IR 05000440/1986017

Insp Rept 50-440/86-17 on 860623-0703.No Violations or Deviations Noted.Major Areas Inspected:Qa for Startup Testing,Maint,Design Changes & Mods,Procurement Control & Tests & Procedures

ML20212A392
Person / Time
Site:	Perry
Issue date:	07/21/1986
From:	Hawkins F, Walker H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20212A383	List: IR 05000440/1986017 ML20212A377
References
50-440-86-17, NUDOCS 8607280172
Download: ML20212A392 (5)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report ?!o. 50-440/86017(DRS)

Docket No. 50-440 License No. NPF-45 Licensee: Cleveland Electric Illuminating Company Post Office Box 5000 Cleveland, OH 44101 Facility Name: Perry Nuclear Power Plant, Unit 1 Inspection At: Perry Site, Perry, OH Inspection Conducted: June 23 through July 3, 1986 Inspector: H. A. Walker 0 b ~7/il l / f3 Dat'e /

Approved By: F. C. Hawkins, Chief '7/2l/86, Quality Assurance Programs Datd

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Section Inspection Summary Inspection on June 23 through July 3,1986 (Report No. 50-440/85014(DRS))

Areas Inspected: Routine, unannounced inspection by one regional inspector of licensee action on previous inspection findings, quality assurance coverage for startup testing, maintenance, design changes and modifications, procurement control, and tests and experiments. This inspection was conducted using NRC Inspection Procedures Nos. 30703, 35501, 35743, 35744, 35746, 35749, 92701 and 9270 Results: No violations or deviations were identifie PDR ADOCK 05000440 G PDR

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DETAILS 1. Persons Contacted

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Cleveland Electric Illuminating Company (CEI)

, S. Baker, Installation Engineer G. S. Cashell, Licensing Engineer

, *V. J. Concel, Senior Design Engineer, PPTD/CEI

! W. M. Devine, Plant Modification Coordinator

! *M. M. Hanbury, Program and Modification Supervisor

. *T. Heathery, Operations Engineer I

• V. K. Higaki, General Supervising Engineer, NQAD

• A. Lambacher, Audit Coordinator, QAU/CEI

, *J. J. Lausberg, Supervisor, OS&P i

E. Leach, Lead - Design Support

! M. D. Lyster, Manager, PP0D/CEI

• J. Mayin, Senior Project Engineer, NED/CEI K. R. Pech, General Supervising Engineer

• E. Riley, Manager, NQAD

• P. A. Russ, Compliance Engineer

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• C. M. Shuster, Manager, NED-

• R. G. Solt, Supervisor, Procurement Quality i

• F. Stead, Manager, PPID

• T. Swausiger, Material Control Supervisor D. J. Takacs, General Supervisor E. J. Turk, Supervisor, ESU

! *B. D. Walrath, General Supervising Engineer, 0QS/NGAD/CEI USNRC i J. A. Grobe, Senior Resident Inspector

• F. C. Hawkins, Chief, QA Programs Section

R. C. Knop, Chief, Reactor Projects Section IB Other personnel were contacted as a matter of routine during the d

inspectio * Indicates those attending the exit meeting on July 3,198 . Licensee Action on Previous Inspection Findings 1 (Closed) Violation (440/85014-03A): Critical characteristics to be verified at receiving inspection were not being specified for commercial grade items. The inspector reviewed the program used to

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verify the acceptability of commercial grade parts to be used in safety-related applications. This program is described in the Spare Parts Documented Position Paper Number 1, Revision 0, " Commercial Grade Parts, Verification of Acceptability." This document describes acceptable methods to dedicate commercial grade items for safety-related use and it requires that critical characteristics be determined and i

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verified. The document also lists generic categories of items with their critical characteristic Review of selected Procurement Document Engineering Evaluation Basis forms (PDEEBs) indicates the document has been implemente The inspector also reviewed Special Project Plan 0402, Revision 0,

" Evaluation of Commercial Grade Parts Received Prior to October 1, 1985 for Dedication for Use in Safety-Related Application." This document provides for the evaluation of both commercial grade parts previously installed and those in stoc (0 pen) Violation (440/85014-038): Procurement procedures lack acceptance criteria for shelf life items and limited life items were not identified. The inspector reviewed stores and material instruction SMI-0006, Revision 3, " Identification and Control of Dated Material." This procedure adequately addresses the control of limited shelf life item Limited shelf life items have been identified, and they are in a computerized control syste Identification of limited shelf life items which were in stock when the program began has not been complete Completion of this item is scheduled for September 15, 198 (Closed) Open Item (440/85037-01): Implementation of the staff training program. The inspector reviewed Operations Manual Chapter 14 and verified that Sections 7.1 through 7.9 adequately describe the training program and specific training requirements for Perry Nuclear Power Plant positions. The inspector has no further concerns in this are . Areas Inspected

