IR 05000261/1982024

IE Insp Rept 50-261/82-24 on 820628-0702.No Noncompliance Noted.Major Areas Inspected:Previous Enforcement Matters, Organization & Administration,Housekeeping & Cleanliness, Test & Measurement Equipment Program & Calibr Program

ML20062H851
Person / Time
Site:	Robinson
Issue date:	07/20/1982
From:	Belisle G, Fredrickson P, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20062H838	List: IR 05000261/1982024 ML20062H835
References
50-261-82-24, NUDOCS 8208160186
Download: ML20062H851 (11)

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p0 MGo UPSITED STATES g , o,, NUCLEAR REGULATORY COMMISSION

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o REGION ll 1 5 y $ 101 M ARIETTA STREET, '

' * ATLANTA, GEORGIA 30303

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Report No. 50-261/82-24 Licensee: Carolina Power and Light Company

, 411 Fayetteville Street Raleigh, NC 27602 Facility Name: Robinson  ;

Docket No. 50-261 License No. DPR-23  ;

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Inspection at Robinson site near Hartsville, South Carolina [

Inspectors: _# 7 k+ A G. A. Bel n'16 ~ c>/ 'Date/ Signed

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$$A fh /

P. E. Fredrick n~' '~ '

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/Date / Signed Approved by: k [ '

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C. M. Upright, tion ef fate [igned

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Engineering Ir) ectio ranch Division of Erf ineering and Technical Programs

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SUMMARY

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Inspection on June 28 - July 2,1982 Areas Inspected This routine, unannounced inspection involved 64 inspector-hours on site in the

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areas of licensee action on previous enforcement matters, organization and administration, the housekeeping and cleanliness program, the test and measure-ment equipment program, calibration, surveillance, maintenance, the audit  ;

program, QA program review, design changes, the QA/QC administration program, and  !

licensee action on previously identified inspection findings.

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Results i No violations or deviations were identified in the 12 areas inspected.

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8200160186 820726 DRADOCK05000g

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! REPORT DETAILS

, Persons Contacted Licensee Employees i P. Abbott, Instrumentation & Control (I&C) Foreman D. Baur, Project QA/QC Specialist R. Chambers, Maintenance Supervisor

• J. Curley, Manager-Technical Support B. Flanagan, Project Engineer

• F. Gilman, Project Specialist - Regulatory Compliance J. Huntley, I&C Foreman

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P. Monroe, Stores Foreman i C. Moon, Associate Engineer C. Mosley, Manager-Operations QA/QC B. Murphy, Senior Engineer-Maintenance P. Odom, Senior Engineer-Maintenance [

• B. Snipes, Senior Specialist - Operator Training

• R. Starkey, Plant General Manager

R. Williamson, I&C Planner i

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• C. Wright, Specialist - Regulatory Compliance

• H. Young, Director - 00A/QC  ;

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Other licensee employees contacted included technicians, mechanics, and

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office personne NRC Resident Inspector

• S. Wei se

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• Attended exit interview  !

l Exit Interview [

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The inspection scope and findings were summarized on July 2, -1982, with :

those persons indicated in paragraph 1 above. The licensee acknowledged the l findings and requested additional clarification of Unresolved Item 81-25-0 t This matter was reviewed by telephone with the Plant General Manager :

following the inspection as discussed in paragraph 3 belo j Licensee Action on Previous Enforcement Matters (92701)

(Closed) Unresolved Item (261/79-19-06): Failure to Establish a Program for Trend Evaluation. .The inspector reviewed MPI-8, Trend Analyses, Revision 0, i

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and interviewed several maintenance engineers to verify the use of this i i procedure to detect and evaluate maintenance problem trend t

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(Closed) Unresolved Item (261/81-27-02): QA/QC Inspection Areas. The site surveillance program covers plant operations, maintenance, and other activities to ensure day-to-day compliance with site procedures and regulatory requirement (Closed) Unresolved Item (261/81-25-05): Requalification Trainin Following the previous inspection in this area, the NRR Operator Licensing Branch confirmed Region II positions regarding the adequacy of certain administrative controls used by licensees in their licensed operator training program. These positions are based on various NRC documents such as NUREG 0660, NUREG 0737, and NRR generic letters. This subject was discussed in detail with utility training representatives in a meeting conducted on January 6, 1982, in Bethesda, Maryland by the Operator Licensing Branch. The need to implement certain administrative changes in the Robinson operator requalification program was discussed by telephone on July 7 with the Plant General Manager. Based on this _ telephone conversa-tion, we understand that plant procedures will be revised to reflect current NRC grading criteria by October 1,1982. This area will be reviewed during subsequent routine inspection . Unresolved Items Unresolved items were not identified during this inspectio . Organization and Administration (36700)

