IR 05000333/1987011

Insp Rept 50-333/87-11 on 870330-0403.Violations Noted: Failure to Follow Procedures & Failure to Implement & Document Nonconformance Corrective Action

ML20214E015
Person / Time
Site:	FitzPatrick
Issue date:	05/08/1987
From:	Eapen P, Hunter J, Luptak A, Napuda G, Prividy L NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I)
To:
Shared Package
ML20214D993	List: IR 05000333/1987011 ML20214D990 ML20214E002
References
50-333-87-11, NUDOCS 8705210597
Download: ML20214E015 (19)

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_ U.S.~ NUCLEAR REGULATORY COMMISSION

REGION I

Report N /87-11 Docket N License N DPR-59 Licensee: Power Authority of the State of New York P. O. Box 41 Scriba, New York Facility Name: James A. FitzPatrick Nuclear Power Plant Inspection'At: Scriba, New York Inspection Conducted: March 30 - April 3, 1987 Inspectors: L/ [f/

G. papuda, Lead Reactor Engineer, DRS / #6te alvd (f. M 4funter III, Reactor. Engineer, DR e6/e7

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date h S4 Y7lD K./ . Luptak, Sr. Resident Inspector, DRP ' date 4/ %'/A g J.Mrt'vidy, dtesident Inspector, DRP sh/r7 date Approved by: @K kafw Dr. P.~ K. Eapen, Chi 6f, Wdatee7 Quality Assurance Section, OB, DRS Inspection Summary: Announced Inspection conducted on March 30 - April 3, 1987 (Inspection Report No. 50-333/87-11).

Areas Inspected: Design Change / Modification Control, Maintenance, Procurement, QA/QC and the effectiveness of quality verification activitie Results: Two violations (failure to follow procedures and failure to implement and document nonconformance corrective action) were identifie >

8705210597 870512 gDR ADOCK 05000333 '

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DETAILS 1.0 Persons Contacted-Power Authority State of New York

• B. Baker, Maintenance Superintendent

• R. Converse, Resident Manager

• J. Erkam, Senior Plant Engineering Supervisor

• Fernandez, Superintendent of Power

• Hansen, Senior Plant Engineer

• T. Herrmann, Senior Plant Engineer

• J. Kerfien, Quality Control Supervisor

• D. Lindsey, Operations Superintendent

• R. Liseno, Planning Superintendent

• T. Moskalyk, Senior Plant Engineer

• D. Patch, Quality Assurance Superintendent

• F. Pesce, Quality Assurance Director

• D. Ruddy, Senior Plant Engineer

• V. Walz, Technical Services Superintendent

• R. Wiese, Jr., Assistant Maintenance Superintendent United States Nuclear Regulatory Commission

• P. K. Eapen, Quality Assurance Section Chief

• Denotes those in attendance at the exit meeting held April 3, 198 Other licensee operations, Technical, QA/QC and administrative personnel were also contacted during the course of this inspectio .0 Design Changes The licensee's quality assurance effectiveness in the area of design changes was assessed through an in-depth review of one recent design change - Plant Modification F1-85-00 Also, portions of several other plant modifications were reviewe The overall inspection emphasis was

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focused on problem solving by the licensee at the various stages of the design change process. This problem solving ranged from relatively simple

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tssks such as the purchase of several feet of pipe to more complex tasks such as the preparation of the installation procedure for the material and equipment concerning the plant modification. The problem solving at the installation procedure stage became even more complex when changes to the original procedures were required to accommodate field conditions. The inspector conducted documentation review and had discussions with various engineering and QA/QC personnel concerning the plant modification . . . _ _ . - -. -

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o..' 3 2.1 Detailed Review of Plant Modification FI-85-009 - Replacement of 3-inch Core Spray System Valves 14MOV-5A and SB Valves 14 MOV-5A and 58 are the Core Spray System minimum flow isolation valves which operate on low pump flow (less than 475 GPM)

