ML20214J606
| ML20214J606 | |
| Person / Time | |
|---|---|
| Site: | FitzPatrick |
| Issue date: | 08/04/1986 |
| From: | Eapen P, Oliveira W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20214J601 | List: |
| References | |
| 50-333-86-11, NUDOCS 8608150094 | |
| Download: ML20214J606 (10) | |
See also: IR 05000333/1986011
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U.S. NUCLEAR REGULATORY COMMISSION
REGION I
Report No.
50-333/86-11
Docket No.
50-333
License No.
Licensee:
New York Power Authority
P. O. Box 41
Lycoming, New York 13093
Facility Name:
James A. FitzPatrick Nuclear Power Plant
Inspection At:
Scriba, New York
Inspection Conducted:
July 14-18, 1986
Inspector:
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W.~0Fiveira, Reactor Engineer
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Approved By:
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Dr. P. K.
Eaben, C61(f, Quality Assurance
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Section, 08, DRS
Inspection Summary:
Routine, unannounced inspection conducted on
July 14-18, 1986 (Report No. 50-333/86-11)
Areas Inspected: Quality Assurance Program; Design Changes; Procurement, Receipt,
Storage, and Handling; and Audits.
Results: One violation was identified regarding the lack of care of items
during storage.
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DETAILS
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1.0. Persons Contacted
Power Authority of the State of New York
F. Catella, Training Ccardinator
E. Conger, Warehouse Supervisor
- R. Converse, Resident Manager
- J. Erkan, Senior Plant Engineering Supervisor
- W. Fernandez, Superintendent of Power
- L. Johnston, Quality Assurance (QA) Supervisor
- J. Kerfien, Quality Control (QC) Supervisor
- D. Lindsey, Operations Superintendent
R. Liseno, Construction Services Superintendent
- P. LoTempio, Manager of Administration and Finance
- R. Patch, QA Superintendent
- D. Simpson, Training Superintendent
- V. Walz, Technical Services Superintendent
- R. Wiese, Assistant Maintenance Superintendent
United States Nuclear Regulatory Commission
A. Luptack,
Senior Resident Inspector
- Indicates those who attended the exit meeting on July 18, 1986.
The inspector also interviewed other site and corporate personnel during
the inspection.
2.0 Quality Assurance Program Annual Review
2.1 General
The purpose of this inspection was to assess the effectiveness of the
licensee's quality assurance (QA) program implementation. The imple-
mentation was assessed by performing inspections in the Design Change /
Modification area; Procurement area; Receipt, Storage and Handling
area; and the QA/QC Audits area.
The inspection results of these areas
are discussed in paragraphs 3, 4, 5 and 6.
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3.0 Design Change / Modification
The design change / modification effort was reviewed against the require-
ments listed in Section II of Attachment A using the Modifications
F1-84-041, "Second Level of Under Voltage Protection on the 4kV bus for
Safety Related Equipment" and F1-75-253, "RHR Keep Full System".
It was
determined that the ?icensee had established the following:
Review and approval process for modifications that is in accordance
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with 10 CFR 50.59, Technical Specifications (TS) and established QA/QC
controls.
Approved procedures are used to centrol modifications.
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Measures to delineate responsibilities and control interfaces among
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participating organizations.
3.1 Findings
The Technical Services Department has checklists to perform independ-
ent reviews and verifications in accordance with ANSI N45.2.11. The
inspector reviewed the modification F1-75-253 and determined that the
reviews were independent and in compliance with ANSI N45.2.11.
The Technical Services Department does not have checklist for review
and verification of contractor prepared modifications. This was evi-
dent in modification F1-84-041.
The inspector reviewed several memor-
anda from the Technical Services Department to corporate staff dis-
cussing the review of the contractor's submittals. The contents of
the memoranda indicated that the reviews ware thorough.
3.2 QA/QC Interface with Design Changes / Modifications
All safety related design changes and modifications are formally re-
viewed by QA/QC via the PDRC Review Document process. During this
review QA/QC verifies that the required QA/QC actions are identified.
These actions are initially specified by the engineering group, and
in some cases are modified by QA/QC during review.
Further evidence
of QA involvement was demonstrated when the inspector reviewed Modi-
fication F1-82-022 " EPIC - Computer Room Halon Vent Installation".
This modification was prepared by a contractor. The QA engineer
identified a number of technical concerns in the conceptual design
and was in the process of recommending that the contractor's design
review / verification methods be investigated.
Corporate QA is required to conduct a full QA program audit of all
oew contractors or contractors that are providing poor quality work.
QA as well as engineering visit the contractors on an as needed basis
to assure that the contractor is complying with the requirements.
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4.0 Procurement Program
The inspector selected five items listed in Attachment B that were purchas-
ed for modifications F1-84-041 and F1-75-253. These items were specified
in the Nuclear Specifications and were incorporated in Purchase Requisi-
tions (PR). Upon reviews by QC and QA, the prs are forwarded to Purchasing
for the preparation of Purchase Order (PO).
