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{{Adams | {{Adams | ||
| number = | | number = ML20054F197 | ||
| issue date = | | issue date = 05/27/1982 | ||
| title = | | title = IE Insp Rept 50-387/82-09 on 820322-0402.Noncompliance Noted:Failure to Obtain Proper Authorization Prior to Work on safety-related Sys & Failure to Conduct Comprehensive Audits of Preoperational Testing | ||
| author name = | | author name = Blumberg N, Caphton D, Eapen P, Meyer G, Napuda G, Shaub E, Shaub T | ||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) | | author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) | ||
| addressee name = | | addressee name = | ||
| addressee affiliation = | | addressee affiliation = | ||
| docket = 05000387 | | docket = 05000387 | ||
| license number = | | license number = | ||
| contact person = | | contact person = | ||
| document report number = | | document report number = 50-387-82-09, 50-387-82-9, NUDOCS 8206150304 | ||
| package number = ML20054F190 | |||
| package number = | | document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | ||
| document type = | | page count = 52 | ||
| page count = | |||
}} | }} | ||
| Line 20: | Line 19: | ||
=Text= | =Text= | ||
{{#Wiki_filter: | {{#Wiki_filter:i 6-I | ||
< U.S. NUCLEAR REGULATORY COMMISSION | |||
==REGION I== | |||
l Report No. 82-09 Docket No. 50-387 _ | |||
License No. CPPR-101 Priority - | |||
Category B Licensee: Pennsylvania Power & Light Com>any l 2 North Ninth Street Allentowr., Pennsylvania- 18101 Facility Name: Susquehanna Steam Electric Station, Unit 1 l Inspection At: Allentown and Berwick, Pennsylvania Inspection Conduc d: March 22-26, 29-31 and April 1-2, 1982 l | |||
Inspectors: #, . W & | |||
G.''Napuda, R4 actor Inspec4.or d' ate ' | |||
['T Yk | |||
@ N. Blumberg, Reactor Inspector S 27 82-date | |||
[ I bh 4 P. K. Eapen, Reactor Inspector 02782-date f$ | |||
G. Meyer, Reactor Inspector | |||
% Z 27 8 date c#f N 7. Shaub', Reactor Inspector 3 27 82-date r 'l./ / / @ 7 h L | |||
~ Caphton, Ctfief, Management Programs /date' | |||
ection En inepring Inspection Branch g | |||
, Approved by: / tiV 7/ 6?// 72- | |||
! D. Ca'pht6nf Chief, Management Programs date' | |||
l Section, Engineering Inspection Branch Inspection Summary: Inspection on March 22-26, 29-31 and April 1-2, 1982 (Inspection Report No. 50-387/82-09) | |||
Areas Inspected: Routine, announced inspection by region based inspectors of 1) | |||
l the Pre-operations Quality Assurance Program implementation, and 2) the readiness l | |||
of the Quality Assurance Program for operations in the areas of design changes / | |||
modifications and engineering; maintenance; plant surveillance testing and | |||
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C206150304 820528 PDR ADOCK 05000387 Q PDR | |||
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calibration control; test and measurement equipment; onsite and offsite. safety committees; non-licensed training; document control; records; procurement; receipt, storage and handling of items; audits; plant procedures,; and, previously identified items. The inspection involved 46 inspector hours in-office by five inspectors, 361 inspector-hours onsite by five region bassd inspectors and one supervisor, and 131 inspector-hours at the corporate offices by four region based inspector , | |||
Results: Of the thirteen areas inspected, two 1.tems of noncompliance were identified in one area (violation - failure to obtain proper authorization prior to work on a safety-related system, paragraph 4'.1; violation - failure'to conduct comprehensive audits of pre-operational testing, paragraph 4.1). | |||
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DETAILS Persons Contacted | |||
A: -Pennsylvania Power & Light Company (PP&L), Allentown, P * W. Barlserich, Supervisor-Nuclear Licensing . | |||
A.' Butt, Consultant Engineer (Quadrex Corp.) | |||
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* J. Calhoun, Senior Vice President - Nuclear | |||
* S. Cantone, Manager - Nuclear Support | |||
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/ . | |||
> L. Clark, Quality Engineer | |||
* A. Craven, Senior Information Specialist - Nuclear Administration | |||
* N. Curtis, Vice President - Engineering | |||
* R. Featenby, Assistant Project Director - Site J. Gutshall, Senior Project Engineer R. Harris, Licensing W. Heske, Manager - Nuclear Administration | |||
* P. Henrikson, Manager Licensing C. Kalter, Assistant to Manager - Nuclear Support | |||
* B. Kenyon, Vice President - Nuclear Operations | |||
, | |||
W. Lurch, Manager - Education and. Training | |||
* A. Male, Manager - Nuclear Design | |||
* C. McVicker, Assistant Manager - Nuclear Quality Assurance (Operations)- | |||
* J. Medeiros, Supervisor - Nuclear Records | |||
* J. Miltenberger, Manager - Nuclear Safety Assessment | |||
* K. Neddenien, Information Specialist - Nuclear Administration- | |||
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,/ / H. 0heim, Group Supervisor - Electrical Design t i * A. Sabol, Manager - Nuclear Quality Assurance O. Sattar, Senior Project Engineer | |||
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j N. Schwan, Assistant Manager - Nuclear Quality Assurance (Engineering / | |||
Procurement) | |||
R. Shovlin, Assistant Project Director B. Skoras, Engineer - Electrical Design | |||
* J. Stefanko, Manager - Nuclear Fuels J. Spadotto, Supervisor - Management Development | |||
* W. Ward, Manager - Training H. Webb, Supervisor - Nuclear Maintenance Support Susquehanna Steam Electric Station, Berwyck, P L. Adans, Supervisor of Operations F. Butler, Instrument and Control / Computer (I&C/C) Supervisor | |||
, R. Byram, Acting Supervisor of Operations P. Cape:osto, Acting Resident Nuclear QA Engineer D. Cassel, Group Supervisor - Nuclear Site Engineering N. Covington, Assistant ISG Supervisor J. Edwards, Personnel and Administrative Supervisor F. Eisenhuth, Senior Compliance Engineer C. Figard, ISG Supervisor (Bechtel) | |||
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F. Graber, Operations Consultant | |||
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J. Graham, Staff Assistant J. Green, Operations QA Supervisor E. Gorski, QC Supervisor M. Johnson, ISG Quality Engineer (Bechtel) | |||
* H. Keiser, Superintendent - Susquehanna Steam Electric Station G. Kuczynski, Electrical Maintenance Supervisor D. Lauer, ISG Coordinator B. Lloyd, Maintenance Engineer W. Lowthert, Supervisor - Technical Training T. Nork, Acting Supervisor - Maintenance A. Piemontese, Power Production Engineer A. Reasin, Test Director - ISG G. Robinson, I&C Foreman M. Rutkoskie, Assistant (I&C) Foreman J. Skrocki, Project Engineer (Spare Parts Analysis) | |||
M. Sherman, Assistant Electrical Foreman D. Sitler, Senior Results Engineer NRC Personnel | |||
* S. Ebneter, Chief, Engineering Inspection Branch, Division of Engineering and Technical Programs | |||
* J. McCann, Resident Inspector | |||
* G. Rhoads, Senior Resident Inspector 2. Licensee Action on Previous Inspection Findings (0 pen) Inspector Follow Item (387/81-24-08): No procedure existed which addressed system cleaning. The inspector observed that new procedure AD-QA-503 provided instructions for determining grades of system cleanliness in accordance with ANSI N45.2.1 but contained no procedures for system cleaning and flushing. The licensee stated that these procedures were contained in corporate engineering procedure M-1039, " Cleanliness of Piping and Associated Components". The inspector determined that M-1039 did conform to ANSI N45.2.1. The licensee agreed to revise AD-QA-503 specify that M-1039 was to be used whenever system cleaning or flushing was required. This item remains open pending completion of licensee actio (Closed) Inspector Follow Item (387/81-24-04): Procedure AD-QA-502, " Work Authorization System", to be revised to further define the makeup of the final work package. The inspector verified that AD-QA-502 has been revised to specify the necessary documents to be part of a completed work packag Based on the above, this item is closed. | |||
l (Closed) Inspector Follow Item (.187/81-24-07) Cleanliness zones as specified | |||
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in Procedure AD-00-48 did not appear to completely conform to those specified in ANSI N45.2.3. The inspector verified that AD-00-48 has been reissued as AD-QA-503, " Housekeeping / Cleanliness Control", a,d has been revised to incorporate the requirements of ANSI N45.2.3. Based on the above, this item is closed. | |||
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3. General The primary intent of this inspection was to ascertain the readiness of the applicant for operation of the plant in the specific areas inspecte Procedures were reviewed to verify they were consistent with commitments and clearly detailed the particular activit Employees were interviewed to determine that thay were aware of their authorities and responsibilities, and knowledgeable in applicable procedures. Records of activities that had taken place were reviewed to determine the effectiveness of the established program. Personnel and training records of selected interviewed employees were also reviewed to verify that job incumbents had adequate education / | |||
experience or proper supplemental training for their positions. When possible, ongoing activities were observed to assure they were accomplished in accordance with established procedures. These areas are discussed in paragraphs 5 -1 Those items that must be corrected / resolved prior to the issuance of an Operating License (0L) or fuel loading are so identified and this action will be verified as appropria+e during a subsequent inspection (s). Those concerns / minor items that must be corrected / resolved prior to or when an activity occurs (other than OL or fuel load) will be examined during sub-sequent routine inspection . Site Nuclear Qi911ty Assurance (NQA) Staff for the Preoperational Testing Prngram 4.1 The NQA site staff responsibilities covers both preoperational testing and operations. As of April 1,1982 the site staff consisted of one QA supervisor, two technical engineers plus one technical contracto The licensee's representative stated that one senior NQA analyst was recently (3/29/82) transferred to the plant staf It was further stated that attempts were underway to fill this vacanc The licensee's representative stated that the NQA site staff utilization had been approximately 60% of available time involved with QA review of pro-cedure QA Audits are scheduled and preplanned. A review of the audits scheduled indicated some slippage relative to the established schedule. A review of the audits performed and completed in the preoperations testing area identified 8 audits (see paragraph 15.3) of the ISG (Integrated Startup Group) controlled preoperational testing work over an approximate 18 month period, June 16, 1980 through March 9, 198 An inspection was made of the QA audits performed on the ISG conducted preoperational testing program to determine audit overall coverage, comprehensiveness and degree of periodicity. The eight QA audits when placed on a matrix to analyze coverage, except in the area of preopera-tional test implementation and test witness, provided essentially a one time audit of some aspects of the ISG controlled run preoperational test program. The audit coverage noticably lacked evidence of periodi- | |||
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city. No reaudits of deficient areas was evident. 'All aspects of the ISG preoperational testing program was not covered by the audits. For example, there were no comprehensive audits of ISG handling and pro-cessing into the ISG program the turned over system packages from construction; and, many Q listed systems lacked evidence of having any aspects audited. A comparison made of the eight audits performed by QA against the Q-list showed there were no planned and periodic QA Audits of, e.g. Q Listed Systems Nos. 4.0, 5.0, 6.0, 9.0, 11.0, 11.0, 17.0, 45.0, 54.0, 55.0, 58.0, 60.0, 61.0,-62.0, 64.0, 69.0, 70.0, 71.0, 73.0, 75.0, 76.0 and 8 A review of the QA audits that were conducted appeared to provide meaningful coverage within the limits of their scope; however, 10 CFR 50 Appendix B Criterion XVIII, Audits, states that a comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the (preoperational testing) quality assurance program and to determine the effectiveness of the program, and Criterion II Quality Assurance Program, states that the "... | |||
program shall provide control over activities ... consistent with their importance to safety". The licensee's QA audits appear not to meet the intent of Criteria XVIII and II in that only some aspects of the preoperational testing program had been audited and many activities regarding Q listed systems important to safety had either no audit coverage or only one time audit coverage (lacked periodicity). This is a violation (387/82-09-01). | |||
The construction turnover over package to ISG for Core Spray System No. 51A was selectively sample reviewed. Twenty items from the construc-tion turnover exception list were examined to determine how they were incorporated into the ISG system. All twenty items had been placed on the ISG Startup Work List (SWL). One item entered on the list on May 16, 1980 was followed up since it was still open and the core spray preoperational pump test had been essentially completed. This item was titled " Install Core Spray Strainers IF 404 A,C on HBB 104-1 after flush." There was also a similar entry on the SWL for Strainers IF 404 B and The flush was completed prior to the core spray pump test. Bechtel Drawing M152, Rev. 15 showed the strainers installation to be two each on the 'A and C' and 'B and D' Core spray pump suction lines inside the suppression pool area. A visual inspection was made inside the suppression pool on April 1, 1982 to determine whether or not the strainers were installe Strainers were visually observed to be installed on the top side of each core spray pump suction line Te The suppression pool had been filled with water, howeve- visual clarity through the water was excellent when aided with light. A blind flange (handle) tab could be seen projecting from the flange at the bottom of the Tee however no strainer was installed on the bottom side of the Te A review made of ISG Startup Work Authori:ations (SWA) identified one written to cover installation of blind flanges for the system 51A Core | |||
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Spray pump suction line, however no SWA was identified by ISG personnel to cover the installation of the strainers found to be installed on the top side of the Te AD 6.4 Rev. 9, Startup Work Authorization, states that"... all hardware-identified under PP&L Quality Assurance Program will require an SWA | |||
... "and" work is considered to be any activity that requires a craftman to perform that activity." The installation of the Q listed core spray pump suction line strainers without an SWA is in violation of the AD 6.4, Rev. 9 procedure. This is a violation (387/82-09-02). | |||
In addition to the two violations identified above, the existing QA staff was found to be inadequate to provide auditing and surveillance coverage for preoperational testing activities and station oparational activities. This concern will be communicated to the licensee by NRC RI managemen The adequacy of licensee management overview (i.e. audits, etc.) of preoperational testing activities and the readiness of the plant for initial OL activities will be reviewed during a subsequent NRC-RI Inspection. (IFI 387/82-09-28). | |||
4.2 Quality Control 4. References | |||
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Regulatory Guide 1.33, Rev. 2, " Quality Assurance | |||
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Program Requirements (Operation)", February,1978 | |||
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ANSI N 18.7 - 1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants" | |||
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ANSI N 45.2.6 - 1978, " Qualifications of Inspection, Examination, and Testing Personnel ... of Nuclear Power Plants" 4. Program Review The inspector reviewed the quality control program, as described in the following licensee administrative document OPS-14, Control of Inspection and Testing, Rev. 1, April 1, 1982 | |||
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NQAP 11.1, Quality Control Program, Rev. O, January 18, 1982 | |||
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QCP-10, Training, Qualification, and Certification of Inspection and Test Personnel, Rev. O, April 28, 1981 | |||
1 : | |||
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QCP-20, Inspection of Maintenance,-Modifications, and Testing Activities, Rev. O, November 8, 1981 | |||
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QCP-21, Establishing Inspection Points, Rev. O, November 8, 1981 | |||
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QCP-50, Quality Control Checklists, Rev. O, June 8, 198 . Implementation The inspector reviewed the implementation of the audit program in the following areas: | |||
-- . Organization Chart of NQA-Quality Control; | |||
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1982 QC Inspection Log; | |||
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1982 QC Call Number Log; and, | |||
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Quality Control Inspection Reports (QCIR's), including QCIR's #82-982, 82-1098, 82-1101, 82-1123, 82-1124 During the review of the quality control program, the inspector verified the followin Inspections are performed by qualified inspectors who are independent of the work being inspected | |||
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The inspectors are notified of the work being performed (e.g., hold points, notification points, sign-off on work authorizations, etc.) and the inspectors utilize importance to safety as a criteria in evaluating which inspections to perform | |||
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The inspections utilize a checklist or procedure covering the areas inspected to ensure a thorough inspection | |||
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Deficiencies identified during inspection are formally entered into a non-conformance/ corrective action system and tracked until resolution 4.2.4 Findings The inspector found no violations or open items relative to Quality Contro ! t 8' | |||
5. Design Changes, Modifications, Tests and Experiments 5.1 References | |||
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ANSI N45.2.8 - 1975, Mechanical Installation, Inspection and Testing | |||
-- ~ ANSI N18.7 - 1976, Administrative Controls and Operational QA | |||
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10 CFR Part 50.59 | |||
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10 CFR Part 50 Appendix B | |||
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Proposed Technical Specifications | |||
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FSAR Sections 13 and 17 5.2 Program Review The inspector reviewed the licensee's programs for design changes, facility modifications, and conduct of tests and experiments to verify the following | |||
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Required QA programs have been developed in accordance with the regulatory requirements, industry standards and licensee's commit-ments | |||
-. Procedures have been established for control of design changes, modifications, and tests and experiments | |||
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Appropriate responsibilities have been established and assigned | |||
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Administrative controls have been established to preclude unautho-rized activities; assure prompt recall of obsolete documents; and facilitate distribution of approved documents | |||
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Administrative control procedures have been established to revise the plant procedures, the training program and the facility drawings as necessary to reflect any facility changes as described in this section | |||
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Proper communication channels have been established among partici-pating organizations | |||
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Provisions have been established to transfer the records to the records storage facility | |||
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Provisions have been established to assure that activities are conducted using approved procedures, whenever applicable | |||
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Post implementation testing and acceptance criteria are established | |||
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Responsibility and the method for reporting activities to the Nuclear Regulatory Commission have been established The following documents were reviewed to assure the program complies with the above requirement OPS-9, Control of modifications and design activities, Rev. 0 | |||
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NDI-QA-2.2.3, Design Responsibility Delegation (Draft) | |||
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NDI-QA-14.2.2, Safety Evlauations, Rev. 0 | |||
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DC 010.0, Review Verification and approved of design documents Rev. 0 | |||
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DC 040, Design Change Mechanism, Rev. 0 | |||
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DC 110.0, Design calculation control, Rev. 0 | |||
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AD-QA-410, Plant Modification program, Rev. 1 | |||
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AD-QA-411, Plant modification design control, Rev. 1 5.3 Implementation The programs discussed in this Section are not required until the facility license is issue Currently, programs for design changes, modifications, and tests and experiments are conducted for the licensee by the Architect Engineer. The licensee representatives advised the inspector that licensee personnel have not completed any safety related activity covered by the programs discussed in this section. However at the time of the inspection, several projects were in progress in this area and the licensee intends to use these activities to determine the effectiveness of established procedures and administrative control The licensee representatives discussed their on going projects with the inspector and demonstrated how the applicable portions of the program were implemented for these project .4 Findings 5. The licensee has no specific procedures that address the conduct of Tests and Experiments under the provisions of 10 CFR 50.59. During discussions with corporate and plant staff, the inspector learned that the licensee intends to conduct these tests and experiments under the provisions of procedure AD-QA-101, Procedure Program. The inspector stated that additional guidance and instructions needed to be developed to aid individuals in performing tests and | |||
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experiments prior.to the issuance of the Operating License and the licensee acknowledged the inspectors statement. The effectiveness of the licensee's tests and experiments program will be followed in future NRC:RI inspection (IFI 50-387/82-09-03). | |||
5. The procedure for delegating design responsibilities had not been issued prior to the completion of this inspection. The licensee's representative told the inspector that the required procedure was being drafted and it would be issued prior to the issuance of the Operating License. The licensee's design change and modification program allows both the corporate and plant staff to perform the modification The plant staff told the inspector that limitations in manpower, expertise and other resources would allow them to undertake only relatively simple design modifications. The inspector stated that the scope of the modifications carried out by the plant staff should be well defined; the plant procedures should be adequate to perform the delegated | |||
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responsibility; and, the plant staff should be adequately trained to perform the delegated responsibility. The licensee representatives told the inspector that the above items would be completed prior to delegating any design respon-sibility to the plant staff. This will be followed in a future NRC:RI inspection (s). (IFI 50-387/82-09-04) | |||
5. As noted in Section 5.3 above, the licensee has not yet completed a safety related project using established pro-cedures. The inspector discussed the need for management controls (Management review. QA review, verification by the Independent Safety Assessmt ,t Group, etc.) of the projects during the trial use of the procedures, to assess the effective-ness of the program and to implement corrective action The licenste representatives agreed to institute the necessary management controls. The effectiveness of these actions will be followed in future NRC:RI inspections (IFI 50-387/82-09-05) | |||
Except for the weaknesses cited above, the licensee's programs for design changes, modifications, and tests and experiments appear to meet the requirements of the references listed in Section 5.1 above. | |||
