
304
--
Bearings, Catalogue No. 1481, P. O. 900021, RIR 80-177
,
--
Impeller Keys, Catalogue No. 13231, P. O. 500213, RIR
l
81-459
l
l
14.3.2
The inspector reviewed the receipt inspection logs for
l
1980, 1981 and 1982 and selectively sampled Receipt Inspection
'
Reports (RIR) that contained nonconforming safety related
items to verify that:
.
y
, , -
--
- _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
'
41
The necessary actions were taken to resolve the existing
--
'
nonconformance; and,
--
Adequate resolution for final disposition of nonconforming
item was obtained.
The following receipt inspection reports were reviewed.
--
RIR 80-243 with nonconformance report (NCR)-80-311 and
Quality Assurance Action Request (QAAR) C-81-023
--
RIR 80-076 with NCR 80-301 and 80-106 and QAAR C-82-014
--
RIR 81-529 with NCR 81-723 and QAAR C-81-166
RIR-459 with QAAR C-82-029
--
--
RIR-81-160 with NCR 81-244
--
RIR 81-180 with QAAR C-81-044
14.3.3
The inspector accompanied licensee personnel during their
monthly inspection of the onsite warehouse to verify:
Controlled access to the PP&L storage area is maintained;
--
--
Cleanliness and good housekeeping practices are enforced;
--
Fire protection was commensurate within the type of
storage area and materials involved;
--
Food and associated items were not permitted;
--
The adequacy of material storage, including protective
coverings, coatings and preservatives;
--
Hazardous material segregation; and,
--
Clear identification of shelf life of applicable material.
14.3.4
The inspector interviewed the materials supervisor to determine
that the current staffing level as depicted in the plant's
organizational charts was adequate to effectively manage and
maintain the spare parts inventory program.
In addition the
inspector reviewed the training records of 2 stockmen and 2
quality control receipt inspector to verify that their
trainino conformed to the training matrix and was adequate
to perform their assigned tasks.
r
f
- _ _ - _ _ _ _ . _ -
- _ _ _ _ _ _ _ _ _ _ _ _ _ .
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _
._
._-
- -
42
14.4 Findings
No violations were identified, however the inspector identified that
work instructions were not being used in the Materials Section. The
materials personnel use administrative procedure AD-QA-200, Material
Control Activities, for all receipt, storage and handling activities.
The inspector expressed a concern that work instructions should be
used to provide more detailed instruction for stores personnel.
The licensee's representative acknowledge the inspector's concern and
stated that:
A draft work instruction index has been generated which identified
--
work instructions that are needed; and,
Work instruction will be written and issued.
--
The inspector had no further question in this area.
15. Audits
15.1 References
Technical Specification Section 6.5.2;
--
--
FSAR Chapter 17.2
Regulatory Guide 1.33, Rev. 2, Quality Assurance Program Require-
--
ments (Operation), February, 1978
--
ANSI N18.7-1976, Administrative Controls and Quality Assurance
for the Operational Phase of Nuclear Power Plants
ANSI N45.2.12-1977, Requirements for Auditing of Quality Assurance
--
Programs for Nuclear Power Plants
ANSI N45.2.23-1978, Qualification of Quality Assurance Program
--
i
Audit Personnel for Nuclear Power Plants
15.2 Program Review
The inspector reviewed the audit program as described in the following
licensee administrative documents.
--
OPS-7, Auditing and Surveillance Activities, Rev. 1, April 1,
1982
--
NDI-QA-8.1.8, Performance of Quality Assurance Audits, Rev. O,
February 15', 1982
1
I
!
l
l
. , .
_ _ _ _ - . _ , _ _ . . . . _ , , _ .
~
_ . . . . . .
__
,,
.
.'
43
NQAP 9.1, Audits, Rev. 1, February 11, 1982
--
NQAP 10.1, Certification of Quality Assurance Auditors, Rev. O,
--
November 30, 1981
'
Training Curriculum - Nuclear Quality Assurance, Rev. O, January
--
25, 1982
15.3 Implementation
The inspector reviewed the implementation of the audit program by
reviewing the following.
