IR 05000029/1976006
| ML19339B388 | |
| Person / Time | |
|---|---|
| Site: | Yankee Rowe |
| Issue date: | 03/12/1976 |
| From: | Glasscock R, Haverkamp D, Mccabe E, Ruhlman W, James Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION I) |
| To: | |
| Shared Package | |
| ML19339B383 | List: |
| References | |
| 50-029-76-06, 50-29-76-6, NUDOCS 8011060840 | |
| Download: ML19339B388 (22) | |
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U. S. NUCLEAR RECUL\\ TORY CC:CIISSIO:t OFFICE OF I::SFECTIO;; A.*D E:iFORCD!E.T
'REGIOI I 50-29/76-06 Docket No:
50-29 IE Inspection P +crt No:
~3 Yankee Atomic Electric Company License No:
Licensee:
20 Turnpike Road Priority:
Westborough, Massachusetts 01581 C
Safeguards Group:
Loca tion:
'Rowe, Massachusetts
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Type of Licensce:
PWR (W) 600 MWt Type of Inspection:
Rc2 tine, Announced, Quality Assurance February 9-13, 1976 Dates of Inspection:
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Dates of Previous Inspection:
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L.T.SmithMJr.,ReactorInspector
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. he, Reporting Inspector:
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Accompanying Inspectors:
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DATE R. B. Glassco
, Re ctor nspector Gdd/
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D.R.Haverkamp,Reacto[ Inspector (2/11 DATE thru 2/13 onl
%. 89. Cs.,y) 'm O
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N W. A. Ruhlman, Reactor Inspector DATE None Other Accompanying Personnel:
DATE
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- eviewed Ey:
DATE E. C. M;Cabe, Jr., Section Chief, Nuolcar Support
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Section No. 1 Reactor Operations and Nuc1 car Support Branch-8011060h90
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SUMMARY OF FINDINGS Enforcement Action A.
Infraction Contrary to 10 CFR 20.203(c)(2) requirements to control each en-trance or access point to a high radiation area, the access to the high radiation area containing the Waste Holdup and Activity Dilu-tion Delay tanks was neither equipped with the required control devices no: locked during the period August 21, 1975 through February 2 1976.
The access to this area was properly locked prior to the ccmpletion of the inspection.
Mcwever, a response detailing actions taken or planned to prevent recurrence is needed for this item.
(Detail 6.b)
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B.
Deficiencies 1.
Contrary to 10 CFR 50, Appendix B, Criterion XVIII and the Operational Quality Assurance Manual,Section V, item XVIII.10 requirements that audit results be docu=ented and reviewed by management having responsibility in the area audited, four of
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the sixteen audits conducted in 1975 had not been reviewed by the Manager of Operations as required through issuance of Plant Position Reports within the prescribed (AP-0208) 30 day period.
The four Plant Position Reports were generated and forwarded for review prior to completion of the inspection.
No addi-
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tional response is required for this item.
(Detail 6.c)
2.
Contrary to 10 CFR 50, Appendix B, Criterion XVI and the Operational Quality Assurance Manual,Section V, item XVI.2 requirements that measures be established :o assure that con-ditions adverse to quality be promptly identified and correc-ted: measures had not been established to assure prompt correction; in that the licensee's prescribed action on his 12/27/74 audit finding that there was an inadequacy in the svstem for updating the FSAR (FHSR)'for design changes or
_sdifications was not resolved as of 2/10/,76. (Detail 6.d)
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Contrary to 10 CFR 50, Appendix B, Criterion II and the Operational Quality Assurance Manual,Section V, item II requirements that the structures, systems and components to be c9vered by the quality assurance program be identified and that the quality assurance program shall provide control over activities affecting the quality of the identified sr.ructures, systems, and components, to an extent consistent with their importance to safety: boron used to control reactivi:y, and fuel oil used in the emergency diesel are not covered by the quality assurance program.
(Detail 8)
Licensee Action on Previous 1v Identified Enforcement Items The item identified in Detail 3.a of Report 50-29/75-13 was inspected with respect to the licensee's response dated November 18, 1975.
While progress toward implementation had been mode, the required procedure revision was not completed at this time.
The corrective action will be reviewed during a subsequent inspection.