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This inspection was conducted to verify compliance with regulatory requirements and QA program commitments. The inspection was performed by reviewing applicable procedures and records, conducting personnel interviews and observing work activities. The inspection results are documented in the following section Quality Assurance for the Startup Testing Program (35501)

The inspector reviewed quality assurance coverage of the Perry startup testing program. This review included procedures and records of audits, surveillances and personnel certifications. Two audits and twenty-two surveillances had been performed on startup testing since the low power operating license was issued in March 198 Detailed checklists were used for both audits and surveillance Audit and surveillance activities were adequate both in scope and frequency. Surveillances appeared to be primarily testing and hardware oriented, while audits were primarily programmatic and records oriented. Audit findings appeared to be appropriately documented and adequately resolved. The Quality Assurance Organization was actively involved in the tracking, followup and resolutior, of quality problems including required corrective action Generally, the program was adequate, and it was properly implemente i

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Specific observations noted in this area were as follows:

(1) In reviewing Procedure NQADI-0240, Revision 2, " Qualification and Certification of Auditors," the inspector noted that Paragraph 6.6 allowed ANSI N45.2.23 requirements for lead auditor certification to be waive Prior to completion of the inspection, the inspector was provided with Revision 3 of the procedure, dated July 2,1986, which eliminated the waiver of lead auditor requirement In reviewing auditor certification files, the inspector found no instances where the waiver had been used. The inspector has no further concerns in this are (2) During the review of auditor certification records, the inspector noted that one lead auditor was due for annual recertification on May 9, 1986, and there was no evidence that recertification had been performed as required. Prior to completion of the inspection, the inspector was provided with a copy of the recertification which was dated February 13, 198 This appeared to be an isolated case of a missing record, and the inspector has no further concerns in this are Design Changes and Modification Program (35744)

The inspector reviewed the design changes and modifications program to verify proper implementation. The computerized system used by engineering for tracking and maintaining status of design change packages (DCPs) was reviewed, and six DCPs (for which installation had been completed) were selected for review. The design change process was well controlled and documented. 10 CFR 50.59 applicability reviews were included in the packages. Required reviews and approvals were properly documente The following specific observations were made:

(1) During the review of the first DCP, a number of documents were found to be missing. The missing documents were located by licensee personnel and provided to the inspector. Missing documents did not become an issue during the review of subsequent packages. The inspector has no further concerns in this are (2) In reviewing the status of DCPs, the inspector noted that only cancelled packages had been transmitted to the permanent records vault. Licensee personnel stated that no packages for which installation had been completed had been submitted to the vaul These DCPs were filed in engineering pending final engineering review and update of drawings to the as-built configuratio Because installation for some of these packages had been completed i for several months, the inspector is concerned that timely reviews and processing of DCPs is not being performed. This item is unresolved pending further review (440/86017-01).

(3) In reviewing the DCPs, the inspector noted that the completed work order (which provides the installation record) does not indicate the revision of the DCP. Two of the DCPs reviewed had

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been revised several times, and the actual revision used for the installation could not be determined from the DCP records package. In discussing this item with licensee personnel, the inspector was shown a computerized status and tracking system for work orders. It provided a sequence of actions relating to specific work orders, and it indicated when a revision had been mad This system provided the necessary information regarding the revisions of the two subject DCPs. While the computer system records provide the appropriate information, the inspector is concerned that they are not afforded appropriate quality assurance record protectio This matter is unresolved pending further revie (440/86017-02). Procurement Control Program (35746)

i The inspector reviewed selected areas of the procurement control program. Seven procedures, incorporating changes made from previous inspections, were reviewed. These procedures covered the establishment and evaluation of procurement requirements, receiving inspection, control of limited life material, verification of certificates of conformance, and the evaluation of commercial grade parts for safety-related use. The inspector placed special emphasis on the methods used for evaluation and dedication of commercial parts to safety-related application Selected records of these evaluations were reviewed. These reviews indicated that the procurement program was adequate and was being properly implemente Tests and Experiments (35749)

The inspector reviewed PAP 1107, Revision 0 ("Special Test Control")

including temporary change TCN-001. Both the procedure and the temporary change were acceptabl . Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations or deviations. Two unresolved items were disclosed during this inspectio . Exit Interview The inspectors met with licensee representatives (denoted in Paragraph 1)

on July 3, 1986, and summarized the purpose, scope and findings of the inspection. The inspectors discussed the likely informational content of the inspection report with regard to documents or processes reviewed by the inspectors during the inspection. The licensee did not identify any such documents or processes as proprietar <