IR 05000219/1985032

Insp Rept 50-219/85-32 on 851021-25.No Violation or Deviation Noted.Major Areas Inspected:Qa Program Changes, Qa/Qc Administration Program,Document Control Program, Onsite Review Committees & Records Program

ML20136H272
Person / Time
Site:	Oyster Creek
Issue date:	11/15/1985
From:	Chaudhary S, Eapen P, Hunter J, Winters R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20136H235	List: IR 05000219/1985032 ML20136H230
References
50-219-85-32, NUDOCS 8511250072
Download: ML20136H272 (9)

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.U.S. NUCLEAR REGULATORY COMMISSION

REGION I

Report N /85-32 Docket.N License No. -DPR-16~

Licensee: .GPU Nuclear Corporation

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100 Interpace Parkway .

Parsippany, New Jersey 07054 Facility Name: Oyster Creek Nuclear Generating Statia Inspection At: Forked River, New Jersey Inspection Conducted: October 21 - 25, 1985 Inspectors: M aubA . ' -

Suresh K. Chaudhafy, Lead Reactor Engineer Nov. /4, / 9 6 $-

date e beu I4. liW Robert W. Winters, Reactor Engineer date

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date gnG. Hunter,-III,ReactorEngineer

' Approved by: . E h ,,/w/er Dr. P. K. Eapen, Chi 6f, QAS, 08, DRS ' date Routine unannounced inspection on October 21-25, 1985 J(Ins ection Report Inspection Summary: No. 50-219/85-32)

Areas Ins)ected: Quality Assurance Program changes, QA/QC Administration Program, Document Control Program, on-site Review Committees, Records Program, and follow-up.on status of IE Bulletin 79-02 and 79-14. The inspection involved 103 inspector hours by three Region based inspector Re*a*'r No violations or deviations were identified.

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Details 1.0 Persons Contacted GPU Nuclear Corporation

• J. Barton, Deputy Director, Oyster Creek (OC)

• R. Fenti, M00/0PS QA Manager, *K. Fickeissen, IOSRG Manager, *P. Fiedler, Vice President, Director, *S. Fuller, Operations QA Manager

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A. Lewis, Supervisor of Document Control Center, *R. Long, Vice President Nuclear Assurance

• R. Markowski, QA Program Development & Audit Manager

• Morrel, Supervisor of Document Control, *T. Quintenz, Acting Safety Review Manager, *G..Simmonetti QA Audit Manager, J. Solakiewicz, QA Engineering & Systems Manager, *J. Sullivan, Director of Operations, B. Stevens, Information Management Manager United States Nuclear Regulatory Commission

• W. Bateman, Senior Resident Inspector

• J. Wechselberger, Resident Inspector

• Denotes those who attended Exit Interview on October 25, 198 .0 Quality Assurance / Quality Control (QA/QC) Program Administration The licensee's QA/QC Program administration was reviewed to determine its adequacy and effectiveness. The inspector reviewed procedures, held dis-cussions with cognizant personnel, and examined documents to assess the adequacy of the licensee's effort in this are Following documents were reviewed / examined:

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GPU Nuclear-0perations QA Plan; Section 2.0 " Quality Assurance Program".

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Procedure #6130-QAP-7205.01. Rev. 2.00, 5/9/83; Preparation and Control of Oyster Creek QA MOD /0PS Procedure #6130-QAP-7205.01, Rev. 3.00, 8/15/84; OC QA mod / ops Document Review Procedures Procedur #1000-ADM-7215.01, Important to Safety Material Nonconformance Reports, Procedure ..

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Procedure #6130-QAP-7202.04, Rev. 4.00, 8/24/84; Deficiency Trend Analysi Trend Analysis of Deficiencies for 198 Procedure #1000-ADM-7202.a, QA Shutdown Recommendation / Directive;

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Cooperative Management Audit Report, #0-COM-84- CAMP Audit, #0-COM-85-0 Oyster Creek QA Department Annual Assessment, 198 Procedure #1000-ADM-7218.1, Response to GPUNC QA Audit GPUNC QA Audit # 0-0C-84-05, 2/6/85

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Procedure

1. 6100-QAP-7202.07, Rev. 0.00 8/1/84, QA Systems Engineering Program Reviews / Evaluatio Based on the above examination and review with licensee personnel, the inspector determined that: Procedures and responsibilities have been established for making changes and/or revision of document Adequate procedural controls have been provided to assure timely

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dissemination of new and/or revised information to the supervisory and working level personnel, The procedural control provides for review and approval of procedures prior to implementation; methods and procedure for changes and revisions; and controls for distribution and recall of documents, The operations QA plan clearly establishes the requirement, and assigns responsibility for overall review of the effectiveness of the QA progra .0 Trend Analysis The inspector examined the trend analysis program, associated procedures, and reviewed the program elements with the licensee's cognizant manage-ment. The above review and discussions were performed to assess the trend analysis program's adequacy and effectiveness. The following

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documents were reviewed:

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6130-QAP-7202.04, Rev. 4.00; Deficiency Trend Analysi QAP-7202.02; Rev. 2.00; Vice President / Director Report.

