ML20217C785

ICAVP Project

ML20217C785
Person / Time
Site:	Millstone
Issue date:	09/30/1997
From:	Beidler G, Longenecker B AFFILIATION NOT ASSIGNED
To:
Shared Package
ML20217C782	List: ML20217C776 ML20217C785
References
IA-9704, NUDOCS 9710020074
Download: ML20217C785 (9)

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PARSONS POWER GROUPINC.

INTERNAL AUDIT 1A 9704 AUDIT Tin.E:

Millstone Unit 2 ICAVP Project AUDIT DATE:

August 5 26,1997 AUDITTEAM:

George R. Beidler, Audit Team Lead Bruce E. Longenecker, Audit Team Member

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PERSONNEL CONTACTED:

See attach-H list (Attacimient iL I c Present at Pre Audit Meeting 2 = Contacted during audi; 3 = Present at Post-Audit Meeting REFERENCE DOCUMENTS:

Parsons Power Group inc, Quality Management Manual. Rev. O dated 12/6/96 Parsont, Power Group inc, Company Procedures Manual. Rev. O 12/20/96 dated

- Indepenaent Corrective Action Verification Program Millstone Unit 2 Project Admmistration Manual

- Rev. 2, dated July 29,1997

-dated IndependentJune 27,1997 Corrective Action Verification Program Millsone Unit 2 Audit Plan. (PLN 01). Rev. 2.

Independent Rev. 2, dated 7/31/97 Corrective Action Verification Program Millstone Unit 2 Communication Plan,(PLN4

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Millstone Unit 2 !CAVP Project Procedures: PP4)I Rev. 2, PP412 Rev.2, PP-03 Rev. 2 PP-04 Rev.1.

05 Rev. I, PP 06 Rev.1, PP4)7 Rev. 2 AUDITED DOCUMENTS:

See Attachnunt 2 SCOPE:

To evaluate the adequacy of program implementation in conducting activities associated with the Parson Power Group Inc. ICAVP for Millstone Unit 2. Program elemems evaluated during this assessment wi

. be used as input for our annual evaluation of our QA Program which is presently in progress. T was expanded to have the results of this audit establish future audit frequency for this project. Program (

areas naae==ed include: Organization, Program. Order Entry, Indoctrination and Training, lustructions / -

Procedures & Drawings, Document Control, Coirective Action.10CFR21. and Quality Records.

9710020074 97093036 PDR ADOCK O F

lA 9704

SUMMARY

An Internal Wrfonmince Based Audit was conducted on August 5 26.1997 of the Parsons Po Inc. Millstone Unit 2 ICAVP Project in Reading, PA. The assessment was conducted by direct observation ofin-process activities w hen poss ble as well as an evaluation of supporting functions.

intersiews with personnel responsible for work processes and quality activities and review ofin pro and completed project documentation.

Programmatic strengtlu identified dunng the assessment included:

A well defined and documented project plan.

Project personnel inteniewed during the assessment exhibited a thorogS understanding of quality program

_ function. requirements, project procedures, and their assigned responsEities as applicable to their job In summary, obrerved project activities were conducted in accordance with approved procedures The NRC approved Audit Plan is being effectively implemented Communiemions are being conducted in accordance with the approved Communications Plan. Project procedures and documentation has e been generated correctly and property approved. All interviewed project personnel wcre properly indocinnated and they all demonstrated a good working knowledge ofimplementing procedures and their assigne responsibilities. Depth ofinvestigation conducted by the project is thorough and adequate.

Due to the complexity of project tasks and projected schedule, we will conduct surveillance / audi on a monthly basis utilizing the resources of the TAG and emplasie.ing technical clTectiveness on all tiers of activity. Two minor items were identified during the audit that prompted immediate resolution of minor discrepancies. The first item was that during manipulation of electronic fonns being used project, it was noticed that one fonn could possibly be altered to a format ditTerent to that of the a version. The electronic forms are correctly controlled and ahcration of them required copying the for and altenng the copy. This process is precluded from happening by procedure and no incorrect s ersio of any fann were found dunng the assessment. The second item was that one Discrepancy Repo seventeen) was transmitted without a required signature. The accomp;m3ing transmittal leuct was sign appropriately by the same individual and the individual was intimately familiar with this Discrepancs Repon. This was evaluated to be an isolated occurrence and no further action is required. These items

- will be monitored during future audits /surveDiance.

No findings were issued during the audit. During the exit discussions, no disagreements were e by Project management in regard to the identified results. Based on the results of this assessment, it w detennined that the Parsons Power Group inc. Millstone Unit 2 ICAVP Project is adequately implementing an effective quality assurance program in conducting activities associated with this task.

