IR 05000269/1981015
| ML15224A425 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 08/04/1981 |
| From: | Belisle G, Fredrickson P, Skinner P, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML15224A424 | List: |
| References | |
| 50-269-81-15, 50-270-81-15, 50-287-81-15, NUDOCS 8109010418 | |
| Download: ML15224A425 (14) | |
Text
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UNITED STATES S
CNUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGIA 30303 Report Nos. 50-269/81-15, 50-270/81-15, 50-287/81-15 Licensee:
Duke Power Company 422 South Church Street Charlotte, NC 28242 Facility Name:
Oconee 1, 2 and 3 Docket Nos. 50-269, 50-270, & 50-287 License Nos. DPR-38, DPR-47, DPR-55 Inspection at Oconee site near Senec, South Carolina Inspectors:
I/7y G. A. BelisleSigned P. E. Fredric~tnMeSge P.'H.-
rin~erate/S igned Approved by:
_13 l
D te S gned Engineering I ection ranch Engineering a Technical Inspection Division SUMMARY Inspection on July 13-17, 1981 Areas Inspected This routine, unannounced inspection involved 99 inspector-hours on site in the areas of licensee action on previous enforcement matters, organization and administration, onsite review committee activities, licensee internal audits, plant procedures, equipment calibration, surveillance testing, maintenance activities, the nonroutine reporting program, design changes and licensee action on previously identified inspection item Results Of the 11 areas inspected, no violations or deviations were identifie PDR ADOCK 05000269 G
PDR'
REPORT DETAILS 1. Persons Contacted Licensee Employees
- R. Brackett, Senior QA Engineer
- E. Kelley, Licensing (Clerk)
- T. Matthews, Licensing Technical Specialist
- J. McCool, QA Surveillance Supervisor
- J. McIntosh, Superintendent of Administration
- J. Pope, Superintendent of Operations
- J. Smith, Station Manager Other licensee employees contacted included technicians, operators, mechanics, and office personne NRC Resident Inspector
- W. Orders
.
- Attended exit interview Exit Interview The inspection scope and findings were summarized on July 17, 1981 with those persons indicated in paragraph 1 abov The licensee acknowledged the inspection finding.
Licensee Action on Previous Enforcement Matters (92702)
The following abbreviations are defined and used throughout this report:
Accepted QA Program Duke Power Company Topical Report, Duke-1-A, Amendment 4 dated June 1978 APM Administrative Policy Manual M&TE Measuring and Test Equipment NSM Nuclear Station Modification PT Periodic Test SD Station Directive WR Work Request
The Unresolved items from IE Reports 50-269,270,287/79-10 and the violation from IE Reports 50-269,270,287/81-06 were reviewed with respect to the licensee's letters dated May 22, 1981 and June 2, 198 (Closed) Unresolved Item (269,270,287/79-10-09): Inadequate internal/
external design interfaces and communications. Revision 19 to the APM was issued on June 30, 1981 as stated in the licensee's correspondence dated June 2, 1981. The internal/external design interfaces have been adequately addressed in APM Section 4.4, Administrative Instructions for Modification, Revision 1 (Closed) Unresolved Item (269,270,287/79-10-10):Inadequate design change procedures. Revision 19 to the APM was issued on June 30, 1981 as stated in the licensee's correspondence dated June 2, 198 APM Section 4.4, Administrative Instructions for Modifications, Revision 19 adequately addresses sections 3.1, 5.1, 5.1.4 and 7.2 of ANSI N 45.2.11-1974 as endorsed by the licensee's accepted QA Progra (Closed)
Violation (269,270,287/81-06-05):
Failure to record the results of reviews. The inspector reviewed QA-190, Review of Quality Assurance Procedures, Revision 0 dated 6/81. This procedure delineates a means of organizing and maintaining review status for quality assur ance procedures. The inspector also reviewed two memos dated May 19, 1981 and June 29, 1981 documenting that QA procedures had been reviewed as required. Some of the procedures are currently undergoing revision and will be implemented upon completion of the revisions being issue (Open)
Unresolved Item (269,270,287/81-06-06):
Lack of formal QA indoctrination for general employees. The final resolution of this item is currently under consideratio (Open)
Unresolved Item (269,270,287/81-06-07):
Use of one-hour fire cabinets for storage of quality records. Discussions with licensee personnel identified that a study on use of one-hour fire cabinets had been performed; however, the documentation was not on sit The documentation is being obtained and will be reviewed during a subse quent inspectio.