The P0s are also verified by
QA.
4.1 Findings
The procurement packages for each of the items were prepared in accor-
dance with Work Activity Control Procedure (WACP) 10.1.4 and Purchas-
ing Instruction (PI) 5.
4.2 QA/QC Interface with the Procurement Program
QA Procedure (QAP) 7.4 describes the the Vendor Evaluation Program
for the vendors who supply safety related items. Vendor evaluation
is determined by existing information, records and historical data.
At user's request QA may conduct a vendor survey. The items selected
for this inspection were procured from those vendors who were pre-
viously evaluated by the licensee. The inspector reviewed several
vendor audits and found them adequate. (see paragraph 6.0 for the
details of the review of licensee audits).
5.0 Receipt, Storage and Handling
5.1 Details of the Review
The items discussed in paragraph 4.0 were also used to assess the
receipt inspection, storage and handling efforts. The warehouse area
is a Level B storage area and is well kept. The receipt inspection
was conducted in accordance with the QA procedure 7.3.
The subject
of receipt inspection is further discussed in paragraph 5.2.
The items required for a modification are classified as non-stock
items. These items are received and stored by construction personnel
in the Construction Services Department Store Room.
The inspector
verified that the under voltage relay for modification F1-84-041 was
stored as a non-stock item in the construction services department
store room.
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5.2 Findings
The nuclear specification and PO 85-7132 did not list any in storage
care (maintenance) requirement. The storeroom personnel did not know
of or receive any in-storage maintenance instructions for the relay
procured through PO 85-7132. Another item, the RHR Keep Full System
pumps (P0 84-2595) was found in the off site warehouse.
P0 84-2595
also did not specify in-storage maintenance requirements and the
store room personnel were not given any instructions regarding in-
storage maintenance.
In the case of P0 84-2595, the RHR Keep Full System pumps were receiv-
ed in April 1984.
The vendor manual required a number of in-storage
maintenances to be conducted periodically.
Rotating the shaft two
and one quarter turns every month was one such requirement. The in-
spector visited the off-site warehouse and found that no vendor speci-
fied in-storage maintenance had been performed for these pumps. The
inspector revisited the main and off-site warehouses and selected ten
items that were not tagged for an engineering evaluation prior to use
in Category I systems. The engineering evaluation was a commitment
made by the Superintendent of Power and reported in NRC Iaspection
Report 84-11. The inspector reviewed five vendor manuals that spec-
ifically dealt with the items selected. The vendor manual for P0
83-1491, Cylinder, rece ved in November 1983, requires the cylinder
be " lubricated and cycled several times" when the item is expected to
be in long term storage. No such in-storage maintenance had been
performed on the cylinder.
Lack of a maintenance program for stored items was addressed initially
in NRC Inspection Report 82-28 (333/82-28-06). The concern was fur-
ther addressed in NRC Inspection Reports 83-09 and 84-11. The licen-
see is developing a Planned Maintenance Program which will be fully
implemented in late 1988.
In the interim, items requiring in-storage
maintenance are not being cared for.
The above findings are contrary to the requirements of 10 CFR 50,
Appendix B, Criterion XIII and Paragraph 6.4.2 of ANSI N45.2.2-1972,
committed by the licensee in FSAR Chapter 17, Appendix 17.2.d.
This
is a violation (50-333/86-11-01).
5.3 QA/QC Interface with Receipt, Storage and Handling
The QC inspectors in performing receipt inspection rely on their expe-
rience to determine whether an item is acceptable. QA Procedure 7.3
requires " dimensional" checks but is not specific as to what dimensions
are to be checked. This is left to the discretion of the QC inspector.
The QA Department recognized this problem and is developing QC Receiv-
ing Instructions (QCRIs). The inspector reviewed a few draft QCIRs,
only one of which has been approved, and found them adequate. The QC
Supervisor is preparing a QA Instruction (QAI) to implement the QCIR
effort. This is an unresolved item pending implementation of the QAI
(50-333/86-11-02).
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6.0 Audit Program
Plant audits are planned, scheduled and conducted in accordance with QA
procedure 18.1.
The QA supervisor prepares and maintains the audit sche-
dule by reviewing the past history and mandatory (technical specifications)
audits and corrective action responses.
The inspector reviewed plant
Standard QA and Surveillance audits in various areas. The inspector also
assessed the knowledge level of the auditors by discussing the preparation,
auditing techniques, and the follow up (verification) of the corrective
action (CA) for the findings with the auditors.
6.1 Findings
Corporate QA conducts 10 CFR 50 Appendix B required audits of the
plant.
Since the site QA group is part of Corporate, this group is
not audited by corporate QA. The site QA group is audited by the
Joint Utility Management Audit (JUMA) team.
