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{{Adams | |||
| number = ML20245C728 | |||
| issue date = 04/12/1989 | |||
| title = Insp Rept 50-382/89-07 on 890227-0303 & 890313-17.Violation Noted.Major Areas Inspected:Previously Identified Findings, Licensee self-assessment Capabilities & Procurement Activities | |||
| author name = Barnes I, Gilbert L, Mcneill W, Stewart R | |||
| author affiliation = NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) | |||
| addressee name = | |||
| addressee affiliation = | |||
| docket = 05000382 | |||
| license number = | |||
| contact person = | |||
| document report number = 50-382-89-07, 50-382-89-7, NUDOCS 8904270360 | |||
| package number = ML20245C716 | |||
| document type = INSPECTION REPORT, NRC-GENERATED, INSPECTION REPORT, UTILITY, TEXT-INSPECTION & AUDIT & I&E CIRCULARS | |||
| page count = 14 | |||
}} | |||
See also: [[see also::IR 05000382/1989007]] | |||
=Text= | |||
{{#Wiki_filter:. - _ _ _ _ _ _ - | |||
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8 | |||
I | |||
APPENDIX B | |||
U.S. NUCLEAR REGULATORY COMMISSION | |||
REGION IV | |||
NRC Inspection Report: 50-382/89-07 Operating License: NPF-38 | |||
Docket: 50-382 | |||
Licensee: Louisiana Power & Light Company (LP&L) | |||
317 Baronne Street | |||
' | |||
New Orleans, Louisiana 70160 | |||
Facility Name: Waterford Steam Electric Steam Station, Unit 3 (W3SES) | |||
Inspection At: W3SES, Taft Louisiana | |||
Inspection Conducted: February 27 through March 3, and March 13-17, 1989 | |||
Inspectors: 8-5 M | |||
L. D. Gilbert, Reactor Inspector, Materials and | |||
/#42.h? | |||
Date | |||
Quality Programs Section, Division of Reactor | |||
Safety | |||
* b __ | |||
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Y | |||
W. M. McNeill, Reactob Inspector, Materials and Date | |||
Quality Programs Section, Division of Reactor | |||
Safety | |||
bct o N trd 2./r9 | |||
R. C. Stewart, Reactor Inspector, Materials and Date | |||
Quality Programs Section, Division of Reactor | |||
Safety | |||
Approved: # $bo, u./2/99 | |||
I.Barnes, Chief,Materialsann.OualRy Date | |||
Programs Section. Division of Reactor Safety | |||
i | |||
4270360 890415 | |||
0 ADOCK 05000392 | |||
PNV | |||
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Inspection Summary | |||
' | |||
Inspection Conducted February 27 through March 3, and March 13-17, 1989 | |||
~~' | |||
(Report 50-382/89-07) | |||
Areas Inspected: Routine, unannounced inspection of action on previously | |||
identified findings, licensee self-assessment capabilities, and procurement | |||
activities. | |||
Results: The licensee has established programs and procedures in regard to | |||
onsite and offsite review committees as well as an independent safety | |||
engineering group (ISEG). The activities of the Safety Review Committee (SRC) | |||
appeared to be well documented and followup on items was satisfactory with some | |||
l | |||
minor exceptions. One apparent violation was identified (paragraph 3.a) in | |||
r | |||
regard to the failure of SRC to review certain 10 CFR 50.59 evaluations. | |||
Activities of the Plant Operations Review Committee (PORC) were not, in | |||
general, well documented. In certain cases, the lack of detail regarding PORC | |||
meeting comments was such that actions on comments could not be verified. Two | |||
examoles of one ~ apparent violation were identified (paragraph 3.b) in regard to | |||
the failure of PORC to satisfy the requirements of the Technical | |||
Specifications (TS). Specifically, PORC failed to meet in a quorum for all | |||
meetings and also failed to review two radioactive releases. ISEG was also | |||
found to be in need of improvement in regard to control and documentation of | |||
work activities. In general, programs for. procurement, receipt, storage, and | |||
handling of safety-related equipment and materials, including the dedication of | |||
commercial grade components, were found to be satisfactory. One apparent | |||
violation was identified (paragraph 4) in regard to the absence of measures for | |||
control of items for which vendors had made unsolicited shelf life | |||
recommendations. Items were also observed in storage without imposed shelf | |||
life limitations and for which current procurement practices would request | |||
shelf life information from vendors. The licensee has committed in response to | |||
Violation 382/8902-03 to establish an overall program for control of limited | |||
shelf life materials, including review of items currently stocked in | |||
warehouses. | |||
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DETAILS | |||
1. Persons Contacted i | |||
LP&L Personnel | |||
*R. C. Azzaretto, Nuclear Operations Engineering & Construction (N0EC) | |||
Manager | |||
*P. N. Backes, Assistant Plant Manager | |||
*D. E. Baker, N0SA Manager | |||
B. C. Baptist, Materials Management Superintendent | |||
*R. P. Barkhurst, Vice President | |||
*L. L. Bass, Nuclear Operations Engineering & Construction (NOEC) | |||
Supervisor | |||
R. F. Burski, Nuclear Safety & Regulatory Affairs Manager | |||
*N. 'S. Carnes, Plant Manage,' | |||
li. Collyer Fire Protection Engineer | |||
*G. M. Davis, Event Analysis Manager | |||
S. E. Farkas, Licensing Engineer | |||
*D. V. Gallodoro, Procurement Engineering Supervisor | |||
*E. B. Hyatt, Nuclear Safety Review Engine (* | |||
*J. E. Howard, NOEC Manager- | |||
*J. H. Johnston, Operations Assessment and Information Dissemination (OA&ID) | |||
Engineer , | |||
*G. F. Koehler, Quality Assurance (QA) Audit Supervisor | |||
W. T. LaBonte, Radiation Protection Superintendent | |||
*L. W. Laughlin, Site Licensing Supervisor | |||
J. Lawrence, Associate Analysts | |||
M. L. Layton, N0SA Engineer | |||
H. C. Leason, Radiological Engineer | |||
B. G. Morrison, Licensing Engineer | |||
*D. F. Packer, Assistant Plant Manager, Operations & Maintenance | |||
0. P. Pipkins, Safety Review Committee, Support Engineer | |||
R. J. Pollock, QA Auditor i | |||
*P. V. Prasankumar, Assistant Plant Manager, Technical Services 1 | |||
J. A. Ridgel, Assistant Radiation Protection Supervisor , I | |||
R. D. Riser, Procurement Engineer j | |||
C. Schmaltz, Warehouse Foreman i | |||
*J. Sleger, Nuclear Safety Review Manager l | |||
H. R. Sonmmers, OA&ID Engineer i | |||
*P. E. Troy, Independent Safety Engineering Group (ISEG) Supervisor ) | |||
J. H. Wade, QA Engineer i | |||
M. Wilson, Warehouse Foreman j | |||
R. F. Wilson, Systems Engineer < | |||
*J. J. Zabritski, QA Nanager J | |||
NRC Personnel l | |||
*T. R. Staker, Resident Inspector | |||
*W. F. Smith, Senior Resident Inspector | |||
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* Denotes those persons that attended the exit meeting on March 17, 1989. | |||
In addition, the NRC inspectors contacted other members of the licensee's | |||
staff. | |||
2. Followup on Previous' Inspection Findings (92701 and 92702) | |||
I | |||
a. (Closed)OpenItem(382/8823-04): The Safety Issues Management | |||
System (SIMS) had blanks in the safety-related data fields. | |||
The NRC inspector reviewed the licensee's actions set out in | |||
Memorandum W3M88-124 dated October 4,1988. The.SIMS data base was | |||
searched on March 16, 1989, at the request of the NRC inspector for | |||
any blanks in safety-related fields. Only four items were found | |||
which had blank fields because of apparent data entry errors. This | |||
is a significant reduction from the 1500 blanks that had been found | |||
earlier. The processing and updating of SIMS now appears in control. | |||
This item.is considered closed, | |||
o | |||
b. (Closed) Violation (382/8810-01): Failure to have documentation of | |||
qualification for the containment cooling fan motors which use | |||