to ensure adequate pump cooling. They are 3-inch, carben steel gate valves and they also function as containment isolation valves providing the first isolation from the suppression pool on the core spray test lines. The original valve design (Velan Valve) utilized threaded replaceable seat rings which had- a history of loosening-during system surveillance testing. This condition prevented the Limitorque motor operator from either opening or closing the valve due to binding of the wedge against the seat rings. Consequently, Plant Modification FI-85-009 was undertaken to provide new valves (Pacific Valves) which would utilize renewable seal welded seat rings The new valves are 'slightly larger (by 75#) but the same Limitorque motor operations are being used. At the time of the inspection the new valves and operators' had been installed but the retest require-ments for the valves and associated welds had not yet been complete The remaining retest requirement consisted of an inspection of the modification during the Type "A" Primary Containment Integrated Leak Rate Tes The licensee controls design changes 'primarily through Work Activity Control Procedure (WACP) No. 10.1.6 " Control of Modifications, Component Changes, and Safety and Environmental Impact Evaluation Reports". This procedure references the many key design input documents such as' the James FitzPatrick Final Safety Analysis Report (FSAR) and Technical Specifications which the Responsible Engineer must appropriately consider as they pertain to the parti-cular modificatio The Responsibie Engineer (normally a Technical Services Engineer) is the key individual who is responsible - for a plant modification and who ensures that the requirements of WACP N .1.6 are me The inspector findings, based on discussions with the Responsible Engineer and a review of the documentation in the design change package are detailed belo A Nuclear Safety Evaluation was properly conducted, documented, and reviewed by the Plant Operations Review Committee in accordance with the requirements of 10 CFR 50.5 This evaluation appropriately considered the affected Sections 3.5 and 4.5 of the Technical Specifications and Sections 5.2.3.5 and 6.4.3 of the FSAR which address Core Spray Systems and Primary Containment isolation valve _ - . _ _ - _ - _ _ . - _ _ . .. _

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f Since the. new ' valves weigh ' approximately 75 lbst ~ more .than .the old -

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< ones', the Responsible- Engineer performed a L eonservative ' analysis to

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confirm that the' additional stress in the piping. in the . vicinity of

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the ; valve - and , adjacent pipe : supports did ' not exceed-. the ANSI B3 : Code (1983j Edition thru Winter .1984 Addenda) allowable stress. The Responsible Engineer's calculations lwere ' professionally Ldone in that they were ~ clearly documented, ' assumptions were properly' stated, and

. conclusions were 'specifically made. All calculations were' indepen-dently. verified. Also, the inspector noted that _ additional conserv-atism was injected into the analysis as the Responsible Engineer'used

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a later version'.(1983 Edition.thru Winter 1984 Addenda) of_the ANSI'

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B31.1 Code -versus the Construction code version (1967- Edition) which -

is committed to in the FSA These measures demonstrated ~ the~

licensee's. implementation of the-design modification requirements of ANSI N45.2.~11-197 '

The -licensee's Engineering Design. Procedure (EDP) No. I requires the -

-use of a design' input check _ list _which serves. to alert _the ' designer of _. various design considerations. The inspector noted- that this

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check list was properly used - for' this-_ plant modification. - Also' the inspector noted .that' the check list had been : revised recently to a

~lert l designers .of thermal expansion considerations. in . plant modifications. A recent _ modification had- been : performed where -_ a

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Limitorque motor, operator interfered with .a nearby support due .to valve / piping ' thermal expansion ~ This improvement to the designer's

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check _ list - demonstrated the licensee's initiative to upgrade the

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design change process to improve qualit The . inspector ' reviewed the following purchase orders pertinerst to this modification:

Purchase Order N Description 86-6607 (1/5/87)_ Purchase of 8 feet of 3-inch .

, carbon steel piping-85-865 (1/28/85) Purchase of 3-inch carbon steel- gate valves _ (Pacific Valve)

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The inspector determined that' proper engineer / procurement interface -

controls were established for the purchase orders including a change

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order to P.O.85-865 which was issued . for the performance' of. a

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seismic analysi Also the licensee demonstrated proper receipt

. . inspection controls in accordance with QA Instruction 7.0 " Receiving E Inspections".

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'The . inspector ' reviewed post work testing for selected modifications

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fto yassure; the components / systems were1 properly tested- following '1 scompletion of-installatio The~ post . work _ testing was foundJ to be-

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l sufficient ato z d.etermine operability of _ the systems -and was satis-

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factorily' performe The . inspector, however, did question':the

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documentation ' of the hydrostatic test performed April '.12,11985, for ,

modification F1-82-33, replacement 'of ? Shutdown Cooling Isolation- "

Valve 10 MOV 18 cand piping. The required ' test pressure was :1875

+20/-0 psig. The : pressure recorded during . the . test .was 1830 , psig with a note stating that because of thef additional head due to the elevation difference between the location: of_ the pressure gauge 1and-