Additional details are provided in the Observation section of this report.

AUDIT OBSERVATIC .c Organization and Program The Millstone Unit 2 ICAVP Project organization is well defired and documented on an Organizatio ~

Chart with responsibilitics described in the Project Administration Manual Overall responsibility for Parsons Power Group t Inc. Nuclear Quality Assurance Program rests with the President. Executive responsibility for moni oring the Program's effectiveness has been delegated to the Manager, C Quality who repons directly to the President and has the authority to identify quality problems. nsure appropriate actions are initiated to develop solutions, and verify their implementation.

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IA 9704 Order Entry Purchase Orders issued to Parsons Power Group Inc. for the performance of this efTort (ICAVP for Millstone Unit 2) were reviewed by Parsons Power Management prior to acceptance and task initiation.

Any questions were identified and resolved with the customer and NRC prior to performance. A Project Administration Manual was developed which contains provisions to satisfy all customer Purchase Order requirements.

Indoctrination and Training The project has established certain documents to be indoctrinated to by personnel uorking on the project.

PAM 4.4 requires all team members to review the documents and signify their understanding on an Indoctrination Record. Tids is a typical process for most Parsons Power projects.

Mr. D. Miller is assigned the responsibility to track an assure that all appropriate personnel submit the signed indoc'rination record. Currently a three ring binder file of all indoctrination records is with Mr.

Miller.

On 8/19, approximately 78 personnel were assigned to the project. A random sampimg of 16 indoctrination records were resiewed from the files. No problems were found with the 16 sets of records.

It she,uld be noted that since the project was initiated two major revisions to the documcats hase occurred, and the indoctrination files contain both indoctrination records for those indwiduals working on the project for those periods of time.

In all cases, the Deputy Project Director, or his designee, has signed and dated the indoctrination record.

Instructions Procedures and Drawings and Document Control A Project Administration Manual has been developed for this Project. A resiew of this Project Administration Manual (PAM), Revision 2, dated July 291997 was performed Approval of the PAM was found satisfactory with the Manager of Company Quality aad Project Director. The Project Director is also a Vice President, a requirement of the Company Procedures Manual (CPM). Control of the PAM distribution was also evaluated and found to meet the requirements of the CPM and PAM. A list of manual holders is maintained as well as receipt acknowledgments for each holder for each revision. Hard copy records are maintained in the project files. Revision control is conducted per the requirements of PAM Section 4.2.

The Project Audit Plan, Communications Plan, as well as Procedures PP41 through PP47 and Project lastruction PI-01 are controlled and distnbution is maintained in the same acceptable manner as the PAM. T. Malioto maintains the process and the files are controlled by L. Culp.

Document control of the RAl's and the NNECo responses was also evaluated. T. Mahoto performs the process that identifies each docmuent and places them into the control system. Use of Encompass as a tool to track the documents was found well implemented. A hard copy file system on the project, maintained by L. Culp makes the documents easily retrievable and accessible. A project tog ofincoming and outgoing correspondence is working well to the requirements of PLN.02 section 4.1. During the course of the audit, fourteen documents were found in the possession of project personnel and all '

documents were properly logged out.

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IA.9704 Corrective Action and 10CFR21 Procedures are in place to accommodate Corrective Action. Provisions of 10CFR21 have been accepted on this project as they apply to error reporting requirements fot Atware/ calculations performed by Parsons during the perfonnance of the project. Appropnate documentation describing the requiremuts and procedure to be used for reportable events was observed posted in the working area bulletin board.

The project is also in direct communication with the NRC on a frequent basis.

Records The PAhi, Sections 4.6 through 4.7 desenbes the project controls for files and records. All documents observed during the audit were legible and controlled in accordance with the PAhi requirements. Project files are maintained in steel cabinets in an environmentally safe location. Proprietary documentation is inaintained in locked steel cabinets. To date, no records have been sent to the Company Records Retention facilities.

Implementation -Tier 1 Activities Inteniews were conducted with the hicchanical, Electrical and l&C Leads to obtain an understanding of Tier I activities. Each 1 cad demonstrated familiarity with the appropnate procedures and med the procedures to explain their activities. Inteniews were then held with disciplined Engmccrs All inteniewed Engineers described the process used to conduct system screening. Completed Form $s (38) which were originated by these Engineers were resiewed and found to be in accordance with procedures.

