IR 05000261/1981005
| ML20054C506 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 08/18/1981 |
| From: | Choules N, Gody A, Hunter D, Jablonski F, Napuda G, Napudaa G, Partlow J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE) |
| To: | |
| Shared Package | |
| ML20054C499 | List: |
| References | |
| 50-261-81-05-01, 50-261-81-5-1, NUDOCS 8204210213 | |
| Preceding documents: |
|
| Download: ML20054C506 (32) | |
Text
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Insoection Summary:
Insoection on June 22-July 2 and July 13-17, 1981 (Report No. 50-261/81-05(PAS)
Areas Inspected:
A special, announced inspection was performed of the licer.see's management controls over selected if censed activities.
The inspection (by five NRC inspector,) involved 507 inspector-hours onsite and at the corporate office.
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Results:
The licensee's management controls for'eight areas were reviewed, and conclusions were drawn in each area based on the observations presented in this report.
The conclusions are presented as Above Average, Average, or Below Average as follows:
Section 2, Licensed Activities (Operations) - Average Section 3, Committee Activities - Average Section 4, Design Changes and Modifications - Average Section 5, Maintenance - Average Section 6, Quality Assurance Audits - Average Section 7, Corrective Action Systems - Below Average Section 8, Training - Average Section 9, Procurement - Average Additionally, a number of observations were presented to the Senior Resident Inspector as potential enforcement findings for followup as appropriate.
These observations were also discussed with the licensee during meetings on
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June 26, July 2, and July 17, 1981.
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TABLE OF CONTENTS PAGE TOPIC
Inspection Scope and Objectives, Section 1
Licensed Activities (Operations), Section 2
Committee Activities, Section 3
Design Changes and Modifications, Section 4
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Maintenance, Section 5
Quality Assurance Audits, Section 6
Corrective Action Systems, Section 7 i
Training, Section 8
Procurement, Section 9
Exit Interview, Section 10
Attachment A, Persons Contacted and Documents Reviewed
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DETAILS 1.
Inspection Scope and Objectives The objective of the inspection was to determine how the licensee performs licensed activities; the results will provide input to the NRC evaluation of licensees from a national perspective.
The inspection effort covered licensed activities in selected functional areas.
In each of the functional areas, the inspectors reviewed written policies, procedures, and instructions; interviewed selected personnel; observed operations; and reviewed selected records and documents to determine whether:
a.
The licensee had established written policies, procedures, or instructions to provide management controls in the subject area; b.
The policies, procedures, and instructions were adequate to control the activities in the subject areas; The licensee personnel who had responsibilities in the subject areas c.
were adequately trained and retrained to perform their re.sponsibilities, d.
The individuals assigned responsibilities in the subject area understood their responsibilities; and The requirements of the subject area had been implemented and e.
appropriately documented in accordance with management policy.
The specific findings in each area are presented as observations which are inspection findings that the inspectors believe to be of sufficient-ignificance to be considered in the subsequent evaluation of the licensee's performance.
The observations include perceived strengths and
';eaknesses in the licensee's management controls which may not have
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specific regulatory requirements or guidance.
These observations have been classified as weaknesses or strengths.
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Where appearing, these are identified in the report by a (W) or (5).
The observations provide the bases for drawing conclusions in each inspected functional area.
The conclusions are presented as above average, average, or below average and represent the team's evaluation of the licensee's management controls in the functional area.
Some observa'tions identified as weaknesses may be potential enforcement findings.'
These observations were discussed with the licensee and were presented to the Region II Resident Inspector.
The followup of these items will be by the IE Region II Office.
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2.
Licensed Activities (Ocerations)
The objective of this portion of the inspection was to evaluate the adequacy.of management controls over licensed activities (operations).
a.
Observations The following observations include perceived strengths and weaknesses in the licensee's management controls which may not have specific regulatory requirements, but will provide the basis for subsequent performance evaluations.
(1) The corporate and plant organizations involved in operations appeared to be effective.
The corporate and plant staffs were qualified and experienced.
The staff turnover rate was low and the overall attitude of the personnel contacted was good.
(S)
, Document review and interviews revealed that the Vice Pres-(2)
ident, Nuclear Safety and Research and the Corporate Nuclear Safety Section responsibilities and authorities were not fully described in the Corporate Quality Assurance Program (CQAP),
Section 2, Organization.
In addition, the CP&L organization, as established and implemented, did not conform with the TS.
(W)
TS 6.2 states that the offsite and onsite organizations shall The be as shown on Figures 6.2-1 and 6.2-2, respectively.
licensee was functioning under the review requirements of the approved TS while staffing to fully implement the review requirements of the Corporate Quality Assurance Program, the implementing procedures, and the proposed TS change submitted to NRC on July 10, 1981.
i This observation was discussed with the licensee and was presented to the NRC Resident Inspector as a potential l
enforcement finding.
Neither the plant administrative and implementing procedures (3)
nor the QA/QC implementing procedures established an i'ndependent inspection (monitoring) program concerning certain operations
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The QA/QC program included inspection of mechanical, activities.
electrical, and special process activities, which was considered a strong point; however, other quality activities were not Not inspected were areas such as
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adequately inspected.
clearance activities, operation work procedure (OWP)
periodic test program activities, lubrication activities, and equipment rotation activities, and other safety-related
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activities performed by the operations staff.
(W)
Independent inspection of activities affecting quality is ANSI required by Criterion X of Appendix B to 10 CFR 50.
N18.7-1976, Section S.2.17, amplifies this requirement
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regarding work functions performed during normal plant operation, routine maintenance, and technical services.
In addition, the Corporate QA Program, Section 10.3.3.1; Appendix-I, item II.7.f; and Appendix I, items X.1 and X.2, required selected inspection of safety-related activities to verify quality.
l This observation was discussed with the licensee and was presented to the NRC Resident Inspector as a potential enforcement finding.
(4)
The program for the periodic re' view of procedures in the Plant Operating Manual (POM) was established;.however, the periodic review of procedures was specified at intervals up to five years for certain procedures in POM Volume I, Section 5.6.1.
(W)
Periodic review of procedures by an individual in the area affected by the procedure is required at least each two years by ANSI N18.7-1976, Section 5.2.15.
This observation was discussed with the licensee and was presented to the NRC Resident Inspector as a potential enforcement finding.
During the inspection, the licensee reviewed the periodic
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review requirements, issued a procedure change notice to revise the POM, and scheduled the completion of the required procedure reviews.
A licensee representative stated that the item had been issued as an action item for tracking purposes to ensure completion.