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Deficiency Trend Analysis for 198 QAP-2210.03, Rev. 3.00; QA M005/0P Inspection Progra Memorandum, M. A. Orski to C. Brookbank, dated 9/12/85

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00Rs: 84-084 and 85-033

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Audit Report, S-0C-84-25, dated 6/18/85

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Audit Report, S-0C-84-09, dated 11/7/85

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Based on the above review, the inspector determined the following:

! ' The licensee has implemented a formalized trend analysis program to provide a systematic analysis of. quality trend Trend reports are widely circulated for information in general, and l specifically provided to the management to determine the need for

extra attention in specific area of concern, if an Analysis techniques appear to be based on sound statistical principles and accepted practice The licensee is currently evaluating the program with a view to broaden its scope and upgrading / enlarging the data base as data ,

become available, i There exists an approved procedure to identify developing adverse i quality trends, and to adjust the QA program overview to provide any l extra emphasis on such problem area The inspector found the deficiency trend analysis program adequate and

effective. The trend reports are designed to be a management tool, and l fulfilling their intended purpose.

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No violations were identifie .0 On-Site Technical and/or Safety Reviews

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l A. Independent Onsite Safety Review Group, i ,

l The licensee has established the Independent On-Site Safety Review Group l (IOSRG) under the direction of a manager of nuclear safety, who in turn (

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report to the Director of Nuclear Safety Assessment Department of Gp ,

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The group is located on-site, i The Responsible Technical Reviewers met or exceeded the qualifications of  :

ANSI N181-1978, Section 4.6 or 4.4 for applicable discipline or had 7 '

years of appropriate experience in the field of his speciality. The train-  ;

ing and certification records of the ISORG were established and maintained '

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current.

l The periodic review functions of the 10SRG included the following on a selective and overview basis:

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Evaluation for technical adequacy and clarity of procedures important >

to the safe operation of the facilit .

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Evaluation of facility operations from a safety perspectiv Assessment of facility nuclear safety progra Assessment of the facility performance regarding conformance to requirements related to safet Any other matter involving safe operation of the nuclear power plant that the Manager - Nuclear Safety deems appropriate for considera-tio The inspectors observed that the manager of nuclear safety was effectively directing the above responsibilities. The inspectors particularly noted that the group was developing a plant status monitoring system by computer modelin The computer model was designed to show the effects of shutdown of selected equipment on other systems and/or equipment. At the time of this inspection approximately ten systems had been covered by this sys-tem / equipment interaction modeling. Through this study the licensee identified some non-safety related (balance of plant) equipment / system which significantly affected the safety of the plant, e.g., make-up water; generator phase direct cooling; and procedures for power limitation when second stage reheaters were not operable. Based on this important inform-ation, several of the balance of plant procedures were revised to improve plant safety. The system of reviews to assure plant safety appeared ade-quat No violations were identifie B. Technical Review of Procedure and Change The licensee's program allows temporary procedure changes if the intent of the original procedure is not altered. A temporary change is approved by two members of GPUNC Management Staff knowledgeable in the area affected by the procedure. For changes which may affect the operational status of facility systems or equipment, at least one of these individuals needed to be a member of facility management or supervision holding a Senior Reactor Operator's License on the facilit The change is documented, subsequently reviewed and approved within 14 days of implementatio By reviow of temporary changes to procedures AISF-3036, Rev. O, and 303, Rev 18, the inspector determined that changes were reviewed for technical adequacy, completeness and for any safety implications by qualified individuals who are certified as responsible technical reviewers. The changes were documented, reviewed and approved in accordance with procedure l

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The licensee's program also requires that the individuals r'esponsible for review shall include a determination of whether or not additional cross-disciplinary review is necessary. The inspector randomly selected eleven procedures and/or changes from the nuclear safety review groups files to determine if this requirement was being fulfilled. Of the eleven docu-ments reviewed, seven had this determination made by the responsible technical reviewer. The remaining four had not had this determination made. However, the inspector determined that none of the above four re-quired cross-disciplinary review and all were reviewed by one specific individual. To determine the significance and prevalence of this omis-sion, the inspector selected twenty (20) additional changes for examina-tion and identified no such omissions. By review of these additional documents and discussions with review group members, the inspector deter-mined that the above omission was an isolated oversight by one individual, and was not indicative of any program weakness. The licensee immediately issued a memorandum to reemphasize this requirement to every reviewe No violations were identifie .0 Records Management System The inspector examined documentation and reviewed the records with cog-nizant licensee personnel to assure the adequacy of the licensee's records management syste The basic requirements for collection storage, and maintenance of quality assurance records are described in the plant tech-nical specifications, and these requirements are implemented by the licensee's Quality Assurance Plan. To verify the adequacy of this QA plan, and effectiveness of implementation procedure, the inspector re-viewed the following documents:

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Plant Technical Specifications, Section 6.1 ANSI N45.2.9, " Requirements for Collection, Storage and Maintenance of Qaality Assurance Records for Nuclear Power Plants 197 ANSI /ASMI NQA-1-1979, Supplements 175-1, and 17A-1.