Mobil-Temp SHC-32 grease in lieu of Chevron SRI-2. | |||
During this inspection, the NRC inspector reviewed the applicable | |||
correspondence relative to the compatibility of the subject greases, | |||
including analysis conducted by Mobil Oil Corporation, letter dated | |||
April 20, 1987, and an analysis conducted by Bolt & Associates | |||
Consulting Services, letter dated November 29, 1988. The results of | |||
. | |||
those studies indicate that the two greases are compatible and that | |||
there is no potential safety concern; however, the licensee plans to | |||
replace the Mobil-Temp SHC-32 grease with the Chevron SRI-2 during | |||
the next extended plant shutdown period. This item is considered | |||
closed, | |||
c. -(Closed) Violation (382/8811-01): Failure to follow procedures with | |||
respect to evaluation of Quality Notices (QNs) for 10 CFR Part 21 ; | |||
deportability. J | |||
J | |||
' | |||
Durir.g this inspection, the NRC inspector reviewed the licensee's | |||
letter of response to this violation and the referenced QAP-012 and | |||
UNT-5-015 precedure revisions dated June 15, and July 1,1988, | |||
respectively. In addition to the procedure revisicns, the licensee's | |||
corrective actions included the change of responsibility for review j | |||
and coordination of ONS for potentially reportable 10 CFR Part 21 { | |||
items to the event analysis reporting and response group. Also, the ! | |||
NRC inspector reviewed the licensing QN log and verified that all | |||
velfd QNs were properly recorded as having beer reviewed for Part 21 | |||
reporteoility. This item is e,onsidered clond. | |||
d. (Closed) Unresolved Item (382/8815-01): QN QA-87-069, relating to | |||
valve stroke time data, remained open on the current QN status report | |||
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-5- | |||
despite a completion schedule 9 months earlier and without supportive | |||
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justification. | |||
During this inspection, the NRC inspector observed that this QN was | |||
also identified in Violation 382/8811-01 noted above. Based on the | |||
licensee's corrective actions, which incorporates this is:ue, this | |||
item is closed. | |||
3. Licensee Self-Assessment Capabilities (40500) | |||
The objective of this inspection was to evaluate the effectiveness of the | |||
licensee's self-assessment programs. In this regard, the NRC inspector | |||
reviewed the activities of the SRC, the PORC, and the ISEG. The thrust of l | |||
this inspection was to measure how effective these groups were in l | |||
identifying of concerns and following them to resolution.- ' | |||
a. SRC | |||
The activities of the SRC were governed by a manual which contained | |||
the charters of the SRC and its two subcommittees. The current SRC | |||
manual is under review and revision by the licensee to incorporate | |||
such changes as a new subcommittee on corrective action. The SRC | |||
currently meets every other mcnth with a quorum of nine: the Vice | |||
President-Nuclear, and managers of Nuclear QA, Nuclear Safety and | |||
Regulatory Affairs, Nuclear Operations Engineering and Construction, | |||
Nuclear Plant Operations, Nuclear Operations Support and | |||
Assessment (NOSA), and also three consultants. The meetings | |||
addressed agenda items such as: | |||
Plant operating status (trips, outages, team inspections, etc.) | |||
Outstanding action items | |||
3,. | |||
* | |||
Reviews by Operations Assessment and Information | |||
Dissemination (OA&ID) of Institute of Nuclear Power | |||
Operations' (INP0s) Significant Operating Experience | |||
Reports -($0ERs), and Significant Event Reports (SERs), and | |||
Combustion Engineerit,g | |||
as well as, Licensee (CE) Availability) | |||
Event Reports (LERs andData | |||
EOSAProgram Reports, | |||
Surveillance | |||
and Assessments | |||
NRC issued violations ; | |||
* | |||
Reports of design deficiencies | |||
OA audits and findings | |||
Licensee amendments and Technical Specification (TS) changes | |||
* | |||
Standing committee reports (audit subcommittee and review , | |||
subcommittee) I | |||
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The NRC inspector reviewed the last three meeting minutes in detail | |||
which were numbered 89-01, 88-19, and 88-16. It was noted that prior | |||
to the above point in time. a different format for SRC meeting was | |||
[ used. There were additional meetings of SRC which were called | |||
"special" in which TS change requests were addressed. The NRC | |||
L -inspector attended the 89-02 meeting. | |||
, | |||
Some observations by the NRC inspector were the following: | |||
* | |||
Agenda Item III-B in the 69-01 meeting discussed Potential | |||
Reportable Event (PRE) 88-054 which dealt with the installation | |||
in Station Modification No.138 of a refueling level indication | |||
system with an excess length of tygon tubing. The root cause | |||
analysis by the licensee concluded that the shift supervisor | |||
! > | |||
should not have accepted the station modification in a. partial | |||
status, namely, without an implementation procedure for'the | |||
operation of the refueling level indication system. It appeared | |||
that the SRC did not question the historical and generic impact. | |||
In other words, were there other station modifications without | |||
an implementation procedure for the system or equipment | |||
modification. | |||
* | |||
Agenda Item III-C addressed two recommendations of a Quality | |||
Effectiveness Assessment Report received by LP&L which was | |||
performed at W3SES by Middle South Utilities. It was not clear | |||
to the NRC inspector if all,'or at least the significant | |||
recommendations, would be discussed by SRC in future meetings. | |||
The Quality Effectiveness Assessment had 26 recommendations and | |||
six dealt with the SRC. The NRC inspector then asked how such | |||
items as INP0 evaluations were dealt with by SRC. The NRC | |||
inspector found that the most recent evaluation had been | |||
addressed in Meetings 88-01 and -02 before the INP0 report had | |||
been issued to LP&L. The discussions were.only of the tentative | |||
or possible findings, and not of the final report's findings and | |||
the corrective actions associated with such. It appeared that | |||
the final reports of external assessments such as INP0 | |||
evaluations of W3SES were not subject to a review of SRC. | |||
* | |||
Agenda item IV-B of 89-01 addressed follow up on the revision of | |||
Procedure N0P-014 on design change control. The subject was | |||
c'losed although it was not clear that the specific question | |||
raised in the 88-19 meeting on the controls to be in the | |||
procedure, in regard tu partial closed verus partial turr.over, | |||
was addresud. There appeared to be only a general discussion | |||
of the design change process. The tracking of the question from | |||
one meeting to the next appeared to have been lost in this case. | |||
* | |||
Agende Item X-A addressed QA audits and states that no | |||
significant QNs were issued. The NRC inspector noted that the | |||
attachment summarized that there had been three QNs on the | |||
subject of bypassing and other controls of " hold points" and the , | |||
Quality Effectiveness Assessment had observed the same problem ! | |||
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.and found it significant enough to issue a recommendation. It | |||
would appear that what is significant for SRC, discussion has not | |||
been clearly defined. | |||
* | |||
* | |||
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Agenda Item X-B addressed the SRC review subcommittee | |||