-the system being hydrostatic tested, the test pressure of 1975 +20/-0 was satisfied. However, no calculations were used .to justify .this statement. After being questioned by the inspector, the licensee conducted - this calculation which concluded the test pressure .was-1874.4 psig which _is within the 1 .psig gauge tolerance. . The-inspector concluded: that the hydrostatic test was. satisfactory; however, the licensee's documentation at the time of the te'st did not'

fully demonstrate that'the test requirements were me The actual-- installation

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of ; the design change occurs via the preparation ' and execution . of ' the Installation __ Procedure (IP). Any changes to the '.IP ' that -are ; required to : resolve field problems are accomplished :by an. Engineering Change Request .(ECR). EDP-5 and 10 govern the scope, preparations, and execution of the IP. and the EC Execution of the actual installation . requires a close coordinated effort among the Responsible Engineer and the: installation and QA/QC ,

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l The inspector reviewed the IP and the 8 ECRs that were re' quired for

,this plant . modification and. had discussions -with the personnel responsible' .for . the installatio Based- on these reviews and discussions the. inspector. determin'ed1that the licensee's implement-ation of the': installation was-- generally acceptabl However, the

, inspector had several . findings which were classified :as either weaknesses in 'the engineering evaluation / review process or a violation of regulat'ory requirements'as discussed belo . During the replacement of valves 14MOV-5A and SB severe pitting of the pipe internals was noted. This severe pitting condition was known at- 14MOV-5B on January 23,- 1987, when ECR N .

FI-85-009-003 was issued to describe the. pitting condition in a 6-inch length of. 3-inch, schedule .40, carbon steel ' piping _

, upstream of the valve. This defective piping was replaced with

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new piping per the engineering resolution of - the ECR. The

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severe: ' pitting condition was also encountered in the pipe internals for valve 14M0V-5A. The pitting condition here was worse .and two ECRs were required to correct the problem. ECR FI-85-009-006 (2/20/87) and FI-85-009-007 (2/23/87) resulted in i

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the replacement of a 28-inch section of piping upstream and a 4-inch section of piping downstream of the valve. The inspector inquired if QC had issued a nonconformance or deficiency report concerning this deficiency in accordance -with the requirements of 10 CFR 50,- Appendix B, Criterion XVI and the New York Power Authority QA Manual. The QC Supervisor advised the inspecto that neither a Nonconformance and Corrective Action form nor a Deficiency and Correction Action Report (DCAR) had been filed by QC, This is a violation (50-333/87-11-01).

i Upon further inquiry the inspector _ determined that QC and Engineering personnel had mutually agreed to issue only an EC While this resolution produced an acceptable solution to the immediate problem, it did not address the deficiency completel Utilizing only an ECR resulted in an incomplete root cause analysis of the pitting problem since the ECR document does not get the same systematic treatment for trend analysis and problem evaluation as the DCA P The inspector questioned engineering personnel if evaluations had been made to determine if the pitting problem could - be present in other safety related systems and if the Core Spray System was still considered to be operable with the pitted piping. While it was apparent that an overall evaluation to determine if. a generic problem existed had not been -conducted, the inspector determined from the Responsible Engineer that some effort had been devoted to-characterize the cause of the pitting proble A potential cause being postulated is possible cavitation in the piping due to the presence of a single hole, flow restricting orifice which is located upstream of the pitting area On April 7, 1987, the licensee did complete a detailed evaluation (Calculation Set 004 for Plant Mod FI-85-009) of the immediate safety implications to the - Core Spray System due to the pipe wall reduction from the severe pittin This evaluation was in response to the inspector's inquiry and to DCAR 87-160 which QC issued on April 2, 1987.

i DCAR 87-160 quantified the worst case pitting condition as being i

30% of the minimal pipe wall thickness (.216") which exceeds the ANSI B31.1 (1967 Edition) allowable tolerance of 12.5% for surface imperfections. The evaluation concluded that the pitted piping was still operable since it would remain functional when all required loadings were considere This evaluation and other aspects of this item will be reviewed in future inspection.

! b. A review of ECRs associated with modifications F1-85-009 and

F1-82-033, Replacement of Shutdown Cooling Isolation Valve 10MOV-18 and Piping, noted several discrepancies. Engineering Design Procedure 10, Engineering Change Requests, Revision 3, l

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requires that-QA/QC review and concur with an ECR that affects a QA requirement or revises a QC inspection requirement. The

'following ECRs were not reviewed or concurred with by QA/Q ECR h. 3 and 6 to F1-85-009 added QC inspection require-ments for the removal and installation of sections of piping for the A and B Core Spray Minimum Flow line These included requirements for weld preparation and post weld inspectio ECR No. 5 to modification F1-82-033 added QC inspection requirements for penetrant testing and post weld heat treating of full penetration welds for pipe replacement of the shutdown cooling suction lin ECR No. 17 to modification F1-82-033 added QC inspection requirement for visual examinations and penetrant testing of socket welds for a sa'-ty related piping which had to be cut to remove interference to facilitate the modification installatio ,

