IR 05000003/1972005
| ML20050C095 | |
| Person / Time | |
|---|---|
| Site: | Indian Point  |
| Issue date: | 09/19/1972 |
| From: | Glasscock R, Howard E, Madsen G, Spessard R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| References | |
| 50-247-72-11, 50-293-72-05, 50-293-72-5, NUDOCS 8204080130 | |
| Download: ML20050C095 (11) | |
Text
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\\ . , . . u U. S. ATOMIC ENERGY CO>Df1SSION s DIRECTORATE OF REGULATORY OPERATIONS '
REGION I
RO Inspection Report Nos.: 50-003/72-05
- 50-247 /72-M Subject: Con Edison Electric Company License Nos.:#1 - DPR-5 Indian Point Units I & II
- 2 - DPR-2 Location: Buchanan, New York Category 1 -C 2-B
. Type of Licensce: Unit I PWR 615 MWt (B&W) . Unit II PWR 2758 MWt (W) Type of Inspection: Special - Review and Evaluate Qual-
ity Program For Operations (IP-162) Dates of Inspection: 7-21-72 through 7-25-72 Principal Inspectors : . 4(.<_ r,k - // ~/ 2- < R. L. Spessard, Reactor Inspector .'Da t e / W1 & < -m., d -
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9 fit;fyy., G\\ L. Madsen, Acting Senior Reactor 'Date j Inspector [[ 7 V ^ Reporting Inspector: -r- - R. B. Glasscock, Reactor Inspector Da'te Other Accompanying Personnel: None fffff)V Revicued by & T :_- E. d. Iloward, Chief, Reactor Construction Br.
D6tc . i Proprietary Information: None
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r- \\. Q .. . . . ' '. !. t . , . i SECTION I Enforcement Action - . None Licensee Action on Previously Identified Enforcement Matters Not Applicable Unresolved Items Criterion I Reference Section II Paragraph 2 n n n u yy
9 " " "
" III ' " " " n IV
" " " " VI
. " " " " VII
" " " " IX
' " " "
" XIII - " " " " XIV
" " " " XV
. . " " " - "
" XVI .) . " " " " XVII
' " " "
" XVIII - . Status of Previously Reported Unresolved Items Not applicable l I' Unusuhl Occurences i None . .. % . O . . . -...%.....c ..e,.. . - -. -.... - - - -, - -- m, . -%-..-ye.
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Vice President, QA & R Con Ed R. B. Hayman Manager, QA Power Supply " " R. Gordon Director, Quality Standards & Re- " " liability Dept.
, G. S. Case QA Engineer, Indian Point Station " " W. R. Cobean Manager, Nuclear ~ Power Generation Dept.
" " , , S. G. Salay Chief Engineer, Unit No. 3 " " W. Ferreir QA&R Site Representative " " The Quality Assurance Program for Operations (CI-240-1, dated March 1, 1972) had been evaluated with respect to all 18 criteria in Appendix B of 10 CFR 50.
Each noncompliance to Appendix B was presented at the meeting.
A.
Te.a inspector stated that the program does not define the responsibilites of the Q.C. Engineer in the operations and maintenance organization, nor does it define the interface between Q.C. Engineer and the Q.A./ Relia-bility Organization.
. , Con Ed stated they will define this as part of the program.
, B.
The inspector pointed out that the Quality Control Engineer reports to the Assistant Manager for Operations and Maintenance.
This does not pro-vide independence for the quality-determining personnel as required by Crit erion I, , . Con Ed presented a July, 1972 revision of the Power Generation organiza-tion and which showed the Quality Control Engineer Title was changed to Quality Assurance Engineer and that he reported to the Station Manager , - for Operations and Maintenance.
, i The inspector stated we would re-evaluate the noncompliance based on the i new organization chart.
Subsequent,to,the management interview, the new organization was evaluated and found acceptable.
' C.
The Program states in Paragraph 1.0, "This instruction describes a
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. --.. -. . ' :.... e . .-. ... .. .. ,, -, ( (! . . -3- - Q.A. Program which is in accordance with the Quality Assurance requirements of the American Society of Mechanical Engineers (ASME) Boiler and Pressure Code for Nuclear Power Plant Components." This appears to be an error in reference since 10 CFR 50 requires that the Q.A. Program for Nuclear Power Plants comply with Appendix B of 10 CFR 50.