--
1982-1983 NQA Audit Schedule, January 29, 1982
,
1981 Audit Status Log
--
Organization Chart of Nuclear Quality Assurance, January 1,1982
--
--
1981 Management Audit of PP&L, October 29, 1981
3
--
Audit 0-81-08, Audit of Plant Technical Specification Compliance,
j
Janua ry 29, 1982
Audit 0-82-Q2, Audit of Nonconformance Control and Corrective
--
Action, February 25, 1982
--
Audit IA-82-2, Audit of NQA Home Office Activities, March 10,
.
1982
i
Audit 0-81-05, Audit of Fire Protection Program, November 20,
--
1981
--
Audit 0-81-03, Audit of ISG Procurement Interface, December 4,
1981
procurement Audit of Power Conversion Products, February 20,19fil
--
!
Audit P-82-01, Supplier Evaluation - Westinghouse Medium Motor
--
and Gearing Division, January 26, 1982
,
--
Spare Parts Quality Verification - Anchor Darling Valve Co.,
October 12, 1981
!
--
Spare Parts Quality Verification - American Air Filter, March 11,
j
1982
Audit * 0-3, NQA Audit of ISG, July 2, 1980
--
- Audits of Preoperational Testing Program
4
.
.-_
, _ _ _ _ . . _ _ _ _ . - _ _
- -
=
44
Audit *0-8, Operations QA Audit of Preoperational Testing Activities,
--
January 26, 1981
--
Audit *0-9, Audit of Initial Instrument Calibration and Analog
Loop Test, January 26, 1981
Audit *0-12, PLNQA Site Operations Audit "Preoperations Tbsting
--
Activities, March 6, 1981
Audit *0-20, Audit of ISG Administrative Controls, July 27, 1981
--
Audit *0-81-01, Audit ISG Implementation of Preoperational Test,
--
October 14, 1981
Audit *0-81-03, Audit of ISG Procurement Interface, December 4,
--
1981
--
Audit *0-82-03, Implementation of Preoperational Testing Activities,
(Audit Period February 1, 1982 to March 9, 1982)
The audit program was inspected for the following:
Audits are performed by qualified audit personnel who are inde-
--
pendent of the area being audited;
--
A long range audit schedule exists and the planned audits are
being completed in a timely manner;
Each audit utilizes an audit checklist or procedure covering the
--
areas scoped for audit;
--
deficiencies identified during the audit are resolved or are
being carried as open items;
--
Periodic review of the audit program is performed to determine
its status and adequacy; and,
--
Review of the audit program by the Susquehanna Review Committee
(SRC), the offsite safety review committee, is performed in an
effective manner and satisfies the Technical Specification require-
ments.
15.4 Findings
The inspector's findings are discussed below.
15.4.1
Technical Specification Section 6.5.2 delineates the respon-
sibilities of the Susquehanna Review Committee (SRC), including
the required audits of unit activities. The Technical
Specification' required audits under the cognizance of the
- Audits of Preoperational Testing Program
.'
45
SRC will be performed by the Nuclear Quality Assurance
Organization. However, there is no administrative procedure
for SRC review of the audits. The SRC Chairman stated that
an administrative procedure for SRC audit review will be
approved by the SRC, issued and sent to the NRC for information
by May 1, 1982. Before issuance of an operating license,
the licensee must establish and issue a proceduce to satisfy
the SRC review of audits required by the Technical Specifi-
cation. This item (IFI 387/82-09-19) will be-reviewed
during a subsequent NRC inspection.
15.4.2
FSAR Section 17.2.1.1 commits the licensee to "the performance
of an annual, preplanned and documented assessment of the
0QA Program in which corrective action is identified and
tracked."
In 1980 and 1981 this annual assessment was
performed by an audit by the Cooperative Management Audit
Program and the findings were resolved. However, there is
no administrative procedure which specifies this FSAR commit-
ment.