(Detail 9)
Unusual Occurrences None Identified
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Design Changes None Identified Other Significant Findings A.
Current Findings
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1.
Acceptable Areas (These are areas which were inspected on a sampling uas is and findings did not include an Item of Noncompliance, Deviation or an Unresolved Item.)
a.
Quality Assurance Program Review.
(Detail 2)
b.
Procurement Control.
(Detail 4)
c.
Receipt, Storage and Handling of Equipment and Materials.
(Detail 5)
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Records.
(Datail 7)
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NSARC and PCRC Review.
(Detail 11)
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.Nonroutine Event Review.
(Datail 12)
2.
Unresolved Items
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(These are items for which additional information is required to determine if the item is Acceptable, a Deviation or an Item
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of Noncompliance.)
'a.
Revision of Procedure OP-3304.
(Detail 9)
b.
Engineering Drawing Control.
(Detail 10)
3.
Licensee Identified Item of Noncompliance (This item was identified by the licensee during the perform-ance of an internal audit for which documentation and initia-tion of corrective action had been v.ndertaken but not yet completed. Although this item was identiffsd by the inspector in the course of the inspection, due to the licensee's correc-
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tive action, no response is required by Region I at this time.)
Deficiency Contrary to 10 CFR 50, Appendix B, Criteria XI, and Adminis-trative Procedure 0001, Paragraph H, changes were made to installation procedures without obtaining approval of the original designer and the departnent head.
(Detail 3.b)
B.
Status of Previously Identified Unresolved Items The Unresolved Item identified in Detail 9 of Report 50-29/75-13 was inspc-ed.
This item is resolved.
(Detail 9)
Management Meeting At the licensce's req'uest a management meeting was conducted to discuss the licensee's concerns regarding the type and details of procedures required to implement the licensee's proposed Quality A.isurance Program, which is currently under review by the Division of Reactor Licensing.
The meeting attendees were as follows:
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Yankee Atomic Elcetric Company Mr. J. L. French, Jr., Manager of-Operations Mr. L. H. Heider, Assistant Vice President Mr. E. W. Jackson, Plant Follow Engineer Mr. R. L. Martin,. Operational Quality Assurance Engineer Mr. D. B. Pike, Manager of Operational Quality Assurance Mr. E. M. Reid, Plant Follow Engineer Vermont Yankee Nuclear Power Corporation Mr. W. F. Conway, Technical Services Supervisor Management Interviews A.
Entrance Interview A pre-inspection interview was conducted onsite at the beginning of the inspection on February 9, 1976, with the following licensee e,rsonnel in attendance:
Mr. H. A. Autfo, Plant Superintendent
,Mr. R. L. Boutwell, Technical Assistant Mr. L. X. Bozek, Site Quality Control and Audit Coordinator Mr. L. L. Reed, Quality Control and Audit Coordinator Mr. J. L. Staub, Technical Acsistant to the Plant Superintendent Mr. N. N. St. Laurent, Assistant Plant Superintendent The licensee was requested to identify any unusual operating events since the last faepection.
The l'.capsee reported a recent compo-nent failure associated with the No. 3 charging pump, which will be the subject of a licensee thirty day report.
During the pre-inspection meeting, the inspector identified the scope and objectives of the inspection.
B.
Exit Management Interview An exit management interview was conducted at tne site at the conclusion of the inspection on February 13, 1976 with the follow-ing licensee personnel in attendance:
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Mr. D. A. Army, Technical Assistant (Maintenance)
Mr. H. A. Autio, Plant Superintendent Mr. R. L. Boutwell, Technical Assistant
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Mr. D. J. Kauppiner, Technical Assistant (Operations)
Mr. D. B. Pike, Manager of Operational Quality Assurance Mr. L. L. Reed, Quality Control and Audit Coordinator Mr. J. H. Shippee, Instrument and Control Supervisor Mr. N. N. St. Laurent. Assistant Plant Superintendent Mr. R. H. Streeter, Storekeeper Mr. D. B. Vassar, Assistant Operations Supervisor
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The following summarizes the items discussed:
A.
Quality Assurance Program Review.
(Detail 2)
B.
Design Changes and Modifications.
