IR 05000272/1980004

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IE Insp Repts 50-272/80-04 & 50-311/80-01 on 800128-31,0201, 04-07 & 11-13.Noncompliance Noted in Areas of QA Program Implementation,Qa/Qc Administration,Document/Drawing Controls & Design Changes & Mods
ML18085A154
Person / Time
Site: Salem  PSEG icon.png
Issue date: 05/04/1980
From: Greenman E, Napuda G, Simonetti G
NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML18085A147 List:
References
50-272-80-04, 50-272-80-4, 50-311-80-01, 50-311-80-1, NUDOCS 8010300263
Download: ML18085A154 (14)


Text

U. S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT 50-272/80-04 Report No /80-01 50-272 Docket No REGION I c

DPR-70 License Nos.. CPPR-53 Priority ----,--

Category __ c __ _

Licensee:

Public Service Electric and Gas Company 80 Park Place Newark, New Jersey 07101 Facility Name:

Salem Nuclear Generating Station, Units 1 and 2 Inspection At:

Hancocks Bridge and Newark, New Jersey Inspection Cond£.d: January 28-31 and February 1, 4.;.7 and Inspectors : :J A~~---rlv~--=----.--=--....,....--------

11-13~ 1980

~ ~Mipu a, Reactor Inspector Belke, Reactor Engineer (NRR-QAB)

Approved b :{ZJ.~.

F E:: eenman:thif,Nucl ear Support S~ction No. 2, RO&NS Branch I

r/z~ird 7 di!te o/hs-Lio dii'te date

-'/tfl<tc d te

Inspection Summary:

Ins ettion on Januar 28-31 and Februar 1, 4-7 and 11-13, 1980 Combined Re art Numbers 50-272/80-04; 50-311/80-01 Areas Inspected: Routine, unannounced inspection by regional based inspectors and an NRR engineer of the Quality Assurance Program (QAP) implementation in the areas of QA/QC administration; design changes and modifications; document/drawing control; audits; QAP changes; and, followup on previously identified items. The inspection involved 124 inspector-hours onsite and 48 inspector-hours at the cor-porate offices by two NRC r_egional based inspectors and one NRC headquarters (NRR-QAB) based enginee.

Region I Form 12 (Rev. April 77)

  • Results:

Of the five areas inspected, three items of noncompliance (nine ex-amples) were identified in two areas (Infraction - failure to develop/establish appropriate instructions/procedures, paragraphs 4.b and 5.b; Infraction - failure to implement/follow established procedures, paragraphs 4.c, 5.c and 5.d; Deficiency

- failure to store records in accordance with established requirements, paragraph 4.d).

  • *

DETAILS Per.sons Contacted Public Service Electric and Gas Company Butl~r, Senior QA Engineer V. Caviello, Senior Designer - Controls (Acting Assistant Chief)

  • F. Christiana, Chief Controls Engineer
    • R. Desanctis, Office Admfoistrator
  • J. Ditinyak, Staff Assistant - Electric Division
  • R. Evans, Assistant Manager - QA R. Griffith, Senior QA Staff Engineer
    • G. Harbin, Engineer - Station Planning
  • C. Hug, Lead Engineer
  • D. Jagt, Manager - Salem Projects
  • C. Johnson, Nuclear Plant Engineer
    • W. Kittle, QA - Resident Group
    • B. Leap, Station QA Supervisor
  • T. Lucas, Staff Assistant - Salem Project
    • H. Midura, Station Manager M. Morroni, Engineer - Site Engineering Controls
  • A. Nassman, Assistant Chief Mechanical Engineer
  • F. Omohundro, Assistant Manager - QA L. Reiter, Principle Engineer F. Robertson, Senior Maintenance Supervisor E. Schwalje, Manager - QA
  • S~ith, Engineer - Nuclear Operations A. Sternberg, Supervisor - QA Systems Division Training J. Stillman, Station QA Engineer W.. Straubmuller, Assistant Chief Designer - Me.chanical T. Taylor, Principle Staff Engineer -. Salem Projects Division
  • W *. Valaika, Principle Staff Engineer - QA Division
  • E. Witkin, Senior QA Engineer
  • J. Wroblewski, Principle Engineer Y. Yaworsky, Assistant Chief Controls Engineer Catalytic, Incorporated C. Brodie, Project Engineer J. Furlong, Resident Project Manager United Engineers and Constructors, Incorporated D. Snyder, Project Engineer

Other Accompanying NRC Personnel

    • J. Chung, Reactor Inspector
    • W. Hill, Resident Inspector L. Norrholm, Resident Inspector

. *denotes those present at the exit i.nterview conducted at the Newark, New Jersey office on February 7, 198 **denotes those present at the exit interv.iew conducted at the Salem Station on February 13, 198 The inspectors also interviewed other licensee and contractor employee They included administrative, construction, engineering, maintenance, operations and quality assurance personne.