Con Ed stated the letter transmitting the manual was signed by the Pres-ident of Con Ed and did state that the manual was to implement the require-ments of Appendix B of 10 CFR 50.
All controlled copies of the manual included the above letter.
, The inspector stated the difference between the policy letter and Program scope was somewhat confusing but did recognize Con Ed's position that Appendix B of 10 CFR was properly referenced by the policy letter.
D.
The Q.A. Program does not include provisions for training /indoctrin-
ation of quality personnel, nor does it provide for regular ret.ews of the Q.A. Program for status and adequacy.
- Con Ed stated they would include this as part of the program.
E.
The inspector stated that the Program does not provide for regulatory concepts to be included in the design.
Con Ed stated they would include this as part of the program.
F.
The inspector stated that the Program does not provide for deviation control.
Con Ed stated they would include this as part of the program.
G, The inspector stated the Program does not require an engineering review for suitability of application of materials, parts, equipment and processes.
Con Ed stated they would include this as part of the' program.
11. The Prograc does not provide for identification and control of design , interfaces.
Con Ed stated they would include this as part of the . , program.
1.
The inspector stated that the Program does not provide for independent , design review to verify conformance to 10 CFR 50, Appendix A, require-l ments.
I Con Ed stated they would include this as part of the program.
J.
The inspector pointed out that the' Program does not include provisions for regulatory requirements to be referenced or included in procure-J ment documents.
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4- . - . . Con Ed stated they would include this as part of the program.
' K.
The Program does not define the conditions that r: quire a contractor or subcontractor to have a Q.A. program which meets the requirements , of Appendix B of 10 CFR 50.
- . Con Ed stated that the instructions were applicable to all Class A items.
They will add the requirement that the contractors and subcontractors comply with the pertinent provisions of Appendix B of 10 CFR 50.
, ' L.
The inspector stated that the program does not define the control over the issuance of documents affecting Quality such as instructions, pro-cedures and drawings and changes thereto.
Con Ed stated they will , include this as part of the program.
I M.
The Program does not require evidence of gaality from suppliers (im-plied in the inspection check sheet, but not stated in the Program).
Con Ed stated they would include this as part of the6 program.
N.
The Program does not require objective evidence of acceptability to be onsite prior to installation.
Con Ed stated they will include a positive statement on this in the program.
O.
The Program does not recognize special processer, except welding and nondestructive testing.
Con Ed stated they would clarify this in the revised program.
P.
The Program does not provide for control over handling, storage,' shipping, ' cleaning, and preservation of material.
t Con Ed stated they would include this as part of th'e program.
! Q.
The inspector stated that the Program does not provide for indicating i the operational status of structures, systems, and components, nor does
it provide for tagging of operational controls.
! Con Ed stated that they were already doing this and would include this as part of the program.
R.
The program does not provide for documented procedures for review, acceptance, repait or rework of nonconforming items.
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,. __ - - - _ _ __ _ ,.; __ _- ,7_ _ _ _ _ _,,,,;__._.,_, ,, _ ,, , . [ . . - - . 5- % - . . Con Ed stated they would clarify this in the program by appropriate reference and include ad.dstional corrections as required to comply.
. S.
The program does not clearly identify the req sirement for analysis to determine cause of ccr. Itions adverse to quality nor does it re-
quire corrective action reports to management.
- Con Ed stated they would clarify and include in the program.
T.
The Progrim does not define the minimum content of inspection and test records as required Ly Criterion XVII.
- Con Ed stated they will include this as part of the program.
! . U.
The Program does not define a planned periodic audit program to verify compliance with all aspe".tv of the Q.A. Program and to determine its effectiveness.
I Con Ed stated that the Prw, ram did include an audit function, but they would supplement it to in<,1ude the detailed requirements as stated by , the inspectors.