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6. Maintenance Programs 6.1 References | |||
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ANSI N18.7 - 1976, Administrative Controls and Operational QA | |||
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: 1 1 ANSI N45.2.6 - 1973, Qualifications of Inspection, Examination, and Testing Personnel | |||
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AN5I N45.2.1 - 1973, Cleaning Fluid Systems and Components | |||
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Proposed Technical Specifications | |||
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Section 13 and 17 of the FSAR 6.2 Program Review The inspector reviewed the licensee's maintenance program to verify the followin Written procedures have been established for initiating requests for routine and emergency maintenance | |||
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Criteria and responsibilities have been established for review and approval of all maintenance requests | |||
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Criteria and responsibilities have been established to identify-safety and non-safety related maintenance activities | |||
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Criteria and responsibilities have been established for verifying work classification and the use of industry accepted procedures | |||
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Criteria and responsibilities have been established for designating hold points and for performing work inspections | |||
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Administrative controls have been established to prepare, assemble, review and store the maintenance records | |||
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A preventive maintenance and a corrective maintenance program have been established | |||
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A program has been established to review the corrective maintenance program, to assess the adequacy of the preventive maintenance program, to identify repetitive failures of parts and components and to identify design deficiencies | |||
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Work control procedures have been established for special process, fire protection, radiation protection, physical security, clean-liness and housekeeping | |||
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Provisions have been established for the Coordination of maintenance activities and interface controls among participating organization | |||
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Methods and responsibilities for equipment control have been established | |||
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Personnel are trained and qualified to perform maintenance The inspector reviewed the following documents to assure that the requirements of the references cited in section 6.1 above are me OPS-13, Maintenance, Installation of modifications and related activities, Rev. 0 | |||
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AD-QA-500, Conduct of Maintenance, Rev. 0 | |||
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AD-QA-502, Work Authorization System, Rev. 2 | |||
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AD-QA-503, Housekeeping / Cleanliness, Rev. 1 | |||
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AD-QA-520, Station Welding Program, Rev. 0 | |||
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AD-QA-521, Brazing and Iiller Metal Control, Rev. 0 | |||
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AD-00-540, Computerized Preventive Maintenance System (Draft), | |||
Re AD-00-504, Preventive Maintenance Program Prior to Full Load, Rev. 0 | |||
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NDI-14.1.2,, Work Process Maintenance, Re OPS-13, Maintenance, Installation of Modifications and Related Activities, Rev. 0 | |||
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MT-GE-001, Motor Inspection and Maintenance, Rev. 0 | |||
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MT-GE-011, Chiller Maintenance and Inspection, Rev. 0 | |||
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MT-GE-013, 480 kV Load Center Inspection and Breaker Maintenance, Rev. 0 | |||
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MT-GE-015, Advanced Control Room (ACR) Electrical Maintenance, Rev. 0 | |||
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MT-64-003, Recirculation Pump Seal Removal and Replacement, Re MT-64-004, Reactor Recirculating Pump Seal Rebuild and Test, Re MT-62-007, Steam Dryer Removal and Installation, Rev.1 l -- | |||
MT-53-001, Standby liquid Control Pump Disassembly and Reassembly, l | |||
Rev. 1 i | |||
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MT-49-001, RHR Pump Disassembly and Reassembly, Rev. 1 | |||
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IC-DC-100, Transmitter / Converted Calibration / Calibration Check Procedure, Rev. 2 | |||
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IC-DC-200, Indicator / Receiver Calibration / Calibration Check Procedure, Rev. 1 | |||
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IC-DC-400, Switch / Bistable / Calibration / Calibration Check Procedure, Rev. 1 | |||
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IC-DC-600,-Temperature Element and Wiring Check Procedure, Rev. 1 6.3 Implementation The inspector reviewed maintenance activities authorized under the following Work Authorizations to assess the effectiveness of the program implementatio U-14666 - Investigate and Rework RBCCW Pump for high vibration | |||
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U-14649 - Clean and Inspect 024 Standby Diesel Generator | |||
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P-10940 - Preventive Maintenance for the control structure emergency supply fa U-27120 - Maintenance for FT 01109 A&B transmitter system | |||
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U-27071 - Check control loop of HPCI | |||
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U-27075 - Wiring change to APRM/RBM channels | |||
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U-27175 - RHR Sample line repair | |||
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U-24300 - Adjust valve position indicator for HV-1F020 (15112) | |||
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U-24225 - HPCI Turbine Exhaust check valve maintenance | |||
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U-24251 - Removal of drywell head | |||
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U-24291 - Gas leak replacement for valves on ADS, MSRV air header 6.4 Findings 6. The inspector noted that the licensee has not establisNd the required procedures to implement planning and scheduling of maintenance as described in Section 5.2 of OPS-13. The licensee representatives told the inspector that the planning and scheduling of maintenance activities would be the respon-sibility of the Unit Co-ordinator; and, the Unit Coordinator's | |||
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14 procedures were being developed to address safety consequences, co-ordination, interface control among participating organi-zations, and methods of acquiring resources for maintenance activitie The inspector told the licensee that the effective-ness of the Unit Coordinator's procedures for planning and scheduling of Safety-Related maintenance activities would be followed it, future NRC:RI: inspections and the licensee acknowledged the inspector's statement. (IFI 387/82-09-06) | |||
6.4.2 The inspector noted that the licensee's maintenance procedures do not address the fire protection requirements adequatel The licensee representatives informed the inspector that they were finalizing the fire protection program for the facility; and upon issuance of the fire protection program the maintenance procedures would be revised to include requirements for a fire watch, control of combustibles and other fire protection aspect The inspector informed the licensee's representative that this item would be followed in a future NRC:RI inspection and the licensee's representative acknowledged the inspector's statemen (IFI 387/80-09-07) | |||
6.4.3 The inspector noted that the program to review, approve and adopt vendor documents for maintenance activities have not been completed. The inspector told the licensee's repre-sentative thit the completion of the review and approval of | |||
. | |||
Vendor documents under the "IOM Program" would be followed during a future NRC:RI inspection and the licensee's repre-sentative acknowledged the inspector's statement. (IFI 387/82-09-08) | |||
6.4.4 The inspector noted that the procedure for Work Authorization (AD-QA-502) did not provide measures to verify classification of maintenance activities as safety-related or non-safety related. The inspector identified this concern to the licensee representative Prior to the conclusion of the inspection the licensee representatives issued Temporary Change No. 82-084 to Procedure No. AD-QA-502 to incorporate a means for verification of the above Work Classificatio The inspector told the licensee's representative that the effectiveness of the licensee's actions, including the above temporary change, would be followed in a future NRC:RI inspection and the licensee's representative acknowledged the Inspector's statement. (IFI 387/82-09-09) | |||
6.4.5 The inspector noted that the procedure for trending and corrective actions, AD-QA-541, was being developed. The inspector told the licensee's representative that the issuance and implementation of AD-QA-541 would be followed in a i | |||
: 1 | |||
future NRC:RI inspection and the licensee's representative acknowledged the inspector's statement. (IFI 387/82-09-10) | |||
\ | |||
6. The inspector noted that the licensee conducted two audits - | |||
in the maintenance area in 1981. The first audit, No. 0-11, was closed out on January 14, 1982. One of the findings, III.A.2, of the second audit (No. 0-21, completed on August 5, 1931) was not resolved at the time of the inspectio The inspector noted that the corrective action response was repeatedly granted extensions. Subsequent to the inspector's discussions with licensee representatives and prior to the conclusion of the inspection, the maintenance department responded to the unresolved item. Closure of this item and the effectiveness of the licensee's management control program in the audit area will be followed in future NRC:RI inspections. (IFI 387/82-09-11). | |||
6. In the areas discussed in Section 5 and 6 of this report, the inspector noticed a lack of communication between the corporate office and the plant, and between levels of manage-ment at each establishment. The inspector discussed this matter with the Plant Superintendent and the Vice President of Operations. These licensee representatives acknowledged the inspector's statements and stated that licensee management was aware of this concern and were diligently pursuing a means to improve communications. The inspector had no 1 further question .4'.8 Other than the weaknesses cited above, the inspector found the licensee's maintenance program to be in compliance with the requirements of the documents stated in Section abov . Plant Surveillance Testing and Calibration Program 7.1 References | |||
-- | |||
Technical Specifications (Proposed), Sections 4 and 6 | |||
-- | |||
Regulatory Guide 1.33-1978, Quality Assurance Program Requirements (Operation) | |||
-- | |||
ANSI N18.7-1976, Administrative Controls and Quality Assurance for ... Nuclear Power Plants | |||
-- | |||
SSES Quality Assurance Manual (QAM), SP-3, Control of Testing and Inspection activities, Rev. 2, September 26, 1980 | |||
~ | |||
: | |||
-- | |||
SSES QAM, Procedure 12.0, Test control, Rev. 5, August 28, 1981 | |||
-- | |||
AD-QA-422, Surveillance Test Program, (Not Issued) | |||
-- | |||
AD-TY-602, I&C Surveillance Draft Procedure Verification Program, Rev. O, August 6, 1981 | |||
-- | |||
AD-QA-605, Maintenance and Calibration of Installed Plant Instru-meatation, Rev. O, December 21, 1981 7.2 Program Review The inspector reviewed the program for surveillance tests, calibrations, calibration checks, and instrument functional tests required by the Technical Specifications; and calibration of plant installed instru-mentation which are used to verify satisfactory performance of Technical Specification Surveillance Testing or Inservice Testing (Pumps and Valves). The program and its administrative procedures were inspected for conformance to the above referenced requirements. The following areas were verifie A master schedule has been established for surveillance an calibration testing | |||
-- | |||
Responsibilities have been assigned for performance of tests and to assure that test schedules are satisfied | |||
-- | |||
Methods and responsibilities have been established for review and evaluation of data, for reporting deficiencies and failures, and for verification that LCO requirements have been satisfied | |||
-- | |||
Adequate manpower was available to perform required testing | |||
-- | |||
Interfaces with other organizations were defined | |||
-- | |||
Responsibilities for training and qualification of test personnel were defined | |||
-- | |||
Implementing procedures for performance of tests have been esta-blished 7.3 Implementation Review The program as defined in paragraph 7.2 has not been completely implemented. Implementing surveillance operating procedures issued, were i reviewed. The results of this review is further detailed in paragraph 1 : 1 | |||
s 7,4 Findings 7. The licensee has established a program for calibration of "Q" system instruments. Calibration frequencies are determined by I&C personnel and data sheets are approved by the I&C supervisor. The inspector informed the licensee that ANSI N18.7-1976, Paragraph 5.2.8, requires that control procedures be instituted for safety related components to assure timely surveillance tests and appropriate documentation, reporting, and evaluation of their results. Moreover, pro-cedures are required for calibration of plant installed instruments used to verify operability of components identified in the Technical Specifications or Inservice Test Progra Additionally, these procedures and the established frequency of calibration must be reviewed by the PORC and approved by the Station Superintendent as required by the Technical Specification The licensee's representative stated that appropriate pro-cedures would be prepared and approved for the calibration of plant installed instruments used to verify Technical Specification Surveillances and Inservice Test This item is required by OL and is open pending completion of-licensee action and subsequent NRC:RI inspection. (IFI 387/82-09-12) | |||
8. Plant Test and Measurement Equipment Calibration and Control Program 8.1 References | |||
-- | |||
Technical Specifications (Proposed), Section 6 | |||
-- | |||
Regulatory Guide 1.33-1978, Quality Assurance Program Requirements (Operation) | |||
-- | |||
ANSI N18.7-1976, Administrative Controls and Quality Assurance for ... Nuclear Power Plants | |||
-- | |||
ANSI N45.2.4-1972, Installation, Inspection and Testing Requirements for Instrumentation . . . of Nuclear Power . . . Stations | |||
-- | |||
SESQAM, Procedure 13.0, Control of Measuring and Test Equipment, Rev. 5 | |||
-- | |||
8.1.6 AD-QA-615, Control and Calibration of Plant Measuring and Test Equipment, Rev. O, February 3, 198 . | |||
} | |||
l 1 | |||
8.2 Program Review The adequacy of the program for calibration and control of test and measurement equipment was inspected. The program and its administrative procedure (reference 8.1.6) were examined for conformance to the' above referenced requirements. The following areas _were verified to be established: | |||
-- | |||
Responsibilities for control of test equipment | |||
-- | |||
Maintenance of a master test equipment list | |||
-- | |||
A calibration schedule Implementation Review Implementation of the test and measurement equipment program was reviewed for conformance to the referenced requirements in paragraph-8.1. The following areas were verifie Calibration schedule was adhered to | |||
-- | |||
Test equipment was in calibration when in use | |||
-- | |||
Calibration data was adequate, accurate and within specified tolerances | |||
-- | |||
Standards used for calibration of test equipment are traceable to the National Bureau of Standards or other testing organization | |||
-- | |||
Test equipment custody control records were adequate | |||
-- | |||
Storage and labeling of test equipment was proper | |||
-- | |||
Primary standardr used for test equipment calibration were in calibration | |||
-- | |||
Usage was traceable for out of calibration test equipment 8.4 Findings 8. The inspector observed that IC-227 (Mensor Mecury Manometer Controller) was used to calibrate IC-247 (Absolute Pressure | |||
'' | |||
Gage) on September 23, 1981; and IC-116 (Dead Weight Tester) | |||
was used to calibrate IC-275 (Torque Wrench) on September 9, | |||
, | |||
1981. In each instance the useage logs for IC-227 and IC- | |||
!' 116 did not reflect the respective calibrations of IC-247 and IC-275. These appeared to be isolated cases and not i part of a general proble , | |||
t | |||
: : | |||
The licensee's_ representative stated that all records would be reviewed against usage logs for the latest calibration period for each piece of test equipment used to calibrate other pieces of test equipment to ensure accuracy. Addition-ally, usage logs for test equipment used by the Calibration Laboratory would be transferred from the I&C Shop to the Calibration Laboratory. Further, clerical personnel would be provided to maintain the logs. The inspector had no further questions concerning this matte . Review Committees 9.1 References | |||
-- | |||
(TS) Sections 6.2.3, 6.5.1 and 6. Proposed TS Sections 6.2.3 and 6. Regulatory Guide 1.33, Rev. 2 and ANSI N18.7-1976, Administrative Controls and Operational QA | |||
-- | |||
NUREG-0737, Clarification of TMI Action Plan Requirements, Item I.B. SECY-80-242, Independent Safety and Engineering Group, May 6, 1980 | |||
-- | |||
FSAR Section 13. .2 Onsite Review Committee 9. Program Review Written procedures addressing the Plant Operations Review Committee (PORC) activities were reviewed to verify that administrative controls have been established for: | |||
-- | |||
Independent review authority and responsibility | |||
-- | |||
Manner by which TS Section 6 reviews will be accomplished | |||
-- | |||
Membership, alternate member, and quorum requirements | |||
-- | |||
Meeting frequency, maintenance and distribution of minutes / records | |||
-- | |||
Lines of communication and interface with other groups such as the offsite review committee | |||
: l | |||
Procedures reviewed were: | |||
-- | |||
Nuclear Department Instruction (NDI) - 1.4.2, Charter-Plant Operations Review Committee, Rev. 0 | |||
-- | |||
NDI-QA-2.1.3, Nuclear Department Open Items Tracking, Rev. 1 | |||
--- | |||
AD-QA-101, Procedure Program, Rev. 4 with temporary changes 82-046, 048 and 049, and a draft revision | |||
-- | |||
AD-QA-102, Plant Operations Review Committee, Rev. 2 and a draft revision | |||
-- | |||
AD-QA-130, Open Items Tracking, Rev. 0 9. Findings The committee has been established; procedures addressing committee activities have been developed; and the committee is functioning with respect to its current responsibilitie The inspector reviewed a number of meeting minutes, interviewed the chairman and another member, and determined the committee is fulfilling its current responsibilities other than the examples discussed in IE Inspection Reports 50-387/81-24 and 82-0 The applicant was aware that a significant increase in the demand on each member's time will occur as review responsi-bilities become greater. Therefore an alternate approach to procedure review has been developed and is described in a proposed change to the TS. Should the proposed TS change be approved by the NRC the applicant has revised applicable procedures which are being held in a final draft form for expeditious review and approval if and when needed. The inspector reviewed the draft procedures and determined that the alternate review could be implemented with a minimum amount of effort and time. | |||
I No violations or concerns were identifie .3 Offsite Review Committee | |||
! | |||
! | |||
9. Program Review Written procedures addressing the Safety Review Committee (SRC) activities were reviewed to verify that administrative controls have been established for: | |||
l | |||
. | |||
: | |||
-- | |||
Independent review and audit authority and responsibility | |||
-- | |||
Manner by which TS Section 6 reviews and audits will be accomplished | |||
-- | |||
Membership, alternate member, and quorum requirements | |||
-- | |||
Meeting frequency, maintenance and distribution of minutes / records | |||
-- | |||
Lines of communication and interface with other groups such as the onsite review committee Procedures reviewed were: | |||
-- | |||
Nuclear Department Instruction (NDI) - QA-1.4.4, Charter-Susquehanna Review Committee, Rev. 1 | |||
-- | |||
NDI-QA-2.1.3, Nuclear Department Open Items Tracking, Rev. 1 | |||
-- | |||
AP-001-001, SRC Rules of Conduct, Rev. 0 | |||
-- | |||
AP-002-001, SRC Review Procedure, Rev. 0 9.3.2 Findings Procedures detailing committee activities have been esta-blished; meetings have been held since May, 1981; the committee has been appointed and is functioning relative to its present level of responsibilities. The inspector reviewed a number of meeting minutes and other records and noted that the committee has conducted meetings on an almost monthly basis. The SRC discussed / reviewed subjects such as: the annual QA audit schedule; documents that will be reviewed; establishment of two standing subcommittees; manner in which reviews are to be accomplished; NRC inspection reports, including those of PAB on other utilities; Cooperative Utility Management audit reports; and, internal audit report The two sub-committees have been established and have conducted meetings. One sub-committee intends to tour the site annually while the other plans two annual visits. Based on document reviews and an interview with the chairman and secretary of tile committee the inspector determined that the committee should fulfill its increased responsibilities as they occu A concern with respect to review of QA audits is addressed in paragraph 15.4.1. | |||
: . | |||
i | |||
No violations or other concerns were identifie .4 Nuclear Safety Assessment Group (NSAG) | |||
9. Program Review The Nuclear Safety Assessment Group (NSAG) program described in the following licensee administrative documents was reviewe NDI-9.1.1, " Charter - Nuclear Safety Assessment Group", | |||
Rev. O, November 11, 1980 | |||
-- | |||
Nuclear Safety Assessment Procedure NSAG-1, Rev. O, January 4, 1982 The program consists of five dedicated engineers responsible for independently assessing the effectiveness and quality of the licensee's nuclear operations and related safety and environinental programs. The NSAG is structured to have three on-site engineers, two corporate office engineers, and a corporate office manager reporting directly to the Senior V.P.-Nuclea . Implementation The inspector reviewed the following areas to ascertain the effectiveness and compliance of NSA Organization Chart, January 1, 1982 | |||
-- | |||
Qualifications of assigned personnel | |||
-- | |||
NSAG Project Report 1-81, September 30, 1981, Circulating Water Pump House Flooding | |||
-- | |||
NSAG Project Report 2-81, November 17, 1981, Potential Safety Hazard Due to Gas Line | |||
-- | |||
NSAG Project Report 1-82, January 19, 1982, Failure to Trip Remotely of Circulating Water Pump | |||
-- | |||
Follow-up actions resulting from the above NSAG Project Reports 9. Findings The inspector's findings are discussed below. | |||
i | |||
: l | |||
9.4.4.1 The Technical Specification requires the NSAG to be composed of "five dedicated, full-time engineers." Currently NSAG has three engineers plus one manager; there are two assigned positions (one onsite and one offsite) that are unfille Before issuance of an operating license, the licensee must staff NSAG to meet the Technical Specifications. This item (IFI 387/82-09-13) will be reviewed during a subsequent NRC inspectio .4.4.2 To maximize NSAG effectiveness in evaluating nuclear safety, NSAG should evaluate nuclear safety issues from many sources. However, there is no established program to inform all Nuclear Department personnel of the NSAG and their ability to assess the safety of licensee nuclear operation The licensee should establish 1) policy for referal of nuclear safety employee concerns to NSAG, including anonymous reporting of such concerns, and ; a continuing means (e.g., | |||
procedures, employee training, employee publications, etc.) | |||
to inform licensee personnel of this polic This item (IFI 387/82-09-14) will be reviewed during a subsequent NRC inspectio .4.4.3 Section 6.4 of NSAO-1 describes follow-up action on NSAG Project Report recommendations, including issuing Open Items in the Nuclear Department Open Items system. The inspector found: | |||
-- | |||