activities. The attachment to the minutes, which was the' review | |||
subcommittee report', stated that the 1988 annual | |||
10 CFR 50.59 report contained 39 evaluations of which 14 had not | |||
been received by the subcommittee. At the request of the NRC | |||
inspector, the licensee followed up further_ on this subject. As | |||
a result, it was established that 32 of the 65 safety | |||
evaluations in the report t<ere not received by SRC until after | |||
the annual 10 CFR 50.59 report. It was identified that the | |||
following four 10 CFR S0.59 evaluations had not been submitted | |||
to SRC: | |||
(1) Project Evaluation /Information Request (PEIR) No. 20000, | |||
" Spent Fuel Pool Heat Load Calculation," with an August 27, | |||
1986, 10 CFR 50.59 evaluation and no apparent PORC review. | |||
(2) PEIR No. 70795 "Use of the Refueling Water Storage Pool | |||
Cross. Connect Line," with a October 8, 1986, 10 CFR 50.59 | |||
evaluation and October 14, 1986, PORC review. | |||
-(3) Condition Identification (CI)/ Work Authorization (WA) | |||
Nos. 255672/01017834, "In-Core Instrument Thimble Failure," | |||
with a May 26, 1988, 10 CFR 50.59 evaluation and May 27, | |||
1988, PORC review. | |||
(4) Special Test Procedure No. 99000104-1, " Seal Oil System | |||
Post Mod Operation," with an April 12, 1988, | |||
10 CFR 50.59 evaluation and May 17, 1988, PORC review. | |||
The failure to perform SRC reviews of these 10 CFR 50.59 evaluations | |||
was identified as an apparent violatica of TS (382/8907-01). | |||
In the above review effort, it was noted that Station Modification | |||
Packages (SMPs) 0097, 0441, 0502, 0804, 1215, 1427, and 1494 were | |||
revised after SRC. review. Inst.f ficient time was availatle during the | |||
4 inspection to ascertain whether a;1ditional 10 CFR 50.59 evaluations | |||
were performed and which were reviewed by the SRC. This is an NRC | |||
inspector followup item (382/8907-04), | |||
* Tne 89-02 neeting was attended by e QA representative, who had | |||
also attended a PORC meeting where some of the same agenda items | |||
were revieved;;e.g.,'iS Change Ivo, 88-21. Attendance at both | |||
meetings appears to have occurred because of a recent change in | |||
the organization. The individual in question did not excuse | |||
himself from the discussion, and he mentioned the PORC review | |||
comments. This situation would appear to be inconsistent with | |||
TS requirements for independent review of PORC by SRC. | |||
l | |||
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-8- | |||
Summary | |||
;. The SRC meetings appeared to be well documented and followup on items | |||
appeared to be satisfactory with the exceptions noted above. It | |||
should be noted that the above review was possible because of the | |||
excellent level of detail and documentation in the SRC meeting | |||
minutes. Also it should be noted the apparent violation on | |||
10 CFR 50.59 reviews reflects more on the' failure of PORC to input | |||
into the SRC. | |||
b. .PORC | |||
The activities of the PORC were governed by Administrative Procedure | |||
No. UNT-1-003 and some associated procedures. The current procedures | |||
were under review by the licensee in order to simplify and clarify | |||
the process of PORC review. The PORC currently meets every week with | |||
a quorum of seven: Assistant Plant Managers of Operations, | |||
Maintenance, and Technical Services; Manager of Operations QA; and | |||
Superintendents of Plant Engineering, Operations, Maintenance, and | |||
Radiation Protection. The meetings addressed such agenda items as: | |||
Procedure changes and revisions | |||
* | |||
LERs and PRES | |||
* | |||
TS changes | |||
* | |||
SMPs and Design Changes | |||
* | |||
CIs and WAs | |||
* Justification for Continued Operations | |||
The NRC inspector reviewed the meeting minutes numbered 88-100 | |||
through -127. The NRC inspector attended PORC Meeting 89-24. | |||
Some observations by the NRC inspector were the following: | |||
A significant fraction of the PORC meeting minutes were | |||
characterized as " walk-thrcugh" meetings where PORC did not meet | |||
es a quorum meeting with all members present. It appeared that | |||
only one or two items were addressed in each of these : | |||
" walk-through" meeting minutes. The " walk-through" process was | |||
a serial ballot review technique in which the members | |||
sequentially reviewed an agenda item. This was described in the | |||
implementing procedure in Step 5.2.7.2. It should be noted t. hat | |||
American National Standard Institute (ANSI) N18.7-1976, a | |||
comm1trent of W3SES, states in 4.3.2.3 for a meeting to be he16, | |||
a cuorum shall be present. The failure to have a qaorum present | |||
for " walk-through" meetings was identified as one example of an | |||
apparent violation (38E/8907 02). | |||
* | |||
At Meetings 88-107 and -112 radioactive releases were presented | |||
to PORC which were not voted upon or apparently reviewed except | |||
to the extent to conclude that the releases were not to be given | |||
PORC review. The releases in question occurred on April 3 and | |||
) | |||
. | |||
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M May 23, 1988, and were minor in character and for which LERs | |||
' | |||
.were not' required. The review of accidental, unplanned or | |||
uncontrolled radioactive releases. including the' evaluations, | |||
recommendations, and disposition of the corrective actions to | |||
prevent.. recurrence is required by TS. The failure to review | |||
these releases was identified'as the second example of an | |||
apparent violation (382/8907-02).. | |||
* | |||
Because of the use of the same forms'by PORC and the normal | |||
document review process to document comments, it is not always | |||
clear what were the comments made at the PORC level of review. | |||
In certain cases, the recorded PORC level coments made during | |||
meetings- failed to have.. sufficient detail to allow verification | |||
of resolution of the coments. It appeared that coments made | |||
in regard to Procedure MI-0-462 made at 88-120 and -127 meetings | |||
were not complied with by the staff. Because of the lack of | |||
detail, an effective evaluation of PORC review activities was | |||
not possible. | |||
Sumary | |||
Improvement is needed in the area of documentation of PORC review | |||
activities which would allow verification of the identification of | |||
4 | |||
items and followup on such. The licensee plans revision of the PORC | |||
procedures and activities. | |||
- c. ISEG- | |||
The activities of the ISEG were governed by Procedure N0 SAP-102 and a | |||
, | |||
supporting procedure. The licensee was planning an additional | |||
procedure, N0 SAP-109, to further define ISEG activities. ISEG was | |||
staffed with a supervisor and four other engineers. ISEG addressed | |||
items identified by management of ISEG and other management sources. | |||
In addition, ISEG performed surveillance and assessments in | |||
accordance with a schedule. | |||
Operating experience, outside and inside W35ES, was reviewed by ISEG. | |||
The NRC inspector reviewed the monthly reports for the last 3 months, f | |||
^ | |||
the 1988 schedule, and a sample of " Assessment" and "Survefilance" | |||
reports. | |||
Some observations by the NRC inspector were the following: | |||
' " | |||
The monthly reports for December through February were | |||
inaccurate-in that the number of recommendations were not , | |||
reported correctly. | |||
* | |||
A schedule for 1989 had not been established as of the time of | |||
this inspection. | |||
_ - _ _ _ _ - - _ _ _ _ _ _ _ _ _ - - - _ - _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ - _ _ _ _ _ | |||
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* | |||
Reports of.." Assessments" and " Surveillance" failed.to include | |||
A ' | |||
.significant details. For example, Re' port 239-88 failed to | |||
L fidentify that a. recommendation in the report was also' identified | |||
' | |||
in a QN and that the closeout of the recommendation would be via | |||
closecut of'the QN . | |||
* | |||
The' status of recommendations and reports was misleading. . . | |||
Reports 194-88 and 197-88 were signed off as closed, when in. | |||
N fact, their status was open. Report 183-88 was not signed.off? | |||
; - | |||
< | |||
.as closed, when in fact, its status was closed. | |||
p | |||
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.There appears.to be a lack of timely. followup on recommendations | |||
which were the result of." Assessments" and " Surveillance." In | |||
~ | |||
, | |||
1988, there^had been 54 recommendations issued.of which 27 were | |||
open.as of the time of this inspection. | |||
''; | |||
There was no documentation of the reviews performed of NRC | |||
Notices, Bulletins, Notice.of Violations, LERs, 10 CFR 50.59 | |||
reviews, PRES, SMPs, procedures and other operating experience | |||
. reports when ,the review by ISEG did not result in'a comment or | |||
recommendation. | |||
* The!1icensee had performed a QA audit of ISEG activities and | |||
, -identified some of the above observations. The QA audit did not | |||
identify the problems above as findings and the report was'in a | |||
draft status as of the time of this inspection. | |||
; | |||
Summary , | |||
ISEG activities were found to be in need of improvement. -ISEG | |||
activities in the'past appears to'have been better managed in certain | |||
areas. such as monthly-reports, and should be reviewed again after | |||
. | |||
implementation of N0 SAP-109. | |||
7 d.- 0ther Organi n tions | |||
-The activitin of N0SA, in particular DA&lD and the assessment group, | |||
were reAewed. -These activities tvers governed by Proceduras N05AP-103 | |||
anu 104. 0A&IO performs reviews of operating experience reports such | |||
i' | |||
.. | |||
:as Significant Occurrence Reports (50Rs) and PRES in accordarce with | |||
6 a checklist for deportability on the nuclear network. INPO S0s, | |||
l<,. SOERs, and SEPS are also reviewed by OA&ID. Several recent evaluations | |||
<" > of PRES and SERS by 0A&ID were examined by the NRC inspector. The | |||
j -identification of items and followup appeared satisfactory. | |||
' | |||
I | |||
" In regard-to the assessment group, it was noted that it shared the | |||
same problem ISEG- had, as identified above, in regard to timely | |||
followup of recommendations. The assessment group reviewed third | |||
, | |||
party audits of W3SES by INP0, Middle South Utilities, and others, in | |||
* | |||
=. - ___ _. _ _ _ _ _ _ .-_ _ _ _ _ _ ___ _____ __ _ ___-__ - - - - - - - | |||
' | |||
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[, | |||
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p | |||
p. - | |||
m .. . | |||
, | |||
h -11- | |||
L | |||
order to establish priorities for its assessment and surveillance | |||
schedule. | |||
Summary | |||
Other organizational activities in regards to self-assessment | |||
appeared to be implemented at W3SES. Some of these activities | |||
appeared to cover areas that are normally addressed by ISEG. | |||
4. Procurement, Recei)t, Storage, and Handling of Equipment and Materials | |||
Program (38701,-33702. and 38703) | |||
Initial NRC inspection of the programs for procurement, receipt, storage, | |||
and handling of equipment and materials is documented in NRC Inspection | |||
Report 50-382/89-02.. During this inspection, the NRC inspectors reviewed | |||
the following additional documents in. order to verify that administrative | |||
controls exist and that they provido measures to ensure that received | |||
materials and equipment will be examined for conformance with requirements | |||
specified in the procurement documentation. The documents were reviewed | |||
to verify that acceptance criteria were' clearly established and that | |||
requirements for documenting the~ performance of receipt inspections were | |||
= delineated.- They were also reviewed to assure that controls exist with | |||
respect to storage and maintenance of safety-related items, and | |||
responsibilities were assigned in writing. | |||
Document No. Revision Title | |||
N0EP-004 1 The Engineering Procurement Process | |||
QAP-251 2.0 Material Storage Inspection | |||
UNT-8-013 3 Receiving, Handling, and' Storage | |||
ME-4-703 7 Routing Electrical' Equipment Inspection | |||
and Maintenance | |||
The NRC inspectors reviewed the licensee's computer listing of commercial | |||
grade parts or components which were designated Quality Class 3 items that | |||
had been installed in safety-related systems or equipment and selected the | |||
following items for review of the procurement and dedication processes: | |||
- | |||
Condition Purchase | |||
identification _ Order Stockcode Description _ | |||
252256 14436 101-A04159 Flanged Bearing for Personnel | |||
Air Lock Hand Wheel Shaft | |||
254069 16795 135-C11563 Diaphragm for Resin Tank | |||
Isolation Valve | |||
_ _ __ _ | |||
, | |||
-. - | |||
. . | |||
. | |||
. | |||
. o | |||
, | |||
-12- | |||
256126 15740 151-F00027 Adhesive Thread Sealant for | |||
Reactor Coolant Loop 2A Cold | |||
Leg Temperature Detector | |||
257372 11740 135-C30772 Insert Disc with Pin and | |||
22961 160-A00034 Bellows Subassembly for | |||
Charging Pump A Discharge | |||
Header Relief Valve | |||
259165 73018 102-C50002 Stud Bolt Nut for Reactor | |||
Coolant Pump 1A and Motor | |||
Coupler Assembly | |||
260848 16688 101-D38476 Seal Kit, Jackscrew | |||
22958 135-C00191 Assembly, Spiral | |||
135-C58055 Assembly, Seal Nut, and | |||
135-C70187 Cylinder Assembly for | |||
23258 135-C00209 Component Cooling Water | |||
Supply Valve Operator | |||
The NRC inspectors reviewed the procurement and receiving inspection | |||
documents while reviewing the commercial grade dedication process for the | |||
items selected above. The reviewed documentation consisted of a purchase | |||
order, a receipt checklist which addresses shipping damage, | |||
identification, documentation received, protective devices, and | |||
cleanliness, and an engineering evaluation. The programs for procurement, | |||
receiving inspection, and dedication of commercial grade parts and | |||
components appeared to be effective with respect to meeting the committed | |||
objectives. | |||
The NRC inspectors also inspected for proper storage of safety-related | |||
equipment ard materials in Warehouses 7B and 2B, and the Service Buildir.g | |||
Warehouse. The buildings were designated Storage Leval B except for a | |||
small room in the Service Building which was controlled as a Storage | |||
Level A. The NRC inspectors reviewed the Warehouse Surveillance | |||
inspection Records of the sturage areas fnr March 6-12, 1989. The | |||
environmental conditions in the storage areas were consistent with the | |||
stora5e level requirements o# Procedure UNT-8-013. Electric motors, which | |||
are required to be heated while in storage, were observed with heaters | |||
energized and maintained as specified in Procedure ME-4-703. During the | |||
tour of the storage areas, tha NRC inspectors selected the following items | |||
to verify the tagging or marking for traceability of the item to purchase | |||
documents, receipt documents, quality certification documents, and if | |||
applicable, limited shelf life. | |||
Stockcode Purchase Order Description | |||
120-A73132 83287 Stainless Steel Tubing | |||
135-B81240 48296 Globe Valve | |||