(Detail 3)
C.
Procurement Control.
(Detail 4)
D.
Receipt, Storage and Handling of Equipment and Materials.
(Detail 5)
E.
, Review and Audits.
(Detail 6)
F.
Records.
(Detail 7)
G.
Safety Relatsl Materials.
(Detail 8)
H.
Report 50-29/75-13.
(Detail 9)
1.
Engineering Drawing Control.
(Detail 10)
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NSARC and PORC Reviews.
(Detail 11)
K.
Nonroutine Event Review.
(Detail 12)
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DETAILS
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1.
Persons Contacted Yankee Atomic Electric Company
- r. D. A. Army, Technical Assistant (Maintenance)
Mr. H. A. Autio, Plant Superintendent Mr. R. L. Eerry, Training Coordinator Mr. W. D. Billings, Chemistry and Health Physics Supervisor Mr. R. L. Boutwell, Technical Assistant Mr. L. X. Bozek, Site Quality Control and Audit Coordinator Mr. H. F. Buchanan, Senior Engineer - Radiation Protection Group Mr. R. M. Cooney. Technical Assistant (ISC)
Mr. R. P. Dobasz, Clerk Mr. J. L. French, Jr., Manager of Operations Mr. L. H. Heider, Assistant Vice President Mr. W. C. Howe, Chief of Security Mr. E. W. Jackson, Plant Follow Engineer Mr. D. J. Kauppinen, Technical Assistant (Operations)
Mr. P. E. Laird, Maintenance Supervisor Mr. R. L. Martin, Operational Quality Assurance Engineer
- Mr. E. L. May, Engineering Assistant Mr. E. A. Miles, Technical Assistant Mr. R. M. Mitchell, Operations Technician-Plant Support Mr. W. H. Monahan, Administrative Supervisor Mr. N. M. Panzarino, Engineer - Radiation Protection Group Mr. D. B. Pike, Manager of Or' rational Quality Assurance Mr. S.
Racz, Clerk (I6C)
Mr. L. L. Reed. Quality Control and Audit Coordinator
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Mr. R. E. Reid, Plant Follow Engineer Mr. D. A. Rice, Technical Assistant (Chemistry and Health Physics)
Mr. I. R. Seybold, Plant Health Physicist Mr. J. H. Shippee, Instrument and Control Supervisor Mr. J. L. Staub, Technical Assistant to the Plant Surcrintendent Mr. N. N. St. Laurent, Assistant Plant Superintendent Mr. R. h. Streeter, Storekeeper Mr. D. B. Vassar, Assistant Operations Supervisor
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Vermont Yankee Nuclear Power Corporation
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Mr. W. F. Conway, Technical Services Supervisor i
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2.
Quality Asaurence Program Review The inspector reviewed the changes ma/-1 to the Operational Quality Assurance Plan implementing procedures for the period from 1/1/75 through 1/1/76.
The inspector checked, on a sampling basis, for conformance with 10 CFR 50, Appendix B.
Through discussions with personnel responsible for the implementation of these changes, the inspector verified that the selected individuals were aware of the changes and were implementing them.
a.
Change Summary Tha procedures listed below were reviewed:
(1) AP-0001, PLANT PROCEDURES, Revision 4 dated 6/13/75.
(2) AP-0002, ABNORMAL OCCURRENCE r5 PORTS, Revision 3 dated 10/9/75.
(3) AP-0200, PLANT DESIGN CRANGES, Revision 2 dated 5/16/75.
(4)
AP.-0201, PLANT MODIFICATIONS, Revision 4 dated 5/30/75.
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(5) AP-0202, ENGINEERING DESIGN CHANGES, Revision 3 dated 8/15/75.
(6) AP-0205, MAINTENANCE REQUESTS, Revision 3 dated 8/15/75.
(7) AP-0208, IN-PLANT AUDITS, Revision 4 dated 10/9/75.
(8) AP-0210, CONTROL OF SPECIAL PROCESSES, Revision 2 dated 12/10/75.
(9) AP-0211, MATERIAL AND SERVICE PURCHASE, Revision 4 dated 9/5/75.
(10) AP-0212, MATERIAL RECEIPT, Revision 4 dated 12/10/75.