NSAG Project Report 1-81 recommended to the Vice President-Operations that eight items be declared open item Contrary to this no open items were declare The eight items were resolved and documented in a memo by the Plant Superintendent in a timely manne On NSAG Project Report 1-82, the V.P.-Operations, at NSAG suggestion, requested the Plant Superintendent to respond to NSAG recommendations by February 12, 198 On April 1, 1982, no response had been made and no open items had been issue The above examples demonstrate the absence of an effective tracking system to provide follow-up action on NSAG recommenda-tion The licensee should establish an effective tracking system and specify it in administrative procedure This item (IFI 387/82-09-15) will be reviewed during a subsequent NRC inspectio __. . . | |||
* | |||
. | |||
I | |||
10. Non-Licensed Training 10.1 References | |||
-- | |||
Proposed Technical Specifications Section Regulatory Guide (RG) 1.8, Rev. I and ANS 3.1-1978, Personnel Selection and Training- | |||
-- | |||
RG 1.33, Rev. 2 and ANSI N18.7-1976, Administrative Controls'and Operational QA | |||
-- | |||
RG 1.58, Rev. 1 and ANSI N45.2.6-1978, Qualifications of Inspection, Examination and Testing Personnel | |||
-- | |||
FSAR Section 1 .2 Program Review Selected por+ ions of the written' training program were reviewed to verify con 'ency with the above requirements in the following area General Employee training / indoctrination (GET) in subjects such as quality assurance, emergency plan, administrative controls, radiological. safety and prenatal exposure, controlled access and security, and fire / industrial safety | |||
-- | |||
Formal and on-the-job (0JT) training for personnel such as crafts-men, technicians, QA/QC, engineers, operators and other plant support workers | |||
-- | |||
Qualification / certification of personnel as applicable | |||
-- | |||
Guicclines such as job analyses, testing methods and position descriptions for use in determining an individuals qualifications and supplementary training needs | |||
-- | |||
Facility equipment such as workshops, classrooms, lesson plans, | |||
' | |||
course material, and visual aids (including mock-ups, items and | |||
; parts similar to those in plant, etc.) | |||
-- | |||
Delineation of training organization, assignment of responsibilities i and identification of objectives i | |||
-- | |||
Training of instructors, training program evaluation and making of needed change, and management involvement | |||
-- | |||
Documentation of training and retention of required records i | |||
, | |||
I i / | |||
'. | |||
.. | |||
_ _ . - _ | |||
-, | |||
* | |||
: | |||
-- | |||
Staffing and qualifications of selected training department' | |||
personnel The inspector toured the on-site Nuclear Training Center and the corporate Training and Development Center; interviewed management, supervision and instructors; and, reviewed the following documents and procedure Training records of five I&C technicians, four QA auditors, four QC inspectors, seven maintenance craftsmen, and nine plant operators | |||
-- | |||
OJT records for several on-site warehouse employees | |||
-- | |||
Curriculum Committee Report-Electrical Maintenance | |||
-- | |||
Job Analyses for Supervisor of Maintenance, Maintenance Foreman, Mechanic, and Nuclear Quality Assurance | |||
-- | |||
Indices of required and recommended training courses for various selected positions | |||
-- | |||
Nuclear Training Manual (selected portions) | |||
-- | |||
Nuclear Department Instruction (NDI)-QA-10.8.1, Nuclear Department Qualification and Training, Rev. 1 | |||
-- | |||
NDI-10.1.7, Verification of. Applicant's Qualifications and | |||
. Experience, Rev. 0 | |||
-- | |||
NDI-QA-4.1.5, Curriculum Planning, Rev. 0 | |||
-- | |||
NDI-QA-4.1.4, Instructor Certification, Rev. 0 10.3 Findings The Susquehanna Training Center has developed a series of procedures detailing their activities and the training program has been implemente The classrooms are well lighted, equipped and sound insulated. Several trailer rooms are being equipped with items such as pump shaft alignment fixtures, valves, and relays for hands-on training of crafts and trades people. An effort to obtain items similar to in plant equipment is eviden The training staff appears to be qualified and adequate for the current level of training effort. A licensee representative stated that the one unfilled instructor position is due to be filled in the near futur During the exit interview the inspector stated i that requests for additional equipment for craft / trade training should receive management support because this would enhance this aspect of training. The inspector also stated that the overall level of training i effort will increase in the future. Licensee management acknowledged i both statements. | |||
! | |||
, | |||
_- - | |||
* | |||
Lesson Plans have been developed and the inspector noted evidence that they are being used. The mechanical maintenance and GET Lesson Plans that were sampled for review appeared adequate for their intended purpose. The inspector noted that Job Evaluations have been developed for positions in areas such as Maintenance, Operations, Nuclear Quality Assurance, In Service Group, Instruments and Controls, Health Physics, Nuclear Safety Assessment Group, Construction, Nuclear Training Group, and Technical. Indices of required and recommended training courses for specific positions have been developed for approximately fifty percent of the plant staff. The development of the remainder is ongoin Supervisors and management are to use the indices' guidance to determine any supplementary training needs of an individua The inspector noted evidence that these determinations and evaluations are being accomplished. The Supervisor-Technical Training stated that the remaining training indices are scheduled to be completed in the near future so that any identified needed training can be completed prior to fuel load. During a subsequent interview the inspector learned that licensee management had directed this same individual to concentrate full time effort on completing the remaining indices. This is evidenc of continued management support in this are The corporate Training and Development Center provides support company wide in the areas of educational services, management development, supervisor training, training design, and craft / trade training for conventional power stations. These facilities provided well equipped workshops, classrooms, and visual aids. The inspector noted that the capability existed for producing TV training tapes. The center was fully staffed and four individuals who were interviewed appeared well qualified for their position No violations or concerns were identifie . QA Record Program 11.1 References | |||
-- | |||
Proposed Technical Specifications, Section 6 Administrative Controls | |||
-- | |||
Final Safety Analysis Report (FSAR), Section 17.2.17 | |||
-- | |||
ANSI N45.2.9-1974, Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants | |||
-- | |||
Regulatory Guide 1.88, Rev. 2 | |||
-- | |||
ANSI N18.7-1976, Administrative controls and quality assurance for the operational phase of nuclear power plants | |||
- | |||
: : | |||
-- | |||
ANSI N45.2-1977 Quality Assurance Program Requirements 11.2 Program Review The licensee's QA program for records management was reviewed for | |||
; | |||
conformance with references in paragraph 11.1 for: | |||
. | |||
-- | |||
Requirements to maintain and retain Quality Assurance type records | |||
-- | |||
Responsibilities are assigned to ensure QA records' identified will be maintained; | |||
-- | |||
Responsibilities are assigned and controls established to assure transfer and retention of construction and preoperational phase records; | |||
-- | |||
Record storage controls are established which identify the record storage facility, designated custodian (s) in-charge of storage facilities, the filing system for record retrieval, a method for verifying records received are in agreement with preestablished checklists, access control to files and accountability maintained when files are removed from storage, and a method for correcting files and disposing of superceded records; | |||
-- | |||
Responsibili. ties assigned to establish retention periods for records not covered by the FSAR, Technical Specifications or 10 | |||
, CFR; and, | |||
-- | |||
Authority and respcnsibility for authorizing disposal of records assigne Procedures reviewed were: | |||
-- | |||
OPS-3, Control and Issuance of Documents, Rev. 1, April 1, 1981 | |||
-- | |||
OPS-8, The Collection, Storage and Maintenance of Quality Assurance Records, Rev. 1, April 1, 1982 | |||
-- | |||
QA-18.1, Quality Assurance Records, Rev. 5, August 18, 1980 | |||
-- | |||
OPS-1, Operational Quality Assurance Program, Rev. 1, April 1, 1982 | |||
-- | |||
NDI-QA-1.1.2, Nuclear Department Instruction System, Rev. 3, March 25, 1981 | |||
-- | |||
NDI-QA 1.2.1, Nuclear Department Correspondence Control, Rev. 1, January 25, 1982 | |||
__ | |||
- | |||
* | |||
! | |||
NDI-QA-1.2.2, Susquehanna SES Records Management System,-Rev. 0,- | |||
- | |||
-- | |||
December 23, 1981 | |||
-- | |||
NOI-QA-1.2.3, Organization and Administration of the Susquehanna-SES Records Management System, Rev, 0, May 21, 1981 | |||
-- | |||
NDI-QA-1.1.3, Nuclear Department Open Item Tracking, Rev.1,- | |||
March 31, 1981 | |||
-- | |||
Susquehanna SES Records Management System (SRMS) Manual, Procedures P-1 through P-15, Index Rev. 10, March 10, 1982 | |||
-- | |||
AD-TY-193, Release of System from Test Status, Rev. O, January 18, 1982 | |||
-- | |||
IP-020.0, Engineering Turnover Documentation Procedure, Rev. 1, February 1, 1982 | |||
~ | |||
-- | |||
AD 6.1, System / Component Turnover to PP&L, Rev. 9, November 16, 1981 | |||
-- | |||
System Power and Engineering Department, Correspondence File - | |||
Procedure, February 5, 1982 | |||
-- | |||
RD 00-007, Receipt and Processing of System Turnover files from ISG. December 15, 1981 11.3 Implementation 11. The inspector reviewed the following documents, records, and instructions to verify implementation of established QA records syste SRMS Training Matrix (draft) | |||
-- | |||
Records type list (draft) | |||
-- | |||
Susquehanna SES QA document list, Rev. 10, December 14, 1981 | |||
-- | |||
SRMS work instructions (corporate office and site) | |||
11. The inspector selectively sampled various QA records to verify that the record: | |||
-- Was listed on a records checklist or index; | |||
-- | |||
Was readily retrievable from its designated file or microfilm storage location as applicable; | |||
, , l '< | |||
. | |||
. | |||
, | |||
, | |||
, . | |||
L | |||
-- | |||
Was provided suitable protection and stored inifile cabinets or container in a predetermined'lecation; and, l When received by Document Control Center, was processed in accordance with the SRMS manual and work instruction The following record types were examine Various PP&L General Correspor.dence , | |||
-- | |||
SRMS personnel training records for three clerks and one supervisor | |||
-- | |||
Fi.ceen receipt inspection reports including,80-076, 80-284, 81-459 and 81-180 | |||
-- | |||
Twenty Work Authorizations including U 12078, E-80-A and S 10156 | |||
, | |||
-- | |||
Eight Procurement Documents (Purchase orders) including 500442, 500C23 and 500070 | |||
-- | |||
Audit SESS, Records Management System (May 1981) and NGA Audit. SRMS (August 1981) | |||
-- | |||
System Turnover Packages P2.1 125 Vdc Battery, P8 Vdc Battery, and P76.1 Leak Detection System | |||
^ | |||
-- | |||
Various plant procedures and manuals 11. The inspector toured the licensee's document control centers (DCC) both at the site and corporate office to verify that file room access was being controlled, microfilming and record processing was being performed as described in work instructions, and records were being transmitted to the DCC with the required transmittal form In addition interviews were conducted with record management system supervisors and personnt.1 to determine if the current staffing level and training was adequat .4 Findings No violations were identified, however the following minor deficiencies were identified by the inspecto . FSAR Table 17.2-1 commits the licensee to full compliance with ANSI N45.2.9-1974, " Requirements for Collection Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants." ANSI N45.2.9, Section 5.6, states that QA | |||
__ _ _ . . _ _ _ _ - | |||
: 1 | |||
records discussed in the standard should be afforded the equivalent protection of a NFPA Class A, four hour minimum rated facilit Currently the licensee does not have an approved storage facility onsite or at the corporate office. Without approved storage facilities, completed Q.A. records, transmitted to the Document Control Center for interior storage prior to microfilming, duplication, and distribution are not provided adequate fire protectio This records storage problem was previously identified in | |||
-' SESS QA audits performed on the Records Management System in May 1981 at the site and August 1981 at the. corporate offic The following corrective action has been planned or is ongoing as a result of these audit A vault type room will be constructed in the new corporate office complex scheduled for completion in the fall of 198 A vault type room will be construction at the site in conjunction with the expansion of the Service and Administration Buildin As an ir,terim measure the licensee is procuring approved | |||
> | |||
_ | |||
offsite storage for completed QA records and, archival storage for aperture cards of design drawing and print Additionally, microfilming of QA records is being performed as soon as possible to reduce the time a QA | |||
/ record must be stored without adequate fire protectio , | |||
The corrective action, as discussed above will be reviewed during a subsequent inspection (IFI 387/82-09-16). | |||
11.4.2 ANSI N45 2.9 Section 5.3 requires that storage procedures be prepared and include the rules governing access to and control of the file The inspector identified that access control to the QA records file room at the site is not adequately define Currently the licensee has several clerks working in the file room and access into the rocm is controlled only by a sign that allows access to " authorized personnel" onl The licensee's representatives acknowledged the inspectors concern and stated that: | |||
' | |||
. | |||
-- | |||
The Document Control Center (DCC) and records file room is to be relocated to the Service and Administration Building in June 1982. This move will establish a separate QA record file room; and, | |||
-- | |||
The procedure for access control to the file room is to be revised and issued concurrently with the planned DCC mov This item will be reviewed in a subsequent NRC:RI inspection (IFI 387/82-09-17). | |||
11.4.3 The inspector determined that no formal control exists for Records Management System Work Instructions at the corporate office. The existing work instructions do not have an index and many pen and ink change are unofficially incorporated into the work instruction The licensee's representatives' acknot:1 edged the inspectors concern and stated that: | |||
-- | |||
P.6., " Preparation, Review and Distribution of New or Revised Susquehanna SES Records Management System Procedures" would be revised to include adn,inistrative control of work instructions or a new work instruction would be developed to provide administrative control; and, | |||
~ | |||
-- | |||
All current work instruction would be reviewed and reissued in accordance with the new procedure or instruc-tio The inspector had no further questions in this are .4.4 The inspector determined that Records Management System (RMS) personnel both at the site and the corporate office were receiving training, but that: | |||
-- | |||
Only a draft instruction exists to delineate the required training for RMS personnel at the corpprate office; and | |||
-- | |||
TM training matrix for RMS personnel at the corporate office should be expanded to include QA/QC indoctrinatio The licensee's representative acknowledged the inspector's concerns and stated that the draft work instruction and training matrix would be revised to include QA/QC indoctrina-tion and then be formally issued. | |||
! | |||
I | |||
, | |||
: : | |||
The inspector had no further questions in this are . Through discussions with RMS supervisor staff and review of current organizational charts the inspector determined that the licensee is adequately staffed to effectively 4 manage the QA records program present workloa The inspector also verified that the licensee had projected future staff requirement for the growth of the QA records progra . Document Control Program 12.1 References | |||
-- | |||
Proposed Technical Specifications, Section 6, Administrative Control | |||
-- | |||
Final Safety Analysis Report (FSAR) Sections 17.2.5 and 17. ANSI N45.2-1977, Quality Assurance Program Requirements | |||
: | |||
-- | |||
ANSI N18.7-1976, Administrative Contrels and Operational Quality Assurance for the Operational Phase of Waclear Power | |||
; | |||
-- | |||
Reg. Guide 1.33, Rev. 2, February 1978, Quality Assurance Program Requirements 12.2 Program Review | |||
. | |||
The licensee's program for document control was reviewed to verify that the program is consistent with the requirements of the references | |||
in paragraph 12.1 above and to determine that the program: | |||
-- | |||
Requires that current as-built drawings, including piping and instrument drawings (P&ID's) be provided to the plant in a timely manner; | |||
-- | |||
Requires that proposed drawing changes and the revised drawings receive the same level of management review required of the 4 original drawings; | |||
-- | |||
Provides provisions for identifying and marking of drawings that have outstanding revisions; | |||
-- | |||
Establishes control of obsolete drawings; | |||
-- | |||
Requires that discrepancies found between as-built drawings and the as constructed facility are handled as design changes; | |||
- _ . . | |||
! | |||
: E | |||
l | |||
-- | |||
Requires master indicies to be maintained for drawings, manuals, technical specifications, procedures that indicate the current revision; and, | |||
-- Provides a mechanism for document issuance, distribution, use, and periodic review. | |||
I The following procedures, which describe the administrativa controls for document control were reviewed by the inspecto OPS-3, Control and Issuance of Documents Rev.1, April 1,1982 | |||
-- | |||
OPS-4, Document Review, Rev. 1, April 1, 1982 | |||
-- | |||
NDI-QA-2.2.6, As-built Drawing Requirements, Rev. O, January 4, 1982 | |||
-- | |||
NDI-QA-8.1.3, Document Review, Rev. O, September 28, 1981 | |||
-- | |||
AD-QA-101, Procedure Program, Rev. 4, February 18, 1982 | |||
-- NQAP 1.1, Preparation and Control of NQA Section Procedures, Re , January 18, 1982 l | |||
-- | |||
AD-QA-301, Operations Procedure Program, Rev. O, January 7, 1982 i -- | |||
AD-QA-500, Conduct of Maintenance, Rev. O, January 6,1982 | |||
-- | |||
AD-QA-600 Conduct of Instrumentation Rev. O, February 1, 1982 l | |||
' | |||
12.3 Implementation The following documents, indices, and instructions were reviewed to verify implementation of the established document control progra Mailing lists for controlled manuals at the corporate office l | |||
l | |||
-- | |||
Open items tracking system (corporate office) for tracking procedure l | |||
review | |||
! | |||
I -- | |||
Time Sharing Option (TS0) master indices for check-off-lists and data sheets | |||
-- | |||
TSO Control Manual list | |||
-- Plant maintenance information system for procedure review tracking | |||
-- | |||
Controlleo procedures master indices for administrative, maintenance, operational surveillance and' operational procedures | |||
: : | |||
-- | |||
Advanced Text Management System (ATMS) | |||
-- | |||
Storage and Information Retrieval System (STAIRS) | |||
-- | |||
Master drawing index and drawing " Stick File" indices | |||
-- | |||
Document Control Work Instructions | |||
-- | |||
Transmittal forms (SUSA-105) for index distribution Drawings, procedures, manuals, check-off-lists (COL) and surveillance data sheets were selectively sampled at the site to verify that con-trolled copies were consistent with the Document Control Center (DCC) | |||
master indices. The following controlled copy locations were checke Control room procedures, COL's, data sheets, and drawing " stick files" | |||
-- | |||
Technical support center (TSC) procedures, COL's, data sheets and drawing " stick files" | |||
-- | |||
Technical library procedures and drawing '.' stick files" | |||
-- | |||
Mechanical Maintenance Shop procedures, data sheets and drawing | |||
" stick files" | |||
-- | |||
Permit Office - drawing " stick files" | |||
-- | |||
Document Control Center procedures C0C's, and data sheets At each location twenty or more administrative, operating, surveillance maintenance procedures, operational procedure COL's, and P&ID's were checked against the master indice Additionally, the inspector randomly sampled station procedures and reviewed the Plant Maintenance Information System's (PMIS) weekly activity worklist to verify completion of the required periodic procedure revie .4 Findings No violations were identified, however the following minor concerns and inspector followup items were identified by the inspecto . Revision to controlled copies of manuals and procedures are issued, distributed and entered by the DCC staf Ruisions to check off list (COL) and surveillance data sheets are issued and distributed by the document control staff to the applicable functional unit The actual COL and data sheet file updating is done by the functional unit receiving the form * | |||
. l | |||
1 The inspector determined that revisions to COL's and Surveil-lance Data Sheets were not all being issued from the DCC with a transmittal, and the control room file of COL's and Data sheets was not consistent with the DCC master indice The licensee's representative acknowledged the inspector's finding and stated that: | |||
-- | |||
All future revision to COL's and Data sheet would be issued to the applicable functional units by transmittal; and, | |||
-- | |||
The control room's file of COL's and data sheets would be completely maintained by the document control staf The inspector had no further questions in this are . Each Functional Unit at the corporate office has issued procedure In addition each unit has established a procedure to control the writing, distribution, use, revision and review of these procedure The inspector identified that the following corporate office Functional Unit's procedures did not address a periodic review as required by ANSI-N18.7 197 . | |||
-- | |||
Susquehanna Records Management System | |||
-- | |||
Nuclear Quality Assurance | |||
-- | |||
Nuclear Licensing | |||
-- | |||
Nuclear Engineering The licensee's representatives acknowledged the inspector's findings and stated that each Functional Unit procedure would be revised to include a periodic review of their procedure The corrective action as stated above will be reviewed during a subsequent NRC:RI inspection (IFI 387/82-09-18). | |||
13. Procurement 13.1 References | |||
-- | |||
Regulatory Guide 1.123, Rev. I and ANSI N45.2.13-1976, QA for Procurement of Items and Services | |||
- | |||
: | |||
- | |||
-- | |||
FSAR Section 1 .2 Program Review The written procurement control program was reviewed to verify that , | |||
administrative controls were established for: | |||
-- | |||
The identification of items purchased; identification of tests and/or special instructions, technical requirements and documenta-tion to certify the item; assuring that the contractor / supplier has implemented a QA program consistent with 10 CFR 50, Appendix B, and where deemed appropriate by the licensee, access to the supplier's plant or records for purposes of audi Accomplishment of an assignment of responsibilities for: initiation of procurement documents; review and approval of specifications differing from the original design documents; review and approval of procurements, including changes thereto; and, the designation of quality classification of procured item Evaluation and approval of bidders / suppliers including assignment of responsibilities for the following functions: review / update of the listing of approved suppliers; providing for rights of access to supplier's facilities and records; and, maintenance of records of suppliers qualifications and audi The following licensee administrative controls / procedures were reviewe ~ Operational Policy Statement (OPS)-10, Procurement Control, Re (a draft) | |||
-- | |||
Nuclear Department Instruction (NDI)-QA-1.4.2, Procurement of Quality Materials for SSES, Rev. 0 | |||
-- | |||
NDI-QA-1.4.3, Procurement of Services for Susquehanna SES, Rev. 0 | |||
-- | |||
NDI-QA-2.1.4, Production, Maintenance and Control of the Defective Device List, Rev. B | |||
-- | |||
NDI-QA-2.1.6, Identification, Evaluation, and Tracking of Class IE Components requiring Environmental Qualification, Rev. 0 | |||
-- | |||
NDI-QA-15.3.2, Identification, Evaluation, and Tracking of Class IE Components Requiring Environmental Qualification, Rev.1 (a draft) | |||
-- | |||
Plant procedure AD-QA-210, Procurement Control Activities, Rev. 0 | |||
-- | |||
Procurement Department procedure (PDN)-QA-2.1, Processing of Orders Requisitioned by SSES Plant Staff, Rev. O | |||
- _ _ _ _ _ _ _ - _ _ _ _ _ _ - . _ _ _ _ _ __ . _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ . | |||
: | |||
-- | |||