The failure to implement EDP 10 is a violation of Technical Specification 6.8(A) which requires procedures be established and implemented that meet or exceeds the requirements or recommendations of Regulatory Guide 1.33, November 1972 (50-333/87-11-02). The Responsible Engineer had checked off "Not Applicable" for Section 11.0 on the Plant Modification Tracking Form (required by QACP 10.1.6) which indicated that no new Maintenance Procedures were required. However, written comments had been received whi'h indicated that new Maintenance Procedures would be required for the Pacific valve In addition, the tracking form for modification F1-82-33 which replaced the shutdown cooling isolation valve 10 MOV 18 did not indicate a new Maintenance Procedure was required. However, the new valve was supplied by a different manufacturer and a new-procedure will be required prior to maintenance being performed on this valv The above is considered a weakness of the licensee engineering review process, d. A review of the installation procedure for 10 MOV SA was conducted. The procedure had been completed; however, -the completed work package had not been reviewed by QC as required to close out the package. Several discrepancies were noted with the documentation of the work packag Various steps of the

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installation procedure L requires the reinstallation of the-motor

operator,be completed in accordance with specifici sections of _MP:

59.-3 - Limitorque -Motor Operators. MP 59.3 contains a sign-off

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- checklist : to be completed for many of Ethe steps contained in -

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-thisi procedur In the completed work packa'ge reviewed,-

-portions off the sign-off checklist were included and properly

' signed off; e however, several portions and

in .-particular the -  ;

section covering the installation of the new? operator. were missing. LThese items were signed as being completed in the installation procedure as required ' by the maintenance _and- QC-individual Also, .some confusion appears to exist'concerning the signing of .

. steps when ECRs .are involve When an' ECR is ' issued that U

changes the . installation procedure, ; a revised page is issued

with the appropriate changes. This page, as with the page prior- '

} ' to the change, contains the sign-offs for completion of the

, ste The inspector noted examples .where. the _QC inspector .had

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signed off for completion of steps on the page- of the install -

ation procedure prior to the . ECR being issued -'and not on the -

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page :which incorporated change .to these steps in.: the ECR. . The mainten'ance personnel signed. off the steps on both pages before-l and after the EC Basedion these examples, appropriate-j^ ' attention was not given to the sign-off of steps completed l for:

M this installation -procedure and therefore do~. not clearly F document- which steps were in fact completed. . This is considered -

a weakness in the licensee's-installation-procedures, t

ji 2.2 Review of Licensee Identified Concern '

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' Internals of-a check Valve Were Not Installed h The licensee was performing: an Inservice Inspection (ISI)'

4l' hydrostatic test of Class -II components and discovered that the internals of the Residual Heat Removal (RHR) to RHR- Service -

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Water (RHRSW) check valve 10-RHR-1778 were not installed (most probably since initial construction). The purpose of the' check valve is to prevent backflow from the RHR system into the_ RHRSW

! system. The absence of the internals led to the upstream _ piping and valves MOV1488 and MOV149B being exposed to RHR temperature: '

and pressure during RHR operation. The inspector reviewed the- ,

licensee's evaluation of the effects on the upstream piping and valves MOV148B and MOV1498 due to the internals not being-

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installe .

The licensee utilized design conditions (280*F and 325 psig),

which were greater than those experienced during RHR system t

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operation, of the downstream piping in evaluating the additional stresses due to the higher temperature and pressure The

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-stress due toJthe high pressure was, calculated and determined to be . within ithe1 allowable . range. The- calculated ; thermal stress "

due'. to the higher temperature exceeded the .allevable range if _

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the assumption is' made that the temperature would have reached -

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280*F .in: the pipe run back to the -nearest anchor point. .The n licensee demonstrated that this' assumption _ was unlikely in that

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the' pipe. run. in question is dead-ended by the MOV1498 and -

MOV148B valves which wo'uld -' preclude the temperature 'at the anchor point from reaching 280* The licensee ' stated that th'e MOV1488 and MOV149B valves were-constructed of A216-WCB carbon steel (150# pressure class) and

'that per ASNI B16.4,.the valves were rated at 400*F for 200 psig (200 psig is the operating pressure of the downstream piping).

The licensee however did not ~ specifically document the condi-tions ~ that ~ the valve _has -been exposed to during previous RHR system operation -in order . to demonstrate acceptabilit The inspector independently verified- that the conditions the valves were exposed to during:RHR operation were within the acceptable-range for the. valve The licensee's analysis further stated , that these valves were well within- their capacity rating at .-the. potential ' conditions'

which could have occurred during' an accident without providing

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the' basis. It should be noted that the RHR design pressure as stated in the= analysis is 325 psig and that these valves were not' analysed- for this pressure. This' item -1s unresolved pendin NRC ' review of . the - 1icensee's; bases to substantiate the above

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conclusion (50-333/87-11-03).