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(5)
Document review and interviews revealed that control room opera' ors were permitted to write equipment clearance l
activities and to specify equipment testing requirements in l
I certain cases.
Shift foreman review of the clearance activity and testing requirements specified by the control room operator was required only after the completion of the activity.
Inte r-views revealed that the Shift Foremen were generally aware of the activity and testing required; however, the procedures did not specify a supervisory review immediately prior to commencing the clearance activity.
(W)
(See Section 5, item a(2))
(6)
Document review and interviews with selected personnel regarding the qualification and experience level of the corporate and plant staffs revealed that the personnel were l
qualified and experienced.
The staffs were also knowledgeable of the operations program requirements concerning their areas l
i of responsibility.
(S)
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(7) Document review and interviews revealed that a written training and retraining program was not established for supervisory and management personnel in areas other than general employee training and management development training.
On-the-job training was provided but was not documented.
(W)
However, document review and interviews revealed that a number of the plant supervisory and management staff were currently main-taining a senior reactor operator license.
(8) The operations program appeared to be implemented as written with the following exceptions.
(W)
A review of the plant jumper and lifted lead log revealed that activities Nos. 691 and 692 (lifted leads) were in
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effect during the period of May 18, 1981, through June 9, j
1981, modifying auxiliary feedwater system (AFW) relay coils to allow opening of the steam generator blowdown valves with steam generator low water level conditions l
existing.
The activities were not considered safety-related and were not performed in accordance with procedural requirements including functional testing, independent verification, authorization, and approval.
l Following che reinstallation of the relay coil wires on June 9, 1981, the wires were not independently verified in l
place nor was a functional test performed to ascertain the closure of the steam generator blowdown valves as a result
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l of low water level conditions.
The control of safety-related jumper and lifted leads was l
established by the POM, Volume I, Section 11.11.
The procedure required classification, authorization, approval, (
l ins.tallation, removal, and independent verification of the I
activity.
TS 6.8.1 requires that written procedures be established and implemented....that meet or exceed the requirements of ANSI N18.7-1972, Section 5.1 and 5.3 and Appendix "A" to USNRC Regulatory Guide 1.33.
This observation was discussed with the 1-icensee and was presented to the NRC Resident Inspector as a potential enforcement finding.
This matter was reviewed with the licensee representative and the licensee stated at the management exit interview that the coil wires had subsequently been verified to be properly installed.
The program and implementing procedures for procedure distri-(9)
bution and change control were established; however, a review of the program implementation revealed that control room working files being utilized by the operations group were not current.
The review determined that the method for maintaining the files
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current was not effective.
The files contained working copies of periodic tests, operation work procedures, checksheets, valve lineups, and miscellaneous forms.
The following four OWPs currently maintained in the files were examples of pro-cedures noted to be obsolete.
(W)
DG-1,, Diesel Generator, revision 4, 6/1/78 (current
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procedure, revision 6, 6/1/81)
DG-2, Diesel Generator, revision 4, 6/1/78 (current
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procedure, revision 7, 6/2/81)
AFW 5, Auxiliary Feedwater, revision 4, 6/1/78 (current
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procedure, revision 6, 7/2/81)
AFW 6, Auxiliary Feedwater, revision 4, 6/1/78 (current
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procedure, revision 6, 7/2/81)
The latest DG-1 and DG-2 procedures established the independent verifications required during the performance of those activities.
This observation was discussed with the licensee and was presented to the NRC Resident Inspector as a potential enforcement finding.
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b.
Conclusions
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The licensee had established an effective organizational structure and corporate and administrative policies in the area of operations.
General job descriptions were provided.
Detailed responsibilities were provided in the implementing procedures.
The company had established a strong, experienced staff and the turnover rate appeared to be low.
The operations program appeared to be adequate with t'e exception of h
the described weaknesses which appear to be related to a need for better understanding of the quality assurance program by the staff.
The new QA program commitments which require review and changes to the implementing procedures further emphasizes the need for additional training of the entire staff regarding the QA program requirements.
Management controls in the area of licensed activities (operations)
were considered average.
3.
Committee Activities The objective of this portion of the inspection was to evaluate the adequacy of management controls over review activities performed by the onsite Plant Nuclear Safety Committee (PNSC) and the offsite Corporate i
Nuclear Safety Section (CNSS).
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a.
Observations The following observations include perceived strengths and
weaknesses in the licensee's management controls which may not have specific regulatory requirements, but will provide the basis for subsequent performance evaluations.
(1)
The corporate and plant organizations conducting review activities appeared to be effective.
The corporate and plant
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I staffs were qualified and experienced.
The staff turnover rate was low and the attitude of the review personnel contacted was
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good.
The licensee was functionin'g under the review require-ments of the approved Technical Specifications (TS) while l
staffing to fully implement the review requirements of the r
l Corporate Quality Assurance Program, the implementing pro-cedures, and the proposed TS change submitted to the NRC on
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f July 10,1981.
The proposed TS change included an onsite and offsite independent review function.
(S)
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l (2)
Document review and interviews revealed that the Vice President, l
Nuclear Safety and Research and the Corporate Nuclear Safety l
Section (CNSS) responsibilities and authorities were not fully described in the Corporate Quality Assurance Program (CQAP),
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Section 2, Organization. (See Section 2, item a(2)).
Addi-tionally, Nuclear Safety and Research Department directives (W)
The were not provided to specify the CNSS review program.
CNSS had prepared detailed written procedures to implement the review requirements of the TS, the newly revised CQAP, and the proposed TS.
(S)
(3) The program for independent review of changes to the facility Document and procedures as described ir. the FSAR was examined.
review and interviews revealt.d that CNSS independent review had been provided for those changes referred to the-group by the PNSC; however, the number of changes referred to CNSS by the PNSC was limited.
A review of the quarterly modification status report for January, February, and March,1981, revealed that a number of significant safety-related changes were not routed to the CNSS.
These modifications and procedure changes appeared to have changed the facility as described in the FSAR.
The following were only four examples of numerous changes not provided to the CNSS for independent review.
Additionally these changes vere not required to be reported to the NRC in the Annual Rep t. (W)
M-519 (R-2), Containment Vessel Extended Pressure Range
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M-472 (R-2), Degraded Grid Voltage and Emergency Power
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System l
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PCN-4551, Volume 10, PT 9.12c (New Periodic Test (PT)
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regarding surveillance of TS required fire barrier penetration.)
PCN-4638, Special Procedure, SP-295 (Pumping Wasta holdup
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Tank (WHUT) to waste condensate tanks.)