The licensee should reflect this FSAR commitment in
the administrative procedures to ensure it is met on an
annual basis. This item (IFI 387/82-09-20) will be reviewed
during a subsequent NRC inspection.
15.4.3
Concerns were developed regarding the QA audit coverage
of the Preoperational Testing Program and the QA staffing
available to perform both Pre Op and Operational audits.
These concerns and violations are discussed in paragraph
.
4.1.
16.
Plant Procedures
16.1 References
Technical Specifications (Proposed)
--
--
Regulatory Guide 1.33-1978, Quality Assurance Program Requirements
(Operation)
--
ANSI N18.7-1976, Administrative Controls and Quality Assurance
for ... Nuclear Power Plants
--
SSESQAM, Procedure 7.1, Control and Issuance of Documents, Rev.
7, November 17, 1980
16.2 Program Review
The administrative procedures for the plant procedures program were
reviewed. Their status including preparation, approval, issuance and
conformance to the above referenced requirements were inspected.
Procedures reviewed were:
i
-
-
,
_
_
'
46
AD-QA-101, Procedure Program, Rev. 4, February 19, 1982
--
AD-QA-102, Plant Operations Review Committee, Rev.'2, March 31,
--
1982
AD-QA-301, Operations Procedure Program, Rev. O, January 7, 1982
--
AD-QA-400, Conduct of Technical Support, Rev. O, January 13, 1982
--
16.3 Implementation Review
A sampling of issued plant procedures were reviewed to determine
compliance to requirements referenced in paragraph 16.1 and admini-
strative procedures detailed in paragraph 16.2.
Procedures were
reviewed for:
--
Proper review and approval
Correct formats
--
--
Conformance to Technical Specification requirements, and system
status during component testing is in conformance with Technical
Specification limiting condition for operaticns (where applicable)
Technical information provided in the procedure was accurate
--
--
Proper past completion reviews for test procedures
~
--
Stepwise instructions provided in the degree of detail necessary
for performing the procedure
Procedures reviewed were:
General Operating Procedures
!
GO-00-002, Plant Startup and Heatup, Rev. O, (not issued)
--
--
G0-00-003, Power Ascension, Rev. D, (not issued)
GO-00-004, Plant Shutdown to minimum power, Rev. D, (not issued)
--
System Operating Procedures
--
OP-02-001, 125 V DC System, Rev. 1, September 2, 1982
--
OP-13-001, Fire Protection System, Rev. 0, March 15, 1982
--
OP-24-001, Diesel Generators, Rev. O, February 10, 1982
.
.,
-
-
-
,
- ,
-
_ _ _ _ _ _ _ _ _ _ .
. _ _ .
_ _ _ _
_ _ _ _ _ _ _ _ ______ _____ ____ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _
47
OP-31-001, Rod Worth Minimizer, Rev. O, December 16, 1981
--
OP-51-001, Core Spray System, Rev. O, December 24, 1981
--
OP-53-001, Standby Liquid Control System, Rev. O, December 16,
--
1981
OP-61-001, Reactor Water Cleanup, Rev. O, March 1,1982
--
OP-83-001, Automatic Depressurization System and Safety / Relief
--
Valves, Rev. O, January 5,1982
OP-84-001, Main Steam, Rev. O, January 7,1982
--
--
OP-73-001, Containment Atomsphere Control, Rev. O, January 18,
1982
Surveillance Operating Procedures
--
50-56-001, Exercising Control Rods Weekly For Operability, Rev.
O, December 10, 1981
--
S0-53-001, Standby Liquid Control System Monthly Operability
Demonstration, Rev. O, December 23, 1981
--
S0-73-001, Semi-Annual Hydrogen Recombiner Test, Rev. O, March 9,
1982
S0-52-002, HPCI Pump Quarterly Flow Verfication, Rev. O, February
--
18, 1982
S0-50-002, RCIC Pump Quarterly Flow Verification, Rev. 0, January
--
18, 1982
--
S0-49-002, RHR System Flow Verification, Rev. O, November 6, 1981
50-31-001, Rod Worth Minimizer Operability Prior to Rod Withdrawal,
--
Rev. O, December 10, 1981
16.4 Findings
16.4.1
10 CFR 50, Appendix B, Criterion V and Technical Specification 6.8 require that approved procedures be established for
performing safety related activities and for operating and
maintaining plant equipment.