107-C00001 66121 Alumina Activated Desiccant | |||
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_ | |||
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-13- | |||
105-A46185 19475 Limitorque Electric Motor | |||
135-B80910 14639 Valve Solenoid | |||
152-C19300 16679 Mass Flowmeter | |||
138-A15424 10458 Welding Material | |||
151-B15408 66101 Welding Material | |||
151-B15407 66101 Welding Material | |||
101-D53873 96954 0-Ring | |||
102-C53947 16176 0-Ring Gland Plate | |||
102-C54033 23305 0-Ring | |||
102-C53944 20768 0-Ring Gland | |||
127-B38461 24764 Spare Parts Kit | |||
127-B53849 24764 0-Ring | |||
The above items were traceable to purchased documents, receipt documents, | |||
and quality certification documents; however, discrepancies were noted | |||
regardir.g the identification of limited shelf life for the following | |||
items: | |||
a. Unsolicited Shelf Life Limitations Provided by Vendor _s, | |||
' The Material Management Information System specified no shelf | |||
life requirements for Stockcode 152-019300 but the vendor | |||
documentation received for the mass flowmeter gave an unsolicited | |||
shelf life of 3 years. | |||
The Material Management Information System specified no shelf | |||
life requirements for Stockcode 101-D53873 but the vendor | |||
documentation received for the 0-Ring gave an unsolicited shelf | |||
life of 20 years. | |||
Although the licensee was attempting to implement unsolicited shelf | |||
life limitations received from vendors, no formal program was in | |||
place to handle this matter. The licensee stated that a procedure | |||
will soon be issued to promulgate the requirements for limited shelf | |||
life, including handling of uronlicited info;mation. This is in | |||
apparent violation for failure to identify and control limited shelf | |||
life materials. (382/8907-03) | |||
b. Shelf Life Limitations Not Requested From Vendors | |||
* The Material Management Informatten System specified no shelf | |||
life requirements for Stockcode 102-C53947. The vendor was not | |||
' requested to provide shelf life limitations for this 0. Ring | |||
gland plate, therefore no information ws.s provided. | |||
The Material Management Information System spec 1fied no shelf | |||
life requirements for Stockcode 102-C54033 from Purchase | |||
Order 23305. The vendor was not requested to provide shelf life | |||
limitations for this 0-Ring, therefore no information was | |||
provided. However, a shelf life was received on another | |||
purchase order for this stockcode. | |||
, | |||
_ __ - _ _ - - _ _ - - _ - - - _ _ - _ _ | |||
- - - -. _ _ _ - _ _ - _ | |||
... .. - | |||
. # ll . | |||
y . . | |||
. | |||
-14- 1 | |||
J | |||
* | |||
The Material Management Information System specified no shelf | |||
life requirements for Stockcode 127-B38461. The vendor was not | |||
requested to provide shelf life limitations for.this spare parts | |||
kit, therefore no information was provided. | |||
* | |||
The Material Management Information System specified no shelf | |||
life requirements for Stockcode 127-B53849. The vendor was not | |||
requested to provide shelf life limitations for this 0-Ring; | |||
therefore no information was provided. | |||
The above discrepancies are additional examples of a recent inspection | |||
finding, Violation 382/8902-03, documented in NRC Inspection | |||
Report 50-382/89-02. The licensee has written Quality Notice QA-89-071 | |||
which will assure that'these items are included in the corrective | |||
action developed for Violation 382/8902-03. The licensee has | |||
committed in response to this violation to establish an overall | |||
program for control of limited shelf life materials, including review | |||
of items currently' stocked in warehouses. | |||
5. Exit Meeting | |||
An exit meeting was held on March 17, 1989, with those individuals denoted | |||
in paragraph 1 of this report. At this meeting, the scope of the inspection | |||
and the findings were sunnarizeo. The NRC resident inspectors also | |||
attended. The licensee did not identify as proprietary any of the | |||
information provided to, or reviewed by the NRC inspectors. | |||
. | |||
I | |||
k | |||
i | |||
}} | |||
Revision as of 01:38, 1 February 2022
| ML20245C728 | |
| Person / Time | |
|---|---|
| Site: | Waterford |
| Issue date: | 04/12/1989 |
| From: | Barnes I, Gilbert L, Mcneill W, Stewart R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML20245C716 | List: |
| References | |
| 50-382-89-07, 50-382-89-7, NUDOCS 8904270360 | |
| Download: ML20245C728 (14) | |
See also: IR 05000382/1989007
Text
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8
I
APPENDIX B
U.S. NUCLEAR REGULATORY COMMISSION
REGION IV
NRC Inspection Report: 50-382/89-07 Operating License: NPF-38
Docket: 50-382
Licensee: Louisiana Power & Light Company (LP&L)
317 Baronne Street
'
New Orleans, Louisiana 70160
Facility Name: Waterford Steam Electric Steam Station, Unit 3 (W3SES)
Inspection At: W3SES, Taft Louisiana
Inspection Conducted: February 27 through March 3, and March 13-17, 1989
Inspectors: 8-5 M
L. D. Gilbert, Reactor Inspector, Materials and
/#42.h?
Date
Quality Programs Section, Division of Reactor
Safety
- b __
'
Y
W. M. McNeill, Reactob Inspector, Materials and Date
Quality Programs Section, Division of Reactor
Safety
bct o N trd 2./r9
R. C. Stewart, Reactor Inspector, Materials and Date
Quality Programs Section, Division of Reactor
Safety
Approved: # $bo, u./2/99
I.Barnes, Chief,Materialsann.OualRy Date
Programs Section. Division of Reactor Safety
i
4270360 890415
0 ADOCK 05000392
PNV
1
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Inspection Summary
'
Inspection Conducted February 27 through March 3, and March 13-17, 1989
~~'
(Report 50-382/89-07)
Areas Inspected: Routine, unannounced inspection of action on previously
identified findings, licensee self-assessment capabilities, and procurement
activities.
Results: The licensee has established programs and procedures in regard to
onsite and offsite review committees as well as an independent safety
engineering group (ISEG). The activities of the Safety Review Committee (SRC)
appeared to be well documented and followup on items was satisfactory with some
l
minor exceptions. One apparent violation was identified (paragraph 3.a) in
r
regard to the failure of SRC to review certain 10 CFR 50.59 evaluations.
Activities of the Plant Operations Review Committee (PORC) were not, in
general, well documented. In certain cases, the lack of detail regarding PORC
meeting comments was such that actions on comments could not be verified. Two
examoles of one ~ apparent violation were identified (paragraph 3.b) in regard to
the failure of PORC to satisfy the requirements of the Technical
Specifications (TS). Specifically, PORC failed to meet in a quorum for all
meetings and also failed to review two radioactive releases. ISEG was also
found to be in need of improvement in regard to control and documentation of
work activities. In general, programs for. procurement, receipt, storage, and
handling of safety-related equipment and materials, including the dedication of
commercial grade components, were found to be satisfactory. One apparent
violation was identified (paragraph 4) in regard to the absence of measures for
control of items for which vendors had made unsolicited shelf life
recommendations. Items were also observed in storage without imposed shelf
life limitations and for which current procurement practices would request
shelf life information from vendors. The licensee has committed in response to
Violation 382/8902-03 to establish an overall program for control of limited
shelf life materials, including review of items currently stocked in
warehouses.