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0.C. Station Procedure 103; " Station Document Control" l --

0.C. Station Procedure 107; " Procedure Control"

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Gpu-Nuclear Record Rotention Policy; 1000-POL-1210.02 i Based on the above review, discussions with cognizant personnel, and

! personal observations, the inspector determined the following: The Itcensee maintains duplicate sets of records in two independent and separate location Majority of the original records are stored in the document control conter on site, and the duplicates are stored in the Forked River facilit ._

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7 Non-reproducible records are also stored in Forked River facility record storage vault, The record storage vault meets the requirements for fire resistance and environmental contro The licensee has not implemented the established retention period for different records; therefore, all QA records have been stored as life time records, The licensee maintains effective control on the documents filed in the record center by logging of the in-coming and out going document The inspector scheduled a random sample of reports and other documents to l determine the retrievability of stored records. The selected records consisted of pre-operation test reports, Quality Assurance audits, surveillance reports, personnel training, and calibration list record The inspector verified that these documents were clearly listed in the master index and were readily retrievabl No violations were identifie .0 Document Control The inspectors examined the licensee's document control system to deter-mine the adequacy and effectiveness of controls to assure the currency, validity, technical adequacy, and distribution of documents affecting quality. The inspectors observed that each division of GpVN controls the review, approval, and issue of their documents in accordance with their procedures. When these documents are to be used for construction or mod-ification in the plant they are issued to the Maintenance and Construction Group (M&C). M&C then takes the package as received from the originating group and establishes " work packages". These " work packages" include the necessary information to perform the necessary tasks. If the change is simple one " work package" may be required. For complex tasks several work packages might be required i.e. one for electrical, mechanical, civil, et Each important to safety work package is reviewed by a responsible technical reviewer, and independent safety reviewer. They are then signed by the Director M&C. The work package is implemented only after receiving approval from the Plant Director. Issue of the work package is controlled by the Document Control Center. When issued one " Execution Copy" and

other controlled copies are released. The " Execution Copy" contains all QC hold points and other information. When work is completed this copy becomes the official record copy with all signatures, data sheets and other records and is returned to the Document Control Center for reten-tio ,

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l GPUN at Oyster Creek uses duplicate storage facilities in lieu of fire-proof storage. For one of a kind records such as strip charts a fire-proof vault is use .0 Follow-up on IE Bulletins 79-02, and 79-14 In response to the inspector's question regarding the status of licensee effort and work in this area, the licensee provided the following infor-mation:

For Bulletins 79-02 and 79-14 All documents utilized in the original verification effort have been acquired from Burns & Roe, the architect / enginee . A task force has been established to assure that all concerns relating to these bulletins are adequately addresse . All inspections are being performed by personnel qualified to ANSI N45.2.6 - 197 . All activities are under full QA coverage (QA Plan, Section 2.3.1.1). Computer analyses of safety related systems will be sent to the NRC as they are completed. The present schedule is January 1986 for this effor For Bulletin 79-02 Actual field work has not started. Procedures and engineering specifications are in the review and approval cycl . Anchor bolts will be pull tested to 125% of calculated tensile load . Slip behaviors in this load range <1/8" for shell type anchors;

<3/8" for wedge typ . The required effort is scheduled to be completed prior to restart from the outage in October 198 For Bulletin 79-14 All reverifications outside the drywell have been completed. Over 470 inspections done to dat . Reverification inside the drywell is being performed 2 shifts / day.

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, , All hangers inside the drywell (except those which were allowed to beperformedduring11Routage)willbecompletedpriort6startu X * Of all the inspections performed, only one sig.a.ificant discrepanty was identifie 'Js - ' Engineering justification / evaluations for all discrepancies identified during a shift are performed during that shif . Anchor-to-anchorevaluationsofaggregatedefic!e5ciesareperformed '

as segments are complete ,. ,

• SeparatesubmittalsrelatingtoSEPsyste$randevaluationshave '

been and will be sent to the NR s

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-, Acceptance criteria for the 1985 reverification program encompass and exceed those specified in 79-1 s,

' The required effort is scheduled to be completed (except Recirc' tup-ports) prior to restart from 10M outage (approximately November 30,

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8.0 Review of Quality Assurance Program '

The"GPUNC Operations QA Plan", 1000-PLN-7200-01 was,rd;iewed for adequacy ,

and acceptability. One concern regarding the applicability of ASME Code '

case 356, related to certification of level-III NBC personnel was roiolve The licensee produced a letter from NRC to the licensee, dated January 16, 1985 that accepted the use of the above code case, altCough the code case has not been incorporated in NRC's Regulatory Guide 1.247, _ .-;

Theinspectorshadnofurtherquestionsatthistime'regardingthe'Qd pla The plan's acceptance and approval by Region I will be transmitted to the licensee by a separate lette *

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9.0 Exit Interview -

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n A management meeting was held at the conclusion of the inspe'ction cd'

October 25, 1985, to discuss the scope and findings of this inspection (see Paragraph I for attendees). No written information was provided to the licensee at any time during the inspection. The licensee indicated'

that no proprietary information was contained in the scope of this inspectio N

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