Previously Identified Items (Open) Open Item (311/79-03-13):_Environmental controls for record storage (e.g., duplicate/microfilmed). The inspector verified that pro-cedures define environmental controls, however work was still in progress in an attempt to implement these environmental controls. This item remains open pending ~urther revie (Closed) Open Item (311/79-03-25): Duplicating/Microfilm.ing of backlogged records. The inspector determined that there is no backlog of records at -

this time.and records are being processed on a current basis. However the inspector identified ari item ~f noncompliance in the records area which is discussed in paragraph 4.d. Thi~ item is considered closed since the item of noncompliance is not directly related to this subjec.

QA Program References FSAR Amendment 43, Appendix D - Quality Assurance Quality Assurance Manual Volume 1, Policies and Procedures and 2, Salem QA Instructions Implementing procedures referenced in subsequent paragraphs of this repor Program Review The inspectors *reviewed the changes made to the QA Manual and imple-menting procedures in order to ascertain that they were consistent with the QA Program as described in FSAR Appendix D.

  • No unacceptable conditions were identified. Three items of noncompli-ance with respect to program implementation were identified. (Refer-ence Details 4.c, 4.d and 5.b) QA/QC Administration *

The inspectors reviewed the referenced documents to verify that:

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The scope and applicability of the QA Program were define Appropriate controls were established to prepare, review and approve QA Program procedures, including changes theret A mechanism has been established to review and evaluate the QA Progra The inspectors review indicated that Procedure QA! 5-1, the Corporate Quality Assuance Manual, Revision 6, was revised in August, 1979, to include a requirement that the QA Manual be reviewed on an annual basis. The inspector identified that a number of QA!s had been last reviewed in excess of a year. The licensee QA Department representative stated that necessary reviews are presently ongoing and that all appropriate QA Manual proc*edures will be reviewed by August, *198 This item is unresolved pending NRC review during a subsequent*

inspection(s) to verify that the subject procedures were reviewe (272/80-04-01; 311/80-01-01) Design Change/Modification Control* References AP-8, Station Design Changes, Tests and Experiments, Revision 4 Engineering Department Organizatton and Design Procedure (EDODP)

Manual, Section 11, Design Verification, Revision 3 Engineering Department Directive (EDD) No. l, Operational Design Change Control - Salem Nuclear Generating Station, Revision l Design Division Manual, Revision 0 (Section 1 is Revision 2)

Controls Division (CD) Procedure 36, Specifications, Revision 1 CD-43, Approved Construction Control Register, Revision l C0-81, Inspection of Panels, Revision 0

.

Mechanical Division (MD) Procedure 3.2, Design Control, Revision l

MD-3.6, Design Verification, Revision 1 Electrical Division Manual Se.ction (EDS) 8, Design Input, Revision 2

  • EDS-11, Design Verification, Revision 2 EDS-16, Design Analysis, Revision 1 Design Division Procedure (DP) 3.2.1, Design Control, Revision 2 DP-6.1, Engineering Changes, Revision 2 Structural Division Manual, Revision 17 Program Review

, The documents listed above were reviewed to determine whether admini-strative controls for design changes/modifications have incorporated the requirements as described in FSAR Amendment No. 43 (Appendix D -

Quality Assurance).

This review determined that administrative controls have been esta-blished except as hereafter discussed, which verify the following:

--.

procedures for control of design changes/modifications have been developed design document control has been established channels of communications between the design organization and the individual responsible for implementation exist design change/modification pack.ages are being con.verted into pl ant records methods exist for identifying and reporting those design changes/

modifications which are within the scope of 10 CFR 50.59 procedural. controls exist for temporary modifications, lifted leads and jumpers responsibilities have been delineated in writing to assure the implementation of the abov An example of an item of noncompliance is discussed belo CFR 50, Appendix B, Criterion V, states in part, 11Activities affecting quality shall be prescribed by documented instructions, procedures... of a type appropriate *to the circumstances...*

FSAR Amendment.43, Section D.2 (Page D.2-4) states in part, 11The En-gineering Department **. (3) Is responsible for identifying structures,

  • systems* and components covered by the QA Program.*.*
  • I Further, AP-17, The Electric Production Department Quality Assurance Program at Salem Generating Station, Revision 5, Paragraph 2.4.1, states in part, 11The General Manager - Engineering is responsible for a) Maintaining and updating the Master Equipment List (MEL)..*.