(11) AP-0213, MATERIAL IDENTIFICATION AND CONTROL, Revision 2 dated 6/13/75.
(12) AP-0214, INSTALLATION AND MAINTENANCE OF SAFETY CLASSIFIED SYSTEMS, COMPONENTS, OR STRUCTURES, Revision 2 dated 4/9/75.
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(13) A*-0215, CONTROL OF 'EASURING AND TEST EQUIPMENT, Revis-ion 3 dated 9/5/75.
(14) AP-0218, PREOPERATIONAL, OPERATIONAL AND SPECIAL TESTS, Revision 2 dated 12/10/75.
(15) AP-0220, SURVEILLANCE TESTS AND RECORDS, Revision 6 dated 10/17/75.
(16) AP-0221, QUALITY ASSURANCE RECORDS, Revision 2 dated 5/30/75.
(17) AP-0222, JOB ORDERS, Revision 1 dated 2/20/73.
Items (3), (5) and (17) were major procedural rewrites; all other items were minor rewrites designed to expand reference lists, include additional items or expand definitions, include currently endorsed ANSI standard practices, clarify methods of handling unusual conditions, and in some cases to expand /
redefine approval mechanism.
The inspector identified no inadequacies in this area.
'b.
Personal Interviews During the course of the inspection, the following personnel were interviewed with respect to their understanding and impicuentation of the selected changes in procedures docu-mented 1. "etail 2.a above.
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(1) Technical Assistant to the Plant Superintendent.
(2) Maintenance Supervisor.
(3)
Instrument and Control Supervisor.
(4) Site Quality Assurance and Audit Coordinator.
The inspector identified no discrepancies in this area.
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Design Changes and Modifications
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Design Changes Evaluated Ten design changes and modifications initiated during 1975 were evaluated'for the following:
(1) Accomplishment in compliance with 10 CFR 50.59.
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(2) Reviewed and approval in accordance with Technical Specifications, established plant procedures, and quality assurance controls.
(3) Completion in accordance with applicable codes.
(4) Inspections and test performed to verify conformance with requirements.
(5) Operating procedures and prints modified as required to reflect the change.
The design changes evaluated are as follows:
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Design Change Request Description 75-21 Add damper on No. 3 charging pump.
75-20 Reconnection of MC flow (AP) to system.
75-18 Replace present Rod Position Indication. Lamps with LEDS.
75-17 Install a valve at cavity recovery connection to main coolant drain header.
75-11 Primary Auxiliary System Instru-mentation Sensing Line upgrading.
75-10 -
Emergency Diesel, DC Motor Control Circuit UV alarm mod-ification.
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Design Change Request Description 75-6 Shutdown cooling Instrumentation Piping changes.
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75-5 S/G NR Level Trip System Modif-ication.
75-2 Raising the S1 Tank (TK-28) Low Level Alarm setpoint.
75-1 Plugging of Flux Mapping Tube H-2 and K-6.
b.
Procedure Approval Contrary to 10 CFR 50, Appendix B, Criterion VI requirements that documents including changes be reviewed for adequacy and approved for release by authorized persons, and to administra-tive procedure 0001, paragraph H, which requires the concurr-ence between the original designer and a department head for changes that do not alter the intent:
procedure OP-6000.44, as used on change request 75-6, was changed without obtaining
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the required approvals.
It was noted that the revised pro-cedure was approved by two SR0s prior to use and reviewed by PORC following completion of the modification.
Audit Report 75-7 completed on 12/15/75 also identified procedures which have been changed in a similar manner.
The above licensee identified audit finding indicates a failure to properly review and approve procedures and is a deficiency level Item of Noncompliance for which corrective action has been initiated and no further response is required.
4.
Procurement Control The inspector reviewed the procurement control phase of the Quality Assurance Program with respect to the requirements of 10 CFR 50, Appendix B, Criteria IV and VI and the Operational Quality Assur-ance Plan implementing procedures.
The following, based upon discussions held with and documentation furnished by licensee personnel, summarizes the inspector's find-ings.
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Personnel Key personnel responsible for the initiation, review and approval of procurement documents were interviewed and in-dicated that they have ready access to the appropriate pro-cedures and understand their individual responsibilities.