The inspector reviewed the qualifications of 48 facility personnel in various levels of authority and verified that they met requirements of the technical specifications. The inspector also verified that changes in the organizational structure have been reported to the NR Based on this review, no violations or deviations were identifie . Housekeeping and Cleanliness Program (54701)

References: (a) AI 11, Plant Safety, Revision 112 (b) MI 1-2, General Cleaning and Flushing Requirements, Revision 0 (c) MI 1-1, Maintenance Administration Program, Revision _4 (d) AI 4.0, Conduct of Operations, Revision 136 The inspector reviewed references (a) - (d) and verified that they met requirements of the accepted QA Program (March 18, 1981 Letter, E. E. Utley to D. G. Eisenhut, Serial No. 00A-81-026), NRC Regulatory Guides, and ANSI Standards as endorsed by that program. The inspector verified the following aspects of the housekeeping and cleanliness control program:

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Administrative controls have been established for general housekeepin Administrative controls have been established for cleanliness practice _ ._ ._ __ _ _ _ _ - . _ _ .

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The inspector conducted a tour of accessible areas of the facility and }

verified that housekeeping and cleanliness controls were in effec Based on this review, no violations or deviations were identifie '

i 7. Test and Measurement Equipment Program (61724)

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p References: (a) MP l-3, Control of Portable Measuring and Test Equip- i ment, Revision 2  ;

i (b) SR-6, Calibration of Special Tools and Equipment, .

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1 Revision 10 The inspector reviewed the references to ensure that they met requirements '

of the accepted QA Program. The following criteria were used during the i review: >

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Criteria and responsibility for assignment of the calibration and }

adjustment frequency have been establishe [

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An equipment inventory list has been prepared which identifies equipment used on safety-related structures, systems, or components and

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the calibration frequency of each piece of equipmen ;

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Requirements exist for marking the latest calibration date on each [

piece of equipmen ,

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A system has been provided for assuring that equipment is calibrated by

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the date required.

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Requirements have been established which prohibit use of equipment l which has not been calibrated within the prescribed frequenc l i

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Calibration controls have been established which require evaluation of  !

! the cause of an out-of-calibration and the acceptability of items  !

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previously calibrate :

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A system exists to ensure that new equipment will be added to the inventory list and calibrated prior to being placed in servic '

Based on this review, no violations or deviations were identifie I

Calibration (56700)

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! References: (a) MI-4, Calibration Program, Revision 3 '

(b) MP 1-3, Control of Portable Measuring and Test Equip- l ment, Revision 2

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Utilizing the licensee's cal Tration program as described in the references, '

the inspector verified that selected instruments and measuring and test

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equipment (M&TE) had received proper calibration according to the following criteria: t

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For completed calibrations, documentation was complete, acceptance

criteria met, proper revision used, and calibration conducted by

qualified individuals.

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For calibration procedures, reviews are as required by Technical -

j Specifications, controls are established to meet limiting conditions

for operation, equipment is returned to service, calibration equipment ,

is traceable, and acceptance values are within required limit ;

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For M&TE, equipment is controlled by site procedures, calibration

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frequency is maintained, storage of equipment is proper, and accuracy ,

is traceable to the National Bureau of Standards or another independent l testing organization.

The inspector determined that implementation of several program areas had previously been reviewed by the NRC resident inspector. Discussions with j the resident revealed that a review of the M&TE program implementation had

not specifically been conducte Consequently, the inspector selected v 1 several torque wrenches, micrometers, and electronic test instruments and j verified that the required calibration controls had been implemented.

I Based on this review, no violations or deviations were identifie . Surveillance (61700)

i The inspector determined that implementation of both the Technical Specification and the inservice inspection periodic surveillance programs had been reviewed by the resident inspecto ;

! 10. Maintenance (62700)

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References: (a) MI-1, Maintenance Administration Program, Revision 3

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(b) MI-3, Preventive Maintenance Program, Revision 3 i (c) MP 1-1, Maintenance Work Request Procedure, Revision 0

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(d) MP 1-8, Trend Analysis, Revision 0 i

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The inspector reviewed the maintenance program on safety-related systems and components to ascertain whether activities were conducted in accordance with approved procedures, regulatory guides, and industry codes and in confor-mance with Technical Specification requirement The following criteria were used during this review:

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Required administrative approvals were obtained prior to initiating the wor :,

