IR 05000269/1976007
| ML19322B766 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 08/11/1976 |
| From: | Alderson C, Burke D, Robert Lewis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19322B767 | List: |
| References | |
| 50-269-76-07, 50-269-76-7, 50-270-76-07, 50-270-76-7, 50-287-76-07, NUDOCS 7912050762 | |
| Download: ML19322B766 (17) | |
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M (4,k UNITED STATES
I NUCLEAR REGULATORY COMMISSION h
h REGION 11
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230 PEACHTREE STREET. N. W. SUITE 818 ATLANTA. GEO RGd A 30303
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IE Inspection Report Nos. 50-269/76-7, 50-270/76-7 and 50-287/76-7 Licensee:
Duke Power Company Power Building 422 South Church Street Charlotte, North Carolina 29201 Facility Name:
Oconee Units 1, 2 and 3 Docket Nos.:
50-269, 50-270 and 50-287 Licensee Nos.:
DPR-38, DPR-47 and DPR-55 Category:
C, C and C Location:
Seneca, South Carolina Type of Inspection:
Routine, Announced Dates of Inspection:
July 12-16, 1976 Dates of Previous Inspection: June 16-18, 1976 Inspector-in-Charge:
C. E. Alderson, Reactor Inspector Nuclear Support Section Reactor Operations and Nuclear Support Branch Accompanying Inspectors:
D. J. Burke, Reactor Inspector Nuclear Support Section Reactor Operations and Nuclear Support Branch T. N. Epps, Reactor Inspector Reactor Projects Section No. 2 Reactor Operations and Nuclear Support Branch J. E. Ouzts, Reactor Inspector Nuclear Support Section Reactor Operations and Nuclear Support Branch Other Accompanying Personnel:
H. C. Dance, Chief
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Nuclear Support Section Reactor Operations and Nuclear Support Branch
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IE Rpt. Nos. 50-269/76-7, 50-270/76-7 and 50-287/76-7-2-
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Principal Inspector:
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T. N. Epps, Jtjp6ctor Inspector Date Reactor Prof (ets Section No. 2 Reactor Operations and Nuclear Support Branch Reviewed By: [.de b
R. C. Lewis, Chief Date Reactor Projects Section No. 2 Reactor Operations and Nuclear Support Branch
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IE Rpt. Nos. 50-269/76-7, 50-270/76-7 and 50-287/76-7-3-SUMMARY OF FINDINGS I.
Enforcement Items Deficiency Contrary to the requirements of Criterion XII of Appendix B to 10 CFR 50 as implemented by Section 17.2.12 of the Duke Power Company Topical Report on Quality Assurance Program, DUKE-1, certain safety-related test and measuring instruments, specifically strain gages and dial indicators, were observed to be improperly tagged and stored with non-safety-related instruments on July 13, 1976.
II.
Licensee Action on Previously Identified Enforcement Matters Not within the scope of this inspection.
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III.
New Unresolved Items 76-7/1 Temporary Jumpers and Bypasses The licensee's procedures do not provide adequate adminis-trative control for temporary jumpers or bypasses.
(Details, Paragraph 10.a)
76-7/2 Safety Review Committee The Duk: Power Company Topical Report on Quality Assurance Prograa includes references to the Safety Review Committee which no longer exists.
(Details, Paragraph 10.b)
76-7/3 Test Equipment Storage Housekeeping in certain areas designated for calibration
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and storage of test and measuring equipment did not appear to be adequate.
(Details, paragraph 16.c)
l 76-7/4 Delineation of Duties and Authorities It does not appear that the licensee has delineated, in writing the duties and responsibilities of certain personnel who may perform safety-related activities.
(Detail,
Paragraph 6)
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IV.
Status of Pr viously Reported Unresolved Items Not within the scope of this inspection.
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Other Significant Findings
The inspectors identified twelve instances where the licensee's documented administrative controls either did not address subjects, or did not address them in sufficient detail to assure that appli-cable requirements would be satisfied by adherence to such instructions.
(Details, paragraphs 4, 8, 9, 13, 14, 15 and 16.c)
VI.
Management Interview Aa exit interview was conducted on July 26, 1976, with Messrs.
J. Hampton, L. Schmid and O. Bradham, and other licensee personnel, and the inspection findings, as presented in the Details of this report, were discussed.