The inspector identified no inadequacies in this area.
b.
~ Procurement Document Control (1) The following safety-related items were randomly selected as samples for the review described in subparagraph (2),
following:
(a) Stainless Pipe and Fittings (P.O. 202872).
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(b) Rotary Switch (P.O. U-3003).
(c) Welding Rod (P.O. U-3016).
(d) Switchboard (P.O. U-30. ).
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(2) The procurement documents for the items listed in sub-paragraph (1), preceeding,were reviewed to verify that the following requirements were =et.
(a) The items were purchased from vendors / suppliers that were " qualified" by the licensee.
(b) Approvals of procurement documents were made in accordance with the licensee's established controls.
(c) Procurement documents contained requirements for the vendor / supplier to supply appropriate documentation of quality.
(d) The items selected were positively identified and traced to the procurement documents.
The inspector identified no inadesuscies in this area.
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Receipt, Storage and !!andling of Equipment and Materials The inspector reviewed the receipt, storage and handling of equip-ment and materials phase of the Quality Assurance Program with
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respect to the requirements of 10 CFR 50, Appendix B, Criteria II, VII, XIII, XIV, XV and XVII and the Operational Quality Assurance Plan implementing procedures.
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The following, based upon discussions held with and documentation furnished by the licensee personnel, summarizes the inspector's findings.
a.
Receipt Inspection A receipt inspector responsible for the receipt inspection of safety-related items was interviewed and demonstrated that he was familiar with AP-0212, " Material Receipt" and AP-0213,
" Material Identification and Control."
The inspector identified no inadequacies in this area.
,b.
Nonconforming Items (1). The following three safety-related items currently in storage and ident!fied by receiving personnel to be in nonconformance with specified requirements, were randomly selected for the review described in subparagraph (2),
following:
(a) Pressure Flow Transmitter (NCR #75-13).
(b) Carbon Brushes for M-G Set (NCR #75-14).
(c)
1300' of #4 Conductor, #9 Cable XLP (NCR #75-19).
(2) The items listed in subparagraph (1) preceeding, were reviewed to verify that the following administrative controls are being implemented.
(a) Provisions have been made for marking and segregating nonconforming items.
(b) Provisions have been made for the disposition of nonconforming items.
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(c) Requirements have been established to prohibit the use of materials or equipment in a "nonconformance" status.
(d) Provisions have been made for notifying affected organizations of nonconforming items.
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(e) Requirements have been established for the documen-tation of nonconforming items.
The inspector identified no inadequacies in this area.
c.
Storage of Material and Equipment (1) The inspector noted that storeroom space was adequate and ample room was available for storeroom activity.
(2) The inspector verified that provision had been made in the storeroom for temperature controlled ovens to store the weld rods.
The inspector identified no inadequacies in this area.
6.
Quality Assurance Audits The inspector reviewed all audits conducted during the previous year (1975) to verify that they were conducted as follows:
in accordance with written procedures /checklistc; by 'crained personnel not having direct responsibility in the area audited; that audit results were documented and reviewed; followup and/or corrective actions were initiated / completed; and, audic frequency was in accordance with the requirements of the licensee's procedure OQA K7III-2, In Plant Audit Program.
a.
Audits Reviewed The audits listed below were reviewed with respect to the criteria set forth above.
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-14-Number Title Date(s) Conducted 75-1 Operations May 28, 19 75 75-2 Chemistry September 17-19, 1975 75-3 Health Physics August 12 14, 1975 l
75-4 Security August 18, 1975 l
75-5 Training December 29, 1975 75-6 Maintenance September 24, 1975 75-7 Plant Changes December 15, 1975
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75-8 Procurement of Materials and l
Services November 13, 1975 75-9 Material Control July 18, 1975 75-10 Nonconformance of Material Installation July 22, 1975 75-11 Control of Special Processes October 3, 1975 75-12 control of Measuring and Test Equipment May 23, 1975 75-13 Surveillance, Testa June 20, 1975
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75-14 Nuclear Material Control December 19, 1975 l
75-15 Reporting Requirements December 15, 1975 l
75-16 Document Control June 26, 1975
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With espect to audit conduct, depth, scope, frequency and the
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qualifications / independence of the auditors, the inspector identified no inadequacies.