Unresolved Items Unresolved items were not identified during this inspectio. Organization and Administration (36700)
References:
(a) Technical Specification 6.1, Organization, Review and Audit
(b)
APM 1.4, Organization, Revision 19 dated 6/81 (c) Accepted QA Program The inspector reviewed references (b) and (c) to assure the requirements of reference (a) were adhered to. The inspector verified that the licensee's onsite organizational structure and the lines of authority and responsi bilities are as described in reference (a).
There has been no recent changes in the organizational structur The review of personnel quali fications as required by reference (a) was accomplished during the March 1981 inspection and is documented in 1E Reports 50-269,270,287/81-06, paragraph Based on this review, no violations or deviations are identifie. Onsite Review Committee (40700)
References:
(a) Technical Specification 6.1.2, Technical Review and Control (b) Memo from Station Manager to Group Heads, Subject:
Qualified Reviewers and Technical Review Committee Membership, File N OS-820.00 (c) Technical Review Committee Charter The inspector reviewed references (b) and (c) to assure they met the requirements of reference (a).
The inspector reviewed the Technical Review Committee meeting minutes during 1980, meetings 80-01 through 80-6 Based on this review, no violations or deviations were identifie. Audits, Audit Program Implementation (40702, 40704)
References:
(a) QA-210, Departmental Audit Procedure, Revision 11 dated 8/80 (b) QA-230, Departmental Audit Scheduling and Follow-up, Revision 8 dated 3/81 (c) QA-130, Qualification and Training of Lead Auditors, Revision 6 dated 4/81 (d) QA-160, Performance of Corporate Quality Assurance Audits, Revision 0 dated 11/78 (e) APM 2.6, Review and Audit, Revision 18 dated 9/79
The inspector reviewed the references listed to assure they met the require ments of the accepted QA Program and ANSI N45.2.12 (Draft 3, Revision 4, 2/74) as endorsed by that Progra The inspector verified the following aspects of the audit program:
-
The scope of the audit program has been defined and is consistent with Technical Specification requirements
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Responsibilities have been assigned in writing for the overall manage ment of the audit program
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Administrative channels have been defined for taking corrective actions when deficiencies are identified during audits
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Controls require the audited organization to respond in writing to audit findings
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Distribution requirements for audit reports and corrective action responses have been defined
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Controls require checklists to be used in performance of audit To verify implementation of the listed aspects of the audit program, the inspector observed a portion of audit SP-81-8 (ON)
currently in progres This audit encompasses defueling, inservice inspection and operations activitie The inspector also reviewed the results of six previous licensee audit The specific audits reviewed are listed below:
Audit Date Conducted SP-81-7 (ON)
6/15 -
7/01/81 0-80-2 1/22 -
1/25/80 0-80-4 3/12 -
3/28/80 0-80-8 6/9 -
6/27/80 0-80-13 9/2 -
9/12/80 0-80-17 11/10 -
11/24/80 The inspector reviewed the qualifications of auditors during an inspection at the McGuire facilit This is documented in IE Reports 50-369/81-17, 50-370/81-0 Based on this review, no violations or deviations were identifie.
Procedures (42700)
References:
(a) APM, Section 4.2, Administrative Instructions for Permanent Station Procedures, Revision 19 dated 6/81 (b) SD 4.2.1 (Mgr.) Procedures, dated 1/81
(c) APM, Section 4.3, Administrative Instructions for Temporary Station Procedures, Revision 19 dated 6/81 (d) ANSI N18.7-1976, Administrative Controls for Nuclear Power Plants (e) Technical Specifications 6.4, Station Operating Proce dures dated 10/78 (f) Regulatory Guide 1.33, Revision 1, Quality Assurance Program Requirements (Operation)
(g) Final Safety Analysis Report The inspector conducted a review of selected plant procedures in accordance with the guidance and requirements provided in references (a) through (g)
above to ascertain whether overall procedures are in accordance with regula tory requirement The following criteria were used during this review:
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Required review and approval of procedures and temporary changes had been performed
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Overall procedure content is consistent with references (e) and (g)
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Records of changes in procedures are being maintained
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Safety reviews pursuant to 10 CFR 50.59 were performed
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Administrative procedures were observed in the preparation and handling of procedures The following procedures were reviewed during this inspection:
OP/0/A/1103/13 RC System Leakage, dated 5/80 OP/1/A/1103/02 Filling and Venting RC System, dated 11/80 OP/1/A/1103/06 RC Pump Operation, dated 1/81 OP/1/A/1104/02 HP Injection System Operation, dated 3/81 OP/2/A/1102/01 Controlling Procedure for Unit Startup, dated 3/81 EP/0/A/1800/11 Loss of Decay Heat Removal System, dated 2/80 EP/0/A/1800/29 Loss of Instrument Air, dated 5/80 EP/0/A/1800/31 Loss of 3KI Bus (and Control Room Indications Powered from 3KI), dated 2/81 MP/0/A/1300/07 HPI Pump Removal and Replacement dated 12/80 Comments of an editorial nature on these procedures were provided to personnel responsible for the preparation of these documents for informa tio Based on this review, no violations or deviations were identifie.