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DETAILS
1. Persons Contacted i
LP&L Personnel
- R. C. Azzaretto, Nuclear Operations Engineering & Construction (N0EC)
Manager
- P. N. Backes, Assistant Plant Manager
- D. E. Baker, N0SA Manager
B. C. Baptist, Materials Management Superintendent
- R. P. Barkhurst, Vice President
- L. L. Bass, Nuclear Operations Engineering & Construction (NOEC)
Supervisor
R. F. Burski, Nuclear Safety & Regulatory Affairs Manager
- N. 'S. Carnes, Plant Manage,'
li. Collyer Fire Protection Engineer
- G. M. Davis, Event Analysis Manager
S. E. Farkas, Licensing Engineer
- D. V. Gallodoro, Procurement Engineering Supervisor
- E. B. Hyatt, Nuclear Safety Review Engine (*
- J. E. Howard, NOEC Manager-
- J. H. Johnston, Operations Assessment and Information Dissemination (OA&ID)
Engineer ,
- G. F. Koehler, Quality Assurance (QA) Audit Supervisor
W. T. LaBonte, Radiation Protection Superintendent
- L. W. Laughlin, Site Licensing Supervisor
J. Lawrence, Associate Analysts
M. L. Layton, N0SA Engineer
H. C. Leason, Radiological Engineer
B. G. Morrison, Licensing Engineer
- D. F. Packer, Assistant Plant Manager, Operations & Maintenance
0. P. Pipkins, Safety Review Committee, Support Engineer
R. J. Pollock, QA Auditor i
- P. V. Prasankumar, Assistant Plant Manager, Technical Services 1
J. A. Ridgel, Assistant Radiation Protection Supervisor , I
R. D. Riser, Procurement Engineer j
C. Schmaltz, Warehouse Foreman i
- J. Sleger, Nuclear Safety Review Manager l
H. R. Sonmmers, OA&ID Engineer i
- P. E. Troy, Independent Safety Engineering Group (ISEG) Supervisor )
J. H. Wade, QA Engineer i
M. Wilson, Warehouse Foreman j
R. F. Wilson, Systems Engineer <
- J. J. Zabritski, QA Nanager J
NRC Personnel l
- T. R. Staker, Resident Inspector
- W. F. Smith, Senior Resident Inspector
_ --_ _ - - _ _ _ - _ _ - _ _ - _ _ _ _ _ _ - _ _ - _
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- Denotes those persons that attended the exit meeting on March 17, 1989.
In addition, the NRC inspectors contacted other members of the licensee's
staff.
2. Followup on Previous' Inspection Findings (92701 and 92702)
I
a. (Closed)OpenItem(382/8823-04): The Safety Issues Management
System (SIMS) had blanks in the safety-related data fields.
The NRC inspector reviewed the licensee's actions set out in
Memorandum W3M88-124 dated October 4,1988. The.SIMS data base was
searched on March 16, 1989, at the request of the NRC inspector for
any blanks in safety-related fields. Only four items were found
which had blank fields because of apparent data entry errors. This
is a significant reduction from the 1500 blanks that had been found
earlier. The processing and updating of SIMS now appears in control.
This item.is considered closed,
o
b. (Closed) Violation (382/8810-01): Failure to have documentation of
qualification for the containment cooling fan motors which use
Mobil-Temp SHC-32 grease in lieu of Chevron SRI-2.
During this inspection, the NRC inspector reviewed the applicable
correspondence relative to the compatibility of the subject greases,
including analysis conducted by Mobil Oil Corporation, letter dated
April 20, 1987, and an analysis conducted by Bolt & Associates
Consulting Services, letter dated November 29, 1988. The results of
.
those studies indicate that the two greases are compatible and that
there is no potential safety concern; however, the licensee plans to
replace the Mobil-Temp SHC-32 grease with the Chevron SRI-2 during
the next extended plant shutdown period. This item is considered
closed,
c. -(Closed) Violation (382/8811-01): Failure to follow procedures with
respect to evaluation of Quality Notices (QNs) for 10 CFR Part 21 ;
deportability. J
J
'
Durir.g this inspection, the NRC inspector reviewed the licensee's
letter of response to this violation and the referenced QAP-012 and
UNT-5-015 precedure revisions dated June 15, and July 1,1988,
respectively. In addition to the procedure revisicns, the licensee's
corrective actions included the change of responsibility for review j
and coordination of ONS for potentially reportable 10 CFR Part 21 {
items to the event analysis reporting and response group. Also, the !
NRC inspector reviewed the licensing QN log and verified that all
velfd QNs were properly recorded as having beer reviewed for Part 21
reporteoility. This item is e,onsidered clond.
d. (Closed) Unresolved Item (382/8815-01): QN QA-87-069, relating to
valve stroke time data, remained open on the current QN status report
!
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-5-
despite a completion schedule 9 months earlier and without supportive
'
justification.
During this inspection, the NRC inspector observed that this QN was
also identified in Violation 382/8811-01 noted above. Based on the
licensee's corrective actions, which incorporates this is:ue, this
item is closed.
3. Licensee Self-Assessment Capabilities (40500)
The objective of this inspection was to evaluate the effectiveness of the
licensee's self-assessment programs. In this regard, the NRC inspector
reviewed the activities of the SRC, the PORC, and the ISEG. The thrust of l
this inspection was to measure how effective these groups were in l
identifying of concerns and following them to resolution.- '
a. SRC
The activities of the SRC were governed by a manual which contained
the charters of the SRC and its two subcommittees. The current SRC
manual is under review and revision by the licensee to incorporate
such changes as a new subcommittee on corrective action. The SRC
currently meets every other mcnth with a quorum of nine: the Vice
President-Nuclear, and managers of Nuclear QA, Nuclear Safety and
Regulatory Affairs, Nuclear Operations Engineering and Construction,
Nuclear Plant Operations, Nuclear Operations Support and
Assessment (NOSA), and also three consultants. The meetings
addressed agenda items such as:
Plant operating status (trips, outages, team inspections, etc.)
Outstanding action items
3,.
Reviews by Operations Assessment and Information
Dissemination (OA&ID) of Institute of Nuclear Power
Operations' (INP0s) Significant Operating Experience
Reports -($0ERs), and Significant Event Reports (SERs), and
Combustion Engineerit,g
as well as, Licensee (CE) Availability)
Event Reports (LERs andData
EOSAProgram Reports,
Surveillance
and Assessments
NRC issued violations ;
Reports of design deficiencies
OA audits and findings
Licensee amendments and Technical Specification (TS) changes
Standing committee reports (audit subcommittee and review ,
subcommittee) I
u__
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<
The NRC inspector reviewed the last three meeting minutes in detail
which were numbered 89-01, 88-19, and 88-16. It was noted that prior
to the above point in time. a different format for SRC meeting was
[ used. There were additional meetings of SRC which were called
"special" in which TS change requests were addressed. The NRC
L -inspector attended the 89-02 meeting.
,
Some observations by the NRC inspector were the following:
Agenda Item III-B in the 69-01 meeting discussed Potential
Reportable Event (PRE)88-054 which dealt with the installation
in Station Modification No.138 of a refueling level indication
system with an excess length of tygon tubing. The root cause
analysis by the licensee concluded that the shift supervisor
! >
should not have accepted the station modification in a. partial
status, namely, without an implementation procedure for'the
operation of the refueling level indication system. It appeared
that the SRC did not question the historical and generic impact.
In other words, were there other station modifications without
an implementation procedure for the system or equipment
modification.
Agenda Item III-C addressed two recommendations of a Quality
Effectiveness Assessment Report received by LP&L which was
performed at W3SES by Middle South Utilities. It was not clear
to the NRC inspector if all,'or at least the significant
recommendations, would be discussed by SRC in future meetings.
The Quality Effectiveness Assessment had 26 recommendations and
six dealt with the SRC. The NRC inspector then asked how such
items as INP0 evaluations were dealt with by SRC. The NRC
inspector found that the most recent evaluation had been
addressed in Meetings 88-01 and -02 before the INP0 report had
been issued to LP&L. The discussions were.only of the tentative
or possible findings, and not of the final report's findings and
the corrective actions associated with such. It appeared that
the final reports of external assessments such as INP0
evaluations of W3SES were not subject to a review of SRC.
Agenda item IV-B of 89-01 addressed follow up on the revision of
Procedure N0P-014 on design change control. The subject was
c'losed although it was not clear that the specific question
raised in the 88-19 meeting on the controls to be in the
procedure, in regard tu partial closed verus partial turr.over,
was addresud. There appeared to be only a general discussion
of the design change process. The tracking of the question from
one meeting to the next appeared to have been lost in this case.
Agende Item X-A addressed QA audits and states that no
significant QNs were issued. The NRC inspector noted that the
attachment summarized that there had been three QNs on the
subject of bypassing and other controls of " hold points" and the ,
Quality Effectiveness Assessment had observed the same problem !