However, three Items.of Noncem-pliance.were found as indicated in Details 6.b, 6.c and 6.d below.
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b.
Audit 75-3
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Finding L.4 of this audit indicated that the access to the high radiation area (greater than 100 mr/hr) containing the
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As indicated above this audit was conducted August 12-14, 1975.
The audit report was issued documenting this finding on l
August 21, 1975.
When the inspector did an inspection of this i
access point on February 10, 1976, the access was not locked.
The licensee stated that the area had not been locked since the issuance of the audit report on August 21, 1975.
10 CFR 20.203 (c)(7) requires that each entrance or access point to a high radiation area either be equipped with control devices or to be locked, except during periods of access.
This failure to provide the required controls or lock is an Infraction -
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level Item of Nonct.mpliance.
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-15-Within twenty minutes after review by the inspector, the required lock had been installed. Although the action taken was satisfactory, the response for this item should detail the steps taken or planned to prevent recurrence of known, readily correctable noncompliances not being corrected for extended periods of time.
c.
Audits 75-5, 75-7. 75-14 and 75-15 The title and date conducted for each of the referenced audits is shown in Detail 6.a precceding.
The audit reports were issued as follows:
75-5 issued 1/2/76; 75-7 issued 12/23/75; 75-14 issued 12/29/75; and 75-15 issued 12/18/75.
10 CFR 50, Appendix B, Criterion XVIII requires in part that:
" Audit results shall be documented and reviewed by management having responsibility in the area audited." The licensee's Operational Quality Assurance Plan states in part in Section V, item XVIII.10 that: " Audit results shall be reviewed by management having responsibility in the area audited." 10 CFR 50, Appendix B, Criterion V, requires that activities affect-ing quality be accomplished in accordance with prescribed instructions and procedures.
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The licensee has delineated a system for handling audit report (AR) findings, formulating positions (Plant Porition Reports -
PPR's) at the plant level for correction, and then forwarding those reccomendations for review by the Manager of Operations (M00) who then directs the actions to be taken.
These actions
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are returned to the plant in a M00 Imple=entation Directive (ID).
These systems are delineated in plant procedure AP-0208, IN PLANT AUDITS, and Operational Quality Control and Audit Department procedure 0QA-XVIII-2, IN PLANT AL*DIT PRO-GRAM.
The Technical Assistant to the Plant Superintendant (TAPS) prepares the PPR.
AP-0208 states, in part, in item 3 of the procedure that: "The PPR shall be prepared and sub-mitted within 30 days of receipt of the AR."
Contrary to the above requirements, PPR's for the four refer-enced audits had not been prepared and submitted as of 2/9/76, exceeding the required 30 day period for all four audits.
This failure to provide management review within the prescribed time-frame is a Deficiency level Item of Noncompliance with 10 CFR 50, Appendix B, Criterion XVIII.
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The licensee detailed the unusually heavy workload for the TAPS during January 1976.
In addition, all four PPR's were prepared and issued prior to the completion of the inapection.
The inspector also observed that all four audit reports were issued within a two week time period thus requiring the four-corresponding PPR's to be issued in a two week time period.
No additional response is required for this item at this time, d.
Audit 74-16-A The referenced audit report documented an inadequacy in the system of design control / change implementation with respect to updating the FSAR (FHSR) pages following a system modifica-tion.
The PPR, in answer to this audit report issued 12/27/74, stated that a procedure (WE-100B) would prescribe that Opera-tions Engineering would either revise the FSAR (FHSR) directly or provide the contents of the needed revision to the plant.
The revised procedure had not been issued to complete the corrective action as of 2/10/76, over one year after issuance of the audit report finding.
10 CFR 50, Appendix B, Criterion XVI requires in part:
" Meas-ures shall be established to assure that conditions adverse to
quality....are prc.nptly identified and corrected." The Opera-tional Quality Assurance Plan,Section V, item XVI.2 states:
" Measures shall be established to assure that conditions are corrected." This failure to establish =easures to assure that corrective actions are completed is a Deficiency level Item of Noncompliance.
