IR 05000416/1986007

Insp Rept 50-416/86-07 on 860331-0404.No Violations or Deviations Noted.Major Areas Inspected:Qa Program Review, Procurement & Receipt,Storage & Handling

ML20198A265
Person / Time
Site:	Grand Gulf
Issue date:	05/08/1986
From:	Belisle G, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20198A260	List: IR 05000416/1986007 ML20198A256
References
50-416-86-07, 50-416-86-7, NUDOCS 8605200397
Download: ML20198A265 (12)

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NUCLEAR REGULATORY COMMisslON REGION 11

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Report No.: 50-416/86-07 Licensee: Mississippi Power and Light Company Jackson, MS 3920 Docket No.: 50-416 License No.: NPF-29 Facility Name: Grand Gulf Inspection Conducted: March 31 - April 4,1986 Inspector:

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h 4 /1 C. Smith'/ / Date ' Signed Approved by: h 757< &

G. Belisle, Actfnf Section Chief f/6/d7, Date Signed Division of Reactor Safety SUMMARY Scope: This routine, unannounced inspection was conducted on site in the areas of quality assurance (QA) program review; procurement; and receipt, storage and handlin Results: No violations or deviations were identifie G

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. REPORT DETAILS

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, Persons Contacted

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Licensee Employees C. Abbott, QA Inspection Group SuperYisor (Acting)

• J. Bailey, Compliance Coordinator

• J. Cross, Site Director ~ s

• L. Daughtery, Compliance Superintendent ,

• W. Edge, Manager, Nuclear Site QA l

• Eiff, Principal Quality Engineer, Nuclear Plant Engineering N. Ernst, QA Supplier,- Audits / Evaluations S. Feith, Director,-QA B. Harris, Compliance Coordinator D. Hunt, Senior QA Representative S. Hutchinson, Principal Electrical Engineer, Nuclear Plant Engineering M. Pampley, Senior Stores Clerk S. Roberts, Materials Supervisor

• R. Rogers, Grand Gulf Nuclear Station (GGNS) General Manager Technical Assistan W. Rogers, Materials Technical Supervisor

• F. Walsh, Materials Management Superintendent

• Attended exit interview Exit Interview The inspection scope and findings were summarized on April 4,1986, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection finding No dissenting comments were received from the license The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio Inspector Followup Item: Revision of program documents to reflect

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organizational changes, paragraphs 5, 6, and > Licensee Action on Previous Enforcement Matters

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This subject was not addressed in the inspectio . Unresolved Ite'ns Unresolved items were not identified during the inspectio : J

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2 QA Program Review (35701)

Reference: (a) 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (b) 10 CFR 50.54(a)(1), conditions of Licenses (c) MP&L Operational QA Manual (MPL-TOP-1A), Revision 4 amended (d) Technical Specification, Section 6.2, Organization The inspector reviewed the licensee's QA program required by references (a)

through (d) to determine if QA program activities were conducted in accordance with regulatory requirements, industry guides and standards, and Technical Specifications (TS). The following criteria were used during this review:

- Personnel responsible for preparing implementing procedures understand the significance of changes to these procedure License procedures are in conformance with the QA progra The documents listed below were reviewed to determine if these criteria had been incorporated into QA program requirements:

MP&L Operatistal QA Manual (MPL-TOP-1A). Revision 4 amended Section 1.0, Organization Section 2.0, Quality Assurance Program AP 01-S-01-1, GGNS Organization, Revision 16 AP 01-S-03-1, GGNS Quality Program, Revision 7 MP&L Policy and Organization Manual, Revision 36 The organf rations and key personnel responsible for developing, imple-menting, and verifying the effectiveness of the operational QA program for Grand Gulf Nuclear Station are described in Section 1.0 of MPL-TOP-1 Various changes to the organization were submitted by the licensee to the NRC for review and approval in the following document MP&L Letter AECM-85/0100 from S. M. Feith, Director, Quality Assurance to Dr. J. N. Grace, Regional Administrator, Subject: Submittal of Operational Quality Assurance Manua MP&L Letter AECM-85/0639 from S. M. Feith, Director, Quality Assurance to Dr. J. N. Grace, Subject: Operational Quality Assurance Manual (MPL-TOP-1A) Organization Chang >

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The organizational changes conveyed by letter AECM-85/0100 included, among others, the merger of the-Plant Quality Organization with the QA Organiza-tion which were implemented on August 13, 1985. Additional changes deline-ated in letter AECM-85/0639 were intended to improve management effective-ness. These changes consolidated support activities and provided a more effective management chain of command for support functions within the Nuclear Production Department (NPD). Discussions were held with NRC management concerning changes delineated in letter AECM-85/0639 prior to their implementation. Approval for the above changes to the Operational QA program was subsequently given in an NRC letter dated January 15, 1986, from Roger D. Walker, Director Division of Reactor Projects to 0. D. Kingsley Jr.,

Vice President, Nuclear Operations, Subject: MPL Operational Quality Assurance Manual (MPL-TOP-1A).