PDN-QA-4.1, Approved Supplier Quality Listing Procedure, Rev. 0 | |||
-- | |||
Power Plant Engineering Nuclear Plant Procedure (PPENPP)-4, Review of Requisitions for Quality Material, Rev. 3 13.3 Findings Detailed procedures for procurement activities have been develope An oasite engineering group has been established and has been reviewin requisitions for spare part Items, components, and sub-components are evaluated as to their intended use and assigned a quality classifi-cation. Procedures identify procurment requirements for each classifi-cation. The item identifier, its classification, procurement require-ments, and stock inventory are entered into a computerized information system. Applicable plant personnel have been trained in the retreival of this information at variously located terminals. The inspector conducted an overview of spares purchasing and determined that engineer-ing evaluations were done; ite 5, devices and sub-components were classified as to the level of their intended use; this information was entered into the information system; and, these activities were being accomplished in accordance with the established procedures. The inspector also conducted a detailed review of the manner in which the onsite engineering group evaluated and classified sub-components of Limitorque Operators (spares) and identified no inadequacie The inspector discussed present and future levels of activities and staffing with the group supervisor who stated that most spares have already been purchased and management made a determination that future activities could be accomplished with the current staffing level. The inspector acknowledged the supervisor's statements and had no further question No violations or concerns were identifie . Receipt, Handling, and Storage 14.1 References | |||
-- | |||
Final Safety Analysis Report (FSAR) Sections 17.2.7, 17.2.13 and 17.2.15 | |||
-- | |||
ANSI IN45.2-1977, Quality Assurance Program Requirements | |||
-- | |||
ANSI N45.2.2-1972, Packaging, Shipping, Receiving, Storage and l | |||
Handling | |||
! | |||
-- | |||
ANSI N45.2.13-1976, Quality Assurance for the Procurement of Items and Services | |||
! | |||
i | |||
, | |||
. - , - - . . | |||
._n,_ -. . - . , _ . - | |||
: : | |||
, | |||
14.2 Program Review The licensee's program for receipt, storage and handling of safety related equipment and materials were reviewed to verify that the program is consistent with the requirements of the references in pagagraph 14.1 above and to determine that administrative controls established: | |||
-- | |||
Requirements for conducting receipt inspections on all incoming safety related materials and equipment; | |||
-- | |||
Requirements that materials and equipment be examined for confor-mance with requirements specified on orginal procurement documents; | |||
-- | |||
Provisions for identification of those materials and equipment that can be accepted by only a " certification of quality" (C of C); | |||
-- | |||
Controls for acceptance of items including tagging / marking for storage or immediate use; | |||
-- | |||
Controls for nonconforming items which include: | |||
. Marking and segregating nonconforming items | |||
' | |||
. Disposition of nonconforming items (reevaluate, rework, repaired, or return) | |||
. Prohibiting use of nonconforming items | |||
. Documentation required of the noncomforming items | |||
. Notification of licensee audit group responsible for supplier (vendor) evaluation documentation of nonconforming items; | |||
-- | |||
Methods for conditional release of nonconforming items including justification for use, documentation and authority for conditional release; | |||
-- | |||
Requirements for providing proper levels of storage and appropriate environmental conditions; | |||
-- | |||
Requirements for specifying storage controls including access, identification, coverings, and preservatives; | |||
-- | |||
Requirements for periodic inspections of the storage areas; | |||
' -- | |||
Requirements for specifying maintenance and care of items in storage including shelf life; | |||
! | |||
- . . - _ . -, --. , | |||
: : | |||
-- | |||
Requirements for routine and special handling measures; and, | |||
-- | |||
Controls for hoisting equipmen The following procedures were reviewed to verify administrative controls have been establishe OPS-10 Procurement Control, Rev. O, April 1, 1982 | |||
-- | |||
OPS-12, Administrative Control of Plant Operations Rev. 1, April-1, 1982 | |||
-- | |||
OPS-17, Control of Plant Material, Rev. 1, April 1, 1982 | |||
-- | |||
OPS-5, Deficiency Control System, Rev. 1, April 1, 1982 | |||
-- | |||
NDI-QA-2.1.6, Identification, Evaluation, and Tracking of Class IE Components Requiring Environmental Qualifications, Rev. O, March 26, 1981 | |||
-- | |||
NDI-QA-2.4.2, Procurement of Quality Materials for SESS, Rev. O November 17, 1980 | |||
-- | |||
NDI-QA-8.1.2, Reportable defects and noncompliance, Rev. 1, October 19,,1982 | |||
-- | |||
AD-QA-200, Material Control Activities, Rev.1, February 3,1982 | |||
-- | |||
AD-TY-190, Preoperational Phase Housekeeping and Protection Program for Safety Related Equipment, Rev. O, February 16, 1982 | |||
-- | |||
AD-QA-109, Nonconforman.ce Control Program, Rev. 0 | |||
-- | |||
NQAP 4.1, Procurement Document and Specification Review, Rev. O, March 13, 1981 | |||
-- | |||
QCP-30, Receiving Inspections, Rev. O, May 27, 1981 | |||
-- | |||
QCP-31, Periodic Inspection of storage facilities, Rev. O December 23, 1981 | |||
-- | |||
Specification P1003, Technical Requirements for the procurement of spare parts, Rev. B 14.3 Implementation 14. The inspector selectively sampled safety related materials and equipment received on site to verify: | |||
L | |||
: : | |||
-- | |||
Receipt inspections were conducted in accordance with administrative controls | |||
-- | |||
Disposition of the item was in accordance with admini-strative controls | |||
-- | |||
Storage of items including packaging, presevatives, covering and environmental conditions were in accordance with manufacturers' recommendations | |||
-- | |||
Tagging / marking allowed tracing the item back to procure-ment documents, receipt documents and " quality certifi-cation" documents | |||
-- | |||
Nonconforming items were clearly marked ar.d segregated from other safety related items | |||
-- | |||
Documentation of nonconforming items was transmitted to affected organization for them to determine final item disposition The following safety related items were selected for revie Shaft Sleeve Catagory No. 8625, P. O. 500109, Receipt Inspection Report (RIR) 81-062 | |||
-- | |||
Pump Gasket, Catalogue No. 1463, P. O. 500009, RIR 80-075 | |||
-- | |||
Weld Rod, Catalogue No. 022005, P. O. 600170, RIR 81-222 | |||
-- | |||
Fan, Catalogue No. 8645, P. O. 500085, RIR 81-114 | |||
-- | |||
Pivot Pins, Catalogue No. 22028, P. G. 500442, RIR 81-073 | |||
-- | |||
Globe Valves, Catalogue No. 8164, P. O. 500070, RIR 80-304 | |||
-- | |||
Bearings, Catalogue No. 1481, P. O. 900021, RIR 80-177 | |||
, | |||
-- | |||
Impeller Keys, Catalogue No. 13231, P. O. 500213, RIR l 81-459 l | |||
l 14. The inspector reviewed the receipt inspection logs for l | |||
1980, 1981 and 1982 and selectively sampled Receipt Inspection | |||
' | |||
Reports (RIR) that contained nonconforming safety related items to verify that: | |||
. | |||
- _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ | |||
: : | |||
' | |||
' | |||
-- | |||
The necessary actions were taken to resolve the existing nonconformance; and, | |||
-- | |||
Adequate resolution for final disposition of nonconforming item was obtaine The following receipt inspection reports were reviewe RIR 80-243 with nonconformance report (NCR)-80-311 and Quality Assurance Action Request (QAAR) C-81-023 | |||
-- | |||
RIR 80-076 with NCR 80-301 and 80-106 and QAAR C-82-014 | |||
-- | |||
RIR 81-529 with NCR 81-723 and QAAR C-81-166 | |||
-- | |||
RIR-459 with QAAR C-82-029 | |||
-- | |||
RIR-81-160 with NCR 81-244 | |||
-- | |||
RIR 81-180 with QAAR C-81-044 14. The inspector accompanied licensee personnel during their monthly inspection of the onsite warehouse to verify: | |||
-- | |||
Controlled access to the PP&L storage area is maintained; | |||
-- | |||
Cleanliness and good housekeeping practices are enforced; | |||
-- | |||
Fire protection was commensurate within the type of storage area and materials involved; | |||
-- | |||
Food and associated items were not permitted; | |||
-- | |||
The adequacy of material storage, including protective coverings, coatings and preservatives; | |||
-- | |||
Hazardous material segregation; and, | |||
-- | |||
Clear identification of shelf life of applicable materia . The inspector interviewed the materials supervisor to determine that the current staffing level as depicted in the plant's organizational charts was adequate to effectively manage and maintain the spare parts inventory progra In addition the inspector reviewed the training records of 2 stockmen and 2 quality control receipt inspector to verify that their trainino conformed to the training matrix and was adequate to perform their assigned tasks. | |||
r f | |||
- _ _ - _ _ _ _ . _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ ._ ._- | |||
:- : | |||
14.4 Findings No violations were identified, however the inspector identified that work instructions were not being used in the Materials Section. The materials personnel use administrative procedure AD-QA-200, Material Control Activities, for all receipt, storage and handling activitie The inspector expressed a concern that work instructions should be used to provide more detailed instruction for stores personne The licensee's representative acknowledge the inspector's concern and stated that: | |||
-- | |||
A draft work instruction index has been generated which identified work instructions that are needed; and, | |||
-- | |||
Work instruction will be written and issue The inspector had no further question in this are . Audits 15.1 References | |||
-- | |||
Technical Specification Section 6.5.2; | |||
-- | |||
FSAR Chapter 1 Regulatory Guide 1.33, Rev. 2, Quality Assurance Program Require-ments (Operation), February, 1978 | |||
-- | |||
ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants | |||
-- | |||
ANSI N45.2.12-1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants i | |||
-- | |||
ANSI N45.2.23-1978, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants 15.2 Program Review The inspector reviewed the audit program as described in the following licensee administrative document OPS-7, Auditing and Surveillance Activities, Rev. 1, April 1, | |||
; 1982 | |||
-- | |||
NDI-QA-8.1.8, Performance of Quality Assurance Audits, Rev. O, February 15', 1982 | |||
I | |||
! | |||
l l | |||
__ ,, | |||
. , . _ _ _ _ - . _ , _ _ . . . . _ , , _ . ~ _ . . . . . . | |||
. | |||
* | |||
.' | |||
-- | |||
NQAP 9.1, Audits, Rev. 1, February 11, 1982 | |||
-- | |||
NQAP 10.1, Certification of Quality Assurance Auditors, Rev. O, | |||
' | |||
November 30, 1981 | |||
-- | |||
Training Curriculum - Nuclear Quality Assurance, Rev. O, January 25, 1982 15.3 Implementation The inspector reviewed the implementation of the audit program by reviewing the followin , | |||
-- | |||
1982-1983 NQA Audit Schedule, January 29, 1982 | |||
-- | |||
1981 Audit Status Log | |||
-- | |||
Organization Chart of Nuclear Quality Assurance, January 1,1982 | |||
-- | |||
1981 Management Audit of PP&L, October 29, 1981 | |||
-- | |||
Audit 0-81-08, Audit of Plant Technical Specification Compliance, j Janua ry 29, 1982 | |||
-- | |||
Audit 0-82-Q2, Audit of Nonconformance Control and Corrective Action, February 25, 1982 | |||
-- | |||
Audit IA-82-2, Audit of NQA Home Office Activities, March 10, | |||
. | |||
1982 i | |||
-- | |||
Audit 0-81-05, Audit of Fire Protection Program, November 20, 1981 | |||
-- | |||
Audit 0-81-03, Audit of ISG Procurement Interface, December 4, 1981 | |||
-- | |||
procurement Audit of Power Conversion Products, February 20,19fil | |||
! | |||
-- | |||
Audit P-82-01, Supplier Evaluation - Westinghouse Medium Motor | |||
, and Gearing Division, January 26, 1982 | |||
-- | |||
Spare Parts Quality Verification - Anchor Darling Valve Co., | |||
October 12, 1981 | |||
! | |||
-- | |||
Spare Parts Quality Verification - American Air Filter, March 11, j 1982 | |||
-- | |||
Audit * 0-3, NQA Audit of ISG, July 2, 1980 | |||
* Audits of Preoperational Testing Program | |||
. .-_ , _ _ _ _ . . _ _ _ _ . - _ _ - - _ _ =_ | |||
: | |||
-- | |||
Audit *0-8, Operations QA Audit of Preoperational Testing Activities, January 26, 1981 | |||
-- | |||
Audit *0-9, Audit of Initial Instrument Calibration and Analog Loop Test, January 26, 1981 | |||
-- | |||
Audit *0-12, PLNQA Site Operations Audit "Preoperations Tbsting Activities, March 6, 1981 | |||
-- | |||
Audit *0-20, Audit of ISG Administrative Controls, July 27, 1981 | |||
-- | |||
Audit *0-81-01, Audit ISG Implementation of Preoperational Test, October 14, 1981 | |||
-- | |||
Audit *0-81-03, Audit of ISG Procurement Interface, December 4, 1981 | |||
-- | |||
Audit *0-82-03, Implementation of Preoperational Testing Activities, (Audit Period February 1, 1982 to March 9, 1982) | |||
The audit program was inspected for the following: | |||
-- | |||
Audits are performed by qualified audit personnel who are inde-pendent of the area being audited; | |||
-- | |||
A long range audit schedule exists and the planned audits are being completed in a timely manner; | |||
-- | |||
Each audit utilizes an audit checklist or procedure covering the areas scoped for audit; | |||
-- | |||
deficiencies identified during the audit are resolved or are being carried as open items; | |||
-- | |||
Periodic review of the audit program is performed to determine its status and adequacy; and, | |||
-- | |||
Review of the audit program by the Susquehanna Review Committee (SRC), the offsite safety review committee, is performed in an effective manner and satisfies the Technical Specification require-ment .4 Findings The inspector's findings are discussed belo . Technical Specification Section 6.5.2 delineates the respon-sibilities of the Susquehanna Review Committee (SRC), including the required audits of unit activities. The Technical Specification' required audits under the cognizance of the | |||
* Audits of Preoperational Testing Program | |||
.' | |||
SRC will be performed by the Nuclear Quality Assurance Organization. However, there is no administrative procedure for SRC review of the audits. The SRC Chairman stated that an administrative procedure for SRC audit review will be approved by the SRC, issued and sent to the NRC for information by May 1, 1982. Before issuance of an operating license, the licensee must establish and issue a proceduce to satisfy the SRC review of audits required by the Technical Specifi-cation. This item (IFI 387/82-09-19) will be-reviewed during a subsequent NRC inspectio . FSAR Section 17.2.1.1 commits the licensee to "the performance of an annual, preplanned and documented assessment of the 0QA Program in which corrective action is identified and tracked." In 1980 and 1981 this annual assessment was performed by an audit by the Cooperative Management Audit Program and the findings were resolved. However, there is no administrative procedure which specifies this FSAR commit-ment. The licensee should reflect this FSAR commitment in the administrative procedures to ensure it is met on an annual basis. This item (IFI 387/82-09-20) will be reviewed during a subsequent NRC inspectio . Concerns were developed regarding the QA audit coverage of the Preoperational Testing Program and the QA staffing available to perform both Pre Op and Operational audit These concerns and violations are discussed in paragraph | |||
. . Plant Procedures 16.1 References | |||
-- | |||
Technical Specifications (Proposed) | |||
-- | |||
Regulatory Guide 1.33-1978, Quality Assurance Program Requirements (Operation) | |||
-- | |||
ANSI N18.7-1976, Administrative Controls and Quality Assurance for ... Nuclear Power Plants | |||
-- | |||
SSESQAM, Procedure 7.1, Control and Issuance of Documents, Re , November 17, 1980 16.2 Program Review The administrative procedures for the plant procedures program were reviewed. Their status including preparation, approval, issuance and conformance to the above referenced requirements were inspecte Procedures reviewed were: | |||
i | |||
- - | |||
, _ _ | |||
' | |||
: | |||
-- | |||
AD-QA-101, Procedure Program, Rev. 4, February 19, 1982 | |||
-- | |||
AD-QA-102, Plant Operations Review Committee, Rev.'2, March 31, 1982 | |||
-- | |||
AD-QA-301, Operations Procedure Program, Rev. O, January 7, 1982 | |||
-- | |||
AD-QA-400, Conduct of Technical Support, Rev. O, January 13, 1982 16.3 Implementation Review A sampling of issued plant procedures were reviewed to determine compliance to requirements referenced in paragraph 16.1 and admini-strative procedures detailed in paragraph 16.2. Procedures were reviewed for: | |||
-- | |||
Proper review and approval | |||
-- | |||
Correct formats | |||
-- | |||
Conformance to Technical Specification requirements, and system status during component testing is in conformance with Technical Specification limiting condition for operaticns (where applicable) | |||
-- | |||
Technical information provided in the procedure was accurate | |||
-- | |||
Proper past completion reviews for test procedures | |||
~ | |||
-- | |||
Stepwise instructions provided in the degree of detail necessary for performing the procedure Procedures reviewed were: | |||
General Operating Procedures | |||
! | |||
-- | |||
GO-00-002, Plant Startup and Heatup, Rev. O, (not issued) | |||
-- | |||
G0-00-003, Power Ascension, Rev. D, (not issued) | |||
-- | |||
GO-00-004, Plant Shutdown to minimum power, Rev. D, (not issued) | |||
System Operating Procedures | |||
-- | |||
OP-02-001, 125 V DC System, Rev. 1, September 2, 1982 | |||
-- | |||
OP-13-001, Fire Protection System, Rev. 0, March 15, 1982 | |||
-- | |||
OP-24-001, Diesel Generators, Rev. O, February 10, 1982 | |||
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_ _ _ _ _ _ _ _ _ _ . . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ ______ _____ ____ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _ | |||
: | |||
-- | |||
OP-31-001, Rod Worth Minimizer, Rev. O, December 16, 1981 | |||
-- | |||
OP-51-001, Core Spray System, Rev. O, December 24, 1981 | |||
-- | |||
OP-53-001, Standby Liquid Control System, Rev. O, December 16, 1981 | |||
-- | |||
OP-61-001, Reactor Water Cleanup, Rev. O, March 1,1982 | |||
-- | |||
OP-83-001, Automatic Depressurization System and Safety / Relief Valves, Rev. O, January 5,1982 | |||
-- | |||
OP-84-001, Main Steam, Rev. O, January 7,1982 | |||
-- | |||
OP-73-001, Containment Atomsphere Control, Rev. O, January 18, 1982 Surveillance Operating Procedures | |||
-- | |||
50-56-001, Exercising Control Rods Weekly For Operability, Re O, December 10, 1981 | |||
-- | |||
S0-53-001, Standby Liquid Control System Monthly Operability Demonstration, Rev. O, December 23, 1981 | |||
-- | |||
S0-73-001, Semi-Annual Hydrogen Recombiner Test, Rev. O, March 9, 1982 | |||
-- | |||
S0-52-002, HPCI Pump Quarterly Flow Verfication, Rev. O, February 18, 1982 | |||
-- | |||
S0-50-002, RCIC Pump Quarterly Flow Verification, Rev. 0, January 18, 1982 | |||
-- | |||
S0-49-002, RHR System Flow Verification, Rev. O, November 6, 1981 | |||
-- | |||
50-31-001, Rod Worth Minimizer Operability Prior to Rod Withdrawal, Rev. O, December 10, 1981 16.4 Findings 16. CFR 50, Appendix B, Criterion V and Technical Specification 6.8 require that approved procedures be established for performing safety related activities and for operating and maintaining plant equipmen The inspector observed that a significant percentage of procedures had not been approved or issued, although procedures required to perform plant activities had been identified by the licensee. Unissued procedures were identified in the following area i l | |||
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AD - Administrative Procedures | |||
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GO - General Operating Procedures | |||
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OP - System Operating Procedures | |||
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ON - Off Normal Procedures | |||
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EO - Emergency Operating Procedures | |||
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AR - Alarm Response Procedure (Control Fire Protection Panels and remote alarm response panels only) | |||
-- | |||
S0 - Operations Surveillance Procedures | |||
-- | |||
SI - Instrument and Control Surveillance Procedures | |||
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SM - Maintenance Surveillance Procedures | |||
-- | |||
SC - Chemistry Surveillance Procedures | |||
-- | |||
RE - Reactor Engineering Procedures The inspector informed the licensee, that with only a few excepti.ons, procedures included in but not limited to the above categories must be issued and ready for implementation upon issuance of an Operating Licensee (OL). The licensee's representative concurred with the inspector's finding and stated that all necessary procedures would be issued by O This is an open item pending completion of licensee action (IFI 387/82-09-21). This finding is related to previous findings in Inspection Report 387/81-24 (Items 387/81-24-05 and 09). | |||
16.4.2 As noted in paragraph 16.4.1 above, the licensee had not established procedures for remote (from the control room) | |||
panel alarms. A licensee representative stated that procedures would be prepared for remote alarms but not necessarily by OL; and noted that the SSES-FSAR, Section 13.5.2.1.5, refers only to the need for Control Room alarm response procedure The inspector informed the licensee's representative that Regulatory Guide 1.33-1978, paragraph 5, requires that procedures be prepared for responses to all safety related alarms and does not differentate between Control Room and remote alarm panels. Additionally, procedures for these alarms would be required to be issued by OL. This is an open item pending completion of licensee action (IFI 387/82-09-22). | |||
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16.4,3 The inspector questioned the availability and control over operating and surveillance operating procedures to be used by operations personnel in the plant. A licensee's repre-sentative stated that a " User Control" system had been established by procedure A0-QA-10I to provide controlled copies of procedures to plant personnel as required. He further stated that the Operations Department was evaluating the establishment of " satellite" files at various locations in the plan The inspector informed the licensee's representative that if | |||
" satellite" files or other methods which are extensions of the " User Control" system are established to provide controlled copies of procedures to operators, then additional admini-strative controls must be established to specify the method Additionally, such controls must be established prior to O This is an open item pending completion of licensee evaluation and action (if any) (IFI 387/82-09-23). | |||
16. In response to a TMI Action Item per NUREG 0737, the licensee's representative committed to providing second verifications of valve status. The inspector observed that valve lineup checkoff lists (COL's) in system operating procedures did not require second verifications nor was second verification of valve position required on restoration from system blockin , However, procedures did require second verification for system blocking tag installation The licensee stated COL's would be revised to ensure that there was second verification of key valves (such as flow path valves and locked valves) and that the system blocking procedure would be revised to provide for second verification on system restoration. The inspector informed the licensee that this action must be completed prior to OL. This is an open item pending completion of licensee action (IFI 387/82-09-24). | |||
; 16. The inspector observed that instrument valves and instrument l isolation valves were not included in system valve lineup COL's nor were they included in system piping diagram (P&ID's). | |||
The licensee's representative stated that instrument valves were under the control of the I&C Department and are controlled by I&C procedures; however, instrument root valves were j under control of the Operations Department. | |||
l The licensee's representative stated that instrument root i valves would be included in valve lineup COL's. He further I | |||
stated that instrument valves downstream of the root valve I would remain in I&C procedures with appropriate verification ~ | |||
The inspector' informed the licensee that this action is required prior to OL. | |||
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This item is open pending completion of licensee action (IFI 387/82-09-25). | |||
16. During review of surveillance operating procedures, the inspector observed that test procedures did not include data required by the Inservice Test Program (IST), ASME Code Article IWV-3000 Series, Pumps and Valves Testing. The licensee's representative confirmed that implementing pro-cedures had not yet been established and that IST's and surveillance procedures were in the process of being revise The inspector informed the licensee's representative that IST implementing procedures are required prior to OL. This is an open item pending completion of licensee action (IFI 387/82-09-26). | |||