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Independent review of certain facility changes, procedures, and tests and experiments is required by TS 6.5.3.3.a and ANSI N18.7-1976, Section 4.3.4, to verify that such changes, tests, or experiments did not involve a TS change or an unreviewed safety question.
Changes to the facility as described in the FSAR include those significant changes that add features to the facility as des-cribed in the original FSAR.
As noted, a number of changes had not been provided to the CNSS nor subsequently reported to the NRC due to the licensee's interpretation as to wnat enanges constituted a change to the facility as described in the FSAR.
This observation was discussed with the licensee and was presented to the NRC Resident Inspector as a potential enforcement finding.
(4)
Document review and interviews with selected personnel regarding the qualifications and experience level of the corporate and plant staffs revealed that the personnel were well qualified and experienced.
The staffs were also knowledgeable of the review function requirements concerning their areas of respon-sibility.
(S)
However, formal written training and retraining programs were not established for supervisory and management members of the CNSS and PNSC. On-the-job training was provided but was not documented.
b.
Conclusions
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The licensee had provided an effective organizational structure and adequate administrative procedures in the areas of onsite committee and offsite review functions.
General job descriptions were provided.
Detailed responsibilities were provided in the implementing proca-dures.
The general responsibilities of the Nuclear Safety and Research Department were not adequately addressed in the CQAP.
The company had established a strong, experienced review staff and the turnover rate appeared to be low.
The licensee was in the process of staffing the onsite review function of the CNSS to meet the proposed TS organization requirements.
The review program appeared to be adequate with the exception of the weaknesses noted.
Management controls in the area of committee review activities were considered average.
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4.
Design Chances and Modifications The objective of this portion of the inspection was to evaluate the adequacy of management controls associated with engineering, design changes, and modifications.
a.
Observations
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The following observations include the perceived strength and weak-nesses in the licensee's management controls which may not have specific regulatory requirements, but-will provide the basis for subsequent performance evaluations.
(1) The corporate design and design change program as defined in the Nuclear Plant Engineering Department Procedures Manual, Engineering Support Section Guides and other procedures appeared to be a sound and effective program.
(S)
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However, some weaknesses were observed in the plant design change program. Volume 20 of the Plant Operating Manual (POM)
contained the engineering procedures which specified the plant design change program.
ENG-5, Plant Design Control, revision 0, was the basic procedure used to process design changes (modifications).
The procedure did not include certain requirements as follows:__(W)
Design analysis, design inputs, and design verifications were not fully addressed per ANSI N45.2.11-1974 which
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specifies that certain requirements regarding the above be included.
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The procedure did not adequately address use and docu-mentation of alternate calculations wher. required and used
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in the preparation of design changes.
The procedure did not adequately address the turnover of
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modified or new equipment resulting from a design change
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to the operations department.
Section 11 of the Corporate Quality Assurance Program (CQAP) specified certain require-
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ments for turnover but these specific requirements were not included in the procedure.
Interviews revealed that the licensee was aware of a number of the above weaknesses and had hired a contractor to prepare new design change control procedures.
They expected to have these procedures in place by August 31, 1981.
Interviews and a review of procedures revealed that following (2)
completion of a design change, the drawing control procedures
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616 not ensure that approoriate personnel were provided with
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updated drawings at the time the equipment was declared opera-tional.
Interviews revealed there was at least a two week delay in providing marked-up drawings to the appropriate
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personnel.
(W)
The licensee had recognized and was planning to correct the above concern.
Interviews and a review of QA audit records showed that many of (3)
the plant drawings were not up to date.
The plant drawing file was not always updated following a design change.
(W)
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The licensee had identified this problem and was in the process of updating drawings.
The Engineering Support Nuclear Plant Section of the corporate'
(4)
Nuclear Plant Engineering Department performed design changes requested by the plant.
The Manager, Engineering Support provided weekly and monthly status reports on design changes and other engineering work to the Vice President, Nuclear Plant Engineering Department.
The Vice President then provi< fed monthly status reports to his management regarding his The Manager, Engineering Support also department activities.
provided a monthly status report to the Plant Manager regarding design changes anc other engineering work requested by the plant.
These reports provided an effective tool to keep management informed of the status of design changes and engineering activities being performed by the Nuclear Plant Engineering Department.
(S)
Both plant and corporate personnel were knowledgeable of the
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(5)
design change program, and were aware of procedural and regulatory requirements.
Plant and corporate person..el morale Personnel appeared to be high and personnel turnover low.
involved in the design change program appeared to be well qualified both academically and by experience.
(S)
A formal program did not exist to ensure that appropriate (6)
personnel were trained in a timely manner regarding newly installed design changes.
Training provided was accomplished on an informal basis.
(W)
A review of selected design changes indicated that the program (7)
had been adequately implemented.
A weakness observed in a number of design change packages was that the drawings to be revised were not positively identified. (W)
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b.
Conclusions The licensee had established a program to control safety related design changes and modifications.
The program appeared to have been adequately implemented.
The corporate program appeared to be well founded and based on sound engineering practices.
Corporate and plant personnel involved in design changes appeared to be well qualified and aware of the program and its requirements.' The plant's program appeared to be adequate with the exception of noted
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weaknesses.
The licensee was in the process of upgrading the design change The current corporate program procedures had been issued program.
in February and revised in April of this year.
The current plant
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The program procedures had been issued in late 1980 and early 1981.
licensee had determined that there were deficiencies in his program and had contracted with a vendor to prepare new program procedures.
The licensee was closely supervising the preparation of these pro-cedures.
The upgrading of the program that has occurred and is
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planned should result in improvement in the licensee's design change program.
Management controls associated with safety related design changes and modifications were considered average.
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5.
Maintenance The objective of this portion of the inspection was to evaluate the adequacy of the licensee's management controls associated with corrective and preventive maintenance activities.
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a.
Observations The following observations include the perceived strengths and weaknesses in the licensee's management controls which may not have specific regulatory requirements, but will provide the basis for subsequent performance evaluations.
(1)
Corrective and preventive maintenance activities were controlled and authorized by Maintenance Instructions (mis):
MI-1, Mainten-ance Administration Program, revision 2; MI-2, Maintenance Work Procedures, revision 0; and MI-3, Preventive Maintenance Program, revision O.
Specific corrective and preventive maintenance activities were authorized through Work Requests (WRs) in accordance with MI-1 and 2.
A review of MI-1 and 2 showed weaknesses as follows:
(W)
The interface between maintenance mechanics and operations personnel for taking equipment out of service and returning
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the equipment to service was not clearly defined in MI-2.