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.and found it significant enough to issue a recommendation. It
would appear that what is significant for SRC, discussion has not
been clearly defined.
'
Agenda Item X-B addressed the SRC review subcommittee
activities. The attachment to the minutes, which was the' review
subcommittee report', stated that the 1988 annual
10 CFR 50.59 report contained 39 evaluations of which 14 had not
been received by the subcommittee. At the request of the NRC
inspector, the licensee followed up further_ on this subject. As
a result, it was established that 32 of the 65 safety
evaluations in the report t<ere not received by SRC until after
the annual 10 CFR 50.59 report. It was identified that the
following four 10 CFR S0.59 evaluations had not been submitted
to SRC:
(1) Project Evaluation /Information Request (PEIR) No. 20000,
" Spent Fuel Pool Heat Load Calculation," with an August 27,
1986, 10 CFR 50.59 evaluation and no apparent PORC review.
(2) PEIR No. 70795 "Use of the Refueling Water Storage Pool
Cross. Connect Line," with a October 8, 1986, 10 CFR 50.59
evaluation and October 14, 1986, PORC review.
-(3) Condition Identification (CI)/ Work Authorization (WA)
Nos. 255672/01017834, "In-Core Instrument Thimble Failure,"
with a May 26, 1988, 10 CFR 50.59 evaluation and May 27,
1988, PORC review.
(4) Special Test Procedure No. 99000104-1, " Seal Oil System
Post Mod Operation," with an April 12, 1988,
10 CFR 50.59 evaluation and May 17, 1988, PORC review.
The failure to perform SRC reviews of these 10 CFR 50.59 evaluations
was identified as an apparent violatica of TS (382/8907-01).
In the above review effort, it was noted that Station Modification
Packages (SMPs) 0097, 0441, 0502, 0804, 1215, 1427, and 1494 were
revised after SRC. review. Inst.f ficient time was availatle during the
4 inspection to ascertain whether a;1ditional 10 CFR 50.59 evaluations
were performed and which were reviewed by the SRC. This is an NRC
inspector followup item (382/8907-04),
- Tne 89-02 neeting was attended by e QA representative, who had
also attended a PORC meeting where some of the same agenda items
were revieved;;e.g.,'iS Change Ivo, 88-21. Attendance at both
meetings appears to have occurred because of a recent change in
the organization. The individual in question did not excuse
himself from the discussion, and he mentioned the PORC review
comments. This situation would appear to be inconsistent with
TS requirements for independent review of PORC by SRC.
l
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Summary
- . The SRC meetings appeared to be well documented and followup on items
appeared to be satisfactory with the exceptions noted above. It
should be noted that the above review was possible because of the
excellent level of detail and documentation in the SRC meeting
minutes. Also it should be noted the apparent violation on
10 CFR 50.59 reviews reflects more on the' failure of PORC to input
into the SRC.
b. .PORC
The activities of the PORC were governed by Administrative Procedure
No. UNT-1-003 and some associated procedures. The current procedures
were under review by the licensee in order to simplify and clarify
the process of PORC review. The PORC currently meets every week with
a quorum of seven: Assistant Plant Managers of Operations,
Maintenance, and Technical Services; Manager of Operations QA; and
Superintendents of Plant Engineering, Operations, Maintenance, and
Radiation Protection. The meetings addressed such agenda items as:
Procedure changes and revisions
LERs and PRES
TS changes
SMPs and Design Changes
CIs and WAs
- Justification for Continued Operations
The NRC inspector reviewed the meeting minutes numbered 88-100
through -127. The NRC inspector attended PORC Meeting 89-24.
Some observations by the NRC inspector were the following:
A significant fraction of the PORC meeting minutes were
characterized as " walk-thrcugh" meetings where PORC did not meet
es a quorum meeting with all members present. It appeared that
only one or two items were addressed in each of these :
" walk-through" meeting minutes. The " walk-through" process was
a serial ballot review technique in which the members
sequentially reviewed an agenda item. This was described in the
implementing procedure in Step 5.2.7.2. It should be noted t. hat
American National Standard Institute (ANSI) N18.7-1976, a
comm1trent of W3SES, states in 4.3.2.3 for a meeting to be he16,
a cuorum shall be present. The failure to have a qaorum present
for " walk-through" meetings was identified as one example of an
apparent violation (38E/8907 02).
At Meetings88-107 and -112 radioactive releases were presented
to PORC which were not voted upon or apparently reviewed except
to the extent to conclude that the releases were not to be given
PORC review. The releases in question occurred on April 3 and
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M May 23, 1988, and were minor in character and for which LERs
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.were not' required. The review of accidental, unplanned or
uncontrolled radioactive releases. including the' evaluations,
recommendations, and disposition of the corrective actions to
prevent.. recurrence is required by TS. The failure to review
these releases was identified'as the second example of an
apparent violation (382/8907-02)..
Because of the use of the same forms'by PORC and the normal
document review process to document comments, it is not always
clear what were the comments made at the PORC level of review.
In certain cases, the recorded PORC level coments made during
meetings- failed to have.. sufficient detail to allow verification
of resolution of the coments. It appeared that coments made
in regard to Procedure MI-0-462 made at 88-120 and -127 meetings
were not complied with by the staff. Because of the lack of
detail, an effective evaluation of PORC review activities was
not possible.
Sumary
Improvement is needed in the area of documentation of PORC review
activities which would allow verification of the identification of
4
items and followup on such. The licensee plans revision of the PORC
procedures and activities.
- c. ISEG-
The activities of the ISEG were governed by Procedure N0 SAP-102 and a
,
supporting procedure. The licensee was planning an additional
procedure, N0 SAP-109, to further define ISEG activities. ISEG was
staffed with a supervisor and four other engineers. ISEG addressed
items identified by management of ISEG and other management sources.
In addition, ISEG performed surveillance and assessments in
accordance with a schedule.
Operating experience, outside and inside W35ES, was reviewed by ISEG.
The NRC inspector reviewed the monthly reports for the last 3 months, f
^
the 1988 schedule, and a sample of " Assessment" and "Survefilance"
reports.
Some observations by the NRC inspector were the following:
' "
The monthly reports for December through February were
inaccurate-in that the number of recommendations were not ,
reported correctly.
A schedule for 1989 had not been established as of the time of
this inspection.
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Reports of.." Assessments" and " Surveillance" failed.to include
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.significant details. For example, Re' port 239-88 failed to
L fidentify that a. recommendation in the report was also' identified
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in a QN and that the closeout of the recommendation would be via
closecut of'the QN .
The' status of recommendations and reports was misleading. . .
Reports 194-88 and 197-88 were signed off as closed, when in.
N fact, their status was open. Report 183-88 was not signed.off?
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.as closed, when in fact, its status was closed.
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.There appears.to be a lack of timely. followup on recommendations
which were the result of." Assessments" and " Surveillance." In
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1988, there^had been 54 recommendations issued.of which 27 were
open.as of the time of this inspection.
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There was no documentation of the reviews performed of NRC
Notices, Bulletins, Notice.of Violations, LERs, 10 CFR 50.59
reviews, PRES, SMPs, procedures and other operating experience
. reports when ,the review by ISEG did not result in'a comment or
recommendation.
- The!1icensee had performed a QA audit of ISEG activities and
, -identified some of the above observations. The QA audit did not
identify the problems above as findings and the report was'in a
draft status as of the time of this inspection.
Summary ,
ISEG activities were found to be in need of improvement. -ISEG
activities in the'past appears to'have been better managed in certain
areas. such as monthly-reports, and should be reviewed again after
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implementation of N0 SAP-109.