11 The inspector no"ted that a number of implementing procedures referenced the use of the MEL (e.g., AP-19, QAI 2-5, etc.) and determined that that list is the manner in which the licensee.intends to comply with the above FSAR requirement. As a result of previously Unresolved Item.

311/79-03-01 (reference Inspection Reports 311/79-03 and 311/79-26)

the licensee had addressed the resolution of safety classification questions that may arise during procurement activities. However, the Engineering Department does not determine the safety classification of all items involved in maintenance, testing, etc., or of all items being procure *

The above failure to develop the required MELs for both plants and the example discussed in Paragraph 5.b constitute two examples of the failure to establish instructions/procedures appropriate to the circumstances and are considered an infraction level item of noncompliance (272/80-04-02; 311/80-01-02). Implementation Review The inspector reviewed the followi_ng design change packages:

lED-0183, Service Water Pump Column Supports lEC-0379, Modify Mounting of Panel 689-lC to Support Panel from Containment Wall (Main Steam)

lEC-0417, Service Water System lEC-0536, Logic Addition to Defeat Motor Driven Auxiliary Feed Pump Runout Protection (TMI Task Force Recommendation)

1EC-0611A, Steam Generator Feedwater System lET-0635, Cha.rging Pump Mini Flow Test lEC-0628, Add Spacer Plates Between Flanges of Charging Pumps 11 and 12 Equalizing Lines The modifications listed above were reviewed to verify that the following requirements ha.ve been implemente CFR 50.59 reviews were performed and documented design changes/modifications were reviewed in accordance with the requirements of the technical specifications and the QA Program design changes/modifications were accomplished in accordance with written procedures acceptance testing was accomplished and deemed satisfactory

procedures and drawings required to be changed or generated as a result of the design change/modification were updated or generated

the design change/modification package has been transmitted to the records re.trieval department for incorporation as a plant record An example of an item of noncompliance is discussed belo CFR 50, Appendix B, Criterion V, states in part, 11Activities affecting quality shall be prescribed by documented instructions, procedures..* and shall be accomplished in accordance with these instructions, procedures..**

11 AP-8 requires that the design change package forwarded to the station for implementation have attached or include the written bases for the safety evaluation; material lists; applicable specifications, the mode of operation, priority and implementation request date entered on the Design Change Request Form; and, all required ODCNs (detail design instructions).

Contrary to the above the following did not have the indicated item lED-0183 did not contain necessary instructions lEC-0379 did not contain a material list, address applicable specifications, or include or have attached to it the written bases for the safety evaluation lEC-0417 did not include or have attached to it the written bases for the safety evaluation lEC-0479 did not have the priority indicated, detail instructions (associated piping diagrams and details), or the written bases for the safety evaluation attached/included 1EC-0611A did not include all the applicable ODCNs when first released for implementation. ODCNs forwarded to the station subsequent to SORC's review of the original package should have been included in the original lEC-0635 did not include the priority, mode of operations or implementation request date The inspector reviewed a portion of the engineering documentation at the corporate offices which evidenced the* performance of required design activities (including safety evaluations) associated with the referenced design cha_nge The above example {Unit 1 only) and the examples discussed in Para-graphs 5.c and 5.tj.(2) constitute an infraction item of noncompliance for failure to implement established procedures (272/ 80-04-03; 311/

80-01-03).

  • 9 Design Change Records The inspector noted that DCPs ED 0173, 0174, 0183, 0227 and 0268 were transmitted from the station to the corporate offices between July, 1917 and January, 1978. The inspector identified that these single copy type records of modifications that had been completed, were stored at the corporate engineering offices in* non-fire rated steel cabinets; 10 CFR 50,.Appendix B, Criterion XVI I, states in part, 11 *** the applicant shall establish requirements concerning record retention, such as duration, location and assigned responsibility.

FSAR Amendment 43, Sect.ion D.2.17, states in part, 11Records.*. shall be i denti fi ed and maintained in accordance with Regulatory Gui de 1. 88.... Design and construction records are replicated via microfilm and stored in the record facility maintained at the generating station and off-site locations.