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1The inspector discussed _ the analysis with the - licensee ' and informed them that the documentation could have been more l clearly ' presented. The' lack of detailed documentation of the evaluated temperature and pressure conditions :that MOV1498 and

, M0V149B had been exposed to and the invalid statement pertaining i the valves under potential accident conditions is indicative of

. a weakness in -the performance, review and approval of

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engineering analyse . Instrument Drift of ASCO Pressure Switches The inspector reviewed the licensee's actions in identifying, evaluating and resolving a problem with several ASCO pressure switches. These switches bypass the Main Steam Line Isolation

, Valve (MSIV) closure scram signal if the reactor mode switch is l' in any position other than run and reactor pressure is less than 1005'psig.

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These switches are required by Technical Specifications (TS) to

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be functionally tested quarterly and calibrated once per cycl After installing these switches in May of 1985, the frequency of

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the functional test was increased to monthly in October 1985, i

due to out of tolerance as found readings (still within TS limits). On March 27, 1986, while the plant was shutdown for a maintenance outage, all four switches were found to be actuating between 1016 and 1036 psig which is . above the required TS setting of 1005 psi The licensee performed confirmatory measurements and checks to assure these readings were accurate and test instruments were correctly calibrate The switches were adjusted to within the required specifications and a review of the problem bega An occurrence report was generated for the out of tolerance condition. The occurrence report is the plant's mechanism for raising problems or events to proper senior management attention and evaluating reporting requirements. The final review and disposition of the occurrence report is conducted by the onsite review group, the Plant Operating Review Committee (PORC). The licensee submitted a Licensee Event Report (LER) reporting the out of tolerance condition to the NRC in accordance with 10 CFR 50.7 Immediately after the switches were found out of tolerance a review of previous surveillance data, the surveillance procedure, the technician's technique in the surveillance and a review of other instruments by the same manufacturer revealed no cause for the out of toleranc The review indicated a pos:ible instrument drift problem. The licensee increased the surveillance frequency to once per week. After thirteen weeks of successful tests the test frequency was reduced to once per two week On October 5, 1986, again while shutdown for maintenance, all four switches were found to be out of tolerance actuating between 1011 and 1021 psig. This indicated the drift occurred when the plant was depressurized. The amount of drift was determined to be dependent on the length of time depressurize The out of tolerance condition was documented on an occurrence report, reviewed by PORC, and a revision to the first LER submitted documenting the second occurrenc The licensee maintained their once per two week surveillance of the switches, and added a requirement for testing prior to shutdowns, start-ups, and within 24 hours2.777778e-4 days <br />0.00667 hours <br />3.968254e-5 weeks <br />9.132e-6 months <br /> after placing the mode switch in ru The licensee also submitted a report of the drift problem to other utilities via the Operating Experience Report network. A 10 CFR 21 reportability review determined this to be not reportable since there is no safety significance associated with the function which the pressure switches perform at FitzPatric . . _ _ _ - - _ _

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The licensee replaced the ASCO pressure switches with a switch from a different manufacturer in March 1987 to resolve the drift

. proble Prior to installation, an engineering evaluation concluded the new pressure switches were properly qualified and had no history of instrument drif The inspector determined the licensee adequately identified, evaluated, reported and resolved the instrument drift of the ASCO pressure switche .3 Summary and Conclusions The licensee's implementation of the design change process from the conceptual stage to the installation stage was performed in a very professional manne Although several procedure inadequacies concerning signoffs and reviews were noted, there appeared to be a e close working relationship among the engineering, installation, and QC personnel. Lack of _ proper identification and complete corrective action of the Core Spray System piping pitting problem and the majority of the other problems occurred during . the installation phase. The high work load on personnel during the refueling outage was a major contributor to the design change problems observe .0 Maintenarce 3.1 Program Review The inspector reviewed the procedures listed in Attachment A to determine that the following were addressed during the performance of maintenance:

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Written procedures provide for initiating requests for post maintenance testin Criteria and . responsibilities for review and approval of maintenanc Criteria and responsibilities for the basis of safety related/

non-safety related activity designatio Procedures specified in the maintenance packages were adequate for the scope of the maintenance performe Methods for performing functional testing following maintenanc Administrative Controls for control and documentation of main-tenance activitie Criteria and responsibilities for inspection of work and testin , -- , - , - --, - . . - - -

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-3.21 Program Implementation Review

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The; licensee's' quality assurance . effectiveness ~ in the area ofc

,- ' maintenance swas . assessed ~ through an in-depth review of. nine Work-RequestE(WR) and twof Preventive- _ Maintenance 1 Work Request (PMWR)- 1

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The licensee controls their maintenance. activities through the

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implementation:of WACP'10.1.1, " Procedure for Control of Maintenance"

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_ and ;WACP .10.1.15, '? Control of Preventive / Predictive Maintenance".