Calibration (56700)
References:
(a) APM, Section 5.1, Standards and Testing Facility, Revision 19, dated 6/81 (b) APM, Section 5.2, Qualification and Testing Facility, Revision 19, dated 6/81 (c) APM, Section 2.3, Control of Measuring and Test Equip ment, Revision 19, dated 6/81 (d) SD 2.3.1, Test and Measuring Equipment Control, Revised 6/81 Utilizing the licensee's calibration program as described in references (a)
through (d), the inspector verified that selected instruments and M&TE had received the proper calibration according to the following criteria:
-
For completed calibrations, the documentation was complete, acceptance criteria met, proper revision used and calibration conducted by quali fied individuals
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For calibration procedures, reviews are as required by Technical 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 limits
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For M&TE, equipment is controlled by site procedures, calibration frequency is maintained, storage of equipment is proper and accuracy is traceable to the National Bureau of Standards or other independent testing organization The inspector determined that implementation of several program areas had previously been reviewed by the NRC resident inspector Discussions with the residents revealed that a review of the M&TE program implementation had not specifically been conducte Consequently, the inspector selected several torque wrenches, micrometers, and electronic test instruments and verified that the required calibration controls had been impose Based on this review, one inspector followup item was identified. A signi ficant portion of the M&TE used at the site is calibrated at the Duke Standards and Testing Facility in Charlotte. To complete the review of the calibration program and its implementation, this facility will be reviewed during a subsequent inspection and is identified as an inspector followup item (269, 270, 287/81-15-01).
1 Surveillance (61700)
References:
(a) APM, Section 3.2.2, Periodic Testing, Revision 19, dated 6/81 (b) SD 3.2.1, Performance of Periodic Testing or Sampling, dated 4/76 (c) SD 3.2.2, Responsibility for Scheduling of Surveillance Requirements, revised 5/81 (d)Section XI, ASME Boiler and Pressure Vessel Code, 1974 Edition through Summer 1975 addenda (e) Oconee Nuclear Station Inservice Inspection Program, dated 5/79 Utilizing the licensee's surveillance program as described in references (a)
through (e),
the inspector verified that selected plant surveillances met several required criteria:
-
Technical Specification surveillances and inservice inspection (ISI)
tests were covered by approved procedures which contained applicable prerequisites and preparations, acceptance criteria and instructions to insure that systems or components are restored to operation following testing
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Completed surveillances were reviewed in accordance with facility administrative requirements, were performed within the required time frequencies, were properly handled when tested items failed acceptance criteria and were performed by qualified individual The inspector determined that implementation of several program areas had previously been reviewed by the NRC resident inspector Discussion with the resident inspectors revealed that the ISI program implementation had not specifically been reviewed. Consequently, the following ISI periodic tests were selected for review:
PERIODIC TEST DATE PT/1/A/150/22A 10/27/80, 2/23/81, 4/27/81 PT/2/A/203/06 1/81 -
6/81 PT/0/A/0290/02 6/27/80, 3/3/81 Based on this review, no violations or deviations were identifie.