16. The inspector observed the following deficiencies in system operating and surveillance procedure OP-13-001, " Fire Protection System", does not yet include fire detection and alarm procedures plus associ-ated checkoff lists. The licensee stated that an expiration date of June 15, 1982 had been established for this procedure to ensure that it is revised to include the abov Procedures OP-83-001, " Automatic Depressurization System and Safety / Relief Valves"; S0-83-001, " ADS System Functional Test"; and 50-83-002, " ADS Valve 18-month Manual Actuation" did not adequately address the operation and use of the Accoustic Monitor Position Detection System. The licensee stated that these procedures would be revised to more completely address the accoustic monito , " Standby Liquid Control System Monthly", did not adequately identify Technical Specification acceptance criteria concerning pump operation and flow path verifi-cation. Additionally, a pump packing leakage check is accomplished by the procedure but a pump run time is | |||
, | |||
not specified. The licensee stated that the procedure | |||
! would be revised. | |||
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S0-49-002, "RHR System Flow Verification", acceptance criteria reaction refers to incorrect procedure paragraphs for determining flow for the suppression pool cooling mode of operation and the procedure acceptance criteria specifies a test line pressure which has not yet been incorporated into current Technical Specification | |||
> | |||
4.5.1.6.2. The licensee stated that this procedure was currently undergoing revision ._ . | |||
_ _ - . | |||
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The inspector informed the licensee that the above procedures must be corrected prior to OL. This is an open item pending completion of licensee action (IFI 387/82-09-27). | |||
The licensee's representative also stated that an " operational shakedown" was in progress and that many of the operating procedures would receive a " walk through" by operators and be revised as required, prior to 0L. The inspector acknow-ledged the licensee's representatives statemen . ANSI N18.7-1976 requires that a mechanism shall be provided for issuance of operating (standing) orders. The inspector observed that no such mechanism exists although an instruction does exist for issuance of night orders (special orders) as required by ANSI N18.7-1976, paragraph 5.2.4. The licen:ce stated that an Operations Department Operating Instruction (01) would be written to cover issuance of st&nding order The inspector had no further question . Exit Interview The findings of this inspection were discussed with licensee representatives periodically during the inspection and the status of the inspection was discussed with licensee management on March 26, 198 Licensee management was informed of the scope and purpose of the inspection on March 12, 1982 and at entrance interviews conducted at the Susquehanna Steam Electric Station and PP&L corporate offices on March 22, 198 An exit interview was conducted at PP&L corporate offices on April 2, 1982, at which time the findings of the inspection were presented (see paragraph I for attendees). PP&L management acknowledged the inspector positions at the exit interview relative to the specific corrective action times contained within this report as applicable to the specific actions to be accomplished before operating license issuance. | |||
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}} | }} | ||
Latest revision as of 11:35, 21 November 2023
| ML20054F197 | |
| Person / Time | |
|---|---|
| Site: | Susquehanna  |
| Issue date: | 05/27/1982 |
| From: | Blumberg N, Caphton D, Eapen P, Meyer G, Napuda G, Shaub E, Shaub T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML20054F190 | List: |
| References | |
| 50-387-82-09, 50-387-82-9, NUDOCS 8206150304 | |
| Download: ML20054F197 (52) | |
Text
i 6-I
< U.S. NUCLEAR REGULATORY COMMISSION
REGION I
l Report No. 82-09 Docket No. 50-387 _
License No. CPPR-101 Priority -
Category B Licensee: Pennsylvania Power & Light Com>any l 2 North Ninth Street Allentowr., Pennsylvania- 18101 Facility Name: Susquehanna Steam Electric Station, Unit 1 l Inspection At: Allentown and Berwick, Pennsylvania Inspection Conduc d: March 22-26, 29-31 and April 1-2, 1982 l
Inspectors: #, . W &
G.Napuda, R4 actor Inspec4.or d' ate '
['T Yk
@ N. Blumberg, Reactor Inspector S 27 82-date
[ I bh 4 P. K. Eapen, Reactor Inspector 02782-date f$
G. Meyer, Reactor Inspector
% Z 27 8 date c#f N 7. Shaub', Reactor Inspector 3 27 82-date r 'l./ / / @ 7 h L
~ Caphton, Ctfief, Management Programs /date'
ection En inepring Inspection Branch g
, Approved by: / tiV 7/ 6?// 72-
! D. Ca'pht6nf Chief, Management Programs date'
l Section, Engineering Inspection Branch Inspection Summary: Inspection on March 22-26, 29-31 and April 1-2, 1982 (Inspection Report No. 50-387/82-09)
Areas Inspected: Routine, announced inspection by region based inspectors of 1)
l the Pre-operations Quality Assurance Program implementation, and 2) the readiness l
of the Quality Assurance Program for operations in the areas of design changes /
modifications and engineering; maintenance; plant surveillance testing and
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C206150304 820528 PDR ADOCK 05000387 Q PDR
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calibration control; test and measurement equipment; onsite and offsite. safety committees; non-licensed training; document control; records; procurement; receipt, storage and handling of items; audits; plant procedures,; and, previously identified items. The inspection involved 46 inspector hours in-office by five inspectors, 361 inspector-hours onsite by five region bassd inspectors and one supervisor, and 131 inspector-hours at the corporate offices by four region based inspector ,
Results: Of the thirteen areas inspected, two 1.tems of noncompliance were identified in one area (violation - failure to obtain proper authorization prior to work on a safety-related system, paragraph 4'.1; violation - failure'to conduct comprehensive audits of pre-operational testing, paragraph 4.1).
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DETAILS Persons Contacted
A: -Pennsylvania Power & Light Company (PP&L), Allentown, P * W. Barlserich, Supervisor-Nuclear Licensing .
A.' Butt, Consultant Engineer (Quadrex Corp.)
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- J. Calhoun, Senior Vice President - Nuclear
- S. Cantone, Manager - Nuclear Support
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/ .
> L. Clark, Quality Engineer
- A. Craven, Senior Information Specialist - Nuclear Administration
- N. Curtis, Vice President - Engineering
- R. Featenby, Assistant Project Director - Site J. Gutshall, Senior Project Engineer R. Harris, Licensing W. Heske, Manager - Nuclear Administration
- P. Henrikson, Manager Licensing C. Kalter, Assistant to Manager - Nuclear Support
- B. Kenyon, Vice President - Nuclear Operations
,
W. Lurch, Manager - Education and. Training
- A. Male, Manager - Nuclear Design
- C. McVicker, Assistant Manager - Nuclear Quality Assurance (Operations)-
- J. Medeiros, Supervisor - Nuclear Records
- J. Miltenberger, Manager - Nuclear Safety Assessment
- K. Neddenien, Information Specialist - Nuclear Administration-
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,/ / H. 0heim, Group Supervisor - Electrical Design t i * A. Sabol, Manager - Nuclear Quality Assurance O. Sattar, Senior Project Engineer
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j N. Schwan, Assistant Manager - Nuclear Quality Assurance (Engineering /
Procurement)
R. Shovlin, Assistant Project Director B. Skoras, Engineer - Electrical Design
- J. Stefanko, Manager - Nuclear Fuels J. Spadotto, Supervisor - Management Development
- W. Ward, Manager - Training H. Webb, Supervisor - Nuclear Maintenance Support Susquehanna Steam Electric Station, Berwyck, P L. Adans, Supervisor of Operations F. Butler, Instrument and Control / Computer (I&C/C) Supervisor
, R. Byram, Acting Supervisor of Operations P. Cape:osto, Acting Resident Nuclear QA Engineer D. Cassel, Group Supervisor - Nuclear Site Engineering N. Covington, Assistant ISG Supervisor J. Edwards, Personnel and Administrative Supervisor F. Eisenhuth, Senior Compliance Engineer C. Figard, ISG Supervisor (Bechtel)
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F. Graber, Operations Consultant
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J. Graham, Staff Assistant J. Green, Operations QA Supervisor E. Gorski, QC Supervisor M. Johnson, ISG Quality Engineer (Bechtel)
- H. Keiser, Superintendent - Susquehanna Steam Electric Station G. Kuczynski, Electrical Maintenance Supervisor D. Lauer, ISG Coordinator B. Lloyd, Maintenance Engineer W. Lowthert, Supervisor - Technical Training T. Nork, Acting Supervisor - Maintenance A. Piemontese, Power Production Engineer A. Reasin, Test Director - ISG G. Robinson, I&C Foreman M. Rutkoskie, Assistant (I&C) Foreman J. Skrocki, Project Engineer (Spare Parts Analysis)
M. Sherman, Assistant Electrical Foreman D. Sitler, Senior Results Engineer NRC Personnel
- S. Ebneter, Chief, Engineering Inspection Branch, Division of Engineering and Technical Programs
- J. McCann, Resident Inspector
- G. Rhoads, Senior Resident Inspector 2. Licensee Action on Previous Inspection Findings (0 pen) Inspector Follow Item (387/81-24-08): No procedure existed which addressed system cleaning. The inspector observed that new procedure AD-QA-503 provided instructions for determining grades of system cleanliness in accordance with ANSI N45.2.1 but contained no procedures for system cleaning and flushing. The licensee stated that these procedures were contained in corporate engineering procedure M-1039, " Cleanliness of Piping and Associated Components". The inspector determined that M-1039 did conform to ANSI N45.2.1. The licensee agreed to revise AD-QA-503 specify that M-1039 was to be used whenever system cleaning or flushing was required. This item remains open pending completion of licensee actio (Closed) Inspector Follow Item (387/81-24-04): Procedure AD-QA-502, " Work Authorization System", to be revised to further define the makeup of the final work package. The inspector verified that AD-QA-502 has been revised to specify the necessary documents to be part of a completed work packag Based on the above, this item is closed.
l (Closed) Inspector Follow Item (.187/81-24-07) Cleanliness zones as specified
'
in Procedure AD-00-48 did not appear to completely conform to those specified in ANSI N45.2.3. The inspector verified that AD-00-48 has been reissued as AD-QA-503, " Housekeeping / Cleanliness Control", a,d has been revised to incorporate the requirements of ANSI N45.2.3. Based on the above, this item is closed.
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3. General The primary intent of this inspection was to ascertain the readiness of the applicant for operation of the plant in the specific areas inspecte Procedures were reviewed to verify they were consistent with commitments and clearly detailed the particular activit Employees were interviewed to determine that thay were aware of their authorities and responsibilities, and knowledgeable in applicable procedures. Records of activities that had taken place were reviewed to determine the effectiveness of the established program. Personnel and training records of selected interviewed employees were also reviewed to verify that job incumbents had adequate education /
experience or proper supplemental training for their positions. When possible, ongoing activities were observed to assure they were accomplished in accordance with established procedures. These areas are discussed in paragraphs 5 -1 Those items that must be corrected / resolved prior to the issuance of an Operating License (0L) or fuel loading are so identified and this action will be verified as appropria+e during a subsequent inspection (s). Those concerns / minor items that must be corrected / resolved prior to or when an activity occurs (other than OL or fuel load) will be examined during sub-sequent routine inspection . Site Nuclear Qi911ty Assurance (NQA) Staff for the Preoperational Testing Prngram 4.1 The NQA site staff responsibilities covers both preoperational testing and operations. As of April 1,1982 the site staff consisted of one QA supervisor, two technical engineers plus one technical contracto The licensee's representative stated that one senior NQA analyst was recently (3/29/82) transferred to the plant staf It was further stated that attempts were underway to fill this vacanc The licensee's representative stated that the NQA site staff utilization had been approximately 60% of available time involved with QA review of pro-cedure QA Audits are scheduled and preplanned. A review of the audits scheduled indicated some slippage relative to the established schedule. A review of the audits performed and completed in the preoperations testing area identified 8 audits (see paragraph 15.3) of the ISG (Integrated Startup Group) controlled preoperational testing work over an approximate 18 month period, June 16, 1980 through March 9, 198 An inspection was made of the QA audits performed on the ISG conducted preoperational testing program to determine audit overall coverage, comprehensiveness and degree of periodicity. The eight QA audits when placed on a matrix to analyze coverage, except in the area of preopera-tional test implementation and test witness, provided essentially a one time audit of some aspects of the ISG controlled run preoperational test program. The audit coverage noticably lacked evidence of periodi-
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city. No reaudits of deficient areas was evident. 'All aspects of the ISG preoperational testing program was not covered by the audits. For example, there were no comprehensive audits of ISG handling and pro-cessing into the ISG program the turned over system packages from construction; and, many Q listed systems lacked evidence of having any aspects audited. A comparison made of the eight audits performed by QA against the Q-list showed there were no planned and periodic QA Audits of, e.g. Q Listed Systems Nos. 4.0, 5.0, 6.0, 9.0, 11.0, 11.0, 17.0, 45.0, 54.0, 55.0, 58.0, 60.0, 61.0,-62.0, 64.0, 69.0, 70.0, 71.0, 73.0, 75.0, 76.0 and 8 A review of the QA audits that were conducted appeared to provide meaningful coverage within the limits of their scope; however, 10 CFR 50 Appendix B Criterion XVIII, Audits, states that a comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the (preoperational testing) quality assurance program and to determine the effectiveness of the program, and Criterion II Quality Assurance Program, states that the "...
program shall provide control over activities ... consistent with their importance to safety". The licensee's QA audits appear not to meet the intent of Criteria XVIII and II in that only some aspects of the preoperational testing program had been audited and many activities regarding Q listed systems important to safety had either no audit coverage or only one time audit coverage (lacked periodicity). This is a violation (387/82-09-01).
The construction turnover over package to ISG for Core Spray System No. 51A was selectively sample reviewed. Twenty items from the construc-tion turnover exception list were examined to determine how they were incorporated into the ISG system. All twenty items had been placed on the ISG Startup Work List (SWL). One item entered on the list on May 16, 1980 was followed up since it was still open and the core spray preoperational pump test had been essentially completed. This item was titled " Install Core Spray Strainers IF 404 A,C on HBB 104-1 after flush." There was also a similar entry on the SWL for Strainers IF 404 B and The flush was completed prior to the core spray pump test. Bechtel Drawing M152, Rev. 15 showed the strainers installation to be two each on the 'A and C' and 'B and D' Core spray pump suction lines inside the suppression pool area. A visual inspection was made inside the suppression pool on April 1, 1982 to determine whether or not the strainers were installe Strainers were visually observed to be installed on the top side of each core spray pump suction line Te The suppression pool had been filled with water, howeve- visual clarity through the water was excellent when aided with light. A blind flange (handle) tab could be seen projecting from the flange at the bottom of the Tee however no strainer was installed on the bottom side of the Te A review made of ISG Startup Work Authori:ations (SWA) identified one written to cover installation of blind flanges for the system 51A Core
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Spray pump suction line, however no SWA was identified by ISG personnel to cover the installation of the strainers found to be installed on the top side of the Te AD 6.4 Rev. 9, Startup Work Authorization, states that"... all hardware-identified under PP&L Quality Assurance Program will require an SWA
... "and" work is considered to be any activity that requires a craftman to perform that activity." The installation of the Q listed core spray pump suction line strainers without an SWA is in violation of the AD 6.4, Rev. 9 procedure. This is a violation (387/82-09-02).
In addition to the two violations identified above, the existing QA staff was found to be inadequate to provide auditing and surveillance coverage for preoperational testing activities and station oparational activities. This concern will be communicated to the licensee by NRC RI managemen The adequacy of licensee management overview (i.e. audits, etc.) of preoperational testing activities and the readiness of the plant for initial OL activities will be reviewed during a subsequent NRC-RI Inspection. (IFI 387/82-09-28).
4.2 Quality Control 4. References
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Regulatory Guide 1.33, Rev. 2, " Quality Assurance
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Program Requirements (Operation)", February,1978
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ANSI N 18.7 - 1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants"
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ANSI N 45.2.6 - 1978, " Qualifications of Inspection, Examination, and Testing Personnel ... of Nuclear Power Plants" 4. Program Review The inspector reviewed the quality control program, as described in the following licensee administrative document OPS-14, Control of Inspection and Testing, Rev. 1, April 1, 1982
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NQAP 11.1, Quality Control Program, Rev. O, January 18, 1982
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QCP-10, Training, Qualification, and Certification of Inspection and Test Personnel, Rev. O, April 28, 1981
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QCP-20, Inspection of Maintenance,-Modifications, and Testing Activities, Rev. O, November 8, 1981
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QCP-21, Establishing Inspection Points, Rev. O, November 8, 1981
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QCP-50, Quality Control Checklists, Rev. O, June 8, 198 . Implementation The inspector reviewed the implementation of the audit program in the following areas:
-- . Organization Chart of NQA-Quality Control;
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1982 QC Inspection Log;
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1982 QC Call Number Log; and,
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Quality Control Inspection Reports (QCIR's), including QCIR's #82-982, 82-1098, 82-1101, 82-1123, 82-1124 During the review of the quality control program, the inspector verified the followin Inspections are performed by qualified inspectors who are independent of the work being inspected
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The inspectors are notified of the work being performed (e.g., hold points, notification points, sign-off on work authorizations, etc.) and the inspectors utilize importance to safety as a criteria in evaluating which inspections to perform
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The inspections utilize a checklist or procedure covering the areas inspected to ensure a thorough inspection
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Deficiencies identified during inspection are formally entered into a non-conformance/ corrective action system and tracked until resolution 4.2.4 Findings The inspector found no violations or open items relative to Quality Contro ! t 8'
5. Design Changes, Modifications, Tests and Experiments 5.1 References
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ANSI N45.2.8 - 1975, Mechanical Installation, Inspection and Testing
-- ~ ANSI N18.7 - 1976, Administrative Controls and Operational QA
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Proposed Technical Specifications
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FSAR Sections 13 and 17 5.2 Program Review The inspector reviewed the licensee's programs for design changes, facility modifications, and conduct of tests and experiments to verify the following
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Required QA programs have been developed in accordance with the regulatory requirements, industry standards and licensee's commit-ments
-. Procedures have been established for control of design changes, modifications, and tests and experiments
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Appropriate responsibilities have been established and assigned
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Administrative controls have been established to preclude unautho-rized activities; assure prompt recall of obsolete documents; and facilitate distribution of approved documents
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Administrative control procedures have been established to revise the plant procedures, the training program and the facility drawings as necessary to reflect any facility changes as described in this section
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Proper communication channels have been established among partici-pating organizations
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Provisions have been established to transfer the records to the records storage facility
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Provisions have been established to assure that activities are conducted using approved procedures, whenever applicable
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Post implementation testing and acceptance criteria are established
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Responsibility and the method for reporting activities to the Nuclear Regulatory Commission have been established The following documents were reviewed to assure the program complies with the above requirement OPS-9, Control of modifications and design activities, Rev. 0
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NDI-QA-2.2.3, Design Responsibility Delegation (Draft)
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NDI-QA-14.2.2, Safety Evlauations, Rev. 0
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DC 010.0, Review Verification and approved of design documents Rev. 0
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DC 040, Design Change Mechanism, Rev. 0
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DC 110.0, Design calculation control, Rev. 0
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AD-QA-410, Plant Modification program, Rev. 1
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AD-QA-411, Plant modification design control, Rev. 1 5.3 Implementation The programs discussed in this Section are not required until the facility license is issue Currently, programs for design changes, modifications, and tests and experiments are conducted for the licensee by the Architect Engineer. The licensee representatives advised the inspector that licensee personnel have not completed any safety related activity covered by the programs discussed in this section. However at the time of the inspection, several projects were in progress in this area and the licensee intends to use these activities to determine the effectiveness of established procedures and administrative control The licensee representatives discussed their on going projects with the inspector and demonstrated how the applicable portions of the program were implemented for these project .4 Findings 5. The licensee has no specific procedures that address the conduct of Tests and Experiments under the provisions of 10 CFR 50.59. During discussions with corporate and plant staff, the inspector learned that the licensee intends to conduct these tests and experiments under the provisions of procedure AD-QA-101, Procedure Program. The inspector stated that additional guidance and instructions needed to be developed to aid individuals in performing tests and
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s
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experiments prior.to the issuance of the Operating License and the licensee acknowledged the inspectors statement. The effectiveness of the licensee's tests and experiments program will be followed in future NRC:RI inspection (IFI 50-387/82-09-03).
