ML20214J606

Insp Rept 50-333/86-11 on 860714-18.Violation Noted:Lack of Maint of safety-related RHR Sys Pumps & Cylinders During Storage

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: ML20214J598 ML20214J603 ML20214J606
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. DPR-59

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: II/ l  :-

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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:

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Review and approval process for modifications that is in accordance

with 10 CFR 50.59, Technical Specifications (TS) and established QA/QC

controls.

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Approved procedures are used to centrol modifications.

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Measures to delineate responsibilities and control interfaces among

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

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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 '

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. 10 CFR 50.59

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. RG 1.33

IV. Receipt, Storage and Handling

1. 10 CFR 50, Appendix B, Criterion XIII

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RG 1.38 (Revision 1, 1973)

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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 2

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III. 'endorV Manuals-

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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