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Limiting conditions for operation were met while components were removed from servic Activities were accomplished by qualified personne The licensee had evaluated system failures and reported them in accordance with Technical Specification Written procedures were established for initiating requests for-routine and emergency maintenanc Criteria and responsibilities for review and approval of maintenance requests were establishe Criteria and responsibilities that form the basis for designating the activity as safety or non-safety related were establishe Criteria and responsibilities were designated for performing work inspection of maintenance activitie Provisions and responsibilities were established for the identification of appropriate inspection hold points related to maintenance activi-tie Methods and responsibilities were designated for performing functional testing of structures, systems, and components following maintenance work and/or prior to their being returned to servic The inspector determined that the implementation of the maintenance program had previously been reviewed by the NRC resident inspecto Within this area, no violations or deviations were identifie . Audit Program (40702)

References: (a) CQAP Section 16, Audits, Revision 0 (b) CQAP Section 15, Nonconformance Control and Corrective Action, Revision 3 (c) QAP-201, Surveillance Program, Revision 4 (d) CQAD 80-1, Procedure for Corporate Audits, Revision 1 (e) CQAD 80-2, Procedure for Training and Qualification of Quality Assurance Program Audit Personnel, Revision 0 (f) CQAD 80-3, Procedure for Participating in Joint Quality Assurance Audits and Preparing, Distributing and Maintaining the QA Audit Documents, Revision 0 The inspector reviewed references (a) - (f) and verified that they met requirements of the accepted QA Program, NRC Regulatory Guides, and ANSI Standards endorsed by that program. The inspector verified the following aspects of the audit program:

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Methods have been defined for takfng corrective action when deficien-cies are identified during audit The audited organization is required to respond in writing to audit !

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Distribution requirements for audit reports and corrective action !

responses have been define I

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Checklists are required to be used in the performance of audit '

Audits are conducted by trained personnel not having direct responsi-

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bility in the area being audited.

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The frequency of audits is in conforrance with Technical Specification

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The scope of the audit program has been defined and is consistent with the Technical Specifications.

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Responsibilities have been assigned in writing for the overall manage- i ment of the audit progra Based on this review, no violations or deviations were identified.

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! 12. QA Program Review (35701) ,

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References: (a) CQAD Sections 1-16 .

(b) QAP-101, Preparation and Approval of QA and QC 1 r

Procedures, Revision 4 (c) QAP-102, Quality Assurance / Quality Control Document F Control, Revision 2 (d) QAP-103, Indcctrination. Training, Qualification, and Certification of QA/QC Personnel, Revision 4 (e) QAP-201, Surveillance Program, Revision 4 (f) QAP-202, Document Review, Revision 2 (g) QAP-203, Procurement Document Review, Revision 5 (h) QAP-204, Nonconformance Control, Revision 4 (i) QAP-205, Receipt Inspection, Revision 0 The inspector reviewed references (a) - (1) and verified that they met requirements of the accepted QA Program and ANSI Standards endorsed by that program. The inspector verified the following aspects of the QA Program:

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Licensee personnel, having responsibility for preparing implementing procedures to NRR-approved changes to the accepted QA Program for operation, understand the significance of these change Implementing procedures are in conformance with the accepted QA Progra . -.

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Provisions have been made for informing supervisory personnel of new i and existing regulatory commitment Based on this review, no violations or deviations were identifie , 13. Design Changes (37700, 37702) l

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References: (a) CQAP Section 3, Design Control - New Plants _and Nuclear +

Fuel, Revision 1 l (b) ENG-5.0, Plant Design Control, Revision 3  !

(c) ENG-5.1, Modification / Package Development and Revision, Revision 0 (d) ENG-5.2, Technical / Functional Review (Design Verifica-

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tion), Revision 0 (e) ENG-5.4, Turnover and Closeout of "As Built" Modifica- [

tion Packages, Revision 0 L (f) ENG-5.5, Design Change Notice (DCN), Revision 0 (g) ENG-5.6, Temporary Repairs, Revision 0 (h) CQAP Section 14, Operating Plant Modification Control, Revision 1 (i) AI 4.0, Conduct of Operations, Revision 136 (j) AI 6.0, Plant Modifications and Temporary Repairs, Revision 134 (k) AI 11.0, Plant Safety, Revision 102

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The inspector reviewed references (a) - (k) and verified that they met t requirements of the accepted QA Program, NRC Regulatory Guides, and ANSI

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Standards endorsed by that program. The inspector verified the following aspects of the design change program:

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Procedures have been established for control of design and modification change request Procedures and responsibilities for design control have been estab-lished.