In response to a 1985
JUMA audit finding a full time training coordinator position was esta-
blished and staffed. The audit schedule is provided to the site
management on a quarterly basis. Management supports QA to complete
the audits as schedulad.
The auditors are qualified, knowledgeable of the requirements and
seek the assistance of the QA engineers and the QC inspectors. They
are doing less paper audits and are getting into the field more regu-
larly as compared to the last review during NRC inspection 30-333/
85-13. The conduct of Surveillance audits has also helped the auditors,
since the Surveillance audits key into a specific action such as a
test, special inspection or verification effort.
The inspector reviewed those Standard QA audits and Surveillance au-
dits listed in Attachment B.
Standard QA audits were basically pro-
cedural compliance audits. The auditors verified the implementation
of the procedure steps in the conduct of work. The audits were tho-
rough and directed to the requirement (s). The Surveillance audits
dealt with prerequisites, current procedures, plant conditions, quali-
fied personnel and test equipment, data taking and the reporting of
the results.
The corrective action responses were provided generally well within
the thirty day limit. However, in one case an extension was formally
requested and granted.
Verification of the corrective action and the
closing of the open findings are conducted in a timely manner.
The QA Department has developed the task analysis in their quest to
have their training program eventually INP0 accredited. QA management
is aware of INP0's plans to accredit training program for QA personnel.
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7.0 Unresolved Items
Unresolved items are matters about which more information is required to
ascertain whether they are acceptable items, items of noncompliance, or
deviations. One unresolved item was identified during the inspection and
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is discussed in Section 5.3.
8.0 Exit Meeting
The inspector met with the licensee staff denoted in paragraph 1 on July
18, 1986, to discuss the scope and findings as detailed in this report.
The licensee representatives acknowledged the inspector's findings.
At no time during this inspection was written material provided to the
licensee by the inspector.
The inspection involved no proprietary
information.
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ATTACHMENT A
Requirements / References
I.
QA Program
1.
10 CFR 50, Appendix B, Criterion II
2.
FSAR Chapter 17
3.
Regulatory Guide (RG) 1.33 (Revision 1, 1972) "QA Program Requirements
4.
QA Program Manual for Nuclear Plant Operation
5.
QA Procedure Manual
II. Design Change / Modification
1.
10 CFR 50, Appendix B, Criterion III
2.
3.
RG 1.64 (Revision 1, 1973) "QA Requirements for the Design of Nuclear
Power Plants."
3.
Engineering and Design Procedures Manual
III. Procurement
1.
10 CFR 50, Appendix B, Criteria IV and VII
2.
IV. Receipt, Storage and Handling
1.
10 CFR 50, Appendix B, Criterion XIII
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RG 1.38 (Revision 1, 1973)
V,
Audits
1.
10 CFR 50, Appendix B, Criterion XVIII
2.
RG 1.146 (Revision 0,1980) " Qualifications of QA Program Auditing
Personnel for Nuclear Power Plants."
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ATTACHMENT B
Documents Reviewed
I.
Procedures
1.
QA Procedure (QAP) 3.1 Design Control, Revision 5
2.
QAP 4.1 Procurment Document Review, Revision 1
3.
QAD 7.3 Receiving Inspection, Revision 1
4.
QAP 7.4' Vendor-Selection, Revision 1
5.
QAP 18.1 QA Audit Program - Plant, Revision 0
6.
Engineering and Design Procedure (EDP) 1 Procedure for Design /
Engineering Activities, Revision 3
7.
EDP 3 Design Verificatior., Revision 3
8.
EDP 4 Generation of Purchase Specifications, Revision 3
9.
EDP 10 Engineering Change Requests, Revision 3
10. Work Activity Control Procedure (WACP) 10.1.4 Procurement of Material
& Services, Revision 7
11. WACP 10.1.6 Control of Modifications, Component Changes, and Safety
& Environmental Impact Evaluation Reports
II. Procurement Packages
1. Purchase Order (PO) 85-4978, Switch (Electro Switch Inc)
2. PO 85-4980, Cable (Rockbestos Co)
3 PO 85-4981, Relay Panel (System Control)
4. PO 85-7132, Under Voltage Relay (Brown Baveri)
5. PO 85-2595, RHR Keep Full System Pumps (Union Pump Co.)
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Attachment B
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III. 'endor Manuals-
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1.
PO 85-2595, Union Pump Co.
2.
PO 83-1491, Miller Fluid Power
3.
P0 85-2940, Berger Patterson (Snubbers)
4.
P0 2095-77C, W. Powell (Limitorque Motor Operators)
5.
P0 84-6038, J.E. Lonegan Co. (Relief Valves)
IV. Audit Reports
1.
Standard QA Audits: 523; 514; 511; 569; 568; 563; 558; 551; 550; 505
(vendor); 502; 582; 485.
2.
Surveillance Audits: 1108; 1105; 1104; 1103; 1098; 1097; 1091; 1085;
1082; 1078; 1070; 1065; 1028; 1005.
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