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IE Rpt. Nos. 50-269/76-7-1-50-270/76-7 and 50-287/76-7 DETAILS Prepared by:
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C. E./ lderson, Reactor Inspector Date Nuclea Support Section Reactor Operations and Nuclear upp rt Br ch tab Y -\\D -%
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Date
% D. J.' Bkrke, Reactor Inspector Nuclear Support Section Reactor Operations and Nuclear Support Branch
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T. N. Epps, dtor Inspector Dace Reactor Pr e ts Section No. 2 Reactor Operations and Nuclear Support Br (d
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/.E.Ouzts,EdactorInspector Date clear Support Section eactor Operations and Nuclear Support Branch Dates of Inspection: July 12-16, 1976 II
Reviewed by:
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H.' C. Dance, Chief
'Date Nuclear Support Section Reactor Operations and Nuclear Support Branch 1.
Individuals Contacted Duke Power Company - QA J. Wells - Manager, QA J. Barbour - QA Manager, Operations J. Cox - Senior QA Engineer P. Fant - Junior QA Engineer G. Dunlop - QA Auditor
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J. Brackett - Assistant QA Engineer
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50-270/76-7 and 50-287/76-7 Duke Power Company - Steam Production J. Smith - Plant Manager L. Schmid - Operations Superintendent W. McClain - Shift Supervisor F. Owens - Shif t Supervisor B. Phillips - Shift Supervisor B. Jones - Shif t Supervisor E. Force - Reactor Operator L. Evans - Reactor Operator S. Pryor - Reactor Operator O. Bradham - Maintenance Superintendent L. Wilkie - Welding Engineer R. Adams - Instrument Engineer R. Wilson - Performance Engineer J. Davis - Planning Engineer T. Barr - Technical Service Engineer R. Nichols - Training Coordinator R. Kelley - Laboratory Technician (I&C)
D. McMahon - Instrument Technician W. Holcombe - Mechanical Foreman F. Lark - Machinist J. Sites - Storekeeper M. Thorn - HP Supervisor M. Roach - Clerk N. Rutherford - Director, Nuclear Safety Review Board J. Hampton - Director, Administrative Services J. Brackett - Assistant QC Engineer R. Koehler - Superintendent of Technical Services 2.
Abbreviations The following licensee documents are referred to by abbreviation, as noted in parenthesis following the title, throughout this report.
a.
" Duke Power Company Topical Report on Quality Assurance Program, DUKE-1" (DUKE-1)
b.
" Final Safety Analysis Report for Duke Power Company Oconee Nuclear Station Units 1, 2 and 3" (FSAR)
c.
" Duke Power Company Steam Production Department Administrative Policy Manual for Nuclear Stations" (APMNS)
d.
"Oconee Nuclear Station Directives Manual" (ONSD)
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3.
Qualification of Personnel QA program documents and administrative procedures were reviewed to
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determine whether minimum qualifications had been established for
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personnel performing or directing safety-related activities, and
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responsibilities assigned to assure that the minimum qualifications j
were met.
The program was evaluated for conformance to Sections 6.1.1.4 and 6.1.3 of the Technical Specifications, Section 12.1.3 i
of the FSAR, Appendix A to DUKE-1, ANSI N18.1-1971, and ANSI N45.2.6-1973. Personnel records for selected personnel were reviewed to verify implementation of the program.
The following documents were reviewed:
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APMNS 2.5 (Rev. 9), Qualifications and Training of Personnel ONSD 2.5.1 (dtd. 7-8-74), Qualifications and Training of Personnel ONSD 3.6.1 (dtd. 3-16-76), Welding Program
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QA-508 (Rev. 0), Certification of Q.C. Inspectors-Operations Position Description - Training Coordinator Position Description - Station Senior QA Engineer
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Resume - Corporate QA Manager Resume - QA Manager, Operations
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Within the areas inspected no discrepancies were identified.
4.
Training The licensee's training programs for licensed personnel, operational QA personnel, technicians and maintenance craf tsmen were reviewed.
The programs were evaluated for conformance to 10 CFR 55 and ANSI N18.1-1971.
Implementation of the program was verified by review of training program outlines and training records of selected personnel. The following documents were reviewed:
APMNS 2.5 (Rev. 9), Qualifications and Training of Personnel
Operator Licensing Program
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Operator Requalification Program Training Records for two reactor operator trainees, two technicians and two maintenance craftsmen Within the areas inspected one discrepancy was identified.