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Guidance was not provided for preparing corrective main-
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tenance procedures such as the information contained in MI-3 for preparation of preventive maintenance procedures.
There was no specific requirement for the maintenance
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foreman to ensure the work specified on a work request was accomplished by qualified personnel.
There was no requirement for a general fire hazards review
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of each work request activity.
Instructions for trending were limited.
Only a review of
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current records prior to permanent transfer to the QA vault was required.
There was no requirement to review historical records.
In addition, safety-related equipment failures were not included in a formal trending program.
If maintenance to be performed exceeded the scope of the
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original work request, a mechanic was allowed to change the work request with only QA approval.
The approval of the maintenance foreman who originally approved the work request was not required.
QA review of work requests before and after completion of
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the work was required; however, guidance was not provided on the specific QA requirements to be included in QA reviews.
At the time of this inspection the licensee was in the process of revising MI-1 and MI-2.
(2) Control of the removal of equipment from service and the return to service during maintenance and testing activities was estab-lished by POM, Volume I, Section 11.6V, local clearance and test request (LCTR).
A control room operator filled out LCTR forms to specify tag outs, valve lineups, and required testing to remove equipment from and return to service.
The applicable procedure and the LCTR form did not require that a responsible individual perform a review to evaluate the adequacy of the activity and ensure that the shift foreman was kept fully informed of s_vstem status.
In addition, when an operations work procedure was specified by the control room operator, a responsible individual did not verify that the correct procedure had been specified.
(W)
The only time that a supervisor was required by procedure to review the proceedings described above and document this review was after the equipment had been tested prior to returning the equipment to service.
Interviews with shift foremen indicated they were generally aware and involved in the removal from and returning equipment to service even though documentation of this was not required by procedure.
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(3)
A review of instrument calibration data sheets showed there was, no acceptance criteria specified on the data sheets.
This lack of acceptance criteria increased the ootential for errors.
(W)
(4)
Interviews with plant maintenance personnel indicated they were knowledgeable of maintenance procedures and familiar with the work request system.
Morale appeared to be high and personnel turnover low.
Maintenance personnel appeared to be well qualified and capable of performing their assigned duties. (S)
(5)
Interviews and a review of training records and procedures showed that some training to maintain proficiency had been accomplished for plant maintenance personnel.
However, a formal technical and non-technical retraining program with defined schedules, goals, and objectives had not been developed at the plant level for maintenance personnel. (W)
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b.
Conclusions The licensee had established a program to control safety-related maintenance activities.
The program appeared to have been adequately implemented with the exception of the noted weaknesses.
Personnel involved in the maintenance program appeared to be well qualified and knowledgeable of procedures and the wor'k request system.
The licensee had expended considerable effort upgrading the mainten-ance program during the past 18 months.
Most of the program proced-ures.had either been revised or newly issued during this time.
The licensee had recently implemented an integrated maintenance program.
The purpose of this program was to' provide increased planning of maintenance activities, to utilize maintenance personnel more effec-tively, and to establish a means of collecting statistical data to accomplish these goals.
As indicated above, there were still pro-cedural weaknesses in the program.
The licensee had recognized a number of these weaknesses and was in the process of upgrading the program procedures.
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Management controls associated with the safety related maintenance program were censidered average.
6.
Quality Assurance Audits The objective of this portion of the inspection was to determine the adequacy of the licensee's management controls associated with quality assurance audit activities.
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Observations a.
The following observations include perceived strengths and weaknesses
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in the licensee's management controls which may not have specific regulatory requirements, but will provide the basis for subsequent performance evaluations.
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(1) The licensee's program for QA audits was described in the j
attachment to CP&L's letter to NRC dated March 18, 1981.
The 1etter described the licensee's recent reorganization and the establishment of the Corporate Quality Assurance Department.
Further description of the audit program was provided in
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Section 6.5.3 of the recently submitted revision to the TS.
The Corporate QA Program policy statement, signed by the Senior Executive Vice President - Chief Operating Officer, assigned audit functions to the Corporate QA Department.
Commitments
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and exceptions to codes, standards, and guides were also delineated.
Operationa'l QA audit responsibilities were divided into a Corporate Performance Evaluation Unit and a Site Surveillance function.
The Performance Evaluation Unit was responsible for conducting independent corporate audits to evaluate the effec-tiveness of the QA program for CP&L's operating plants, plants under construction, and corporate engineering and procurement activities.
Corporate implementing audit procedure CQAD-1, Corporate and ASME QA Audits, revision 1, provided guidance in the preparation and use of checklists; the procedure met the requirements of ANSI N18.7 and ANSI N45.2.12.
All corporate audits were forwarded to the Corporate Nuclear Safety Section for review of significant concerns which may have been identified.
The Director, Corporate Health Physics was responsible for performance of an independent overall review of corporate QA audit activities.
(S)
(2) The Site Surveillance function was controlled by a series of procedures which were part of the Site QA/QC Control Unit Manual including QAP-101, Preparation and Approval of QA and QC Procedures, revision 0, and QAP-201, Surveillance Program, revision O.
The following procedural weaknesses were noted:
(W)
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l The site QA/QC Control Unit Manual lacked a policy
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statement and was not reviewed and approved by the Corporate QA Manager.
The requirement to review site QA procedures every two
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years did not include a periodic review for changes to regulatory requirements, commitments, codes, standa-ds,No corporate procedures, and other pertinent documents.
written guidance for the scope of the review to be per-
formed was provided.
The Surveillance Program did not require direct observ-ations to be made of plant activities such as security,
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operations, health physics, and calibrations.
Surveillance Program minimum requirements addressing preparation, conduct, documentation, and assessment of
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plant operational activities were not included.
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The Surveillance Program did not include requirements for
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use of personnel with specialized expertise such as licensed-reactor operators and engineers to augment the surveillance function.
Verification of corrective action implementation in the
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various operating plant departments was not included in the QA surveillance schedule.
C'iteria had not been established to evaluate the effectiveness (3)
r of Corporate QA audits or Site Surveys by trending potentially generic or repetitive problems identified by the audit process.
The Corporate Principal QA Specialist of the Performance Evalu-ation Unit was mandated by the Corporate QA Manager to establish criteria against which QA functions would be evaluated, including a trend analysis by January, 1982.
Such a mandate was not given to the Site QA Director. (W)
(4) A comprehensive cross reference or matrix of department procedures, instructions, technical specifications, and QA program requirements had not been established by the Corporate Audit or Site Surveillance groups.
The existing audit and survey planning schedules did not provide assurance that required plant operational activities would be verified by audit during the biennial period specified in ANSI N18.7.