Pursuant to the above changes to the Operational QA program and in accor-dance with 10 CFR 50.30 licensee management requested an amendment to the operating license. These changes were directed to the administrative controls of the Technical Specifications (TS) and reflected the proposed changes in the organizations described in letter AECM-85/0639. These organizational changes were implemented concurrent with the request to the NRC for TS changes on November 14, 198 The inspector conducted interviews with licensee management concerning the above organizational change Additional discussions were held with licensee management responsible for performing activities in the procurement and receipt storage functional areas to ascertain the adequacy of each organizational unit's documented procedure These inspection activities are discussed 1 ter in the repor A review of the upper-tier program documents identified a discrepancy between the QA program description in MPL-TOP-1A, and Section 6.2 of the Technical specification (TS). This discrepancy concerned the organizational structure of the off-site organization and the organizational structure delineated in section 1.0 of MPL-TOP-1 Licensee management attributes this discrepancy to a delay in the processing of the TS change request previously submitted to the NR Within this area, one inspector followup item was identifie Additional discussions were held with licensee manageaent concerning conformance of the QA program documents with the organizational structure, functional responsi-bilities, levels of authority, and lines of internal and external inter-faces. The inspector determined that an outstanding list of 39 QA program documents are scheduled for revision to accurately reflect the reorganiza-tional changes. Licensee management stated that existing program documents were consistent with the presently approved TS; and revisions to these documents were being held pending approval of the TS change request submitted on November 14, 198 The inspector requested information concerning the impact on the conduct of plant activities caused by the above changes. He was informed that minimal changes occurred to working level instructions used in the performance of plant activities.

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The hierarchial relationship of the QA program procedures which documents the written policies, procedures, and instructions of the QA program in descending order is as foilows:

MP&L Operational QA Manual (MPL-TOP-1A) Revision 4 amended Plant Administrative Procedures Section Procedures Section Instructions The licensee is required to have a documented QA program which ensures the performance of commitments delineated in MPL-TOP-1A. Plant Administrative Procedures are the upper-tier program documents which ensure conformance with these commitments relative to the management and operation of GGN The licensee has identified upper-tier program documents which need to be revised because of organizational changes. These procedures address plant activities within the following functional areas:

Operating Organization Operations Program Quality Assurance

Plant Operations Procurement and Materials Control Maintenance and Modification Control i

Licensing and Deficiency Coordination The licensee also identified Maintenance Section procedures which will require revision because of reorganizational change Until appropriate upper-tier and lower-tier program documents have been revised; this is collectively combined with other examples discussed in paragraphs 6 and 7 of this report to constitute Inspector Followup Item 416/86-07-0 . Procurement (38701)

References: (a) 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (b) 10 CFR 50, Part 21, Reporting of Defects and Noncomp-liance

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(c) Regulatory Guide 1.38, Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage and Handling of Items for Nuclear Power Plants (d) ANSI N45.2.2-1972, Packing, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants (e) Regulatory Guide 1.33, Quality Assurance Program Requirements (Operations)

(f) ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants (g) Regulatory Guide 1.58, Qualification of Nuclear Power Plant Inspection, Examination, and Testing Personnel (h) ANSI N45.2.6-1978, Qualification of Inspection, Examina-tion, and Testing Personnel 4 (1) Regulatory Guide 1.123, Quality Assurance Requirements for Control of Procurement of Items and Services for Nuclear Power Plants (j) ANSI let5.2.13-1976, Quality Assurance Requirements for Control of procurement of Items and Services for Nuclear Power Plants The inspector reviewed the licensee's procurement program required oy references (a) through (j) to determine if the program had been established in accordance with regulatory requirements and industry guides and stand-ards. The following criteria were used during this review to determine the overall acceptability of the established program:

- Administrative Controls had been established to assign departmental responsibilities for procurement activitie Administrative Control had been established to identify safety-related equipment, supplies, consumables, and services to be procured under the QA progra Administrative Control had been established to provide measures and assign responsibilities for the preparation, review, approval, and changes to procurement document Procedures had been established for qualifying and maintaining approved vendors, suppliers, and contractor _ . .