Respon-sibility for assuring implementation of the various phases of training for maintenance craftsmen, chemistry technicians and other non-licensed personnel did not appear to be specified in writing.
i This will be the subject of further review.
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IE Rpt. Nos. 50-269/76-7,
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Management and Review Administrative procedures and QA program documents were reviewed to verify that a program for the management of the QA Program, and review of safety-related documents and activities had been esta-blished. The program was evaluated for conformance to Criteria II, XI, XVI and XVIII of Appendix B to 10 CFR 50, Sections 6.1 and 6.6 of the Technical Specifications, and ANSI N1.8.7-1972.
Implementa-tion of the program was also inspected.
Tra following documents were reviewed:
APMNS 2.6 (Rev.10), Review and Audit APMNS 2.8 (Rev. 9), Incident Reports APMNS 3.1 (Rev. 7), Operations APMNS 3.2 (Rev. 4), Testing APMNS 3.3 (Rev. 4), Maintenance APMNS 4.2 (Rev.10), Permanent Station Procedures APMNS 4.3 (Rev. 9), Temporary Station Procedures APMNS 4.4 (Rev. 9), Modifications ONSD 2.7.1 (dtd. 3-5-76), Interfacing Department Equipment Responsibility and Control i
ONSD 3.1.10 (dtd. 4-2-76), Review of Shif t Supervisor's Log Book for Identification of Incidents ONSD 3.1.19 (dtd. 4-2-76), Unit Supervisor's Log Book ONSD 3.1.20 (dtd. 4-2-76), Reactor Operations Log ONSD 3.2.1 (dtd. 4-2-76), Performance of Periodic Testing or Sampling ONSD 3.2.2 (dtd. 6-4-74), Responsibility for and Scheduling of Periodic Tests ONSD 4.2.1 (dtd. 3-31-76), Procedures ONSD 4.2.2 (dtd. 3-16-76), Technical Review Committee Within the areas inspected, no discrepancies were identified.
6.
Inspections Administrative procedures and QA program documents were reviewed to determine whether a program of inspections of safety-related activities had been established.
The program was evaluated for conformance to Criterion X of Appendix B to 10 CFR 50, ANSI N18.7-1972, ANSI N45.2-1971, and ANSI N45.2.3-1973.
Implementation of the program was also inspected. The following documents were reviewed:
APMNS 3.1 (Rev. 7), Operations APMNS 3.2 (Rev. 4), Testing
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IE Rpt. Nos. 50-269/76-7,
-5-50-270/76-7 and 50-287/76-7 APMNS 3.3 (Rev. 4), Maintenance APMNS 3.11 (Rev. 4), Housekeeping and Cleanliness APMNS 4.4 (Rev. 9), Modifications ONSD 3.1.3 (dtd. 4-2-76), Duties of the Operator on the Control Board ONSD 3.3.1 (dtd. 9-24-75), Safety-Related Components or Equip-ment Repair ONSD 3. 3.2 (dtd.10-8-74), Tools and Test Equipment Control ONSD 3.3.3 (dtd.10-15-74), operation, Inspection and Maintenance of Cranes and Hoists ONSD 3. 3.4 (dtd.10-14-74), Maintenance Group Information Logs ONSD 3.3.5 (dtd. 4-5-76), Maintenance Work Request ONSD 3.3.6 (dtd.11-4-75), Preventive Maintenance and Periodic Tests ONSD 3.3.7 (dtd. 9-11-75), Preventive Maintenance on Stored Equipment ONSD 3.3.8 (dtd. 3-3-76), control of Lif ting Devices for Safety Related Components ONSD 3.3.9 (dtd. 12-16-75), Control of Turbine Building 25 Ton Crane Stop Blocks ONSD 3.3.10 (dtd. 6-21-76), Processing QA Nonconforming Item
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Reports ONSD 4.4.1 (dtd.11-10-75), Station Modification Familiarization ONSD 4.4.2 (dtd. 7-29-74), Processing Station Modifications Inservice Inspection Manuals 1, 2 and 3 (Babcock and Wilcox)
Modification No. 0507, LPI System Piping Modification Modification No. 566, Steam Generator Valve Replacement Memo on Housekeeping Responsibility (Plant Manager to Depart-ment Heads)
Within the areas inspected one unresolved item was identified.