(W)
(5)
Communications were established between the Corporate Manager of Operations QA/QC and the Site Director of QA/QC that included weekly and monthly QA activity reports.
However, the reports reviewed did not.contain information on identified problems, corrective actions, and status of the effectiveness of the site QA/QC program.
(W)
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(6)
Site Surveillance and Corporate Audit personnel were know-ledgeable and aware of the responsibilities delineated in their job descriptions and individual QA program requirements.
Both groups displayed a positive attitude and morale was high.
It was the consensus of nearly every person interviewed that QA had a positive impact on the activities audited.
The corporate audit group was held in high esteem by personnel audited by them.
(S)
(7)
Training of auditors and surveillance personnel was in most cases limited to self study of codes and standards and on-the-job training.
Corporate Audit personnel had not been utilitized to train and indoctrinate Site Surveil-lance personnel.
Only lead auditors received out-of-company formalized training and formal training in codes, standards, regulations, corporate QA program, auditing techniques, and audit planning.
(W)
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(8)
Implementation of both the Corporate Audit and Site Surveil-lance programs had not progressed to a point for objective comment because of the recent reorganization.
There appeared to be the potential for a viable Site Surveillance and Corporate Audit program based upon review of past audit results and personnel qualification.
Previous audits were performed by many of the same personnel still associated with the reorganized groups.
The strongest area in both the Corporate Audit and Site Surveil-lance groups was personnel qualification.
In almost every case there was evidence of extensive education and QA/QC experience.
(S b.
Conclusions The QA audit program appeared fundamentally sound, However, several weaknesses were identified.
The new QA audit program implementation had not progressed sufficiently for objective comment.
The review of past audits and the well qualified staff indicated potential for a continuing viable QA audit
and surveillance program.
Management controls associated with the QA audit program were considered average.
___
7.
Corrective Action Systems The objective of this portion of the inspection was to determine the adequacy of the licensee's management controls over the corrective action system.
.
a.
Observation The following observations include the. perceived strengths and weaknesses in the licensee's management controls which may not have specific regulatory requirements, but will provide.the basis for subsequent performance evaluations.
-
(1) The corrective action system was described in the attachment to CP&L's letter to NRC, March 18, 1981, and implementing corporate and site procedures QAP 15 (Nonconformance Control and Corrective Action, revision 0), and QAP 204.{Nonconformance Control, revision 0).
Conditions requiring corrective action were further described in TS Section 6, Corporate QA Program procedures, Maintenance Instructions, and Administrative Instructions.
The program was fragmented and the following weaknesses were observed:
(W)
Training in corrective action was not specifically
.
provided to either corporate or site personnel.
i
.
. -. -.. _ _ _. _ - -
,-
-
.,
,
.,.,...,-___.m_.n._
_
,, _ _. - _, _ _,
_ _. _ _, _
--
.
.
-
l l
.
.
The implementing corporate and site procedures for noncon-
.
'
formance control and corrective action were not designed l
for interdisciplinary use but only by the QA organizations.
l The procedures did not appear to meet the intent of the attachment to CP&L's March 18, 1981, letter to the NRC t
which implied a corporate wide system of effective
'
corrective action.
The nonconformance report had limited application.
Conditions
.
l adverse to quality or safety occurring in areas such as operations, security, engineering, plant modifications,
!
l housekeeping, and training were not routinely identified l
on the nonconformance report.
There was no single person, group, or method of tracking
.
all identified problems ia order to evaluate, trend,
!
analyze, and ensure that measures had been taken to reduce
!
or eliminats. recurrence of the problems.
l (2) Awareness of the corrective action program was limited to areas
!
where items of noncompliance, reportable occurrences, or corpor-l ate audit findings were identified.
Interviews revealed that the personnel awareness of the corrective action program in tne j
areas of health physics, security, fire protection, maintenance, and operations was limited.
(W)
(3) Written management controls had not been established for distribution, review, and resolution of problems identified in t
Corporate-audit findings, NRC inspection reports, and IE Bulletins and Circulars.
(W) A follow-up action item list was maintained informally by the Site Surveillance group and appeared to be adequate.
Open items were tracked, followed, and closed.
The licensee planned to implement a formalized program by August 1981.
.
(4)
Implementation of the corrective action program was displayed on graphs which indicated numbers of reportable occurrences, items of noncompliance, audit findings, surveillances, and Corporate Nuclear Safety items.
Cause codes, such as operator error, procedure weakness, and material discrepancy were included for reportable occurrences only.
Except for a plot of numbers from the data accumulated, no apparent analysis of the defi-ciencies had been performed.
A trend analysis program had not been developed for review of audit findings, surveillance reports, nonconformance reports, maintenance work requests, or other types of difficiency reports to determine if generic, repetitive or impending problems existed with management, personnel, materials, procedures, systems, or components.
(W)
(5) A program was not established to assimilate and analyze identified conditions adverse to quality such as personnel
!
i
. -.,
. -, - -
_ _ _ _
. -.
. _ _ - _
_
..
.
.
errors, procedure deficiencies, equipment malfunctions, significant operating events, and event reports for adverse trends.
Additionally, conditions adverse to quality which were documented in logs, data sheets, and checklists were not routinely accumulated and analyzed for adverse trends.
(W)
(6) The establishment in August, 1980, of the Site Human Factors Evaluation was a unique method of corrective action.
A human factors screening and evaluation was required is be performed for all job related accidents, forced unit outages, noncom-pliances, reportable occurrences, and procedural violations.
Deficiencies in training, procedures, communications, design, man / machine interface, and judgement were areas which the licensee had recognized as possibly requiring actions to correct and preclude problems.
While review of the 1981 file on human factors evaluations revealed that several reportable occurrences, noncompliances, and corporate audit findings had not been evaluated for human factors, this system appeared to be one potentially valuable input to a corrective action program.
(S)
'
b.
Conclusions
.The corrective action program appeared fragmented and not well defined.
Awareness and training were weak.
There was no overall program for identifying and tracking problems to ensure evaluation and closure.
The most significant weakness was the failure to develop a comprehensive trend analysis system.
The human factors screening and evaluation system should prove to be one viable method of corrective action when fully implemented.
Management controls associated with the corrective action program were considered below average.
.
8.
Training The objective of this portion of the inspection was to evaluate the adequacy of management controls in the area of training.
Other sections
,
i of this report make specific comments on certain aspects of training.
a.
Observations The following observations include perceived strengths and weak-nesses in the licensee's management controls which may not have specific regulatory requirements, but will provide the basis for subsequent performance evaluations.