5. The procedure for delegating design responsibilities had not been issued prior to the completion of this inspection. The licensee's representative told the inspector that the required procedure was being drafted and it would be issued prior to the issuance of the Operating License. The licensee's design change and modification program allows both the corporate and plant staff to perform the modification The plant staff told the inspector that limitations in manpower, expertise and other resources would allow them to undertake only relatively simple design modifications. The inspector stated that the scope of the modifications carried out by the plant staff should be well defined; the plant procedures should be adequate to perform the delegated
'
responsibility; and, the plant staff should be adequately trained to perform the delegated responsibility. The licensee representatives told the inspector that the above items would be completed prior to delegating any design respon-sibility to the plant staff. This will be followed in a future NRC:RI inspection (s). (IFI 50-387/82-09-04)
5. As noted in Section 5.3 above, the licensee has not yet completed a safety related project using established pro-cedures. The inspector discussed the need for management controls (Management review. QA review, verification by the Independent Safety Assessmt ,t Group, etc.) of the projects during the trial use of the procedures, to assess the effective-ness of the program and to implement corrective action The licenste representatives agreed to institute the necessary management controls. The effectiveness of these actions will be followed in future NRC:RI inspections (IFI 50-387/82-09-05)
Except for the weaknesses cited above, the licensee's programs for design changes, modifications, and tests and experiments appear to meet the requirements of the references listed in Section 5.1 above.
,
6. Maintenance Programs 6.1 References
,
--
ANSI N18.7 - 1976, Administrative Controls and Operational QA
. - .
- 1 1 ANSI N45.2.6 - 1973, Qualifications of Inspection, Examination, and Testing Personnel
--
AN5I N45.2.1 - 1973, Cleaning Fluid Systems and Components
--
Proposed Technical Specifications
--
Section 13 and 17 of the FSAR 6.2 Program Review The inspector reviewed the licensee's maintenance program to verify the followin Written procedures have been established for initiating requests for routine and emergency maintenance
--
Criteria and responsibilities have been established for review and approval of all maintenance requests
--
Criteria and responsibilities have been established to identify-safety and non-safety related maintenance activities
--
Criteria and responsibilities have been established for verifying work classification and the use of industry accepted procedures
--
Criteria and responsibilities have been established for designating hold points and for performing work inspections
--
Administrative controls have been established to prepare, assemble, review and store the maintenance records
--
A preventive maintenance and a corrective maintenance program have been established
--
A program has been established to review the corrective maintenance program, to assess the adequacy of the preventive maintenance program, to identify repetitive failures of parts and components and to identify design deficiencies
--
Work control procedures have been established for special process, fire protection, radiation protection, physical security, clean-liness and housekeeping
--
Provisions have been established for the Coordination of maintenance activities and interface controls among participating organization
--
Methods and responsibilities for equipment control have been established
- t
--
Personnel are trained and qualified to perform maintenance The inspector reviewed the following documents to assure that the requirements of the references cited in section 6.1 above are me OPS-13, Maintenance, Installation of modifications and related activities, Rev. 0
--
AD-QA-500, Conduct of Maintenance, Rev. 0
--
AD-QA-502, Work Authorization System, Rev. 2
--
AD-QA-503, Housekeeping / Cleanliness, Rev. 1
--
AD-QA-520, Station Welding Program, Rev. 0
--
AD-QA-521, Brazing and Iiller Metal Control, Rev. 0
--
AD-00-540, Computerized Preventive Maintenance System (Draft),
Re AD-00-504, Preventive Maintenance Program Prior to Full Load, Rev. 0
--
NDI-14.1.2,, Work Process Maintenance, Re OPS-13, Maintenance, Installation of Modifications and Related Activities, Rev. 0
--
MT-GE-001, Motor Inspection and Maintenance, Rev. 0
--
MT-GE-011, Chiller Maintenance and Inspection, Rev. 0
--
MT-GE-013, 480 kV Load Center Inspection and Breaker Maintenance, Rev. 0
--
MT-GE-015, Advanced Control Room (ACR) Electrical Maintenance, Rev. 0
--
MT-64-003, Recirculation Pump Seal Removal and Replacement, Re MT-64-004, Reactor Recirculating Pump Seal Rebuild and Test, Re MT-62-007, Steam Dryer Removal and Installation, Rev.1 l --
MT-53-001, Standby liquid Control Pump Disassembly and Reassembly, l
Rev. 1 i
!
_ _ _ _ .- ___ . _ . _ - _ _
- t
--
MT-49-001, RHR Pump Disassembly and Reassembly, Rev. 1
--
IC-DC-100, Transmitter / Converted Calibration / Calibration Check Procedure, Rev. 2
--
IC-DC-200, Indicator / Receiver Calibration / Calibration Check Procedure, Rev. 1
--
IC-DC-400, Switch / Bistable / Calibration / Calibration Check Procedure, Rev. 1
--
IC-DC-600,-Temperature Element and Wiring Check Procedure, Rev. 1 6.3 Implementation The inspector reviewed maintenance activities authorized under the following Work Authorizations to assess the effectiveness of the program implementatio U-14666 - Investigate and Rework RBCCW Pump for high vibration
--
U-14649 - Clean and Inspect 024 Standby Diesel Generator
--
P-10940 - Preventive Maintenance for the control structure emergency supply fa U-27120 - Maintenance for FT 01109 A&B transmitter system
--
U-27071 - Check control loop of HPCI
--
U-27075 - Wiring change to APRM/RBM channels
--
U-27175 - RHR Sample line repair
--
U-24300 - Adjust valve position indicator for HV-1F020 (15112)
--
U-24225 - HPCI Turbine Exhaust check valve maintenance
--
U-24251 - Removal of drywell head
--
U-24291 - Gas leak replacement for valves on ADS, MSRV air header 6.4 Findings 6. The inspector noted that the licensee has not establisNd the required procedures to implement planning and scheduling of maintenance as described in Section 5.2 of OPS-13. The licensee representatives told the inspector that the planning and scheduling of maintenance activities would be the respon-sibility of the Unit Co-ordinator; and, the Unit Coordinator's
_
14 procedures were being developed to address safety consequences, co-ordination, interface control among participating organi-zations, and methods of acquiring resources for maintenance activitie The inspector told the licensee that the effective-ness of the Unit Coordinator's procedures for planning and scheduling of Safety-Related maintenance activities would be followed it, future NRC:RI: inspections and the licensee acknowledged the inspector's statement. (IFI 387/82-09-06)
6.4.2 The inspector noted that the licensee's maintenance procedures do not address the fire protection requirements adequatel The licensee representatives informed the inspector that they were finalizing the fire protection program for the facility; and upon issuance of the fire protection program the maintenance procedures would be revised to include requirements for a fire watch, control of combustibles and other fire protection aspect The inspector informed the licensee's representative that this item would be followed in a future NRC:RI inspection and the licensee's representative acknowledged the inspector's statemen (IFI 387/80-09-07)
6.4.3 The inspector noted that the program to review, approve and adopt vendor documents for maintenance activities have not been completed. The inspector told the licensee's repre-sentative thit the completion of the review and approval of
.
Vendor documents under the "IOM Program" would be followed during a future NRC:RI inspection and the licensee's repre-sentative acknowledged the inspector's statement. (IFI 387/82-09-08)
6.4.4 The inspector noted that the procedure for Work Authorization (AD-QA-502) did not provide measures to verify classification of maintenance activities as safety-related or non-safety related. The inspector identified this concern to the licensee representative Prior to the conclusion of the inspection the licensee representatives issued Temporary Change No.82-084 to Procedure No. AD-QA-502 to incorporate a means for verification of the above Work Classificatio The inspector told the licensee's representative that the effectiveness of the licensee's actions, including the above temporary change, would be followed in a future NRC:RI inspection and the licensee's representative acknowledged the Inspector's statement. (IFI 387/82-09-09)
6.4.5 The inspector noted that the procedure for trending and corrective actions, AD-QA-541, was being developed. The inspector told the licensee's representative that the issuance and implementation of AD-QA-541 would be followed in a i
- 1
future NRC:RI inspection and the licensee's representative acknowledged the inspector's statement. (IFI 387/82-09-10)
\
6. The inspector noted that the licensee conducted two audits -
in the maintenance area in 1981. The first audit, No. 0-11, was closed out on January 14, 1982. One of the findings, III.A.2, of the second audit (No. 0-21, completed on August 5, 1931) was not resolved at the time of the inspectio The inspector noted that the corrective action response was repeatedly granted extensions. Subsequent to the inspector's discussions with licensee representatives and prior to the conclusion of the inspection, the maintenance department responded to the unresolved item. Closure of this item and the effectiveness of the licensee's management control program in the audit area will be followed in future NRC:RI inspections. (IFI 387/82-09-11).
6. In the areas discussed in Section 5 and 6 of this report, the inspector noticed a lack of communication between the corporate office and the plant, and between levels of manage-ment at each establishment. The inspector discussed this matter with the Plant Superintendent and the Vice President of Operations. These licensee representatives acknowledged the inspector's statements and stated that licensee management was aware of this concern and were diligently pursuing a means to improve communications. The inspector had no 1 further question .4'.8 Other than the weaknesses cited above, the inspector found the licensee's maintenance program to be in compliance with the requirements of the documents stated in Section abov . Plant Surveillance Testing and Calibration Program 7.1 References
--
Technical Specifications (Proposed), Sections 4 and 6
--
Regulatory Guide 1.33-1978, Quality Assurance Program Requirements (Operation)
--
ANSI N18.7-1976, Administrative Controls and Quality Assurance for ... Nuclear Power Plants
--
SSES Quality Assurance Manual (QAM), SP-3, Control of Testing and Inspection activities, Rev. 2, September 26, 1980
~
--
SSES QAM, Procedure 12.0, Test control, Rev. 5, August 28, 1981
--
AD-QA-422, Surveillance Test Program, (Not Issued)
--
AD-TY-602, I&C Surveillance Draft Procedure Verification Program, Rev. O, August 6, 1981
--
AD-QA-605, Maintenance and Calibration of Installed Plant Instru-meatation, Rev. O, December 21, 1981 7.2 Program Review The inspector reviewed the program for surveillance tests, calibrations, calibration checks, and instrument functional tests required by the Technical Specifications; and calibration of plant installed instru-mentation which are used to verify satisfactory performance of Technical Specification Surveillance Testing or Inservice Testing (Pumps and Valves). The program and its administrative procedures were inspected for conformance to the above referenced requirements. The following areas were verifie A master schedule has been established for surveillance an calibration testing
--
Responsibilities have been assigned for performance of tests and to assure that test schedules are satisfied
--
Methods and responsibilities have been established for review and evaluation of data, for reporting deficiencies and failures, and for verification that LCO requirements have been satisfied
--
Adequate manpower was available to perform required testing
--
Interfaces with other organizations were defined
--
Responsibilities for training and qualification of test personnel were defined
--
Implementing procedures for performance of tests have been esta-blished 7.3 Implementation Review The program as defined in paragraph 7.2 has not been completely implemented. Implementing surveillance operating procedures issued, were i reviewed. The results of this review is further detailed in paragraph 1 : 1
s 7,4 Findings 7. The licensee has established a program for calibration of "Q" system instruments. Calibration frequencies are determined by I&C personnel and data sheets are approved by the I&C supervisor. The inspector informed the licensee that ANSI N18.7-1976, Paragraph 5.2.8, requires that control procedures be instituted for safety related components to assure timely surveillance tests and appropriate documentation, reporting, and evaluation of their results. Moreover, pro-cedures are required for calibration of plant installed instruments used to verify operability of components identified in the Technical Specifications or Inservice Test Progra Additionally, these procedures and the established frequency of calibration must be reviewed by the PORC and approved by the Station Superintendent as required by the Technical Specification The licensee's representative stated that appropriate pro-cedures would be prepared and approved for the calibration of plant installed instruments used to verify Technical Specification Surveillances and Inservice Test This item is required by OL and is open pending completion of-licensee action and subsequent NRC:RI inspection. (IFI 387/82-09-12)
8. Plant Test and Measurement Equipment Calibration and Control Program 8.1 References
--
Technical Specifications (Proposed), Section 6
--
Regulatory Guide 1.33-1978, Quality Assurance Program Requirements (Operation)
--
ANSI N18.7-1976, Administrative Controls and Quality Assurance for ... Nuclear Power Plants
--
ANSI N45.2.4-1972, Installation, Inspection and Testing Requirements for Instrumentation . . . of Nuclear Power . . . Stations
--
SESQAM, Procedure 13.0, Control of Measuring and Test Equipment, Rev. 5
--
8.1.6 AD-QA-615, Control and Calibration of Plant Measuring and Test Equipment, Rev. O, February 3, 198 .
}
l 1
8.2 Program Review The adequacy of the program for calibration and control of test and measurement equipment was inspected. The program and its administrative procedure (reference 8.1.6) were examined for conformance to the' above referenced requirements. The following areas _were verified to be established:
--
Responsibilities for control of test equipment
--
Maintenance of a master test equipment list
--
A calibration schedule Implementation Review Implementation of the test and measurement equipment program was reviewed for conformance to the referenced requirements in paragraph-8.1. The following areas were verifie Calibration schedule was adhered to
--
Test equipment was in calibration when in use
--
Calibration data was adequate, accurate and within specified tolerances
--
Standards used for calibration of test equipment are traceable to the National Bureau of Standards or other testing organization
--
Test equipment custody control records were adequate
--
Storage and labeling of test equipment was proper
--
Primary standardr used for test equipment calibration were in calibration
--
Usage was traceable for out of calibration test equipment 8.4 Findings 8. The inspector observed that IC-227 (Mensor Mecury Manometer Controller) was used to calibrate IC-247 (Absolute Pressure
Gage) on September 23, 1981; and IC-116 (Dead Weight Tester)
was used to calibrate IC-275 (Torque Wrench) on September 9,
,
1981. In each instance the useage logs for IC-227 and IC-
!' 116 did not reflect the respective calibrations of IC-247 and IC-275. These appeared to be isolated cases and not i part of a general proble ,
t
- :
The licensee's_ representative stated that all records would be reviewed against usage logs for the latest calibration period for each piece of test equipment used to calibrate other pieces of test equipment to ensure accuracy. Addition-ally, usage logs for test equipment used by the Calibration Laboratory would be transferred from the I&C Shop to the Calibration Laboratory. Further, clerical personnel would be provided to maintain the logs. The inspector had no further questions concerning this matte . Review Committees 9.1 References
--
(TS) Sections 6.2.3, 6.5.1 and 6. Proposed TS Sections 6.2.3 and 6. Regulatory Guide 1.33, Rev. 2 and ANSI N18.7-1976, Administrative Controls and Operational QA
--
NUREG-0737, Clarification of TMI Action Plan Requirements, Item I.B. SECY-80-242, Independent Safety and Engineering Group, May 6, 1980
--
FSAR Section 13. .2 Onsite Review Committee 9. Program Review Written procedures addressing the Plant Operations Review Committee (PORC) activities were reviewed to verify that administrative controls have been established for:
--
Independent review authority and responsibility
--
Manner by which TS Section 6 reviews will be accomplished
--
Membership, alternate member, and quorum requirements
--
Meeting frequency, maintenance and distribution of minutes / records
--
Lines of communication and interface with other groups such as the offsite review committee
- l
Procedures reviewed were:
--
Nuclear Department Instruction (NDI) - 1.4.2, Charter-Plant Operations Review Committee, Rev. 0
--
NDI-QA-2.1.3, Nuclear Department Open Items Tracking, Rev. 1
---
AD-QA-101, Procedure Program, Rev. 4 with temporary changes82-046, 048 and 049, and a draft revision
--
AD-QA-102, Plant Operations Review Committee, Rev. 2 and a draft revision
--
AD-QA-130, Open Items Tracking, Rev. 0 9. Findings The committee has been established; procedures addressing committee activities have been developed; and the committee is functioning with respect to its current responsibilitie The inspector reviewed a number of meeting minutes, interviewed the chairman and another member, and determined the committee is fulfilling its current responsibilities other than the examples discussed in IE Inspection Reports 50-387/81-24 and 82-0 The applicant was aware that a significant increase in the demand on each member's time will occur as review responsi-bilities become greater. Therefore an alternate approach to procedure review has been developed and is described in a proposed change to the TS. Should the proposed TS change be approved by the NRC the applicant has revised applicable procedures which are being held in a final draft form for expeditious review and approval if and when needed. The inspector reviewed the draft procedures and determined that the alternate review could be implemented with a minimum amount of effort and time.
I No violations or concerns were identifie .3 Offsite Review Committee
!
!
9. Program Review Written procedures addressing the Safety Review Committee (SRC) activities were reviewed to verify that administrative controls have been established for:
l
.
--
Independent review and audit authority and responsibility
--
Manner by which TS Section 6 reviews and audits will be accomplished
--
Membership, alternate member, and quorum requirements
--
Meeting frequency, maintenance and distribution of minutes / records
--
Lines of communication and interface with other groups such as the onsite review committee Procedures reviewed were:
--
Nuclear Department Instruction (NDI) - QA-1.4.4, Charter-Susquehanna Review Committee, Rev. 1
--
NDI-QA-2.1.3, Nuclear Department Open Items Tracking, Rev. 1
--
AP-001-001, SRC Rules of Conduct, Rev. 0
--
AP-002-001, SRC Review Procedure, Rev. 0 9.3.2 Findings Procedures detailing committee activities have been esta-blished; meetings have been held since May, 1981; the committee has been appointed and is functioning relative to its present level of responsibilities. The inspector reviewed a number of meeting minutes and other records and noted that the committee has conducted meetings on an almost monthly basis. The SRC discussed / reviewed subjects such as: the annual QA audit schedule; documents that will be reviewed; establishment of two standing subcommittees; manner in which reviews are to be accomplished; NRC inspection reports, including those of PAB on other utilities; Cooperative Utility Management audit reports; and, internal audit report The two sub-committees have been established and have conducted meetings. One sub-committee intends to tour the site annually while the other plans two annual visits. Based on document reviews and an interview with the chairman and secretary of tile committee the inspector determined that the committee should fulfill its increased responsibilities as they occu A concern with respect to review of QA audits is addressed in paragraph 15.4.1.
- .
i
No violations or other concerns were identifie .4 Nuclear Safety Assessment Group (NSAG)
9. Program Review The Nuclear Safety Assessment Group (NSAG) program described in the following licensee administrative documents was reviewe NDI-9.1.1, " Charter - Nuclear Safety Assessment Group",
Rev. O, November 11, 1980
--
Nuclear Safety Assessment Procedure NSAG-1, Rev. O, January 4, 1982 The program consists of five dedicated engineers responsible for independently assessing the effectiveness and quality of the licensee's nuclear operations and related safety and environinental programs. The NSAG is structured to have three on-site engineers, two corporate office engineers, and a corporate office manager reporting directly to the Senior V.P.-Nuclea . Implementation The inspector reviewed the following areas to ascertain the effectiveness and compliance of NSA Organization Chart, January 1, 1982
--
Qualifications of assigned personnel
--
NSAG Project Report 1-81, September 30, 1981, Circulating Water Pump House Flooding
--
NSAG Project Report 2-81, November 17, 1981, Potential Safety Hazard Due to Gas Line
--
NSAG Project Report 1-82, January 19, 1982, Failure to Trip Remotely of Circulating Water Pump
--
Follow-up actions resulting from the above NSAG Project Reports 9. Findings The inspector's findings are discussed below.
i
- l
9.4.4.1 The Technical Specification requires the NSAG to be composed of "five dedicated, full-time engineers." Currently NSAG has three engineers plus one manager; there are two assigned positions (one onsite and one offsite) that are unfille Before issuance of an operating license, the licensee must staff NSAG to meet the Technical Specifications. This item (IFI 387/82-09-13) will be reviewed during a subsequent NRC inspectio .4.4.2 To maximize NSAG effectiveness in evaluating nuclear safety, NSAG should evaluate nuclear safety issues from many sources. However, there is no established program to inform all Nuclear Department personnel of the NSAG and their ability to assess the safety of licensee nuclear operation The licensee should establish 1) policy for referal of nuclear safety employee concerns to NSAG, including anonymous reporting of such concerns, and ; a continuing means (e.g.,
procedures, employee training, employee publications, etc.)
to inform licensee personnel of this polic This item (IFI 387/82-09-14) will be reviewed during a subsequent NRC inspectio .4.4.3 Section 6.4 of NSAO-1 describes follow-up action on NSAG Project Report recommendations, including issuing Open Items in the Nuclear Department Open Items system. The inspector found:
--
NSAG Project Report 1-81 recommended to the Vice President-Operations that eight items be declared open item Contrary to this no open items were declare The eight items were resolved and documented in a memo by the Plant Superintendent in a timely manne On NSAG Project Report 1-82, the V.P.-Operations, at NSAG suggestion, requested the Plant Superintendent to respond to NSAG recommendations by February 12, 198 On April 1, 1982, no response had been made and no open items had been issue The above examples demonstrate the absence of an effective tracking system to provide follow-up action on NSAG recommenda-tion The licensee should establish an effective tracking system and specify it in administrative procedure This item (IFI 387/82-09-15) will be reviewed during a subsequent NRC inspectio __. . .