(The-: licensee's quality assurance -program . interaction with .the-p

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maintenance and preventive. maintenance. programs ' includes Quality Control (QC) inspection points and QC review of the completed work .

package The various. QC inspection points include hold points, checks, examinations, L verifications and witness. point These

points r are ' described in API.7, " Quality Assurance Program", along

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L with the required actions ofiinstallation/ maintenance personnel to -

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J ensure ' implementation and1 adherenc The licensee ~ has -incorporated "

.the inspection points into the' procedures used to. perform maintenance '

and utilizes. checklists to. document inspection activities performed without detailed procedures centaining QC inspection point .

The inspector reviewed the WRs and PMWRs,' listed in Attachment A, for proper safety ' classification, QA/QC coverage, appropriate po'st maintenance . . testing prior to returning the component- to service, logging of measuring and test equipment (M&TE) usage, spare parts -

.. . identification and adequacy, procedural controls, 'specialL process-E control and appropriate supervisory: review and approval 'The procedures, listed .in- Attachment- A,' ;used to perform the b maintenance activities were . reviewed to determine that they were controlled - in accordance with administrative - procedures; post maintenance ' testing was adequate -for- the work- performed; QC

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inspection and hold points were defined and- met; the activity was .

I sufficiently described; radiologicai, temperature, pressure and

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-electrical hazards were addressed; fire- protection, cleanliness :and

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housekeeping . . were addressed and that a method existed to notify

, _ operations of removal and return to service of the components worked upon.

The inspector selected the following M&TE from the WRs and PMWRs

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reviewed to determine that the equipment was in calibration at the

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time of-use, the calibration could be traced to nationally recognized standards and that the equipment was prop' N stored, controlled, identified and labeled.

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Serial # Instrnment E-817 Biddle megger PMWR 13-03730 and WR 23-33055 E-976 Fluke multimeter PMWR 13-03730 E-794 Cronus Stopwatch PMWR 13-03730 E-937 Amprobe ammeter PMWR 13-03730 E-808 Fluke multimeter WR 23-33055 M-873 Starrett dial indicator WR 10-42638 The inspector also reviewed the preventive maintenance (PM) program to determine that a master schedule had been developed, a compilation of late and incomplete PM activities was developed and available for management review, procedures are sufficiently detailed and available and that a lubrication control system has been implemente .3 Findings and Conclusions Based on the inspector's reviews and discussions with cognizant personnel, except for the violation noted below, the licensee's program for the control of maintenance activities adequately addressed the inspection attributes discussed in Sections 3.1 and abov The ' licensee's administrative procedure AP4.2, " Control of Measuring and Test Equipment," establishes the control of M&TE used in activities affecting quality of Class I systems or component The procedure requires that each test instrument has some form of. log to record where, when used and the initials of the use While

. reviewing the selected log cards for the instruments listed above in Section 3.2, the - inspector determined that three instances of not recording M&TE usage on the respective log card had occurred when Biddle megger E-817 used for PMWR 03730 on 1/18/87 on the QA category 1EH RCIC inboard steam isolation ' valve (13MOV-15) motor and Biddle megger E-817 and Fluke multi-meter E-808 used for WR23-033055 on 10/2/86 on the QA category 1EH HPCI inboard containment isolation valve (23MOV-15) motor were not logged. The failure to record usage on the respective log cards is an example of the violation for failure to follow procedures (50-333/87-11-02).

The inspector determined that the QC personnel were aware of the safety related maintenance activities being scheduled and performe The required inspection points were initialed in the work packages reviewed by the inspector which demonstrated that the QC personnel were/are actively involved in the plant maintenance activitie In one isolated instance, the QC inspector failed to fully complete a QC welding checklist, however the pertinent information was documented and verified, by the QC inspector, on the Weld History Form. The inspector concluded that the QC overview of maintenance activities is

adequate and implemented in accordance with licensee procedure __

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The licensee-management's involvement and control.in assuring quality

. was ' evidenced by- the planning and .prioritization of' maintenance e  : activities, the ' active role of- QC regarding maintenance activities,

_ w the control of . completed maintenance . records, _ the ^ review of ~ main- -

tenance documentation and the establishment of a_ work. control center,

inithe control room, to effectively control the work package The ' licensee's maintenance ' staff positions are identified with

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authorities and responsibilities define The staffing appears-adequate to perform normal maintenance activities during operation The' licensee added three supervisors and 31 craft personnel into the-mechanical and 1 electrical disciplines, a valve consultant (for leak

, rate testing)' and 14 tool room attendants- to support the outage maintenance activitie '

,

It' was noted- that some maintenance procedures directed the- worker to f 5 accomplish the - itask ; (e.g. calibration, maintenance) in _ accordance

~

with ' the = instructions provided _in the .' applicable vendor's manual .