7 d.- 0ther Organi n tions
-The activitin of N0SA, in particular DA&lD and the assessment group,
were reAewed. -These activities tvers governed by Proceduras N05AP-103
anu 104. 0A&IO performs reviews of operating experience reports such
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- as Significant Occurrence Reports (50Rs) and PRES in accordarce with
6 a checklist for deportability on the nuclear network. INPO S0s,
l<,. SOERs, and SEPS are also reviewed by OA&ID. Several recent evaluations
<" > of PRES and SERS by 0A&ID were examined by the NRC inspector. The
j -identification of items and followup appeared satisfactory.
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" In regard-to the assessment group, it was noted that it shared the
same problem ISEG- had, as identified above, in regard to timely
followup of recommendations. The assessment group reviewed third
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party audits of W3SES by INP0, Middle South Utilities, and others, in
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order to establish priorities for its assessment and surveillance
schedule.
Summary
Other organizational activities in regards to self-assessment
appeared to be implemented at W3SES. Some of these activities
appeared to cover areas that are normally addressed by ISEG.
4. Procurement, Recei)t, Storage, and Handling of Equipment and Materials
Program (38701,-33702. and 38703)
Initial NRC inspection of the programs for procurement, receipt, storage,
and handling of equipment and materials is documented in NRC Inspection
Report 50-382/89-02.. During this inspection, the NRC inspectors reviewed
the following additional documents in. order to verify that administrative
controls exist and that they provido measures to ensure that received
materials and equipment will be examined for conformance with requirements
specified in the procurement documentation. The documents were reviewed
to verify that acceptance criteria were' clearly established and that
requirements for documenting the~ performance of receipt inspections were
= delineated.- They were also reviewed to assure that controls exist with
respect to storage and maintenance of safety-related items, and
responsibilities were assigned in writing.
Document No. Revision Title
N0EP-004 1 The Engineering Procurement Process
QAP-251 2.0 Material Storage Inspection
UNT-8-013 3 Receiving, Handling, and' Storage
ME-4-703 7 Routing Electrical' Equipment Inspection
and Maintenance
The NRC inspectors reviewed the licensee's computer listing of commercial
grade parts or components which were designated Quality Class 3 items that
had been installed in safety-related systems or equipment and selected the
following items for review of the procurement and dedication processes:
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Condition Purchase
identification _ Order Stockcode Description _
252256 14436 101-A04159 Flanged Bearing for Personnel
Air Lock Hand Wheel Shaft
254069 16795 135-C11563 Diaphragm for Resin Tank
Isolation Valve
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256126 15740 151-F00027 Adhesive Thread Sealant for
Reactor Coolant Loop 2A Cold
Leg Temperature Detector
257372 11740 135-C30772 Insert Disc with Pin and
22961 160-A00034 Bellows Subassembly for
Charging Pump A Discharge
Header Relief Valve
259165 73018 102-C50002 Stud Bolt Nut for Reactor
Coolant Pump 1A and Motor
Coupler Assembly
260848 16688 101-D38476 Seal Kit, Jackscrew
22958 135-C00191 Assembly, Spiral
135-C58055 Assembly, Seal Nut, and
135-C70187 Cylinder Assembly for
23258 135-C00209 Component Cooling Water
Supply Valve Operator
The NRC inspectors reviewed the procurement and receiving inspection
documents while reviewing the commercial grade dedication process for the
items selected above. The reviewed documentation consisted of a purchase
order, a receipt checklist which addresses shipping damage,
identification, documentation received, protective devices, and
cleanliness, and an engineering evaluation. The programs for procurement,
receiving inspection, and dedication of commercial grade parts and
components appeared to be effective with respect to meeting the committed
objectives.
The NRC inspectors also inspected for proper storage of safety-related
equipment ard materials in Warehouses 7B and 2B, and the Service Buildir.g
Warehouse. The buildings were designated Storage Leval B except for a
small room in the Service Building which was controlled as a Storage
Level A. The NRC inspectors reviewed the Warehouse Surveillance
inspection Records of the sturage areas fnr March 6-12, 1989. The
environmental conditions in the storage areas were consistent with the
stora5e level requirements o# Procedure UNT-8-013. Electric motors, which
are required to be heated while in storage, were observed with heaters
energized and maintained as specified in Procedure ME-4-703. During the
tour of the storage areas, tha NRC inspectors selected the following items
to verify the tagging or marking for traceability of the item to purchase
documents, receipt documents, quality certification documents, and if
applicable, limited shelf life.
Stockcode Purchase Order Description
120-A73132 83287 Stainless Steel Tubing
135-B81240 48296 Globe Valve
107-C00001 66121 Alumina Activated Desiccant
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105-A46185 19475 Limitorque Electric Motor
135-B80910 14639 Valve Solenoid
152-C19300 16679 Mass Flowmeter
138-A15424 10458 Welding Material
151-B15408 66101 Welding Material
151-B15407 66101 Welding Material
101-D53873 96954 0-Ring
102-C53947 16176 0-Ring Gland Plate
102-C54033 23305 0-Ring
102-C53944 20768 0-Ring Gland
127-B38461 24764 Spare Parts Kit
127-B53849 24764 0-Ring
The above items were traceable to purchased documents, receipt documents,
and quality certification documents; however, discrepancies were noted
regardir.g the identification of limited shelf life for the following
items:
a. Unsolicited Shelf Life Limitations Provided by Vendor _s,
' The Material Management Information System specified no shelf
life requirements for Stockcode 152-019300 but the vendor
documentation received for the mass flowmeter gave an unsolicited
shelf life of 3 years.
The Material Management Information System specified no shelf
life requirements for Stockcode 101-D53873 but the vendor
documentation received for the 0-Ring gave an unsolicited shelf
life of 20 years.
Although the licensee was attempting to implement unsolicited shelf
life limitations received from vendors, no formal program was in
place to handle this matter. The licensee stated that a procedure
will soon be issued to promulgate the requirements for limited shelf
life, including handling of uronlicited info;mation. This is in
apparent violation for failure to identify and control limited shelf
life materials. (382/8907-03)
b. Shelf Life Limitations Not Requested From Vendors
- The Material Management Informatten System specified no shelf
life requirements for Stockcode 102-C53947. The vendor was not
' requested to provide shelf life limitations for this 0. Ring
gland plate, therefore no information ws.s provided.
The Material Management Information System spec 1fied no shelf
life requirements for Stockcode 102-C54033 from Purchase
Order 23305. The vendor was not requested to provide shelf life
limitations for this 0-Ring, therefore no information was
provided. However, a shelf life was received on another
purchase order for this stockcode.
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The Material Management Information System specified no shelf
life requirements for Stockcode 127-B38461. The vendor was not
requested to provide shelf life limitations for.this spare parts
kit, therefore no information was provided.
The Material Management Information System specified no shelf
life requirements for Stockcode 127-B53849. The vendor was not
requested to provide shelf life limitations for this 0-Ring;
therefore no information was provided.
The above discrepancies are additional examples of a recent inspection
finding, Violation 382/8902-03, documented in NRC Inspection
Report 50-382/89-02. The licensee has written Quality Notice QA-89-071
which will assure that'these items are included in the corrective
action developed for Violation 382/8902-03. The licensee has
committed in response to this violation to establish an overall
program for control of limited shelf life materials, including review
of items currently' stocked in warehouses.
5. Exit Meeting
An exit meeting was held on March 17, 1989, with those individuals denoted
in paragraph 1 of this report. At this meeting, the scope of the inspection
and the findings were sunnarizeo. The NRC resident inspectors also
attended. The licensee did not identify as proprietary any of the
information provided to, or reviewed by the NRC inspectors.
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