Criterion I of Appendix B to 10 CFR 50 states in part that "The authority and duties of persons.
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ting the safety-related functions of structures, systems, and components shall be clearly established and delineated in writing."
Section 17.0 of DUKE-1 states that the licensee's QA program conforms to the criteria of ANSI N18.7-1972.
Section 5.1.1 of the Standard states that " responsibilities and authorities of the plant staff shall be delineated" and Section 5.1.3 states in part that "(written)
instructions.
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operators and others." While the licensee had delineated duties and authorities for most personnel it appeared that this had not been accomplished for some personnel who may perform safety-related activities such as the utility operators identified in Table 6.1.1 of the Technical Specifications.
This is designated as Unresolved Item 76-7/4.
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7.
Audits Administrative procedures and QA program documents were reviewed to determine whether administrative controls had been established, and responsibilities assigned, to assure that a program of audits is conducted in accordance with the requirements of Criterion XVIII of Appendix B to 10 CFR 50, Section 6.1.3 of the Technical Specifi-cations, Sections 17.1.18, 17.2.2, 17.2.16 and 17.2.18 of DUKE-1, Section 4 of ANSI N18.7-1972, and Section 19 of ANSI N45.2-1971.
Implementation of the established program was also inspected.
The following QA department procedures and other documents were reviewed:
QA-100 (Rev. 2), Preparation and Issue of QA Procedures QA-110 (Rev. 0), Transmittal of QA Documentation QA-130 (Rev. 0), Qualification and Training of Lead Auditors QA-150 (Rev. 0), Trend Analysis QA-200 (Rev. 1), QA Training QA-210 (Rev. 2), Level II Audit Procedure QA-230 (Rev.1), Level II Audit Scheduling and Followup (
QA-409 (Rev. 0), Certification of QA Records Personnel QA-412 (Rev. 2), Level I Audits of Design Engineering Department QA-500 (Rev. 5), Conduct of Level I Audits for Operations Audit Report Nos. 76-3, 76-24, 76-26, 76-29 and 76-34 Audit Schedule for 1976 Within the areas inspected, no discrepancies were identified.
8.
Document Control Administrative procedures and QA program documents were reviewed to verify that a program for the control of safety-related documents had been established, and responsibilities assigned, for the preparation, review, approval and distribution of new or revised drawings and procedures; recall or control of superseded drawings and procedures; control of temporary changes to procedures; and preparation and maintenance of operating logs.
The program was evaluated for conformance to 10 CFR 50.59, Criteria V and VI of Appendix B to 10 CFR 50, Section 6.1 and 6.4 of the Technical Specifications, Section 17.2.4, 17.2.5, 17.2.6 and 17.2.11 of DUKE-1, ANSI N18.7-1972 and ANSI N45.2-1971.
Implementation of the program was also inspected. The following documents were reviewed:
APNMS 1.5 (Rev. 8), Administration of the Manual (APMNS)
APMNS 2.1 (Rev.10), Document Control i
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APMNS 3.2 (Rev. 4), Testing
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-7-50-270/76-7 and 50-287/76-7 APMNS 4.2 (Rev. 10), Permanent Station Procedures APMNS 4.3 (Rev. 9), Temporary Station Procedures APMNS 4.4 (Rev. 9), Modifications ONSD 3.1.8 (dtd. 4-2-76), Shift Relief and Turnover ONSD 3.1.19 (dtd. 4-2-76), Unit Supervisor's Log Book ONSD 3.1.20 (dtd. 4-2-76), Reactor Operation Log QA-100 (Rev. 2), Preparation and Issue of QA Procedures QA-403 (Rev. 4), QA Specification Review QA-502 (Rev. 0), Evaluating and Approving QC Inspection Records QA-504 (Rev. 2), QA Records, Operations QA-505 (Rev. 2), QA Procurement Document Review and Processing Within the areas inspected the following discrepancies were identi-fied.
a.
APMNS 4.2.3.6 establishes a requirement for a Master copy (permanent record) of each procedure.
It also requires that additional copies (working copies) of each procedure be " main-tained in a controlled manner" but does not provide specific instructions as to how this is to be accomplished and thus I
does not assure proper implementation of the requirements of Criteria V and VI of Appendix B and Section 6.4.1 of the Technical Specifications.
b.