- Procedures had been established to assure that vendors, contractors, and suppliers conform to procurement and quality assurance document requirements, industry standards and codes; and that nonconformances are properly reported and correcte Controls had been established to provide for audits and surveillances of procurement activitie The documents listed below were reviewed to determine if the above criteria had been incorporated into the licensee QA program to control procurement of safety-related items and services:

MP&L Operational Quality Assurance Manual (MPT-TOP-1A), Revision 4 amended Section 7.0, Control of Purchased Material, Equipment, and Services i AP 01-S-09-1, Procurement of Materials, Equipment and Services, Revision 19 AP 01-S-02-1, Description and use of the GGNS Operational Manual, Revision 10 QAP 4.10, Review of MP&L Procurement Documents, Revision 11 QAP 7.11, Periodic Evaluation of Suppliers, Revision 5 QAP 7.10, Supplier Pre-award Evaluation, Revision 11 NPEAP No.01-201, Organization, Revision 3 NPEAP No.01-306, Specifications, Revision 6 Maintenance Section Procedure No. 07-S-06-101, Processing of Requisi-tions on Purchasing, Revision 1 Maintenance Section Procedure No. 07-S-06-15, Qualification and Certifi-cation of Materials Engineers, Revision 1 Section 4.6 of the Operational QA Manual assigns the responsibility for performing quality reviews of procurement documents, prior to issuance to the QA Audit organizatio The inspector conducted interviews t:ith licensee personnel from this organization to ascertain the degree of their involvement in the procurement proces Licensee personnel were knowledge-able of requirements of their job, and were conversant with the procedural controls delineated in QAP 4.1 _ .__

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Instructions for the initiation and processing of requisitions for procure-ment of materials, equipment, and services are delineated in AP 01-S-09- Responsibility has been assigned to the Materials Engineering Group for performance of the following actions:

2. Determination of the Safety Class and Quality Level appli-cable to materials, parts and services specified in Requisi-tions on Purchasin (Except items exempted by Substep 6.1.1.b Note)

2. Identifying the design bases and technical and quality requirements to be imposed on Requisitions on Purchasing by reference to specific drawings, specifications, codes, regulations, industrial standards, or other document . Documenting technical, quality, documentation, receipt inspection, and storage requirements on Requisitions on 4 Purchasing and/or Attachment . Generating Requisition on Purchasing - Recurring Item Cards for items requisitioned for MP&L warehouse stoc The inspector conducted extensive interviews with personnel from this group to ascertain the training level and technical expertise of the staff members, ease of access to design basis documents, and external interface require-

. ments with Nuclear Plant Engineering in the generation of purchase requisi-tions. The inspector determined that a recent change had occurred to this organization in that the organization is now headed by the Materials Manage-ment Superintendent, and Materials Engineering is now called the Materials Specialist group. Licensee management confirmed that changes were not made to the organization structure, functional responsibilities, levels of authority or lines of internal and external interface The inspector reviewed the following document regarding the organizational changes which requires a change to the TS:

Safety Environmental Evaluation Form; Reference TS Change Request #

86-03, dated March 12, 1986 The licensee had established a training program for Materials Engineering Staff members to ensure the required level of competency was achieved for successful performance of job functions. A library is maintained within the work area of the group which provides for ready access to the FSAR, Vendors Technical Manuals, Specificatior.., Codes and Standards, etc. Access to design basis documents is facilitated by Nuclear Plant Engineering and or obtained from Record Storage. An uncontrolled copy of the Qualified Suppliers List was identified in the area by the inspector. Licensee management stated that final responsibility for ensuring that purchase orders are placed with qualified suppliers is given to the Contract Supervisor. A copy is maintained in the work area of the Materials Specia-list group for information onl . - _ ,

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Within this area, one inspector followup item was identified. The activi-ties of Nuclear Plant Engineering (NPEF) in the preparation of procurement documents were discussed with licensee engineering stoff members. Based on these discussions and a review of the administrative procedure for prepara-tion of specifications, the program controls appear adequate except that a documented method for the performance of bid evaluations did not exis Licensee management was responsive to this finding and stated that correc-tive actions would be initiated in the development and implementation of an administrative procedure to satisfy this nee The inspector determined that licensee management is in the process of developing section level instructions for the Materials Engineering grou Administrative procedure 07-S-06-101, which delineates the method by which materials Engineering processes and evaluates purchase requisitions, is also scheduled to be revised. These activities are grouped with other action's addressed in this report regarding QA program document changes and collec-tively identified as an Inspector Followup Ite Until a procedure is developed and implemented for performance of bid evaluations, section level instructions for the Material Engineering group are developed and AP 07-S-06-101 is revised this is collectively combined with other examples identified in paragraphs 5 and 7 to constitute Inspector Followup Item 416/86-07-0 An inspection of the implementation of the procurement program to verify conformance to procedural requirements was not performed. A reinspection of this functional area' to verify compliance with regulatory requirements, and procedural conformance during program implementation is required upon completion of the proposed changes to the QA program document . Receipt, Storage, and Handling of Equipment and Materials (38702)

References: (a) 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (b) 10 CFR, Part 21, Reporting of Defects and Noncompliance (c) Regulatory Guide 1.38, Quality Assurance Requirements for Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants (d) ANSI N45.2.2-1972, Packaging, Shipping, Receiving, Storage, and Handling of Items for Nuclear Power Plants (e) Regulatory Guide 1.33, Quality Assurance P.*ogram Requirements (Operations)