.
I
10. Non-Licensed Training 10.1 References
--
Proposed Technical Specifications Section Regulatory Guide (RG) 1.8, Rev. I and ANS 3.1-1978, Personnel Selection and Training-
--
RG 1.33, Rev. 2 and ANSI N18.7-1976, Administrative Controls'and Operational QA
--
RG 1.58, Rev. 1 and ANSI N45.2.6-1978, Qualifications of Inspection, Examination and Testing Personnel
--
FSAR Section 1 .2 Program Review Selected por+ ions of the written' training program were reviewed to verify con 'ency with the above requirements in the following area General Employee training / indoctrination (GET) in subjects such as quality assurance, emergency plan, administrative controls, radiological. safety and prenatal exposure, controlled access and security, and fire / industrial safety
--
Formal and on-the-job (0JT) training for personnel such as crafts-men, technicians, QA/QC, engineers, operators and other plant support workers
--
Qualification / certification of personnel as applicable
--
Guicclines such as job analyses, testing methods and position descriptions for use in determining an individuals qualifications and supplementary training needs
--
Facility equipment such as workshops, classrooms, lesson plans,
'
course material, and visual aids (including mock-ups, items and
- parts similar to those in plant, etc.)
--
Delineation of training organization, assignment of responsibilities i and identification of objectives i
--
Training of instructors, training program evaluation and making of needed change, and management involvement
--
Documentation of training and retention of required records i
,
I i /
'.
..
_ _ . - _
-,
--
Staffing and qualifications of selected training department'
personnel The inspector toured the on-site Nuclear Training Center and the corporate Training and Development Center; interviewed management, supervision and instructors; and, reviewed the following documents and procedure Training records of five I&C technicians, four QA auditors, four QC inspectors, seven maintenance craftsmen, and nine plant operators
--
OJT records for several on-site warehouse employees
--
Curriculum Committee Report-Electrical Maintenance
--
Job Analyses for Supervisor of Maintenance, Maintenance Foreman, Mechanic, and Nuclear Quality Assurance
--
Indices of required and recommended training courses for various selected positions
--
Nuclear Training Manual (selected portions)
--
Nuclear Department Instruction (NDI)-QA-10.8.1, Nuclear Department Qualification and Training, Rev. 1
--
NDI-10.1.7, Verification of. Applicant's Qualifications and
. Experience, Rev. 0
--
NDI-QA-4.1.5, Curriculum Planning, Rev. 0
--
NDI-QA-4.1.4, Instructor Certification, Rev. 0 10.3 Findings The Susquehanna Training Center has developed a series of procedures detailing their activities and the training program has been implemente The classrooms are well lighted, equipped and sound insulated. Several trailer rooms are being equipped with items such as pump shaft alignment fixtures, valves, and relays for hands-on training of crafts and trades people. An effort to obtain items similar to in plant equipment is eviden The training staff appears to be qualified and adequate for the current level of training effort. A licensee representative stated that the one unfilled instructor position is due to be filled in the near futur During the exit interview the inspector stated i that requests for additional equipment for craft / trade training should receive management support because this would enhance this aspect of training. The inspector also stated that the overall level of training i effort will increase in the future. Licensee management acknowledged i both statements.
!
,
_- -
Lesson Plans have been developed and the inspector noted evidence that they are being used. The mechanical maintenance and GET Lesson Plans that were sampled for review appeared adequate for their intended purpose. The inspector noted that Job Evaluations have been developed for positions in areas such as Maintenance, Operations, Nuclear Quality Assurance, In Service Group, Instruments and Controls, Health Physics, Nuclear Safety Assessment Group, Construction, Nuclear Training Group, and Technical. Indices of required and recommended training courses for specific positions have been developed for approximately fifty percent of the plant staff. The development of the remainder is ongoin Supervisors and management are to use the indices' guidance to determine any supplementary training needs of an individua The inspector noted evidence that these determinations and evaluations are being accomplished. The Supervisor-Technical Training stated that the remaining training indices are scheduled to be completed in the near future so that any identified needed training can be completed prior to fuel load. During a subsequent interview the inspector learned that licensee management had directed this same individual to concentrate full time effort on completing the remaining indices. This is evidenc of continued management support in this are The corporate Training and Development Center provides support company wide in the areas of educational services, management development, supervisor training, training design, and craft / trade training for conventional power stations. These facilities provided well equipped workshops, classrooms, and visual aids. The inspector noted that the capability existed for producing TV training tapes. The center was fully staffed and four individuals who were interviewed appeared well qualified for their position No violations or concerns were identifie . QA Record Program 11.1 References
--
Proposed Technical Specifications, Section 6 Administrative Controls
--
Final Safety Analysis Report (FSAR), Section 17.2.17
--
ANSI N45.2.9-1974, Requirements for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants
--
Regulatory Guide 1.88, Rev. 2
--
ANSI N18.7-1976, Administrative controls and quality assurance for the operational phase of nuclear power plants
-
- :
--
ANSI N45.2-1977 Quality Assurance Program Requirements 11.2 Program Review The licensee's QA program for records management was reviewed for
conformance with references in paragraph 11.1 for:
.
--
Requirements to maintain and retain Quality Assurance type records
--
Responsibilities are assigned to ensure QA records' identified will be maintained;
--
Responsibilities are assigned and controls established to assure transfer and retention of construction and preoperational phase records;
--
Record storage controls are established which identify the record storage facility, designated custodian (s) in-charge of storage facilities, the filing system for record retrieval, a method for verifying records received are in agreement with preestablished checklists, access control to files and accountability maintained when files are removed from storage, and a method for correcting files and disposing of superceded records;
--
Responsibili. ties assigned to establish retention periods for records not covered by the FSAR, Technical Specifications or 10
, CFR; and,
--
Authority and respcnsibility for authorizing disposal of records assigne Procedures reviewed were:
--
OPS-3, Control and Issuance of Documents, Rev. 1, April 1, 1981
--
OPS-8, The Collection, Storage and Maintenance of Quality Assurance Records, Rev. 1, April 1, 1982
--
QA-18.1, Quality Assurance Records, Rev. 5, August 18, 1980
--
OPS-1, Operational Quality Assurance Program, Rev. 1, April 1, 1982
--
NDI-QA-1.1.2, Nuclear Department Instruction System, Rev. 3, March 25, 1981
--
NDI-QA 1.2.1, Nuclear Department Correspondence Control, Rev. 1, January 25, 1982
__
-
!
NDI-QA-1.2.2, Susquehanna SES Records Management System,-Rev. 0,-
-
--
December 23, 1981
--
NOI-QA-1.2.3, Organization and Administration of the Susquehanna-SES Records Management System, Rev, 0, May 21, 1981
--
NDI-QA-1.1.3, Nuclear Department Open Item Tracking, Rev.1,-
March 31, 1981
--
Susquehanna SES Records Management System (SRMS) Manual, Procedures P-1 through P-15, Index Rev. 10, March 10, 1982
--
AD-TY-193, Release of System from Test Status, Rev. O, January 18, 1982
--
IP-020.0, Engineering Turnover Documentation Procedure, Rev. 1, February 1, 1982
~
--
AD 6.1, System / Component Turnover to PP&L, Rev. 9, November 16, 1981
--
System Power and Engineering Department, Correspondence File -
Procedure, February 5, 1982
--
RD 00-007, Receipt and Processing of System Turnover files from ISG. December 15, 1981 11.3 Implementation 11. The inspector reviewed the following documents, records, and instructions to verify implementation of established QA records syste SRMS Training Matrix (draft)
--
Records type list (draft)
--
Susquehanna SES QA document list, Rev. 10, December 14, 1981
--
SRMS work instructions (corporate office and site)
11. The inspector selectively sampled various QA records to verify that the record:
-- Was listed on a records checklist or index;
--
Was readily retrievable from its designated file or microfilm storage location as applicable;
, , l '<
.
.
,
,
, .
L
--
Was provided suitable protection and stored inifile cabinets or container in a predetermined'lecation; and, l When received by Document Control Center, was processed in accordance with the SRMS manual and work instruction The following record types were examine Various PP&L General Correspor.dence ,
--
SRMS personnel training records for three clerks and one supervisor
--
Fi.ceen receipt inspection reports including,80-076,80-284, 81-459 and 81-180
--
Twenty Work Authorizations including U 12078, E-80-A and S 10156
,
--
Eight Procurement Documents (Purchase orders) including 500442, 500C23 and 500070
--
Audit SESS, Records Management System (May 1981) and NGA Audit. SRMS (August 1981)
--
System Turnover Packages P2.1 125 Vdc Battery, P8 Vdc Battery, and P76.1 Leak Detection System
^
--
Various plant procedures and manuals 11. The inspector toured the licensee's document control centers (DCC) both at the site and corporate office to verify that file room access was being controlled, microfilming and record processing was being performed as described in work instructions, and records were being transmitted to the DCC with the required transmittal form In addition interviews were conducted with record management system supervisors and personnt.1 to determine if the current staffing level and training was adequat .4 Findings No violations were identified, however the following minor deficiencies were identified by the inspecto . FSAR Table 17.2-1 commits the licensee to full compliance with ANSI N45.2.9-1974, " Requirements for Collection Storage, and Maintenance of Quality Assurance Records for Nuclear Power Plants." ANSI N45.2.9, Section 5.6, states that QA
__ _ _ . . _ _ _ _ -
- 1
records discussed in the standard should be afforded the equivalent protection of a NFPA Class A, four hour minimum rated facilit Currently the licensee does not have an approved storage facility onsite or at the corporate office. Without approved storage facilities, completed Q.A. records, transmitted to the Document Control Center for interior storage prior to microfilming, duplication, and distribution are not provided adequate fire protectio This records storage problem was previously identified in
-' SESS QA audits performed on the Records Management System in May 1981 at the site and August 1981 at the. corporate offic The following corrective action has been planned or is ongoing as a result of these audit A vault type room will be constructed in the new corporate office complex scheduled for completion in the fall of 198 A vault type room will be construction at the site in conjunction with the expansion of the Service and Administration Buildin As an ir,terim measure the licensee is procuring approved
>
_
offsite storage for completed QA records and, archival storage for aperture cards of design drawing and print Additionally, microfilming of QA records is being performed as soon as possible to reduce the time a QA
/ record must be stored without adequate fire protectio ,
The corrective action, as discussed above will be reviewed during a subsequent inspection (IFI 387/82-09-16).
11.4.2 ANSI N45 2.9 Section 5.3 requires that storage procedures be prepared and include the rules governing access to and control of the file The inspector identified that access control to the QA records file room at the site is not adequately define Currently the licensee has several clerks working in the file room and access into the rocm is controlled only by a sign that allows access to " authorized personnel" onl The licensee's representatives acknowledged the inspectors concern and stated that:
'
.
--
The Document Control Center (DCC) and records file room is to be relocated to the Service and Administration Building in June 1982. This move will establish a separate QA record file room; and,
--
The procedure for access control to the file room is to be revised and issued concurrently with the planned DCC mov This item will be reviewed in a subsequent NRC:RI inspection (IFI 387/82-09-17).
11.4.3 The inspector determined that no formal control exists for Records Management System Work Instructions at the corporate office. The existing work instructions do not have an index and many pen and ink change are unofficially incorporated into the work instruction The licensee's representatives' acknot:1 edged the inspectors concern and stated that:
--
P.6., " Preparation, Review and Distribution of New or Revised Susquehanna SES Records Management System Procedures" would be revised to include adn,inistrative control of work instructions or a new work instruction would be developed to provide administrative control; and,
~
--
All current work instruction would be reviewed and reissued in accordance with the new procedure or instruc-tio The inspector had no further questions in this are .4.4 The inspector determined that Records Management System (RMS) personnel both at the site and the corporate office were receiving training, but that:
--
Only a draft instruction exists to delineate the required training for RMS personnel at the corpprate office; and
--
TM training matrix for RMS personnel at the corporate office should be expanded to include QA/QC indoctrinatio The licensee's representative acknowledged the inspector's concerns and stated that the draft work instruction and training matrix would be revised to include QA/QC indoctrina-tion and then be formally issued.
!
I
,
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The inspector had no further questions in this are . Through discussions with RMS supervisor staff and review of current organizational charts the inspector determined that the licensee is adequately staffed to effectively 4 manage the QA records program present workloa The inspector also verified that the licensee had projected future staff requirement for the growth of the QA records progra . Document Control Program 12.1 References
--
Proposed Technical Specifications, Section 6, Administrative Control
--
Final Safety Analysis Report (FSAR) Sections 17.2.5 and 17. ANSI N45.2-1977, Quality Assurance Program Requirements
--
ANSI N18.7-1976, Administrative Contrels and Operational Quality Assurance for the Operational Phase of Waclear Power
--
Reg. Guide 1.33, Rev. 2, February 1978, Quality Assurance Program Requirements 12.2 Program Review
.
The licensee's program for document control was reviewed to verify that the program is consistent with the requirements of the references
in paragraph 12.1 above and to determine that the program:
--
Requires that current as-built drawings, including piping and instrument drawings (P&ID's) be provided to the plant in a timely manner;
--
Requires that proposed drawing changes and the revised drawings receive the same level of management review required of the 4 original drawings;
--
Provides provisions for identifying and marking of drawings that have outstanding revisions;
--
Establishes control of obsolete drawings;
--
Requires that discrepancies found between as-built drawings and the as constructed facility are handled as design changes;
- _ . .
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l
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Requires master indicies to be maintained for drawings, manuals, technical specifications, procedures that indicate the current revision; and,
-- Provides a mechanism for document issuance, distribution, use, and periodic review.
I The following procedures, which describe the administrativa controls for document control were reviewed by the inspecto OPS-3, Control and Issuance of Documents Rev.1, April 1,1982
--
OPS-4, Document Review, Rev. 1, April 1, 1982
--
NDI-QA-2.2.6, As-built Drawing Requirements, Rev. O, January 4, 1982
--
NDI-QA-8.1.3, Document Review, Rev. O, September 28, 1981
--
AD-QA-101, Procedure Program, Rev. 4, February 18, 1982
-- NQAP 1.1, Preparation and Control of NQA Section Procedures, Re , January 18, 1982 l
--
AD-QA-301, Operations Procedure Program, Rev. O, January 7, 1982 i --
AD-QA-500, Conduct of Maintenance, Rev. O, January 6,1982
--
AD-QA-600 Conduct of Instrumentation Rev. O, February 1, 1982 l
'
12.3 Implementation The following documents, indices, and instructions were reviewed to verify implementation of the established document control progra Mailing lists for controlled manuals at the corporate office l
l
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Open items tracking system (corporate office) for tracking procedure l
review
!
I --
Time Sharing Option (TS0) master indices for check-off-lists and data sheets
--
TSO Control Manual list
-- Plant maintenance information system for procedure review tracking
--
Controlleo procedures master indices for administrative, maintenance, operational surveillance and' operational procedures
- :
--
Advanced Text Management System (ATMS)
--
Storage and Information Retrieval System (STAIRS)
--
Master drawing index and drawing " Stick File" indices
--
Document Control Work Instructions
--
Transmittal forms (SUSA-105) for index distribution Drawings, procedures, manuals, check-off-lists (COL) and surveillance data sheets were selectively sampled at the site to verify that con-trolled copies were consistent with the Document Control Center (DCC)
master indices. The following controlled copy locations were checke Control room procedures, COL's, data sheets, and drawing " stick files"
--
Technical support center (TSC) procedures, COL's, data sheets and drawing " stick files"
--
Technical library procedures and drawing '.' stick files"
--
Mechanical Maintenance Shop procedures, data sheets and drawing
" stick files"
--
Permit Office - drawing " stick files"
--
Document Control Center procedures C0C's, and data sheets At each location twenty or more administrative, operating, surveillance maintenance procedures, operational procedure COL's, and P&ID's were checked against the master indice Additionally, the inspector randomly sampled station procedures and reviewed the Plant Maintenance Information System's (PMIS) weekly activity worklist to verify completion of the required periodic procedure revie .4 Findings No violations were identified, however the following minor concerns and inspector followup items were identified by the inspecto . Revision to controlled copies of manuals and procedures are issued, distributed and entered by the DCC staf Ruisions to check off list (COL) and surveillance data sheets are issued and distributed by the document control staff to the applicable functional unit The actual COL and data sheet file updating is done by the functional unit receiving the form *
. l
1 The inspector determined that revisions to COL's and Surveil-lance Data Sheets were not all being issued from the DCC with a transmittal, and the control room file of COL's and Data sheets was not consistent with the DCC master indice The licensee's representative acknowledged the inspector's finding and stated that:
--
All future revision to COL's and Data sheet would be issued to the applicable functional units by transmittal; and,
--
The control room's file of COL's and data sheets would be completely maintained by the document control staf The inspector had no further questions in this are . Each Functional Unit at the corporate office has issued procedure In addition each unit has established a procedure to control the writing, distribution, use, revision and review of these procedure The inspector identified that the following corporate office Functional Unit's procedures did not address a periodic review as required by ANSI-N18.7 197 .
--
Susquehanna Records Management System
--
Nuclear Quality Assurance
--
Nuclear Licensing
--
Nuclear Engineering The licensee's representatives acknowledged the inspector's findings and stated that each Functional Unit procedure would be revised to include a periodic review of their procedure The corrective action as stated above will be reviewed during a subsequent NRC:RI inspection (IFI 387/82-09-18).
13. Procurement 13.1 References
--
Regulatory Guide 1.123, Rev. I and ANSI N45.2.13-1976, QA for Procurement of Items and Services
-
-
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FSAR Section 1 .2 Program Review The written procurement control program was reviewed to verify that ,
administrative controls were established for:
--
The identification of items purchased; identification of tests and/or special instructions, technical requirements and documenta-tion to certify the item; assuring that the contractor / supplier has implemented a QA program consistent with 10 CFR 50, Appendix B, and where deemed appropriate by the licensee, access to the supplier's plant or records for purposes of audi Accomplishment of an assignment of responsibilities for: initiation of procurement documents; review and approval of specifications differing from the original design documents; review and approval of procurements, including changes thereto; and, the designation of quality classification of procured item Evaluation and approval of bidders / suppliers including assignment of responsibilities for the following functions: review / update of the listing of approved suppliers; providing for rights of access to supplier's facilities and records; and, maintenance of records of suppliers qualifications and audi The following licensee administrative controls / procedures were reviewe ~ Operational Policy Statement (OPS)-10, Procurement Control, Re (a draft)
--
Nuclear Department Instruction (NDI)-QA-1.4.2, Procurement of Quality Materials for SSES, Rev. 0
--
NDI-QA-1.4.3, Procurement of Services for Susquehanna SES, Rev. 0
--
NDI-QA-2.1.4, Production, Maintenance and Control of the Defective Device List, Rev. B
--
NDI-QA-2.1.6, Identification, Evaluation, and Tracking of Class IE Components requiring Environmental Qualification, Rev. 0
--
NDI-QA-15.3.2, Identification, Evaluation, and Tracking of Class IE Components Requiring Environmental Qualification, Rev.1 (a draft)
--
Plant procedure AD-QA-210, Procurement Control Activities, Rev. 0
--
Procurement Department procedure (PDN)-QA-2.1, Processing of Orders Requisitioned by SSES Plant Staff, Rev. O
- _ _ _ _ _ _ _ - _ _ _ _ _ _ - . _ _ _ _ _ __ . _ _ _ _ _ _ . _ _ _ _ _ _ . _ _ _ _ _ _ .
--
PDN-QA-4.1, Approved Supplier Quality Listing Procedure, Rev. 0
--
Power Plant Engineering Nuclear Plant Procedure (PPENPP)-4, Review of Requisitions for Quality Material, Rev. 3 13.3 Findings Detailed procedures for procurement activities have been develope An oasite engineering group has been established and has been reviewin requisitions for spare part Items, components, and sub-components are evaluated as to their intended use and assigned a quality classifi-cation. Procedures identify procurment requirements for each classifi-cation. The item identifier, its classification, procurement require-ments, and stock inventory are entered into a computerized information system. Applicable plant personnel have been trained in the retreival of this information at variously located terminals. The inspector conducted an overview of spares purchasing and determined that engineer-ing evaluations were done; ite 5, devices and sub-components were classified as to the level of their intended use; this information was entered into the information system; and, these activities were being accomplished in accordance with the established procedures. The inspector also conducted a detailed review of the manner in which the onsite engineering group evaluated and classified sub-components of Limitorque Operators (spares) and identified no inadequacie The inspector discussed present and future levels of activities and staffing with the group supervisor who stated that most spares have already been purchased and management made a determination that future activities could be accomplished with the current staffing level. The inspector acknowledged the supervisor's statements and had no further question No violations or concerns were identifie . Receipt, Handling, and Storage 14.1 References
--
Final Safety Analysis Report (FSAR) Sections 17.2.7, 17.2.13 and 17.2.15
--
ANSI IN45.2-1977, Quality Assurance Program Requirements
--
ANSI N45.2.2-1972, Packaging, Shipping, Receiving, Storage and l
Handling
!