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, ,., - ~ .. .1 - - -.. -. - - .. ... , r-p . ' - - . . s . SECTION II Additional Subjects Inspected, Not Identified in Section I, Where No , Deficiencies or Unresolved Items Were Found.
1.
General
' . This report is prepared to document the results of an evaluation of the Con. Edison's " Quality Assurance Program for Operation of Indian Point" ! -(Instruction Number CI-240-1 dated March 1,1972).
i - The program has been compared with the requirements of Appendix B of 10 CFR 50 and appears to be in compliance with Criteria V, VII, X, XI and XII. ; The major variations from the remaining criteria requirements are iden- . tified below. The variations were discussed with Con Ed on July 28, 1972.
Details of Subjects Discussed in Section I ! 2.
Criterion I - Organization ' The Program does not define the responsibilities of the Q.C. Engineer in the operations and maintenance organization, nor does it define the inter-face between Q.C., and the Q.A. and Reliability Organization.
This omis- ! sion does not comply with criterion I which states in part, "The authority l and duties of persons and organizations performing Quality Assurance ' . functions shall be clearly established and delineated in writing."
l ' , The Quality Control Engineer reports to the Assistant Manager for Oper- ! ations and Maintenance.
This does not provide independence for the l quality-determining personnel as required by Criterion I which states in ! part, "The individual or group assigned the responsibility for checking... i or otherwise verifying that an activity has been correctly performed, is , k independent of the individual or group directly responsible for performing - the specific activity."
The above was based on the limited information contained in the program.
Con Ed presented a detailed organization chart (dated July) at the
July 28 meeting which has been evaluated and found acceptable.
i '3.
Criterion II - Quality Assurance Program i The Program states in Paragraph 1.0, "This Instruction describes a Q.A.
Program which is in accordance wiqh the Quality Assurance requirements j of the American Society of Mechanical Engineers (ASME) Boiler and Pres-
sure Code for Nuclear Power Plant Components." This appears to be an k
error in reference since 10 CFR 50 requires that the Q.A. Program for , Nuc1 car Power Plants comply vith Appendix B of 10 CFR 50.
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... --.__ - -- - -. r 3b K . - 7 -- - g Con Ed explained at the July 28 meeting that the corporate policy state-ment did include the correct reference and was to be considered part of the manual since all controlled copies did include the policy state-i t ment.
liue Q.A. Program does not include provisions for training / indoctrination of quality personnel, nor does it provide for regular reviews of the Q.A. Program for status and adequacy.
This omission does not meet the requirements of Criterion II which states in part, "The Program shall provide for indoctrination and training of perconnel performing act- .ivities affecting quality.... The Applicant shall regularly review the ' status and adequacy of the Q.A. Program."
t 4.
Criterion III - Design Control { The Program does not provide for regulatory concepts to be included in the design. This does not comply with Criterion III which states in ' part, 'hcasures shall be established to assure that regulatory re-quirements... are correctly translated into specifications and draw-
ings..." The Program does not provide for deviation control.
This does not ap-pear to comply with Criterion III which states in part, " Measures shall include provisions to assure that appropriate quality standards are , specified and included in design documents and that deviations from such standards are controlled."
The Program does not provide ~for review for suitability of application of materials, parts, equipment and processes.
This does not appear to comply with Criterion III which states in part, 'Heasures shall be , established for the selection and review for suitability of application of materials...." } The Program does not provide for identification and control of design interfaces.
This does not appear to comply with Criterion III which states in part, " Measures shall be established for the identification , and control of design interfaces... These shall include procedures among participating design organizations for the review... of documents ' involving design interfaces."
, The Program does not provide for independent design review to verify the adequacy and conformance to 10 CFR 50 Appendix A requirements.
This does L not appear to comply with Criterion III which states in part, "The design
control measures shall provide for verifying or checking the adequacy of design...." i- - - l - ..
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Criterion IV - Procurement Document Control The Program does not include provisions for regulatory requirements to be reference s or included in procurement documents.
This does not ap- .- ' r pear to comply with Criterion IV.which states in part, " Measures shall ' be established to assure that applicable regulatory requirements...- i necessary to assure adequate quality are included or referenced in the documents for procurement of material..." - s 1he Program does not define the conditions that require a contractor or
' - subcontractor to have a Q.A. Program which meets the requirements of Appendix B of 10 CFR 50.