, These manuals' are in the validation process which _is described in the

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Nuclear -Utility Task Action Committee-(NUTAC) Vendor Equipment i~ Technical- Information Program-(VETIP) published in March 1984. In a-

, response- to" a'_1986._INP0 (Institute of ; Nuclear Power Operation) ,

evaluation finding the licensee stated " ensuring accuracy is part of '

the overall planned.ma'intenance progr'am expansion scheduled over the-

,

next few: years" (i.e. validation of the accuracy and adequacy of the

! vendor technical manuali information). In . response letters (November

. 9,'1983; 3eptember 6, 1983; and March 40, 1984) to NRC Generic Letter ~ .

83-28, the licensee stated that the NUTAC VETIP would be followed and that validation of vender technical manuals was expected to - be

! completed by December 1, 1985.

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The status _and expected completion date of this validation process

_

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were discussed with licensee management who were not prepared - to-provide a definite schedule ~for completio .0 Procurement and Material Management -

!- _ Implementation Several components and parts (see Attachment A) associated with the-

- modifications ~ discussed in paragraph 2 were selected for an in-depth

review so as to evaluate the procurement process and material l, management. These items had been installed, accepted and in use.

3 The purchase requisitions were compared to the technical requirements L imposed on the item (s) by source documents such as quality classi-

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fication, the FSAR, specifications, and the respective modification package engineering documents. Also, the issued Purchase Order (PO)

,

was compared to the requisitio '

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&* 15 The P0s were reviewed to assure appropriate regulatory and QA Program requirements (e.g. licensee access to the vendor's plant, assignment of appropriate quality program elements to be implemented, and certifications and reports to be provided) were included. The status of the vendor's acceptability to provide the'. given. item (s) was also determine The review and approval of changes to the P0 and original stipula-tions, receiving . inspection activities, and issuance of items were reviewed with respect to requirements. .The receipt of certifica-tions, reports and other required documentation was also examine The main warehouse was toured and the storage, maintenance. and care of like items . to those selected were examined for adequacy. This included environmental conditions, identification, disposition, shelf life control and preventive maintenance of the item General cleanliness, space sufficiency, ~ access controls, item-protection, traceability and identification were observe .2 Findings and Conclusions The Administrative and . Technical requirements were adhered to as specified in the P0 and implementing procedure Warehouse conditions and controls were adequat Especially notable was the ongoing process to envelope, other than large items, in porous transparent plastic wra Items subject to shelf life and preventive maintenance were so identifie Warehouse management was especially conscientious in executing their responsibilitie An indication of this was the communication and interfaces with engineering personnel about shelf life provisions for previously stocked item .

Audits and surveillances of procurement and material management were being accomplished. Receiving inspection and associated controls were implemente The procurement, material . management and assurance of quality .is implemented effectivel No violations were identifie .0 -QA/QC Involvement and Overview 5.1 Implementation Various staffing charts, schedules, plans, logs and reports were reviewe Discussions of the foregoing and licensee actions to enhance QA/QC overview were discussed with onsite and offsite QA managemen . - - . - . - .

. - -- . - .

. e[ '

s ,

d' 16 The licensee had augmented the normal onsite QA/QC staff with 52 ,

contracted personnel at the peak of outage activities. Regular QC '

employees served in supervisory capacity and monitored contracted personnel on a day-to-day basi The contracted personnel had been proficiency tested by the. supplier of their : services and then NDE personnel were retested by the licensee prior'to. assuming onsite duties. A one week indoctrination course was also presented to the contracted personnel prior to the assumption of onsite dutie The background check of contracted personnel ' included licensee contact 'with their former employer Inspection points have been inserted into work procedures and clearly identify the actual QA action required. Approximately 660 Preventive Maintenance Requests (PMRs) ard Work Requests (WRs) issued for the outage involved Q QA Surveillances (monitoring) of ongoing work are being conducte Examples . are the observation of off loading and on loading the-nuclear fuel, review of the video tape of the loaded core, breaker maintenance, instrument calibrations and operation -surveillance testin The audit program is undergoing ' major revision. .The former methodology that emphasized procedure compliance and audits narrowly focused on one of or a portion of procedures in a functional area is being replaced by a more broad and comprehensive approac The basis of this enhancement of the audit program is the use of plans to scope prooram aspects and requirements; preparation of checklists derived from source documents such as NRC NUREGs; and -

development of a matrix that identifies what procedures implement given program element The first round of these enhanced audits will evaluate the respective

. programs, procedures and implementation thereof. Subsequent audits

.will evaluate program, and procedure changes and overall implement-ation and effectiveness of program The intent of licensee QA management is to convert most of the current compliance oriented audits to QA Surveillances (monitoring).