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Other examples of failures to take corrective action include the following audit report findings which were unresolved /in-complete for the time periods indicated.
(1) Lack of training schedules for Chemistry and Health Physics Training, identified originally in Audit Report 74-03-A issued October 16, 1974 and uncorrected after 15b months.
(2)
Issuance of a Chemistry Department QA Program as the corrective action for six inadequacies identified during audit 75-2 (9/29/75) was specified in the PPn for com-pletion of the procedural description on 11/15/75 and for implementation on 1/1/70.
Neither procedure issuance (though one procedure had been written and rejected by PORC) or implementation was effected as of February 10
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-17-(3) Lack of control of a high radiation area as previously documented in Detail 6.b of this report was an uncorrec-ted audit finding for seven months.
The response to this Item of Noncompliance should detail the measures to be established to assure that corrective actions are completed in a timely manner (immediately when conditions warrant). Provisions for modifying completion dates when justified are appropriate to such measures.
7.
Records The inspector requested the records listed below to verify that the licensee's program for control, storage, retention and retrieval of records met the requirements of Criterion XVII of 10 CFR 50, Appendix B, the Technical Specifications, and AP-0221, " Quality Assurance Records."
a.
Records Selected (1) PORC Minutes.
(2) NSARC Minutes and Reports.
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(3) NRC Inspection Reports.
(4) Changes to Technical Specifications.
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Inservice Inspection.
(6) Maintenance Requests.
(7) Plant Design Changes.
(8) Engineering Design Changes.
(9) Plant Information Reports.
(10) Westboro NSD Directives.
(11) Nonconformance Reports.
(12) Special Tests.
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-18-(13) Plant Monthly Reports.
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(14) Semi-Annual Operating Report.
In each case, the record requested by the inspector was made'
available by the licensee.
The inspector had no further questions in the Records area.
8.
Safety-Related Materials A *eview of the list of safety-related items covered by the quality assurance program indicates that boric acid used in the reactor and safety systems and fuel oil used in the emergency diesels were not included. During a review of the controls applied to these items it was determined that all incoming ship =ents of boric acid are analyzed in accordance with procedure DP-9113, which appearei adequate to determine the acceptability of the material.
There is no procedure for analysis of the fuel oil (except for water content)
prior to unloading into the plant storage tanks.
Failure to designate the materials involved as safety-related makes
, inapplicable the administration controls which require establish-
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i ment, adherence to. and controlled modification of measures which determine the initial suirability for use of such materials.
This J
is contrary to 10 CFR 50 Anpendix B, Criterion II and the Opera-
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tional Quality Assurance M eual,Section V. item II requirements i
that the structures, systems and components to be covered by the l
quality assurance program be identified and that the quality assur-
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ance program provide control over activities affecting the quality
of the identified structures, systems and components to an extent I
consistent with their importance to safety.
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This is a Deficiency.
f 9.
Report 50-29/75-13 Detail 9 of the referenced report indicated that the completion /
issuance of a referenced Fire Fighting Procedure and the implemen-tation of training for that procedure was an Unresolved Item.
The required procedure, OP-3017, FIRE EMERGENCY, was approved / issued on February 12, 1976.
The training for plant personnel with respect-to fire fighting had been scheduled. This item is resolved.
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The licensee's response to the Item of Noncompliance set forth in J
Detail 3.a of the referenced report stated that procedure OP-3304 would be revised to require recording of the date of the oldest cannister on the inventory checklict.
The inspector reviewed the latest completed iraentory checklist and noted that the date of the oldest cannister was recorded.
Ilowever, 5-ocedure OP-3304 had not yet been revised to make the recording of this date a requirement.
This item will be reviewed during a subsequent inspection.
10. Engineering Drawing Control The inspector reviewed the engineering drawing control phase of the Quality Assurance Program with respect to the requirements of 10 CFR 50, Appendix B, Criterion VI and AP-0225, " Plant Drawings."
a.
Engineering brawings Selected Twenty safety-related drawings were randomly selected from the In Plant Index. The plant and corporate drawings were checked against the Index to determine that they were in agreement.
The review produced the following results.
Drawing Number and Plant Corp. Engineering Revi. tion From In Plant Index Revision No.
Revision No.