--
ANSI N45.2.13-1976, Quality Assurance for the Procurement of Items and Services
!
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._n,_ -. . - . , _ . -
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,
14.2 Program Review The licensee's program for receipt, storage and handling of safety related equipment and materials were reviewed to verify that the program is consistent with the requirements of the references in pagagraph 14.1 above and to determine that administrative controls established:
--
Requirements for conducting receipt inspections on all incoming safety related materials and equipment;
--
Requirements that materials and equipment be examined for confor-mance with requirements specified on orginal procurement documents;
--
Provisions for identification of those materials and equipment that can be accepted by only a " certification of quality" (C of C);
--
Controls for acceptance of items including tagging / marking for storage or immediate use;
--
Controls for nonconforming items which include:
. Marking and segregating nonconforming items
'
. Disposition of nonconforming items (reevaluate, rework, repaired, or return)
. Prohibiting use of nonconforming items
. Documentation required of the noncomforming items
. Notification of licensee audit group responsible for supplier (vendor) evaluation documentation of nonconforming items;
--
Methods for conditional release of nonconforming items including justification for use, documentation and authority for conditional release;
--
Requirements for providing proper levels of storage and appropriate environmental conditions;
--
Requirements for specifying storage controls including access, identification, coverings, and preservatives;
--
Requirements for periodic inspections of the storage areas;
' --
Requirements for specifying maintenance and care of items in storage including shelf life;
!
- . . - _ . -, --. ,
- :
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Requirements for routine and special handling measures; and,
--
Controls for hoisting equipmen The following procedures were reviewed to verify administrative controls have been establishe OPS-10 Procurement Control, Rev. O, April 1, 1982
--
OPS-12, Administrative Control of Plant Operations Rev. 1, April-1, 1982
--
OPS-17, Control of Plant Material, Rev. 1, April 1, 1982
--
OPS-5, Deficiency Control System, Rev. 1, April 1, 1982
--
NDI-QA-2.1.6, Identification, Evaluation, and Tracking of Class IE Components Requiring Environmental Qualifications, Rev. O, March 26, 1981
--
NDI-QA-2.4.2, Procurement of Quality Materials for SESS, Rev. O November 17, 1980
--
NDI-QA-8.1.2, Reportable defects and noncompliance, Rev. 1, October 19,,1982
--
AD-QA-200, Material Control Activities, Rev.1, February 3,1982
--
AD-TY-190, Preoperational Phase Housekeeping and Protection Program for Safety Related Equipment, Rev. O, February 16, 1982
--
AD-QA-109, Nonconforman.ce Control Program, Rev. 0
--
NQAP 4.1, Procurement Document and Specification Review, Rev. O, March 13, 1981
--
QCP-30, Receiving Inspections, Rev. O, May 27, 1981
--
QCP-31, Periodic Inspection of storage facilities, Rev. O December 23, 1981
--
Specification P1003, Technical Requirements for the procurement of spare parts, Rev. B 14.3 Implementation 14. The inspector selectively sampled safety related materials and equipment received on site to verify:
L
- :
--
Receipt inspections were conducted in accordance with administrative controls
--
Disposition of the item was in accordance with admini-strative controls
--
Storage of items including packaging, presevatives, covering and environmental conditions were in accordance with manufacturers' recommendations
--
Tagging / marking allowed tracing the item back to procure-ment documents, receipt documents and " quality certifi-cation" documents
--
Nonconforming items were clearly marked ar.d segregated from other safety related items
--
Documentation of nonconforming items was transmitted to affected organization for them to determine final item disposition The following safety related items were selected for revie Shaft Sleeve Catagory No. 8625, P. O. 500109, Receipt Inspection Report (RIR)81-062
--
Pump Gasket, Catalogue No. 1463, P. O. 500009, RIR 80-075
--
Weld Rod, Catalogue No. 022005, P. O. 600170, RIR 81-222
--
Fan, Catalogue No. 8645, P. O. 500085, RIR 81-114
--
Pivot Pins, Catalogue No. 22028, P. G. 500442, RIR 81-073
--
Globe Valves, Catalogue No. 8164, P. O. 500070, RIR 80-304
--
Bearings, Catalogue No. 1481, P. O. 900021, RIR 80-177
,
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Impeller Keys, Catalogue No. 13231, P. O. 500213, RIR l 81-459 l
l 14. The inspector reviewed the receipt inspection logs for l
1980, 1981 and 1982 and selectively sampled Receipt Inspection
'
Reports (RIR) that contained nonconforming safety related items to verify that:
.
- _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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'
'
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The necessary actions were taken to resolve the existing nonconformance; and,
--
Adequate resolution for final disposition of nonconforming item was obtaine The following receipt inspection reports were reviewe RIR 80-243 with nonconformance report (NCR)-80-311 and Quality Assurance Action Request (QAAR) C-81-023
--
RIR 80-076 with NCR 80-301 and 80-106 and QAAR C-82-014
--
RIR 81-529 with NCR 81-723 and QAAR C-81-166
--
RIR-459 with QAAR C-82-029
--
RIR-81-160 with NCR 81-244
--
RIR 81-180 with QAAR C-81-044 14. The inspector accompanied licensee personnel during their monthly inspection of the onsite warehouse to verify:
--
Controlled access to the PP&L storage area is maintained;
--
Cleanliness and good housekeeping practices are enforced;
--
Fire protection was commensurate within the type of storage area and materials involved;
--
Food and associated items were not permitted;
--
The adequacy of material storage, including protective coverings, coatings and preservatives;
--
Hazardous material segregation; and,
--
Clear identification of shelf life of applicable materia . The inspector interviewed the materials supervisor to determine that the current staffing level as depicted in the plant's organizational charts was adequate to effectively manage and maintain the spare parts inventory progra In addition the inspector reviewed the training records of 2 stockmen and 2 quality control receipt inspector to verify that their trainino conformed to the training matrix and was adequate to perform their assigned tasks.
r f
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14.4 Findings No violations were identified, however the inspector identified that work instructions were not being used in the Materials Section. The materials personnel use administrative procedure AD-QA-200, Material Control Activities, for all receipt, storage and handling activitie The inspector expressed a concern that work instructions should be used to provide more detailed instruction for stores personne The licensee's representative acknowledge the inspector's concern and stated that:
--
A draft work instruction index has been generated which identified work instructions that are needed; and,
--
Work instruction will be written and issue The inspector had no further question in this are . Audits 15.1 References
--
Technical Specification Section 6.5.2;
--
FSAR Chapter 1 Regulatory Guide 1.33, Rev. 2, Quality Assurance Program Require-ments (Operation), February, 1978
--
ANSI N18.7-1976, Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants
--
ANSI N45.2.12-1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants i
--
ANSI N45.2.23-1978, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants 15.2 Program Review The inspector reviewed the audit program as described in the following licensee administrative document OPS-7, Auditing and Surveillance Activities, Rev. 1, April 1,
- 1982
--
NDI-QA-8.1.8, Performance of Quality Assurance Audits, Rev. O, February 15', 1982
I
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. , . _ _ _ _ - . _ , _ _ . . . . _ , , _ . ~ _ . . . . . .
.
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NQAP 9.1, Audits, Rev. 1, February 11, 1982
--
NQAP 10.1, Certification of Quality Assurance Auditors, Rev. O,
'
November 30, 1981
--
Training Curriculum - Nuclear Quality Assurance, Rev. O, January 25, 1982 15.3 Implementation The inspector reviewed the implementation of the audit program by reviewing the followin ,
--
1982-1983 NQA Audit Schedule, January 29, 1982
--
1981 Audit Status Log
--
Organization Chart of Nuclear Quality Assurance, January 1,1982
--
1981 Management Audit of PP&L, October 29, 1981
--
Audit 0-81-08, Audit of Plant Technical Specification Compliance, j Janua ry 29, 1982
--
Audit 0-82-Q2, Audit of Nonconformance Control and Corrective Action, February 25, 1982
--
Audit IA-82-2, Audit of NQA Home Office Activities, March 10,
.
1982 i
--
Audit 0-81-05, Audit of Fire Protection Program, November 20, 1981
--
Audit 0-81-03, Audit of ISG Procurement Interface, December 4, 1981
--
procurement Audit of Power Conversion Products, February 20,19fil
!
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Audit P-82-01, Supplier Evaluation - Westinghouse Medium Motor
, and Gearing Division, January 26, 1982
--
Spare Parts Quality Verification - Anchor Darling Valve Co.,
October 12, 1981
!
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Spare Parts Quality Verification - American Air Filter, March 11, j 1982
--
Audit * 0-3, NQA Audit of ISG, July 2, 1980
- Audits of Preoperational Testing Program
. .-_ , _ _ _ _ . . _ _ _ _ . - _ _ - - _ _ =_
--
Audit *0-8, Operations QA Audit of Preoperational Testing Activities, January 26, 1981
--
Audit *0-9, Audit of Initial Instrument Calibration and Analog Loop Test, January 26, 1981
--
Audit *0-12, PLNQA Site Operations Audit "Preoperations Tbsting Activities, March 6, 1981
--
Audit *0-20, Audit of ISG Administrative Controls, July 27, 1981
--
Audit *0-81-01, Audit ISG Implementation of Preoperational Test, October 14, 1981
--
Audit *0-81-03, Audit of ISG Procurement Interface, December 4, 1981
--
Audit *0-82-03, Implementation of Preoperational Testing Activities, (Audit Period February 1, 1982 to March 9, 1982)
The audit program was inspected for the following:
--
Audits are performed by qualified audit personnel who are inde-pendent of the area being audited;
--
A long range audit schedule exists and the planned audits are being completed in a timely manner;
--
Each audit utilizes an audit checklist or procedure covering the areas scoped for audit;
--
deficiencies identified during the audit are resolved or are being carried as open items;
--
Periodic review of the audit program is performed to determine its status and adequacy; and,
--
Review of the audit program by the Susquehanna Review Committee (SRC), the offsite safety review committee, is performed in an effective manner and satisfies the Technical Specification require-ment .4 Findings The inspector's findings are discussed belo . Technical Specification Section 6.5.2 delineates the respon-sibilities of the Susquehanna Review Committee (SRC), including the required audits of unit activities. The Technical Specification' required audits under the cognizance of the
- Audits of Preoperational Testing Program
.'
SRC will be performed by the Nuclear Quality Assurance Organization. However, there is no administrative procedure for SRC review of the audits. The SRC Chairman stated that an administrative procedure for SRC audit review will be approved by the SRC, issued and sent to the NRC for information by May 1, 1982. Before issuance of an operating license, the licensee must establish and issue a proceduce to satisfy the SRC review of audits required by the Technical Specifi-cation. This item (IFI 387/82-09-19) will be-reviewed during a subsequent NRC inspectio . FSAR Section 17.2.1.1 commits the licensee to "the performance of an annual, preplanned and documented assessment of the 0QA Program in which corrective action is identified and tracked." In 1980 and 1981 this annual assessment was performed by an audit by the Cooperative Management Audit Program and the findings were resolved. However, there is no administrative procedure which specifies this FSAR commit-ment. The licensee should reflect this FSAR commitment in the administrative procedures to ensure it is met on an annual basis. This item (IFI 387/82-09-20) will be reviewed during a subsequent NRC inspectio . Concerns were developed regarding the QA audit coverage of the Preoperational Testing Program and the QA staffing available to perform both Pre Op and Operational audit These concerns and violations are discussed in paragraph
. . Plant Procedures 16.1 References
--
Technical Specifications (Proposed)
--
Regulatory Guide 1.33-1978, Quality Assurance Program Requirements (Operation)
--
ANSI N18.7-1976, Administrative Controls and Quality Assurance for ... Nuclear Power Plants
--
SSESQAM, Procedure 7.1, Control and Issuance of Documents, Re , November 17, 1980 16.2 Program Review The administrative procedures for the plant procedures program were reviewed. Their status including preparation, approval, issuance and conformance to the above referenced requirements were inspecte Procedures reviewed were:
i
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, _ _
'
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AD-QA-101, Procedure Program, Rev. 4, February 19, 1982
--
AD-QA-102, Plant Operations Review Committee, Rev.'2, March 31, 1982
--
AD-QA-301, Operations Procedure Program, Rev. O, January 7, 1982
--
AD-QA-400, Conduct of Technical Support, Rev. O, January 13, 1982 16.3 Implementation Review A sampling of issued plant procedures were reviewed to determine compliance to requirements referenced in paragraph 16.1 and admini-strative procedures detailed in paragraph 16.2. Procedures were reviewed for:
--
Proper review and approval
--
Correct formats
--
Conformance to Technical Specification requirements, and system status during component testing is in conformance with Technical Specification limiting condition for operaticns (where applicable)
--
Technical information provided in the procedure was accurate
--
Proper past completion reviews for test procedures
~
--
Stepwise instructions provided in the degree of detail necessary for performing the procedure Procedures reviewed were:
General Operating Procedures
!
--
GO-00-002, Plant Startup and Heatup, Rev. O, (not issued)
--
G0-00-003, Power Ascension, Rev. D, (not issued)
--
GO-00-004, Plant Shutdown to minimum power, Rev. D, (not issued)
System Operating Procedures
--
OP-02-001, 125 V DC System, Rev. 1, September 2, 1982
--
OP-13-001, Fire Protection System, Rev. 0, March 15, 1982
--
OP-24-001, Diesel Generators, Rev. O, February 10, 1982
.
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_ _ _ _ _ _ _ _ _ _ . . _ _ . _ _ _ _ _ _ _ _ _ _ _ _ ______ _____ ____ - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ - - _ _ _ _ _ _ _
--
OP-31-001, Rod Worth Minimizer, Rev. O, December 16, 1981
--
OP-51-001, Core Spray System, Rev. O, December 24, 1981
--
OP-53-001, Standby Liquid Control System, Rev. O, December 16, 1981
--
OP-61-001, Reactor Water Cleanup, Rev. O, March 1,1982
--
OP-83-001, Automatic Depressurization System and Safety / Relief Valves, Rev. O, January 5,1982
--
OP-84-001, Main Steam, Rev. O, January 7,1982
--
OP-73-001, Containment Atomsphere Control, Rev. O, January 18, 1982 Surveillance Operating Procedures
--
50-56-001, Exercising Control Rods Weekly For Operability, Re O, December 10, 1981
--
S0-53-001, Standby Liquid Control System Monthly Operability Demonstration, Rev. O, December 23, 1981
--
S0-73-001, Semi-Annual Hydrogen Recombiner Test, Rev. O, March 9, 1982
--
S0-52-002, HPCI Pump Quarterly Flow Verfication, Rev. O, February 18, 1982
--
S0-50-002, RCIC Pump Quarterly Flow Verification, Rev. 0, January 18, 1982
--
S0-49-002, RHR System Flow Verification, Rev. O, November 6, 1981
--
50-31-001, Rod Worth Minimizer Operability Prior to Rod Withdrawal, Rev. O, December 10, 1981 16.4 Findings 16. CFR 50, Appendix B, Criterion V and Technical Specification 6.8 require that approved procedures be established for performing safety related activities and for operating and maintaining plant equipmen The inspector observed that a significant percentage of procedures had not been approved or issued, although procedures required to perform plant activities had been identified by the licensee. Unissued procedures were identified in the following area i l
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AD - Administrative Procedures
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GO - General Operating Procedures
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OP - System Operating Procedures
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ON - Off Normal Procedures
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EO - Emergency Operating Procedures
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AR - Alarm Response Procedure (Control Fire Protection Panels and remote alarm response panels only)
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S0 - Operations Surveillance Procedures
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SI - Instrument and Control Surveillance Procedures
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SM - Maintenance Surveillance Procedures
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SC - Chemistry Surveillance Procedures
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RE - Reactor Engineering Procedures The inspector informed the licensee, that with only a few excepti.ons, procedures included in but not limited to the above categories must be issued and ready for implementation upon issuance of an Operating Licensee (OL). The licensee's representative concurred with the inspector's finding and stated that all necessary procedures would be issued by O This is an open item pending completion of licensee action (IFI 387/82-09-21). This finding is related to previous findings in Inspection Report 387/81-24 (Items 387/81-24-05 and 09).
16.4.2 As noted in paragraph 16.4.1 above, the licensee had not established procedures for remote (from the control room)
panel alarms. A licensee representative stated that procedures would be prepared for remote alarms but not necessarily by OL; and noted that the SSES-FSAR, Section 13.5.2.1.5, refers only to the need for Control Room alarm response procedure The inspector informed the licensee's representative that Regulatory Guide 1.33-1978, paragraph 5, requires that procedures be prepared for responses to all safety related alarms and does not differentate between Control Room and remote alarm panels. Additionally, procedures for these alarms would be required to be issued by OL. This is an open item pending completion of licensee action (IFI 387/82-09-22).
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16.4,3 The inspector questioned the availability and control over operating and surveillance operating procedures to be used by operations personnel in the plant. A licensee's repre-sentative stated that a " User Control" system had been established by procedure A0-QA-10I to provide controlled copies of procedures to plant personnel as required. He further stated that the Operations Department was evaluating the establishment of " satellite" files at various locations in the plan The inspector informed the licensee's representative that if
" satellite" files or other methods which are extensions of the " User Control" system are established to provide controlled copies of procedures to operators, then additional admini-strative controls must be established to specify the method Additionally, such controls must be established prior to O This is an open item pending completion of licensee evaluation and action (if any) (IFI 387/82-09-23).
16. In response to a TMI Action Item per NUREG 0737, the licensee's representative committed to providing second verifications of valve status. The inspector observed that valve lineup checkoff lists (COL's) in system operating procedures did not require second verifications nor was second verification of valve position required on restoration from system blockin , However, procedures did require second verification for system blocking tag installation The licensee stated COL's would be revised to ensure that there was second verification of key valves (such as flow path valves and locked valves) and that the system blocking procedure would be revised to provide for second verification on system restoration. The inspector informed the licensee that this action must be completed prior to OL. This is an open item pending completion of licensee action (IFI 387/82-09-24).
- 16. The inspector observed that instrument valves and instrument l isolation valves were not included in system valve lineup COL's nor were they included in system piping diagram (P&ID's).
The licensee's representative stated that instrument valves were under the control of the I&C Department and are controlled by I&C procedures; however, instrument root valves were j under control of the Operations Department.
l The licensee's representative stated that instrument root i valves would be included in valve lineup COL's. He further I
stated that instrument valves downstream of the root valve I would remain in I&C procedures with appropriate verification ~
The inspector' informed the licensee that this action is required prior to OL.
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This item is open pending completion of licensee action (IFI 387/82-09-25).
16. During review of surveillance operating procedures, the inspector observed that test procedures did not include data required by the Inservice Test Program (IST), ASME Code Article IWV-3000 Series, Pumps and Valves Testing. The licensee's representative confirmed that implementing pro-cedures had not yet been established and that IST's and surveillance procedures were in the process of being revise The inspector informed the licensee's representative that IST implementing procedures are required prior to OL. This is an open item pending completion of licensee action (IFI 387/82-09-26).
16. The inspector observed the following deficiencies in system operating and surveillance procedure OP-13-001, " Fire Protection System", does not yet include fire detection and alarm procedures plus associ-ated checkoff lists. The licensee stated that an expiration date of June 15, 1982 had been established for this procedure to ensure that it is revised to include the abov Procedures OP-83-001, " Automatic Depressurization System and Safety / Relief Valves"; S0-83-001, " ADS System Functional Test"; and 50-83-002, " ADS Valve 18-month Manual Actuation" did not adequately address the operation and use of the Accoustic Monitor Position Detection System. The licensee stated that these procedures would be revised to more completely address the accoustic monito , " Standby Liquid Control System Monthly", did not adequately identify Technical Specification acceptance criteria concerning pump operation and flow path verifi-cation. Additionally, a pump packing leakage check is accomplished by the procedure but a pump run time is
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not specified. The licensee stated that the procedure
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S0-49-002, "RHR System Flow Verification", acceptance criteria reaction refers to incorrect procedure paragraphs for determining flow for the suppression pool cooling mode of operation and the procedure acceptance criteria specifies a test line pressure which has not yet been incorporated into current Technical Specification
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4.5.1.6.2. The licensee stated that this procedure was currently undergoing revision ._ .
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The inspector informed the licensee that the above procedures must be corrected prior to OL. This is an open item pending completion of licensee action (IFI 387/82-09-27).
The licensee's representative also stated that an " operational shakedown" was in progress and that many of the operating procedures would receive a " walk through" by operators and be revised as required, prior to 0L. The inspector acknow-ledged the licensee's representatives statemen . ANSI N18.7-1976 requires that a mechanism shall be provided for issuance of operating (standing) orders. The inspector observed that no such mechanism exists although an instruction does exist for issuance of night orders (special orders) as required by ANSI N18.7-1976, paragraph 5.2.4. The licen:ce stated that an Operations Department Operating Instruction (01) would be written to cover issuance of st&nding order The inspector had no further question . Exit Interview The findings of this inspection were discussed with licensee representatives periodically during the inspection and the status of the inspection was discussed with licensee management on March 26, 198 Licensee management was informed of the scope and purpose of the inspection on March 12, 1982 and at entrance interviews conducted at the Susquehanna Steam Electric Station and PP&L corporate offices on March 22, 198 An exit interview was conducted at PP&L corporate offices on April 2, 1982, at which time the findings of the inspection were presented (see paragraph I for attendees). PP&L management acknowledged the inspector positions at the exit interview relative to the specific corrective action times contained within this report as applicable to the specific actions to be accomplished before operating license issuance.
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