This does not appear to comply with Criterion IV , which states in part, "To the extent necessery, procurement documents . shall require contractor or subcontractors to provide a Q.A. Program , consistent with the pertinent provisions of this Appendix."
,
Con Ed pointed out at the meeting on July 28 that the scope of the pro-gram applies to all Class A items.
Contractors or subcontractor, supplying Class A items, must have a Q.A. Program that meets the pert- ' - - inent provisions of Appendix B or 10 CFR 50.
. 6.
Criterion VI - Document Control - 1he Prv6 cam does not provide control for the issuance of documents
, affecting quality.
This does not appear to comply with the requirement of Criterion VI which states in part, " Measures shall be established to ! control the issurance of documents, such as instructions, procedures' ! and drawings including changes thereto which prescribe all activities affecting quality.
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7.
Criterion VII - Control of Purchased Material, Equipment and Services
The Program does not require evidence of quality from suppliers (implied in the inspection check sheet, but not stated in the Program).
This does not appear to comply with Criterion VII which states in part, " Measures . - shall include provisions as appropriate, for... objective evidence of ! quality to be furnished by the contractor or subcontractor."
( ' The Program does not provide for evidence of acceptability prior to installation.
This does not appear to comply with Criterion VII which l states in part, " Documentary evidence that material and equipment conform i to the procurement requirements shall be available at the nuclear power [ plant site prior to installation or use of such material and equipment."
I i ' 8.
Criterion IX - Control of Special Processes The Program does not recognize special processes, except welding and non-
destructive testing.
This,does not appear to comply with Criterion IX ' ' . I e
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. . which states in part, 'Heasures shall be established to assure that special processes, including welding, heat treating and nondestructive testing will be controlled..." , 9.
Criterion XIII - Handling, Storage & Shipping The Program does not provide for control over handling, storage, ship-ping, cleaning, and preservation of material.
This does not appear to comply with criterion XIII which states in part, " Measures shall be
' - established to control the handling, storage... in accordance with work and inspection instructions to prevent damage or deterioration."
> 10. Criterion XIV - Inspection Test and Operating Status ' The Program does not provide for indicating the operational status of structures, systems, and components, nor does it provide tagging of operational controls.
This does not appear to comply with Criterion XIV which states in part, " Measures shall also be established for indicating the operational status of structures... by such means as tagging valves and switches to prevent inadvertent operation."
11. Criterion XV - Nonconforming Fbterials, Parts or Components The Program does not provide documented procedures for review, acceptance, rejection, repair or rework of nonconforming items.
This does not appear , to comply with Criterion XV which states in part, " Nonconforming items shall be reviewed and accepted, rejected, repaired or reworked in ac-corda'nce with documented procedurcs."
12. Criterion XVI - Corrective Action ,
The Program does not clearly identify the requirement for an analysis
to determine the cause of conditions adverse to quality, nor does it ' require corrective action reports to management. This does not appear , to comply with the requirements of Criterion XVI which states in part,
" n the case of significant conditions adverse to quality, measures , .uall assure that the cause of the condition is determined and cor- ' rective action taken to preclude repetition.
The identification of the i significant condition adverse to quality, the cause..., and the cor- , rective action taken shall be documented and reported to appropriate levels of management."
t i 13. Criterion XVII - Quality Assurance Records j
r The Program does not define the minimum content of inspection and test . records.
This does not appear to comply with Criterion XVII which , states in part, " Inspection and test records shall as a minimum identify [' the inspector, or data recorder, the type or observation, the results, , the acceptability and the action utilized during correc, tion of any ,
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deficiencies noted."
14. Criterion XVIII - Audits - i , i The Program does not define a planned periodic audit program to verify ' compliance with all aspects of the Q.A. Program and to determine the effectiveness of the Program.
This does not appear to comply with Criterion XVIII which states-in part, "A comprehensive system of plan- > ned and periodic audits shall be carried out to verify compliance with l all aspects of the quality assurance program and to determine the effect- ! - , iveness of the Program."
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