(1) 9699-FK-3A Sh. 1 Rev. 2
2 (2) 9699-FK-12A Rev. 6
6 (3) 9699-FP-1A Sh. Rev. 7
7 I
(4) 9699-FP-2A Sh. 1 Rev. 6
6 (5) 9699-FP-42D Sh. 4 Rev. 8
8 (6) 9699-FV-1A Rev. 5
5 l
(7) 9699-FV-1X Sh. 1 Rev. 5
5
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(8) 517F419 Rev. 5
Missing (9) 646J642 Rev. 8
Missing
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(10) 7246D25 Rev. 3
Missing (11) 517F502 Rev. 12
Missing (12) 549D214 Rev. 10
Missing (13) 549D299 Rev. 8
Missing (14) 673C331 Rev. 4
Missing (15) YE-D-31 Orig.
Orig.
Orig.
(16) YM-B-21 Rev. 1 Missing
(17) n!-ll-9 Rev. 2
2
(18) YM-B-10 Orig.
Missing Orig.
(19) U!-II-7 Rev. 1
1 (20) YM-it-10 Rev. 2
2
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Contrary to 10 CFR 50, Criterion VI requirement that drawings are distributed to and used at the location where the pre-scribed activity is performed, of the twenty drawings randomly selected for review, ten percent were missing at the site and thirty-five percent were missing at corporate headquarters.
The. licensee stated that drawings are supplied to corporate engineering f rom the plant on an as-needed basis, thereby eliminating the need for maintaining complete engineering drawing files at corporate engineering.
The licensee stated that the two missing plant drawings would be replaced within
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ten days of this inspection.
In addition, the licensee stated that the In Plant Index would be reviewed and any missing plant drawings would be replaced by August 1, 1976.
Time limitations prevented detailed review of the procedural con-trols established over drawings.
This area is Unresolved and will be reinspected.
11.
NSARC and PORC Reviews
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a.
The Nuclear Safety Audit and Review Committee (NSARC) and Plant Operations Review Committee (PORC) review functions wore reviewed to verify that:
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(1) All NSARC and PORC meetings convened during.1975 were held at the frequency required by the Technical Spec-ifications; U
(2) ~The meeting membership of the NSARC and PORC meetings convened during 1975 satisfied the quorum requirements of the Technical Specifications; (3) Proposed tests and experiments which affect nuclear safety or whose performance may constitute an unreviewed safety question were reviewed as required by the Techni-cal Specifications;
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(4) Noncompliances with Technical Specifications or rules and regulations were reviewed as required by the Technical Specifications; (5) Proposed changes to Technical Specifications were reviewed as required by the Technical Specifications.
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The review included discussions with licensee personnel and review of Technical Specifications and the following plant procedures and records.
(1) Operational Quality Assurance Manual.
(2) NSARC Charter, 4/18/75.
(3) NSARC Meeting Minutes 75-1-S through 75-17-S of 1/13/75 through 12/23/75.
(4) AP-0003, Plant Operations Review Committee, dated 2/11/74.
(5)
Semi-Annual Reports for the periods 7/1/74-12/31/74 and 1/1/75-6/30/75.
(6) Technical Specification Proposed Changes 125, 130 and 134.
c.
The inspector identified no discrepancies in this area.
12.
Nonroutine Event Review
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a.
The licensee's practices and requirements relating to non-routine events were reviewed to verify that responsibilities i
have been assigned or delegated for the following.
(1) Prompt review and evaluation of off-normal operating events to assure identification of safety related events.
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(2)
Prompt review of planned and unplanned maintenance and testing activities to assure identification of noncompli-ance with the limiting condition for operation require-ments of the Technical Specifications.
(3)
Reporting safety-related operating events internally and to the NRC.
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(4) Assuring completion of corrective actions relating to safety-related operating events.
The review 'ncluded discussions with licensee personnel and b.
i review of Technical Specifications and the-following plant procedures.
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l Operational Quality Assurance Manua. Rev. 3, dated (1)
AP-0002, Abnormal Occurrence Reports, 10/9/75 Rev. 2, dated 8/15/75 (2)
AP-0004, Plant Information Reports,ancies in non-event (3)
The inspector identified no discrep c.
handling.
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