APMNS 4.2.4 and 4.3.4 require written safety evaluations for major changes to existing procedures prior to implementation; however, APMNS 4.2.3.5 and 4.3.3.5 do not require written safety evaluations for new procedures except for those which involve a proposed test or experiment. This does not assure proper implementation of the requirements of 10 CFR 50.59(b)
as they relate to new procedures which change operational methods or modes described in the FSAR.
9.
Maintenance The licensee program for management control of maintenance activi-ties was reviewed and evaluated for conformance to Criteria V, IX, XIV and XVII of Appendix B to 10 CFR 50, and ANSI 18.7-1972. This included control of work requests, review and approval, procedure requirements, inspections, testing, corrective actions, records and responsibilities.
Implementation of this licensee's program was reviewed during a previous inspection and items of noncompliance involving improper implementation of procedural and management controls were cited in IE Report Nos. 50-269, 50-270, 50-287/76-6.
Documents reviewed during this inspection included the following:
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APMNS 2.7 (Rev. 9), Control of Interfacing Individuals and Organizations APMNS 3.3 (Rev. 4), Maintenance APMNS 4.2 (Rev.10), Permanent Station Procedures APMNS 4.3 (REV. 9), Temporary Station Procedures ONSD 3.1.28 (dtd. 4-2-76), Out of Normal Check Sheet ONSD 3.3.5 (dtd. 4-5-76), Maintenance Work Request (MWR)
ONSD 3.6.1 (dtd. 3-16-76), Welding Program Within the areas inspected, one discrepancy was identified. Attach-ment No. 2 of ONSD 3.3.5 states that a written work request is not required before work is started for Priority No. 1 work, but must be prepared bafore the end of the shift, or upon completion of the job. Allowing work to be performed without a properly prepared and approved MWR (which designates whether a maintenance item is safety-related or non-safety-related), could result in the procedural and operational requirements being bypassed.
The licensee stated that this would be reviewed and corrective action determined.
10.
Design Changes and Modifications QA program documents and administrative procedures ware reviewed to determine whether a program for controlling design changes and modifications had been established.
The program was evaluated for conformance to Section 6.1.2.1 of the Technical Specifications, Section 17.2.3 of DUKE-1, Section 5 of ANSI N18.7-1972, and Section 4 of ANSI N45.2-1971.
Implementation of the program was also inspected. The following documents were reviewed:
APNNS 3.4 (Rev. 8), Modifications APMNS 4.4 (Rev. 9), Administrative Instructions for Modifications ONSD 3.3.5 (dtd. 4-5-76), Maintenance Work Request (MWR)
OnSD 4. 4.1 (d td. 11-10-75), Station Modification Familiarization ONSD 4.4.2 (dtd. 7-29-74), Processing Station Modification Reports (SMR)
Within the areas inspected, two unresolved items were identified.
a.
The licensee's administrative procedures, especially ONSD 3.3.5, do not adequately control temporary jumpers or bypasses, nor do they require personnel to specify the functional testing required after maintenance work or troubleshooting is performed on safety-related equipment.
The licensee has issued a memo to provide interim control of jumpers and lif ted leads which permits their use only for troubleshooting.
The licensee stated that the administrative procedures are being revised to provide the required control.
This is designated as Unresolved Item 76-7/1 pending completion of the procedure revision.
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b.
Section 17.2.3 and 17.2.6 for DUKE-1 both include references to the Station Review Committee which has been replaced by a Technical Review Committee.
The licensee stated that an amendment to DUKE-1 would be submitted to NRR. This is designated as Unresolved Item 76-7/2 pending review of the amendment by NRR.
11.
Surveillance Testing Administrative procedures and OA program documents were reviewed to determine whether a program for surveillance testing had been established. The program was evaluated for conformance to Section 4 of the Technical Specifications, Criterion XI of Appendix B to 10 CFR 50, and Section 12 of the FSAR.
Implementation of the program was also inspected. The following documents were reviewed:
APMNS 3.2 (Rev. 4), Testit; APMNS 4.2 (Rev.10), Permanent Station Procedures ONSD 3.2.1 (dtd. 4-2-76), Performance of Periodic Testing or Sampling Ten Periodic Tests as follows:
-HP/0/B/1005/01-PT/0/A/600/15-PT/2/A/0203/04-PT/3/A/600/ll-PT/1/A/0150/4-IP/0/A/275/5P-IP/0/A/310/130-PT/0/A/150/15B-HP/0/B/1005/01-PT/0/A/203/06 Within the areas inspected, no discrepancies were identified.