The inspector observed that a significant percentage of
procedures had not been approved or issued, although procedures
required to perform plant activities had been identified by
the licensee. Unissued procedures were identified in the
following areas.
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AD - Administrative Procedures
--
GO - General Operating Procedures
--
OP - System Operating Procedures
--
ON - Off Normal Procedures
--
--
EO - Emergency Operating Procedures
AR - Alarm Response Procedure (Control Fire Protection
--
Panels and remote alarm response panels only)
--
S0 - Operations Surveillance Procedures
--
SI - Instrument and Control Surveillance Procedures
SM - Maintenance Surveillance Procedures
--
--
SC - Chemistry Surveillance Procedures
RE - Reactor Engineering Procedures
--
The inspector informed the licensee, that with only a few
excepti.ons, procedures included in but not limited to the
above categories must be issued and ready for implementation
upon issuance of an Operating Licensee (OL). The licensee's
representative concurred with the inspector's finding and
stated that all necessary procedures would be issued by OL.
This is an open item pending completion of licensee action
(IFI 387/82-09-21). This finding is related to previous
findings in Inspection Report 387/81-24 (Items 387/81-24-05
and 09).
16.4.2
As noted in paragraph 16.4.1 above, the licensee had not
established procedures for remote (from the control room)
panel alarms. A licensee representative stated that procedures
would be prepared for remote alarms but not necessarily by
OL; and noted that the SSES-FSAR, Section 13.5.2.1.5, refers
only to the need for Control Room alarm response procedures.
The inspector informed the licensee's representative that
Regulatory Guide 1.33-1978, paragraph 5, requires that
procedures be prepared for responses to all safety related
alarms and does not differentate between Control Room and
remote alarm panels. Additionally, procedures for these
alarms would be required to be issued by OL. This is an
open item pending completion of licensee action (IFI 387/82-
09-22).
i
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_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ _ .
_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
_ _ - _ _ _ _ _ _ _ _ _ _
_ _ _ _
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16.4,3
The inspector questioned the availability and control over
operating and surveillance operating procedures to be used
by operations personnel in the plant. A licensee's repre-
sentative stated that a " User Control" system had been
established by procedure A0-QA-10I to provide controlled
copies of procedures to plant personnel as required. He
further stated that the Operations Department was evaluating
the establishment of " satellite" files at various locations
in the plant.
The inspector informed the licensee's representative that if
" satellite" files or other methods which are extensions of
the " User Control" system are established to provide controlled
copies of procedures to operators, then additional admini-
strative controls must be established to specify the methods.
Additionally, such controls must be established prior to OL.
This is an open item pending completion of licensee evaluation
and action (if any) (IFI 387/82-09-23).
16.4.4
In response to a TMI Action Item per NUREG 0737, the licensee's
representative committed to providing second verifications
of valve status. The inspector observed that valve lineup
checkoff lists (COL's) in system operating procedures did
not require second verifications nor was second verification
of valve position required on restoration from system blocking.
However, procedures did require second verification for
,
system blocking tag installations.
The licensee stated COL's would be revised to ensure that
there was second verification of key valves (such as flow
path valves and locked valves) and that the system blocking
procedure would be revised to provide for second verification
on system restoration.
The inspector informed the licensee
that this action must be completed prior to OL. This is an
open item pending completion of licensee action (IFI 387/82-
09-24).
16.4.5
The inspector observed that instrument valves and instrument
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isolation valves were not included in system valve lineup
COL's nor were they included in system piping diagram (P&ID's).