(f) ANSI N18.7, Administrative Controls and Quality Assurance for the operational Phase of Nuclear Power Plants i

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(g) Regulatory Guide' 1.58, Qualification of Inspection, Examination, and Testing Personnel (h) ANSI 'l45.2.6-1978, Qualification of Inspection, Examination, and Testing Personnel The inspector reviewed the licensee's receipt, storage, and handling program required by references (a) through (h) to determine if the program had been established in accordance with regulatory guides and industry guides and standards. The following criteria were used during this review to determine the overall acceptability of the established program:

- Controls had been established .for conducting and documenting receipt inspections and reporting nonconformance Controls had been established for item disposition marking, storing, and protection of items during storag Controls had been established for limited shelf life items and for performing audits and surveys of storeroom activitie Controls had been established for - qualification of inspection personne Controls had been established for item conditional releas Controls had been established for item storag Controls had been established for item handlin The documents listed below were reviewed to determine if the above criteria had been incorporated into the licensee QA program to control receipt, storage, and handling of equipment and materials:

MP&L Operational QA Manual (MPL-TOP-1A), Revision 4 amended Section 7.0, Controls of Purchased Material, Equipment and Service's Section 8.0, Identification and Control of Materials, Parts and Components Section 15.0 Non::onforming Materials, Parts or Components l

Section 16.0 Corrective Action i

i AP 01-S-09-2, Materials Receipt, Handling and Storage Control, i Revision 11

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Maintenance Section Procedure No. 07-S-06-215 Implementation of Material Controls Receipt, Handling and Documentation Control, Revision Maintenance Section procedure No. 07-S-06-418, Shelf Life, Revision 1 Maintenance Section Procedure No. 07-5-06-109, Engineering Receipt Inspection, Revision 0 QAP 2.50, Quality Assurance Inspector Certification, Revision 2 QAP 10.00, Quality Inspection, Revision 2 QAP 10.20, Quality Warehouse Inspection, Revision 0 QAP 15.20, Material Nonconformance Reports (MNCRs), Revision The inspector conducted interviews with personnel from the Nuclear Site QA group to ascertain the degree of their involvement in the receipt, storage, and handling of equipment and materials at the site. The following audit reports were reviewed by the inspector in connection with this effort:

Memo from S. F. Tanner, General Manager, Nuclear Site QA to J. E. Cross, General Manager, GGNS Subject: QA Audit Report MAR 85/0044 and Corrective Action Requests (CAR's) 2146 and 2147 Unit 1, dated 4/05/85 Memo from S. F. Tanner, General Manager, Nuclear Site QA to J. E. Cross, General Manger, GGNS Subject: QA Report MAR 85/0093, Unit 1, dated 7/26/85 Memo from W. E. Edge, Manager, Nuclear Site QA, to C. R. Hutchinson, General Manager GGNS, Subject: QA Audit Report MAR 86/0007, Unit 1, dated 2/5/86 The inspector determined that appropriate corrective actions were initiated for identified nonconformance Licensee management, using the guidelines for QA Inspector and Nondestruc-tive Examination Technician Training prepared by INPD, had developed a comprehensive inspector training program. Lesson p cs had been prepared for the training courses, and cross-disciplinary training of inspectors had been implemente The inspector determined that QA inspectors were being qualified to ANSI N45.2.6-1978 requirements. The following documents were reviewed in connection with this effort:

Memorandum from D. L. Hunt to Distribution, Subject: Inspection Training, dated 2/17/86 Memorandum from D. L. Hunt to S. F. Tanner, Manager, Program Quality Assurance, Subject: QA Monthly Training Status dated 2/28/86

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A random selection of purchase requisitions for items received on site was made from the files of the Materials Engineering grou These purchase requisition numbers were used to verify that the requirements for receipt, inspection, and storage of items received on site were being adequately implemented. Based on this materials handling program implementation the program controls appear to be adequate. The following purchase requisition numbers were used in this effort:

Purchase Requisition No. GG 37101, dated 10/17/85 Purchase Requisition No. GG 37052, dated 10/3/85 Purchase Requisition No. GG 37348, dated 1/8/86 Purchase Requisition No. GG 37060, dated 10/7/85 Purchase Requisition No. GG 25430, dated 2/23/84 Within this area, one inspector followup item was identifie Pursuant to the reorganizational changes previously discussed, QA program documents associated with materials handling need to be revised. Additionally, the l inspector determined that section level instructions were being developed for the Stores Supervisor's personne Until QA program documents associated with materials handling are revised to reflect organizational changes and section level instructions are developed for stores personnel, this is collectively combined with other examples identified in paragraphs 5 and 6 to constitute Inspector Followup Item 416/86-07-01.