12.
Procurement QA program documents and administrative procedures were reviewed to determine whether a program to control the procurement of safety-related components and equipment had been established.
The program was evaluated for conformance to Section 6.1.2.1 of the Technical Specifications, Sections 17.2.4 and 17.2.7 of DUKE-1, Section 5 of ANSI N45.2-1971, and ANSI N45.2.2-1972.
Implementation of the program was also inspected.
The following documents were reviewed:
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APMNS 2.4 (Rev. 10), Control of Materials, Parts and Components APMNS 2.9 (Rev.10), Control of Purchased Services APMNS 4.5 (Rev. 9), Administrative Instructions for Purchase Specifications ONSD 2.4.2 (dtd. 3-30-76), Control of Material and Labor Purchasing OCG-1-R4, Receipt, Inspection, and Control of Materials, Parts, and Components Important to Nuclear Safety Except Nuclear Fuel Documentntion for Several Vendor Audits Within the areas inspected, no discrepancies were identified.
13. Receipt, Storage and Handling Administrative procedures and QA program documents were reviewed to determine whether a program to control the receipt, storage and handling of safety-related equipment and materials had been estab-lished. The program was evaluated for conformance to Section 6.1.2.1 of the Technical Specifications, Sections 17.2.7, 17.2.8, (
17.2.10,17.2.13 and 17.2.15 of DUKI-1, Sections 8 and 9 of ANSI N45.2-1971 and ANSI N45.2.2-1972.
Implementation of the program was also inspected.
The following documents were reviewed:
APMNS 2.4 (rev.10), Control of Materials, Parts and Components APMNS 2.9 (Rev.10), Control of Purchased Services ONSD 2.4..
(dtd. 8-26-75), Receiving, Storing, Issuing, Handling, Packaging, and Shipping of Material OCG-1-R4, Receipt, Inspection and Control of Materials, Parts, and Components Important to Nuclear Safety Except Nuclear Fuel Within the areas inspected, one discrepancy was identified. Certain safety-related items (chemicals) stored in Auxiliary Warehouse No.
4 were not properly segregated from non-safety-related materials as required by APMNS 2.4.
This had been identified by the licensee's internal audits and construction of segregating enclosures was nearing completion. The licensee also stated that Warehouse No. 4 will be cleaned, repaired and controlled in accordance with his procedures. Warehouse No. 4 will be re-inspected during a future inspection.
i 14. Records Administrative procedures and QA program documents were reviewed to verify that administrative controls had been established, and responsibilities assigned, for the collection, retention and
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preservation of operational and QA records.
The established program was evaluated for conformance to 10 CFR 50.59, Criterion XVII of Appendix B to 10 CFR 50, Section 6.5.1 and 6.5.2 of the Technical Specifications, Section 17.2.17 of DUKE-1, and ANSI N45.2.9-1974.
Implementation of the program was also inspected, as were the physical storage facilities.
The following administrative procedures were reviewed:
ONSD 2.1.2 (dtd. 2-17-75), Procedure for Microfilming Documents ONSD 2.2.1 (dtd. 12-16-75), Procedure for Records Management APMNS 2.1 (Rev. 10), Document Control APMNS 2.2 (Rev.10), Records Management APMNS 4.2 (Rev. 9), Permanent Station Procedures QA-410 (Rev.1), Processing of QA Records for Purchased Items QA-504 (Rev. 2), QA Records, Operations Within the areas inspected the following discrepancies were identified:
a.
ONSD 2.2.1 and QA-504 allow filing of supplemental records and correction of existing records; however, they do not specify review and approval of such actions as required by Section 3.2.6 of ANSI N45.2. 9-1974.
b.
The wording of APMNS 4.2.9.1 and 4.3.8 appear to imply that records of changes to safety-related procedures need not be retained beyond six years; however Technical Specification 6.5.1.k requires that such records be retained for the life of the facility.
c.
The lists of records to be retained that appear in APMNS 2.2, ONSD 2.1.2 and ONSD 2.2.1 address only operational type records specified in Section A.6 of Appendix A to ANSI N45.2.9-1974.
The procedures do not address, and thus do not assure retention of the types of records specified in Section A.1 through A.5 of the Standard.