.. -
j
-
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Non-Licensed Training (1) A comprehensive training program had been recently established for craft and technical plant personnel such as auxiliary operators, mechanics, electricians, and I&C technicians.
The overall program was described in the Training Manual which provided the basic details on the program's structure.
Almost all training was to be given at the offsite Training Center (TC) which was under the direction of the Manager of Nuclear and Fossil Training who reported directly to the Vice President of Technical Services.
The TC staff, assisted by company and non-company personnel, assessed training needs, performed job analyses, and developed training presentation methods.
Interviews and reviews of selected training materials revealed that the methodology
~
used to analyze job tasks, structure courses into incremental modules, develop lesson plans, conduct post training critiques, and evaluate the program were founded on sound training principles.
(S)
(2) The craft and technician training courses were structured into a series of BEsic, Intermediate, and Advanced ~1evels.
A new employee was required to attend either the Basic course within 18 months or the Intermediate course within 18 to 24 months according to his level of experience.
A " top class journeyman" level individual was required to attend the Advanced course every two years.
Annual training schedules were developed and firm course dates were published semi-annually.
A long tarin schedule hzd also been developed that projected training needs and plans over several years.
(S)
Not all cr ft and technician training course material had been o
completely developed (e.g. incremental inedules and lesson plans).
The long range schedules indicated that some current craftsmen and technicians will not receive this training until 1983 and the training program may not be on a-routine schedule until 1984.
(W)
(3) The basic Auxiliary Operator (fossil plants AO) course was 22 weeks long.
Selected A0s then attended the Nuclear Auxiliary Operator (NAO) course which was 44 weeks long.
Examinations were periodically given throughout each cycle.
The Vice President of Technical Services received weekly reports on exam results and held discussions with the Manager of Training on student progress.
A Qualification Card system was used at the site to document on-the-job training and to initially certify an individual for a position.
Continuing training and re-training was also documented on this card.
(S)
i l
.
-
-
(4) The plant portion of the training program was described in several procedures.
These procedures did not clearly describe the periodic retraining to be provided to those auxiliary operators who remain in non-licensed operator positions.
(W)
(5) An onsite fire prevention and protection training course was established for the fire brigade and other plant personnel that was well defined in written procedures.
The course outline indicated that emphasis was placed on hands-on training.
Realistic plant fire drills were critiqued by both participants and observers who provided input to management for evaluation and program improvement.
Other courses included some often j
neglected areas such as Fire Watch Designee training.
(S)
i l
(6) Training Department personnel, including managers and supervisors, l
had a comprehensive understanding of the established program l
and appeared well qualified.
Instructors who were interviewed
!
appeared well qual-ified. The use of a management level Evaluation
!
and P?anning Committee, followup surveys, and monthly reports
!
to management on the progress and status of students appears to l
provide management with sufficient information to indicate whether the program is meeting its objectives so that necessary changes may be implemented.
(S)
.
l (7)
Interviews revealed that.the craft supervisors' understanding of the overall training program required improvement.
(W)
,
i l
(8) A written program for the training of corporate office personnel was established.
However, the goals, objectives, and schedules for the training of individuals were not included in the program.
The management of corporate training programs was not
,
centralized as were the programs for the Training Center. and I
plant.
(W)
(9)
Interviews and a review of procedures and training records i
showed that some training and retraining of both corporate and plant design change personnel had been accomplished on an informal basis.
General employee training was accomplished on a formal basis.
A formal technical and non-technical training and retraining program with schedules, goals, and objectives l
had not been developed by the plan and had only recently been developed by the corporate office.
(W)
l Licensed Training (1)
The program had been upgraded to meet post TMI licensing criteria and written courses were established for initial and refresher training.
Lesson plans and schedules were developed for refresher training given at the plant.
.
l
'
__
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-
-_
_
l r
.
.
The most recent licensed Reactor Operator (RO) candidate class had received five weeks of simulator training at the Training l
Canter and this had been expanded so that future classes will
'
receive eight weeks.
Instructors had taken certification courses and their periodic ratraining was planned.
The Senior Reactor Operator (SRO) instructors had received a requalification exam developed and administered by an outside consultant.
(S)
(2) A consultant had been used for technical subjects such as core physics, thermodynamics, and fluid flow.
A math course taught by college instructors was provided onsite for licensed and other interested employees with overtime pay for participants.
Another consultant had been scheduled to provide seven weeks of technical training to SR0s.
These examples indicated management support for licensed training.
(S)
b.
Conclusions
.
Non-Licensed Training The portions of the training program that were the responsibility of the Training Center were well defined in written procedures.
The courses and lesson plans that had been developed were above average and the physical facilities were good.
The instructors and managers
. of the program were aware of their responsibilities, displayed a knowledge of governing procedures, and appeared well qualified.
The implemented portions of the program were monitored by various levels of management.
The status,of implementation was the only deficiency that detracted from the program established at the Training Center.
The goals, objectives, and schedules concerning training for corporate individuals had not been established.
The corporate office training programs were not under central: zed management.
Periodic retraining for operators remaining in non-licensed positions was not well defined in procedures.
Pleqt craft supervisors' understanding of
>
the training program required improvement.
Licensed Training
,
The licensee had established a strong written program to provide initial l
training for license candidates.
The eight week simulator training for license candidates had not been implemented.
The written retraining l
program for licensed operators was established, implemented, and con-sidered adequate.
The seven weeks of technical training for SR0s by an i
outside consultant had not been implemented.
The lack of full imple-I mentation of the planned training detracted from an otherwise above average program.
l Management controls in the area of training were considered average.
,
p----
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-.,
-..
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. -
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9.
Procurement
,
The objective of this portion of the inspection was to evaluate the adequacy of the licensee's management controls associated with the pro-curement of materials and services important to safety.
a.
Observations The following observations include the perceived strengths and weaknesses in the. licensee's management controls which may not have specific regulatory requirements, but will provide the basis for subsequent performance evaluations.
(1) Corporate office purchasing activities were described in a comprehensive Corporate Purchasing Procedures Manual.
An interview with the Manager of Purchasing (MP) indicated that there was an ongoing effort aimed at further improving the purchasing function.
The MP and his staff analyzed the purchasing function and categorized the activities into approximately 24 elements.
Those elements which were determined to be in need of attention by the MP and his staff were assigned as tasks to various staff members.
The MP closely tracked the progress and results of each assigned task.
(S)
(2)
Purchasing, receipt inspection, storage, and other procurement activities were addressed in a number of Construction Department, Plant, and QA procedures.
A review of these procedures and practices identified the following deficiencies.