The failure to maintain the above records via microfilm or in accor-dance with requirements for single copy records is considered to be a deficiency item of noncompliance (272/80-04-05). Document/Drawing Control References AP-1, Administrative Procedure Program, Revision 9 Controls Division Procedure 62, Processing Manufacturers Prints, Revision 0 Design Division Procedure (OP) 2.1.1, O.rawing I.D. System, Revision 2

.DP-4.1.6, As-Built Drawings, Revision 1 DP-7.*1,. M~nufacturers Drawings and Sepias, Revis ion 1 Electrical Division Manual Section 4, Document Control, Revision 2 Mechanical Division Procedure (MD) 3.3.1, Schematics and Piping Diagrams, Revisfon 1 MD-3.3.2, Preparation of Piping Schematics, Revision 3 MD-3.5.2.1, Manufacturers Drawings, Specifications and Approval, Revision 3 Other documents referen~ed in this report as appropriate Program Review The documents referenced above were reviewed to verify that administra-

'tive controls for document and drawing management have incorporated the requirements of FSAR Amendment No. 43 *

The inspector stated that he did not complete the program review in this area and it would be examined during a subsequent inspection. The licensee acknowledged the inspector's statemen An example of an item of nohcompl i_ance is discussed belo FSAR Amendment No. 43 (Pages D.2-11 and 13) state in part, "These activities shall be performed in compliance with *.. (8) Regulatory Guide 1.64....... which endorses ANSI N45.2.lt-July 1973, Quality As-surance Requirements for the Design of Nuclear Power Plants. Paragraph 4.3 of the standard states in part, "Procedures shall be established for the preparation and control of drawings. Typical subjects to be covered by such procedures are:... (10) As-Built Drawings...*

  • The inspector determined that a number of months may pass before an as-built drawing is distributed (see Paragraph 5.d") to the station Technical Document Room. The inspector identified that established procedures do not address how users of these controlled drawings are alerted that a given drawing may not depict as-built conditions as the result of a completed modification nor how the user can determine the as-built conditio The inspector also identified established procedures do not address the manner in which as-built information is disseminated to operations personnel in this interim, especially to the Control Rnom prior to returning the plant to power after completion of a modification. With respect to drawings that are necessary to operate the plant, the inspector verified that an informal method is utilized to inform Control Room personnel of as-built conditions. Although this informal method is not for other controlled drawings in the Control Room, the inspector determined that no immediate safety concern existed because interviewed operations personnel were aware of the modifications that were sample These two instances of failure to establish procedures to control all aspects of as-built information with respect to distributed controlled drawings and their use is considered to be an example of the item of noncompliance discussed in Paragraph Document Control Implementation The inspector compared 9 randomly selected procedures from AP Controlled Copy No. 36 with those in the Master Copy at the station. The inspector also requested to see documentation of the annual reviews of the various Engineering Department Procedures utilized during this inspection and listed under 11_References 11 in applicable paragraphs of this report *

An example of an item of noncompliance is discussed belo The 11 Introduction 11 to the Engineering Department Operating and Design Procedure (EDODP) Manual establishes a requirement that Design De-partment procedures be reviewed on an annual cycle and revised as necessary if the review so indicate Contrary to the above, the inspector identified that the following procedures are not betng reviewed on an annual basi Controls Division Procedures CD-2, Revision 10 (9/7/78); CD-36, Revision 1 (5/5/76); CD-43, Revision 1 (9/29/76); CD-62, Revision 0 (6/15/73); and, CD-81, Revision 0 (9/30/75)

Design Division Procedures 2.1.1, Revision 2; 3.2.1, Revision 2; 4. 1.6, Revision 1; *6.1, Revision 2; and, 7.1, Revision 1 (no dates on individual procedures, index indicates document review done 2/24/78)

Electrical Division Manual, Section 4, Revision 2, Section 8, Revision 2; Section 11, Revision 2; Section 13, Revision 2; and, Section 16, Revision 1 (revisions are not dated and no documenta-tion exists indicating review date)

Mechanical Division Procedures 3.2, Revision 1 (8/26/75); 3.3.1, Revision 1 (10/1/75); 3. 3.2, Revision 3 (3/26/76); 3.5.2.1, Revision 3 (3/26/76); and, 3.6, Revision 1 (3/18/76)

The above are considered to be an example of the item of noncompliance discussed in Paragraph Drawing Control Implementation The inspector selected certain drawings associated with modifications (Paragraph 4) to determine that established controls were being im-plemented and that operations personnel had access to up-to-date as-buil t information. The s e 1 ected aperture cards and drawings, as app 1 i cable, were examined at the Control Room and Station Technical Document Room to specifically verify that:

Drawings were maintained in accordance with governing procedures New and obsolete drawings and drawing changes were controlled 11As-Buil t 11 conditions were incorporated

.