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Administrative controls for design document control have been estab-i lishe '

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Administrative controls assure that design changes are incorporated into plant procedures, operator training, and the updating of drawing Controls have been developed that define channels of communication '

between design and responsible organization Administrative controls require that design documentation and records be collected and store Controls require that implementation of approved design changes be in accordance with approved procedures, j

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Controls require that post-modification testing be performed per-approved test procedures and that the test results are evaluate Responsibility has been assigned for identifying post-modification testing requirement Responsibility and method for reporting design changes to the NRC in accordance with 10 CFR 50.59 have been identifie Similar methods and controls were also verified for use of temporary modifications (jumpers and disconnected leads).

The inspector reviewed six modifications (432, 509, 559, 470, 452, and 626)

to verify implementation of previously stated aspect Based on this review, no violations or deviations were identifie .

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14. QA/QC Administration Program (35751)

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References: (a) ENG-2, Q-List Control Procedure, Revision 7 (b) QAP-101, Preparation and Approval of QA and QC Proce-dures, Revision 4 (c) CQAD 10-1, Preparation, Approval, and Distribution of Corporate Quality Assurance Department Procedures,

, Revision 0 (d) CQAD 80-1, Procedure for Corporate QA Audits, Revision '

The inspector reviewed references (a) - (d) and verified that they met requirements of the accepted QA Program and ANSI Standards' endorsed by that prog ra The inspector verified the following aspects of the QA/QC administration program:

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The licensee's QA program documents clearly define or identify those

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structures, systems, components, documents, and activities to which the QA program applies.

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Procedures . and responsibilities have been established for making l changes to these documents.

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The licensee has established administrative controls for QA/QC procedures which provide for procedure review and approval prior to issuance, methods and procedures for changes and revisions, and methods

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for distribution and recall.

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Responsibilities have been established to assure overall review of the

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effectiveness of the QA progra Methods exist to modify QA program weakness areas.

i- Based on this review, no violations or deviations were identified.

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1 Licensee Action on Previously Identified Inspection Findings (92701)

(Closed) Open Item (261/81-25-03): Procedure for 10 CFR 21 Evaluation f The Administrative Instructions, Section 13.0, Instructions for Compliance

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to 10 CFR 21, describes the review methods and responsibilities to be used

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for site identified 10 CFR 21 finding .

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(Closed) Open Item (261/81-25-11): Nonroutine ' Reporting. A system is in

. place- to handle nonroutine events that could . affect both -Robinson and

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, (Closed) Inspector Followup Item (261/81-27-05): Supervisory and Management l

] Personnel Training Programs. A program is ongoing to provide management l personnel with selected training in order to maintain working proficienc ;

(Closed) Inspector Followup Item (261/81-27-07): Corporate Nuclear Safety .

j Section (CNSS) Responsibilities. Procedures have been written to implement '

the Technical Specification review responsibilities of the CNS i

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(Closed) Open Item (261/81-27-13): Maintenance Personnel Trainin Maintenance personnel are being trained and appear qualified to perform .

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! their assigned duties.

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(Closed) Open Item (261/81-27-14)

Site Surveillan:e Procedural Weaknesse ;

The inspector reviewed Robinson QA/QC Unit Manual of Procedures and verified '

that weaknesses identified by Inspection Report 50-261/81-05, paragraph

, 6.a.(2), have been incorporated into revised procedures of this manual.

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( Cl osed.' Open Item (261/81-27-16): Audit Activities. The inspector reviewed audit schedules and areas to be audited and verified that these

! meet requirements for frequency and activities to be audited as required by i Technical Specification '

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j (Closed) Open Item (261/81-27-17): Status Report Informatio The [

l inspector interviewed the Director-QA/Q During this interview the  ;

j inspector verified that weekly and monthly QA activity reports now contain information on identified problems, corrective actions, and status ~ of the ef fectiveness of the site QA/QC organization. This information is also

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discussed during monthly senior management meetings.

l (Closed) Open Item (261/81-27-18): Training of Auditors and Surveillance

Personnel. The inspector reviewed plant procedures relative to training of- I QA/QC personnel. The training of auditors and surveillance personnel ,

j appears to be adequat i l (Closed) Inspector Followup Item (261/81-27-26): Craft-Supervisor Training l

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Knowledge. Improvements to the training programs are in progress and appear .

satisfactor j

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(Closed) Open Item (261/81-27-27): Corporate Office Personnel Trainin Training progress in this area appears satisfactory. Based on a recent corporate inspection, office personnel were considered qualified for their positions.

, (Closed) Open Item (261/81-27-28): Design Change Personnel Trainin Training progress in this area appears satisfactory.