15.
Tests and Experiments Administrative procedures and QA program documents were reviewed to verity that a program of administrative controls had been established, and responsibilities assigned, for the review, approval, conduct and documentation of tests and experiments.
The program was eval-uated for conformance to 10 CFR 50.59, Criterion XI of Appendix B to 10 CFR 50, Sections 6.1.3 and 6.6.1 of the Technical Specifica-tions, and Section 17.2.11 of DUKE-1.
Implementation of the program was also inspected. The following administrative procedures were reviewed:
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IE Rpt. Nos. 50-269/76-7,
-12-
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50-270/76-7 and 50-287/76-7
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APMNS 3.2 (Rev. 4), Testing APMNS 3.3 (Rev. 4), Maintenance APMNS 4.3 (Rev. 9), Temporary Station Procedures APMNS 4.4 (Rev. 9), Modifications Memo (dtd. 2-17-76) f rom Superintendent, Technical Services to Technical Services Engineer Within the areas inspected, the following discrepancies were identified:
APMNS 4.3.3.5(c) assigns responsibility for review of proposed
a.
tests or experiments to determine wnether an unreviewed safety question exists; however, it does not assign responsibility
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for comparing the proposed test w1th those described in the FSAR and thus does not assure that the requirements of 10 CFR 50.59 will be met.
b.
APMNS 4.3.3.5(c) requires a documented safety evaluation for
l any proposed test or experiment but does not specifically require that such documentation include the bases for deter-
mination that the proposed test does/does not involve an
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unreviewed safety question as required by 10 CFR 50.59(b).
i APMNS 4.3.3.5(d) and (e) appear to allow temporary approval
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c.
j and use of Temporary Test Procedures before the review required by 4.3.3.5(c) is accomplished. -For proposed tests or experi-
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ments not described in the FSAR, the review by the Station Manager or his designee must be accomplished prior to conducting the test to satisfy the requirements of 10 CFR 50.59.
16. Test and Measuring Equipment QA program documents and adminstrative procedures were reviewed to determine whether a program for the control of test and measuring equipment had been established.
The program was evaluated for con-formance to Criterion XII of Appendix B to 10 CFR 50, Section i
17.2.12 of DUKE-1, ANSI N18.7-1972 and ANSI N45.2-1971.
Implementa-tion of the program was also inspected. The following documents were reviewed:
APMNS 2.3 (Rev. 10), Control of Measuring 'and Test Equipment Selected Instrument Calibration Records Memo (dtd. 3-4-76), Retesting as a Result of Use of Out-of Cali-bration Test Instrument (Instrument Engineer to I&C Foremen)
Ten Periodic Test Procedures
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IE Rpt. Nos. 50-269/76-7,
-13-
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50-270/76-7 and 50-287/76-7 Within the areas inspected, the following discrepancies were noted; Section 17.2.12 of DUKE-1 which implements Criterion XII of a.
Appendix B to 10 CFR 50 requires in part that safety-related instruments bear " Accepted" or " Rejected" tags.
APMNS 2.3.3.3 states that storage locations for safety-related devices shall be sufficiently separate from storage locations for non-controlled devices so as to preclude confusion between controlled and non-controlled devices.
Contrary to these requirements and instructions, out-of-calibration strain gages and dial indicators were found to be improperly tagged and stored in a drawer with non-safety-related test equipment on July 13, i
1976. This is designated as a Deficiency.
b.-
Section 17.2.12(f) of DUKE-1 states that " Devices are stored under conditions which are in accordance with, or more conserva-tive than, the applicable manufacturer's recommendations."
APMNS 2.3.3.3 contains a similarly worded instruction. During the inspection of the facilities designated for calibration and storage of electrical test equipment, and for torque 7 g wrenches, it did not appear that the relative degree of house-
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keeping in these areas was in keeping with the stated require-ments. The licensee stated that work to upgrade these facili-ties had been initiated.
This is designated as Unresolved Item 76-7/3 pending completion of this work.
Several of the periodic test procedures reviewed did not have c.
spaces identified on the data sheets for recording the serial numbers of test instruments used. Failure to record this data would make it difficult, if not impossible, to satisfy the requirements of APMNS 17.2.12(e). The licensee agreed to review his periodic test procedures and add a requirement to record the serial number (s) of any test equipment used where missing.
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