The licensee's representative stated that instrument valves
were under the control of the I&C Department and are controlled
by I&C procedures; however, instrument root valves were
j
under control of the Operations Department.
l
The licensee's representative stated that instrument root
i
valves would be included in valve lineup COL's.
He further
I
stated that instrument valves downstream of the root valve
I
would remain in I&C procedures with appropriate verifications.
~
The inspector' informed the licensee that this action is
required prior to OL.
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_ _ _ _ _ _
. _ _
. _ _ _ _ _ _ _ _ _ _ _ _
- _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ - _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _
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This item is open pending completion of licensee action (IFI
387/82-09-25).
16.4.6
During review of surveillance operating procedures, the
inspector observed that test procedures did not include data
required by the Inservice Test Program (IST), ASME Code
Article IWV-3000 Series, Pumps and Valves Testing. The
licensee's representative confirmed that implementing pro-
cedures had not yet been established and that IST's and
surveillance procedures were in the process of being revised.
The inspector informed the licensee's representative that
IST implementing procedures are required prior to OL. This
is an open item pending completion of licensee action (IFI
387/82-09-26).
16.4.7
The inspector observed the following deficiencies in system
operating and surveillance procedures.
OP-13-001, " Fire Protection System", does not yet
--
include fire detection and alarm procedures plus associ-
ated checkoff lists.
The licensee stated that an
expiration date of June 15, 1982 had been established
for this procedure to ensure that it is revised to
include the above.
Procedures OP-83-001, " Automatic Depressurization
--
System and Safety / Relief Valves"; S0-83-001, " ADS
System Functional Test"; and 50-83-002, " ADS Valve 18-
month Manual Actuation" did not adequately address the
operation and use of the Accoustic Monitor Position
Detection System.
The licensee stated that these
procedures would be revised to more completely address
the accoustic monitor.
50-53-001, " Standby Liquid Control System Monthly", did
--
not adequately identify Technical Specification acceptance
criteria concerning pump operation and flow path verifi-
cation. Additionally, a pump packing leakage check is
accomplished by the procedure but a pump run time is
not specified. The licensee stated that the procedure
,
!
would be revised.
!
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--
S0-49-002, "RHR System Flow Verification", acceptance
criteria reaction refers to incorrect procedure paragraphs
for determining flow for the suppression pool cooling
mode of operation and the procedure acceptance criteria
specifies a test line pressure which has not yet been
incorporated into current Technical Specification 4.5.1.6.2.
The licensee stated that this procedure was
>
currently undergoing revisions.
._ _.
.
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The inspector informed the licensee that the above procedures
must be corrected prior to OL.
This is an open item pending
completion of licensee action (IFI 387/82-09-27).
The licensee's representative also stated that an " operational
shakedown" was in progress and that many of the operating
procedures would receive a " walk through" by operators and
be revised as required, prior to 0L. The inspector acknow-
ledged the licensee's representatives statement.
16.4.8
ANSI N18.7-1976 requires that a mechanism shall be provided
for issuance of operating (standing) orders. The inspector
observed that no such mechanism exists although an instruction
does exist for issuance of night orders (special orders) as
required by ANSI N18.7-1976, paragraph 5.2.4.
The licen:ce
stated that an Operations Department Operating Instruction
(01) would be written to cover issuance of st&nding orders.
The inspector had no further questions.
17.
Exit Interview
The findings of this inspection were discussed with licensee representatives
periodically during the inspection and the status of the inspection was
discussed with licensee management on March 26, 1982.
Licensee management was informed of the scope and purpose of the inspection
on March 12, 1982 and at entrance interviews conducted at the Susquehanna
Steam Electric Station and PP&L corporate offices on March 22, 1982.
An exit interview was conducted at PP&L corporate offices on April 2, 1982,
at which time the findings of the inspection were presented (see paragraph
I for attendees).
PP&L management acknowledged the inspector positions at
the exit interview relative to the specific corrective action times contained
within this report as applicable to the specific actions to be accomplished
before operating license issuance.
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