Information requests were reviewed and found to be in accordance uith the Commumcation Plan PDCRs in the custody of the hicchanical Engineer were properly logged out of the file storage area. Fonns I & 2 associated with the AFW system were observed in the development process. Inter-olTice communications were properly conducted and accurately documented. Tier I activities are being implemented in 5 accordance with the NRC approved Audit Plan.

implementation Tier 2 Activities Inteniews were conducted with the Tier 2 Leads. Desenbcd actintics were in accordance with the appropriate procedures and Audit Plan. Chapter 11 analyses were reviewed and Cntical Design Characteristics were extracted. Concurrent with this review, Systems Enginecrs prepared boundary diagrams, pulling out infonnation from P&lDs. Boundanes went one level back from the analy/cd components. Reviewed diagrams were originated, checked. reviewed and approved by appropriate personnel. The Project isjust getting started with developing Critical Safety Function Diagrams. Two Critical Characteristic packages submitted to the NRC were reviewed. Two personnel were sent to Siemans to obtain infonnation. Communications were properly conducted in accordance with the Communications Plan. The next step in Tier 2 aciivities is to determine as-documented information and the project is a month away from this evolution. All Critical Characteristics must be approved by the NRC and all requests for infonnation are going through NNECO. Tier 2 activities teuch 56 systems for 29 accidents. 45 have been identified to date. Tier 2 activities are bemg imp!cmented in =cordance with the NRC approved Audit Plan.

implementation-Tier 3 Activities

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Inteniews with the Tier 3 Lead explained theit mechanism to esaluate the change processes. Originally, Parsons had received both old and new procedures so we requested current information This was properly done in accordance with the Communication Plan Tier 3 personnel then modeled the procedures and conducted training for our personnel. They then selected their review sample by 4

determining the number ofinspection areas that cut across. Set Point changes were identified by a resiew 4

IA-9704 of modifications and a setpoint change list. The Set Point change list was not always maintali.- i by

• - NNECO so a word search was conducted on the Cale Logs to identify Set Points that were clun ;ed Tier

- 3 activities are being conducted in accordance with the NRC approved Audit Plan.

- Implementation - Regulatory Review Information obtained by the Regulatory Review Lead was obtained externally from the NRC Public Document w Room. Requests were made by FAX and a file of the responses is naintained Infonnation

. as obtained before the systems were selected so information is available for the entire plant. Infonwion was obtained and activities were conducted in accordance with PP4H and Regulatory Rctiew activities are being conductd in accordance with approved processes.

Discrepancy Report Resiew Sixteen Discrepancy Reports have been generated by the project to date and a review of these documents indicated that they are being generated in accordance with approved procedures and tracked properly.

004 was transmitted without proper approval signatures. The Prnject Director had signed the transmittal letter for this DR and was familiar with this DR. He documented his approval in the appropriate area.

Internal Audit IA-9704 was prepared by: _ f*P d fMfNJ corygd Beidler Manager Coihpany Duilit.i 1

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, IA 9704

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- Attachment i .

• PERSONNEL _ CONTACTED:

Abdul M. Ahmad - Mechanical- 2 Michael J. Akins Tier 2 Lead - 2,3 Eric A Blocher - Deputy Project Director - 1,2,3 Deborah M. Bosler - Information Sen ices - 2

' Lora Culp - Project Support - 2 Dar.':1 L Curry - Project Director '- 2,3 Bruce W. Deist - Tier 3 - 2 Wayne L. Dobson - Tier 3 Lead - 1,2,3 Randall S, Faust - Tier 2 Systems Review - 2 Richard T. Glaviano - Tier 2 - 1.2,3 Evans Goodling - Structural- 2 Marc J. Grammes - Regulatory Review 2 John F. Hilbish - Regulatory Review Lead 1.2.3 John loannidi- Tier i Lead - 1,2,3 Kenneth W. Mayers -I&C Tier 1 - 2 William E. Meek - Technical Advisory Group Lead - 2 David C. Miller - Project Sappon - 2 Terry A. Moliatu - Projxt Records - 2 Samir J, Serhan - Structural Tier 1 -2

- Paul J. Shipper - Tier 2 - 2 Edward B. Tell - Mechanical Lead Tier 1 - 2 Dotty J. Volker - Project Support - 2 ,

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IA-9704 Attaciunent 2 AUDITED DOCUMENTS Independent Corrective Action Verification Program Millstone Unit 2 Project Administration Manual <

Rev. 2, dated July 29,1997 ICAVP Audit Plan (PLN-01)

- Rev. 2, dated June 27,1997 ICAVP Communication Plan (PLN-02)

Rev. 3, dated July 31,1997 Millstone Unit 2 ICAVP Project Procedures: PP-01 Rev. 2, PP-02 Rev.2, PP-03 Rev. 2, PP-04 Rev.1.