(W)
i The plant procedures permitted non-technical personnel to
.
initiate and process purchase requisitions for off-the-shelf stock items by identifying tha item with a.part number and referencing a previous purchase order for the same item.
The only requirement placed on the vendor was to provide a l
Certificate of Conformance stating that the part was the same as supplied on the referenced previous purchase order.
There was no requirement for a review of the purchase requisition by engineering or other technical
-
personnel to assure that a given item had not been affected by new technical, regulatory, or other require-
!
l ments.
Plant and QA procedures require a purchase requisition review by the initiator's supervisor and a QA technician.
.
These procedures provided only guidance on what information should appear on a purchase requisition but did not describe l
the specific requirements that purchase requisition review
'
should accomplish.
These procedures did not clearly define the method for verifying the validity of vendors'
Certificates of Conformance.
.
--
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.
,
.
.
Routine receipt inspection of off-the-shelf stock items
.
consisted of an item identification and condition check.
The inspection did not. require a technical review by a cognizent person to verify that the item received was the l
same as the original item.
This review was not required-y the purchase order or the receipt inspection checksheet.
It was noted that subsequently a limited functional test was performed on the item.
(3) A tour of storage facilities identified a general shortage of indoor storage space and the following deficiencies.
(W)
There was no evidence that electric motors had received
.
insulation resistance testing at receipt.
On hold material was so identified but was stored among
.
acceptable items on what appeared to be a space available l
basis.
'
.
Pallets of safety-related material were stored in many of
.
the aisles between storage racks that contained nonsafety-related equipment.
Chemicals, reagents, and other such materials were stored
.
in an unventilated,. unheated storage shed.
There was no preventive maintenance schedule for either
.
insulation testing of electric motors or shaft rotation of appl.icable equipment.
A 300 hp Service Water Pump Motor was stored in a building
.
that had no temperature controls.
The above examples were discussed with the licensee and presented to the Resident Inspector as a potential enforcement finding.
t I
The licensee immediately inventoried the in-stock electric motors and.a memorandum (July 7, 1981) was sent to Mechanic and I&C foremen asking for evaluations as to the type of preventive maintenance these motors required and the scheduling of that maintenance.
The licensee had recognized the potential problem of inadequate storage space and a proposal for the construction of a new l
warehouse was being prepared for submittal to senior management.
(4)
A number of items subject to shelf life were not included in the shelf life control system.
It was determined these items had been purchased prior to the incorporation of shelf life provisions into existing procedures.
(W)
L
s
i
,
-
The licensee initiated iamediate action and inventoried all shelf life type items.
Those items subject to shelf life and not in the contiol system were placed on a list that the inspector reviewed on July 14, 1981.
Licensee management stated that this list will be sent to the engineering department for evaluation of the items and appror?iate action would be taken.
(5)
It was obse'rved that in spite of somewhat crowded conditions the warehouse personnal generally maintained good practices with respect to housekeeping, stacking and placing items, identification of items and locations, access control, and prohibited activities (i.e., eating and smoking).
Persons encountered during tours and examinations of warehouse facilities displayed a positive attitude toward their work.
(S)
(6)
Corporate management personnel were knowledgeable of and understood the procurement program and were aware of their responsibilities.
Plant supervision and employees were knowledgeable of procedure content and requirements.
(S)
b.
Conclusions The licensee had established a written program and implementing procedures to control procurement activities.
These documents, with noted exceptions, appeared adequate to ensure conformance with overall requirements.
Personnel appeared knowledgeable, qualified, committed to the QA Program, and had a positive attitude toward their work.
A significant weakness was that the storage of material was not consistent with certain ANSI N45.2.2 and licensee QA Program j
requirements.
The licensee's responsiveness to the inspector's i
observations provided emphasis to the apparent commitment management and employees displayed toward the QA Program.
Managem#nt controls in the area of procurement were considered
l average.
10.
Management Exit Interview An exit meeting was conducted on July 17, 1981, at the Carolina Power and Light Company corporate office with the licensee representatives identified in Attachment A.
Additional meetings were held during the inspection on June 26 and July 2, 1971, with site and corporate management represent-atives.
The team leader discussed the scope of the inspection and stated that the inspection would continue with further in office data review and analysis by the team members and that the team would draw a conclusion for each functional area inspected and classify the management controls of that
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area as either Above Average, Average, or Below Average.
The issuance of an appraisal report containing observations classified as a strength or a weakness, the conclusions for each functional area, and an Executive Summary were oiscussed.
The licensee was informed that a written response would be requested for any areas designated as Below Average and for significant. weaknesses and that some.of the observations classified as a weakness are or may become " Potential Enforcement Findings" that would be presented to the Region II Resident Inspector for further disposition.
,
The team members presented their observations for each functional area.
The licensee was informed that the observations included the perceived strengths and weaknesses in their management control systems and that the, observations would be utilized in the evaluation of the licensee's programs.
.
m m
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,,,.--.w
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Attachment A 1.
Persons Contacted The following lists (by title) the individuals contacted.during this inspection.
The matrix to the right of the listing indicates the area for which that individual provided significant input.
The number at the top of each column refers to a specific section of the report.
Other individuals, including technical and administrative personnel, were also contacted during the inspection.
.
Title of Individual a.
Corporate Office
3'
5
7
9 Executive Vice President X
X Power Supply and Engineering & Construction
- + Senior Vice President Power Supply
-
- + Vice President Nuclear X
X X
.X X
Operations Vice President Corporate X
X X
X
Nuclear Safety and Research
+ Vice President Technical X
Services
- + Vice President Nuclear Plant X
X Engineering
- + Manager Corporate Quality X
X X
X X
X Assurance Manager Operations QA/QC
Manager Nuclear Training X
X
X
^+ Manager Materials Management Manager Corporate Nuclear X
X Safety
.
Manager Licensing & Permits X
X
- + Manager Purchasing X
X Manager Engineering Support X
X
'
l Nuclear Plants
- + Manager Engineering and X
X Construction QA/QC Manager Generation Operations X
and Maintenance Director Nuclear and Simulator X X
Training Director Corporate Health X
X Physics Director Craft Technical X
Training
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Attachment A
Corporate Office (Cont'd)
3_
g
{
7_
g
-
Director Curriculum X
Development Project Engineer Corporate X
Nuclear Safety Principal Engineer Corporate X
Nuclear Safety Principal Engineer Nuclear X
X Licensing Principal Engineer, X
In-Core Analysis Project Engineer, X
In-Core Analysis Principal Engineer, Mechanical X
X P*oject Engineer, Electrical X
X X
(2)
Project Engineer, Mechanical X
X X
(2)
Senior Engineer, Mechanical X
X X
X Senior QA Engineer X
X Engineer, Electrical X
+ Generation Maintenance Engineer X
Project Specialist, Planning X
X Maintenance Management Senior Specialist Regulatory X
X
Compliance Principal QA Specialist, X
X Performance and Evaluation Project QA Specialist, Training X
X and Procedures
.