Current drawings were distributed as required Drawings were legible As-Built conditions were incorporated and operations personnel had access to up-to-date as-built information The selected drawi_ngs are listed belo, Revision 6 (TDR)

205236, Revision 4 (TOR & CR)*

207452, Revision 15 (TOR)

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207522, Revision 12 (TOR & CR)

207530, Revision 12 (TOR)

211333, Revision 12 (TOR & CR)

222708, Revision 6 (TOR & CR)

231000, Revision 11 (TOR)

239958, Revision 1 (TOR & CR)**

  • as-built sketches supplied to the Control Room informally, print required
  • for plant operation **print incorporated modification but stated it applied to Unit 2 only whereas it actually _applied to Unit 1 als One unresolved item and two examples of an item of noncompliance are discussed belo (1) The in.spector identified that Drawing 207522 depicted local Pressure Indicator PL1047 and associated piping/valves tied into the Auxiliary Feed Storage Tank Recirculating Lines between the discharge side of the Heater Pump and the first downstream check valve while Drawing 205236 depicts the same tie in between the first downstream check valve and the adjacent gate valve downstream. The inspectors verified that the (Units 1 and 2) as-built conditions were correctly depicted on the latter drawin The 1 i censee' representative stated that Orawi ng 207522 would be corrected. This item is unresolved pending NRC verification during a subsequent inspection(s) that the subject drawing was corrected (272/80-04-04; 311/ 80-01-04).

(2). The inspector identified that the drawings distributed to the Control Room did not depict the latest as-puilt conditions, were not annotated in some fashfon. to alert the user that they did not depict as-built conditions nor was there a method whereby the user could determine the as-built conditions. The inspector verified that the same situation applied to the drawings in the station Technical Document Room and further determined that this appeared to be a general conditio CFR 50, Appendix B, Criterion II states that the QA Program shall be documented by written policies, procedures and instructions and the program shall be carried out in accordance with these policies, procedures and instruction FSAR Amendment 43 established a commitment to ANSI NlS.7-1976, Administrative Controls for Quality Assurance for the Operational Phase of Nuclear Power Plant Paragraph 5.2.7 of the standard states that the guidance of ANSI N45.2.8, Supplementary Quality Assurance Requirements for Installation, Inspection and Testing for

the Construction Phase of Nuclear Power Plants, shall be applied to operating plants. ANSI N45.2.8 states that a system of controls be established to assure that as-built information is being processe AP-17, Paragraph 5.4, states in part, 11The General Manager - Engineering is responsible for:... Ensuring the copies of these documents { drawings} at the station are kept current by incorporation of imple-mented design change *

The failure to maintain as-built drawings in the Control Room and Technical Document Room which reflect implemented design changes or provide a means to determine as-built conditions resulting from completed modifications is an example of the item of noncompliance discussed in Paragraph 4.c (e.g. failure to implement established procedures). Audits References QAP-18, Quality Audits, Revision 5 QAI-18-1, Audits by the Quality Assurance Department, Revision 7 QAI-18-2, Audit Report Format, Revision 9 Review The inspectors reviewed Audits 79-2, 79-4, 79-8 and 79-21 conducted by the Quality Assurance Department of various engineering activities of the Engineering Department. The inspectors v~rified that these audits were conducted in accordance with written procedures and checklists; with audit findings documented and reviewed; with followup action completed/initiated/closed out; and general audit conduct in accor-dance with established schedules and procedure The inspectors noted that the audits.identified in part the inspectors findings with respect to Design Change Packages not being complete and the annual review of the EDODP Manual not being performe No items of noncompliance were identifie.

Pl ant Tour The inspectors toured selected areas of the Auxiliary Building (Units 1 and 2), Control Rooms, Turbine Building and Maintenance Shop of Units 1 and The inspectors observed various activities in progress such as welding, general maintenance, document/drawing control and shift operations acti-

. vitie *

No items of noncompliance were identifie * Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, items of noncompliance or deviations. Unresolved items identified during this inspection are discussed in Paragraphs 3.c and * Preliminary Findings The inspectors met with licensee representatives (denoted in Paragraph 1)

on February 7, 1980~ at the corporate offices and onsite on February 13, 1980, at the conclusion of the inspection. The scope and findings of the inspection as documented in this report were presented at these meetings and during two subsequent telephone conversations on March 19, 1980, between the inspector and licensee representatives.


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