PP 05 Rev.1, PP 06 Rev.1 PP-07 Rev. 2 Millstone Unit 2 ICAVP Project Instruction PI-01 Rev. I Northeast Utility Purchase Orders 02021321 Rev.0 and Rev.001, dated 04/14/97 & 07/23/97 respectively i Millstone Unit 2 ICAVP SVSR System Modification Screening Summaries. Fonn 5. Doc. ids - SMSS-AF W 01 through 08,25 & 30 Rev. O, dated 8/19/97: Doc. ids SMSS-AFW 32. 33,34, 35. & 37. Rev.0. dated 8/20/97, Doc. ID SMSS-AFW 36. Rev. o dated 8/22/97, all for Aux Feedwater & CST Mods; Doc ID -SMSS-HPSI -8 Rev. O dated 8/19/97 for High Pressure Safety injection 5gtem Millstone Unit 2 ICAVP SVSR Modification Review Checklist. Fonn 7. Doc. ID - RC-MOD-ul for Ausihary Feedwater System Millstone Unit 2 ICAVP SVSR System Scope & Boundary Definition. Fonu 01, Doc. ID - SSBD-AFW 01.Rev. O, dated 8/21/97 for Aux Feedwater System including Condensate Storage Tank Millstone Unit 2 ICAVP SVSR Licensing Bases-Current Change 46 of FSAR, Form 02, Doc. ID - LBCD AFW.

01, Rev.0, dated 8/21/97 for Aux Feedwater System including Condensate Storage Tank ICAVP Millstone Unit 2 Request For Additional Information (RAI) #s: RAl-0102. Rev 01. dated 7/8/97; RAl-0113 Rev 01, dated 7/18/97; RAl 0162, Rev 00 dated 7/24/97; RAl-0170. Rev 00. dated 7/22/97; RAl-0201. Rev 01, dated F/7/97 ICAVP Millstone Unit 2 Discrepancy Repons DR Numbers DR-0001 through (Kil 7 Critical Design Characteristics for the FSAR Chapter 14 Overcooling Events submittal to the NRC for NRC approval, Doc Ids Parsons NUM2-PPNR-0316-L. dated 18 July 97 and NUM2-PPNR-034 l L. dated 25 July 97 Critical Design Characteristics for the FSAR Chapter 14 Reactor Coolant Pressure Boundary Events, and Main Steam Line Break / Loss of Coolant Accident Containment Analyses CDC's submittal to the NRC for NRC approval, Doc Id Parsons NUM2-PPNR 0383-L. dated August 4.1997 Sample Identification for Tier 3 Process Review submittal to the NRC for NRC approval. Rev. O. dated 25 July 97. ~

Doc. ld Parsons NUM2-PPNR-0342-L Regulatory Review Summary Form for Document title Generic Letter 88-03. dated February 171988, GL 8803. DOC, dated 8/18/97 MP2 Information Request READING, PA for Week Ending: 07/12/97 7

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I A 9704 Millstone Unit 21CAVP Tier 3 Procedure Consideration / Review indes Matrix Document - Tier i Mechanical Group PDCR's received from NNECO. dated 8/20/97 Parsons Drawing Tier 2 Figure #M2 T2SBO-SYMB. 3 S stem Boundary Diagram Sy mbols. Res. 0.Origmation date 8/18/97 Project Indoctnnation Records for:

A. Alunad 6/20 - 8/17/97 C, Akdogan 8/12/97 D. Boster 7/16 - 8/17/97 J. Brendien 8/14/97 J. Cajigas 8/I1/97 T. Chen 8/6/97 R.Cox 8/14/97 V. Pizzi 8/6/97 G. Cranston 7/31/97 L Culp 8/12/97 B. Deist 8/14/97 M. Fitzgerald 8/l1/97 S. Fogelson 8n/97

1. Katter 8/13/97 K. Mayers 8/6/97 D. Sterling 8/10/97 en t

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? Additonal Distribution:

M. Akins.:- . - - _

G. Beidler -

E. Blocher D. Curry B. Deist .

W. Dobson - -

J. Garrick R. Glaviano '

J. IElbish J. Ioannidi J. Lambright

. G. Leitch

- K. Mayers W. Meek s

E. Toll J. Townsend -

Project Records -Reading Project Records-Field Office

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