Maintenance (62700)
References:
(a) APM, Section 3.3, Maintenance, Revision 19 dated 6/81
- 0*
(b)
APM, Section 4.7, Administrative Instructions for Work Requests, Revision 19, dated 6/81 (c) SD 3.3.1, Safety Related or Non-Safety Related Components or Equipment Repair, revised 5/77 (d) SD 3.3.5, Maintenance Work Request, revised 4/81 (e) SD 3.3.6, Preventive Maintenance and Periodic Tests, revised 8/78 (f) SD 3.3.15, Post-Maintenance Performance Tests, revised 5/78 (g) QA 502, Evaluating and Approving QC Inspection Records, Revision 1, dated 2/78 (h) QA 510, Quality Assurance Review of Station Work Requests, Revision 3, dated 3/81 (i) Quality Control Procedures Manual The inspector reviewed maintenance activities on safety-related systems and components to ascertain whether the activities were conducted in accordance with approved procedures, regulatory guides and industry codes and in conformance with Technical Specification requirement The following criteria were used during this revie Required adminstrative approvals were obtained prior to initiating the work
-
Limiting conditions for operation were met while the components were removed from service
-
Approved procedures were used where the activity appeared to be beyond the normal skills of the craft
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Activity was accomplished by qualified personnel
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The licensee had evaluated system failures and reported them in accord ance with the Technical Specifications
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Written procedures were established for initiating requests for routine and emergency maintenance
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Criteria and responsibilities for review and approval of maintenance requests were established
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Criteria and responsibilities that form the basis for designating the activity as safety or non-safety-related were established Criteria and responsibilities were designated for performing work inspection of maintenance activities
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Provisions and responsibilities were established for the identification of appropriate inspection hold points related to maintenance activities
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Methods and responsibilities were designated for performing functional testing of structures, systems or components following maintenance work and/or prior to their being returned to servic The inspector determined that implementation of several program areas had previously been reviewed by the NRC resident inspector Discussions with the resident inspectors revealed that a review of QA/QC records generated from maintenance work had not been conducted. Consequently, the inspector selected work requests as listed below and reviewed the maintenance and repair parts QC documentation:
WR NSM 96258 869 96259 869 96941 0607 97014 0607 97280 0607 96627 1248 96414 0957 Based on this review, no violations or deviations were identifie.
Nonroutine Reporting Program (90714)
References:
(a) APM, Section 2.8, Reporting, Revision 19 dated 6/81 (b) SD 2.8.1, Non-Routine Events and Incident Investigation, revised 8/80 (c) SD 2.8.3, Reporting of Events to NRC/0IE, revised 3/81 (d) SD 2.8.4, Incident Report Format and Content, revised 4/81 (e) SD 2.8.6, Directive for Evaluation of Items Required by 10 CFR 21, revised 8/80 (f) SD 3.8.5, Emergency Procedure, revised 4/81
(g)
SD 4.2.2, Technical Review Committee, dated 3/76 The inspector reviewed references (a) through (g) to verify that administra tive controls for nonroutine reporting events meet the following criteria:
-
Controls have been established for the prompt review and evaluation of off-normal events to assure identification of safety-related events
-
Controls have been established for the prompt review of planned and unplanned maintenance and surveillance testing activities to assure identification of prospective or actual violations of limiting condi tion for operation requirements of the technical specifications
-
Controls have been established for reporting safety-related events internally and to the NRC
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Controls have been established for completion of corrective actions relating to safety-related operating events
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Controls contain provisions for recognition and reporting of events that are covered by 10 CFR Part 21
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Responsibility for implementing these administrative controls has been establishe The inspector also reviewed the licensee's program for handling NRC and vendor circulars and bulletin Based on this review, no violations or deviations were identifie.
Design, Design Changes and Modifications (37700, 37702)
References:
(a) Accepted QA Program, Section 17. (b) APM, Section 3.4, Modifications, Revision 19, dated 6/81 (c) APM, 4.4, Administrative Instructions for Modifications, Revision 19 dated 6/81 (d) SD 4.4.1(M), Station Modification Familiarization, dated 11/75 (e) SD 4.4.2 (TS), Processing Nuclear Station Modifications (NSM), revised 4/79 (f) SD 4.4.3 (TS), Processing Nuclear Station Modifications (NSM),
(by Design Engineering), revised 5/81
(g)
SD 4.4.4.(TS),
Transfer of Completed or Partially Completed Station Modifications, revised 5/81 (h)
QA-506, Quality Assurance Review of Nuclear Station Modifications, Revision 4 dated 4/79 (i) APM, Appendix E The inspector reviewed references (b) through (i) to assure they meet the requirements of the accepted QA Program and Regulatory Guide 1.64, Revision 2 as endorsed by that Program. The inspector verified the following aspects of the NSM program:
-
Procedures have been established for control of NSMs
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Procedures for NSM document control have been established
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Controls and responsibilities have been established to assure NSMs will be incorporated into plant procedures, operator training and updating of plant drawings
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Controls require that documentation of NSM design and review processes were performed and transmitted to records storage
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Controls require that NSMs be performed in accordance with approved procedures
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Controls require that post-modification testing be performed and results evaluated
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Controls of similar requirements exist for jumpers and lifted lead To verify implementation of the previously stated aspects of the NSM program, the inspector reviewed six NSMs that have been implemente The six NSMs reviewed are listed belo NSM IMPLEMENTED ON 0524 10/23/80 ON 0627 2/18/81 ON 0869 5/24/80 ON 1248 6/13/80 ON 1447 2/13/81 ON 1595 12/1/80 Based on this review, one inspector followup item was identified. Perform ance of NSM ON-0869, Replace RBCU Fan Motor Starters as Necessary, imple mented 5/24/80 required drawings to be update Of the drawings required to
be updated (stamped to show that a NSM is in effect) 15 drawing aperture cards were found not stamped as required by reference (f).