QA Specialist X
X Administrative Assistant X
X
- + Assistant to V.P. Nuclear Operations
_
.
- + Assistant to Manager Corp. QA b.
Onsite
3_
g j
g
- +# Plant General Manager X
X X
X X
X X
Manager Technical Support X
X X
X X
X X
Manager Environmental and X
X X
X X
Radiation Control Manager of Operations and X
X X
X X
Maintenance Director QA/QC X
.JL X
X X
X X
X
- # Senior Specialist, Regulatory Compliance Operations Supervisor X
X X
X X
X X
Maintenance Supervisor X
X X
X
l
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Attachm:nt A
Onsite (Cont'd)
3
5
7
9 Engineering Supervisor X
X X
X X
X Environmental and Chemical X
X Supervisor Training Supervisor X
X X
X Administrative Supervisor X
X Project Engineer X
X X
X l
Operations Engineer X
X X
.
Maintenance Engineer X
X l
Plant Engineer (3)
X X
X X
X l
Principal Engineer, CNS X
Shift Foremca (2)~
X X
X X
X X
X X
I&C Foreman (2)
i Maintenance Foreman (2)
X X
X l
Stores Foreman X
X Senior Reactor Operator (2)
X X
X X
't X
Reactor Operator (2)
X X
X X
X X
Auxiliary Operator X
X t
i QA/QC Project Specialist X
X X
X QA/QC Senior Specialist X
X QA/QC Technician (3)
X X
X X
X Maintenance Planner X
Fire Proection Specialist X
Document Control Specialist X
X X
X Cost Control Specialist X
I&C Technician X
X X
Mechanic (2)
X X
X X
X Electrician X
X Maintenance Helper X
X Project Specialist - Operator X
Training Training Instructor (2)
X Construction Site X
Representative Storekeeper X
X
- Denotes those individuals who attended the exit interview on July 17, 1981.
+ Meeting with corporate management on July 2, 1981.
- Meeting with site management on June 26, 1981.
._
__
.
.
' l Attachment A
2.
Documents Reviewed The following is a detailed list of documents reviewed by the Performance l
Appraisal Team during the inspection.
a.
Technical Specifications (TS), Section 6, Administrative Controls.
b.
Final Safety Analysis Report (FSAR), Chapter 13, Conduct of Operations.
c.
Corporate Quality Assurance Program Manual.
l d.
Operational Quality Assurance Program.
.
l
'
e.
Carolina Power and Light (CP&L) Corporate and Plant Organization Charts.
.
f.
Letter to NRR (Eisenhut) f. rom CP&L (Utley) March 18, 1981 - Creation l
of a Corporate Quality Assurance Department.
g.
Nuclear Plant Engineering Department Procedures Manual.
i h.
Carolina Power and Light Training Manual.
i.
Plant Operating Manual l
Volume 1, Administrative Instructions
.
Volume 3, Operating Procedures
.
Volume 4, Overall Plant Operating Procedures
.
Volume 6, Emergency Instructions
.
Volume 10, Periodic Tests
.
Volume 12, Maintenance Instructions
.
Volume 19, Fire Protection Manual
.
Volume 20, Engineering Manual
.
Volume 21, Administrative Procedures
.
-
J.
Selected Corporate QA Program Procedures k.
Selected Site QA Procedures 1.
Corporate Nuclear Safety Guidelines, Procedures, and Instructions.
m.
Management Review of Independent Nucle r Safety Reviews and QA Audit Activities Procedure.
n.
Selected Nuclear Operations Department Procedures.
o.
Selected Operations Work Procedures.
.
- - - - - -
,
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-.
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Attachment A
p.
Selected Special Procedures.
i q.
Selected Power Plant Construction Department Procedures.
r.
Corporate Purchasing Procedures Manual.
s.
Selected Storeroom Procedures and Purchase Orders.
t.
Selected Temporary Repair Procedures, u.
CP&L Training Instructions
,
v.
Corporate QA Audit Schedule (1981).
w.
Corporate Audit and Site Surveillance Reports (1980 and 1981).
x.
Licensee Event Reports (1981).
y.
Site QA Weekly and Monthly Activity Reports (1981).
z.
Selected Nuclear Plant Engineering Department Monthly Status Reports.
aa.
Selected Engineering Support, Nuclear Plant Section, Weekly and Monthly Reports.
bb.
Selected Engineering Support, Nuclear Plant Section, H. B. Robinson Project Status Reports.
cc.
Corporate Nuclear Safety Section Reports (1380 and 1981).
dd.
Plant Operating Experience Reports.
ee.
Human Factors Reviews (1981).
ff.
Selected Correspondence concerning the proposed Independent Review Activities.
gg.
Proposed Technical Specifications Change, July 10, 1981.
,
l hh.
Selected Corporate and Plant Position Descriptions.
ii.
Selected Training Records of Corporate and Plant Personnel.
jj.
Selected Plant Nuclear Safety Committee Meeting Minutes (1980 and 1981).
kk.
Site Surveillance Schedule (1981).
-_
_
_
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.
.
.
.
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Attachment A
11.
Outstanding Action Item Status List.
mm.
Nuclear Plant Engineering Department's External Interface Document for H. B. Robinson Electric Plant, Unit 2, Modification Work.
nn.
Interface Document for Brunswick and Robinson, Plant Modification Work.
ca.
Plant Modification Status Log.
pp.
Selected Modification Packages.
,
qq.
Engineering Support, Nuclear Power Plant Section Guides.
rr.
Selected Instrument Calibration Records.
ss.
Modification and Procedure Change Sumcary (April 16, 1981).
tt.
Control Room Status Board.
Equipment Inoperable Record (Standing Order 11).
uu.
,
vv.
Minimum Equipment List (Standing Order 12).
j ww.
Completed Systems Checkoff Lists.
'
xx.
Standing Orders.
yy.
Operating Notes.
Iz.
Plant Operating Logs.
.
,
Plant Jumper Log.
,
.
Control Room Operator Log.
.
Shift Foreman Log
-
.
Equipment Clearance Log.
.
!
Shift Foreman Key Log.
.
l l
l l
,
-