5.2 Findings and Conclusions The level of QC inspection is adequate. QC inspectors were very aware of work status and knowledgeable in their respective area QA Surveillances (monitoring) are being done and this overview level should improve when the new audit approach is fully implemented and current compliance audits are assimilated into this effor The addition of more personnel would enhance this effor _

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_- . y O~ '- 17 The revised audit program should improve the effectiveness of this overview effort. An especially noteworthy feature is the use of technical specialists during these audit The-QA/QC overview effort is on a positive trend and should so continue with the implementation of planned improvement No violations were identifie .0 Unresolved Items Unresolved Items are matters about which more information is required to ascertain whether they are acceptable items or violations. An Unresolved Item is discussed in paragraph 2.2 .0 Management Meetings Licensee management was informed of the scope and purpose of the inspection at the entrance interview on March 30, 1987. The findings of the inspection were discussed with licensee representatives during the course. of the inspection and presented to licensee management at the April 3,1987, exit interview (sce paragraph I for attendees).

At no time' during the inspection was written material provided to the licensee by the inspector. The licensee did not indicate that proprietary information was involved within the scope of this inspectio _ _ _ - - _ _ _ _ .

.sg *

O ATTACHMENT A

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1.0 Documents Reviewed for the Licensee Identified Item Occurrence Report 87-013 Deficiency and Corrective Action Report 87-045 Calculation Control Sheet, JAF CALC 87-002 2.0 Documents Reviewed for the Maintenance Program Review Work Requests (WRs)

WR23-52670 Body to Bonnet Leak on 23 MOV-60 WE23-33055 Replace Motor and Brake Assembly on 23 MOV-15 WR 02-36309 Repair Damaged Relay Drawer on VMS-71 WR 10-42638 Excessive Vibration on 10-P-IC WR 10-24155 Maintenance on Valve 10-430A WR 10-52718 Valve 10-1778 leaking by WR 02-2-50764 Replace Mechanical Seal on A Recirc Pump WR 10-30724 Replace Sealtite on Position Indication Switches on 10-818 WR 13-51608 Valve 13-05 failed seat leakage test Preventive Maintenance Work Requests (PMWRs)

PMWR 13-03730 Routine Preventive Maintenance on 13MOV-15 PMWR 23-05458 Routine Preventive Maintenance on 23MOV-15 Procedures AP Control of Measuring and Test Equipment, Revision 2 WACP 10. Procedure for Control of Maintenance, Revision 11 WACP 10.1.15 Control of Preventive / Predictive Maintenance, Revision 1 AP Quality Assurance Program, Revision 3 AP Control of Administrative Procedures, Revision 9 AP Control of Plant Procedures, Revision 5 F-IMP-1 Residual Heat Removal System RHR Loop A Maintenance, Revision 10 F-IMP-2 High Pressure Coolant Injection System Pump Pressure Indication, Revision 4 MP-5 Limitorque Motor Operators-SMB Model, Revision 11 MP-59.12 Maintenance Procedure for Non-Pressure Style Swing and Piston Check Valves, Revision 2 MP-4 Maintenance Procedure for RHR Service Water Pumps and Emergency Service Water Pumps, Revision 1 PM-5.9.10 Maintenance Procedure for Non-Pressure Seal Style Gate Valves, Revision 3

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,*, ATTACHMENT A Con e v

3.0 Documents Reviewed for Procurement Program Purchase Orders 814865, Fittings 831906, Packing and Gaskets 824044, Limitorque Motors 831836, Valves 831996, Valves 811521, Valve Studs, Caps, Screws and Rings 811522, Valve Parts 83745, Pump Shaft Sleeve Repair 814719, Pipe and Steel Products 85-006218-001, Grease 4.0 Documents Reviewed for QA/QC Program Review QA/QC Reports SR 1170, Reactor Core Surveillance SR 1167, Instrument Calibration SR 1163, Valve Leak Testing SR 1154, Off/0n Load Fuel SR 1161, Breaker Maintenance