The specific drawings not stamped are listed below:
OM-308-148 sheet 1 0-757-B 0-752-A19 0-757-E 0-757-D 0-752-A2 0-752-A15 0-757 0-757-A OM-308-140 OEE-138-20 OEE-138-21 OEE-138-22 OEE-138-23 Two drawing aperture cards were stamped as required (OM-307-65 and O-757C).
The drawing aperture cards listed for NSM ON-0869 are not all inclusive. A violation is not issued for failure to follow procedure due to the licensee's identification of similar type problems in the drawing control are The identification of these similar type problems is documented in the following: audit SP-81-7, (issued July 13, 1981),
findings 3 and 4; surveillance OS-81-1 (issued February 3, 1981)
which led to issuance of NCI-490; audit 0-80-8 (issued August 8, 1980), finding 6; and, surveillance OS-80-11 (issued March 19, 1980) which led to issuance of NCI-30 Discussions with plant QA personnel identified that progress had been made by plant personnel in upgrading the drawing control syste Until the specific problem with drawings related to NSM ON-0869 and the licensee identified problems on the previously mentioned audits and surveillance are corrected, lack of drawing control is identified as an inspector followup item (269,270,287/81-15-02).
1 Licensee Action on Previously Identified Inspection Items (92701) (Closed) Open Item (269,270,287/81-06-08):
Define periodic retrainin The inspector reviewed APM, Section 2.5, Qualifications and Training of Personnel, Revision 19 dated 6/81 and identified that the time span for retraining had been changed from periodically to annuall (Closed)
Open Item (269,270,287/81-06-09):
Instruct cognizant personnel in effects of prenatal radiation exposur The inspector verified during discussions with the training staff that cognizant personnel are now being trained in effects of prenatal radiatio In a letter from the Station Manager to group heads and section heads dated
May 27, 1981, Subject: Oconee Nuclear Station, Effects of Prenatal Radiation Exposure, File N OS-918.00, it was identified that all employees including supervisors and co-workers had to read the attach ments which included Regulatory Guide 8.1 (Closed) Open Item (269,270,287/81-06-10): Disposition of non-perma nent record The inspector reviewed SD 2.2.1(AS),
Procedure for Records Management, revised 5/81. This procedure delineates controls for disposition of non-permanent record (Open)
Open Item (269,270,287/81-06-11):
Organizational structur The inspector reviewed Technical Specification Figure 6.1.1 and APM 1.4, Organization, Revision 19 dated 6/81 and determined that the APM organizational structure does not accurately reflect the Technical Specification Fiqure 6.1-1 requirements with respect to nuclear safety engineers. The licensee plans to correct this discrepancy in the next revision of APM (Closed)
Inspector Followup Item (269,270,287/81-06-12):
Clarity of handwritten exams for microfilming. The inspector reviewed SD 2. (AS),
Procedure for Microfilming Documents, revised 6/81 and determined that positive controls had been established to assure that only legible microfilms were in storage. The inspector visited the training center and discussions with training personnel verified identified that tests were being written on white paper in either pencil or black ink and graded in black ink to insure that these records could be adequately microfilme (Closed)
Inspector Followup Item (269, 270, 287/81-06-13):
Inspect duplicate storage facility at company offices. During the QA inspec tion of the McGuire facility (IE Inspection Reports 50-369/81-17 and 50-370/81-05)
the company office records storage facilities were reviewe The same method of record storage is used for Oconee documents.