IR 05000280/1980010
| ML18139A720 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 07/03/1980 |
| From: | Belisle G, Ruhlman W, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18139A716 | List: |
| References | |
| 50-280-80-10, 50-281-80-11, NUDOCS 8009050441 | |
| Download: ML18139A720 (32) | |
Text
UNITED STATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGIA 30303 Report Nos. 50-280/80-10 and 50-281/80-11 Licensee:
Virginia.Electric and Power Company Richmond, VA 23261 Facility Name:
Surry 1 and 2 Docket Nos. 50-280 and 50-281 License Nos. DPR-32 and DPR-37 Inspection at Surry site near Surry, Virginia and a.t corporate offices in Richmond, Virginia I
.
I Inspe~tors:
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& 11 flviJzz~,Z:b D. S. Price SUMMARY Inspection on May 5-9, 12-16, and 20-23, 1980 Areas Inspected
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~cfo teigned This routine, announced* inspection involved 187 inspector-hours on site in the areas of QA Program Review, QA/QC Administration Program, Organization and Administration, Design Change Program, Test and Experiments, Receipt, Storage and Handling of Equipment and Material, Procurement, Document Control, Audit Program, Offsite Support Staff, Housekeeping/Cleanliness, Temporary Modifications, Offsite Review Committee; Review of Equipment Taken Out of Service; Qualification Practices for Quality Assurance Personnel; Observation of Activities; and Licensee Actions on Previously Identified Item B OOQ O 5-0 J./lf I*
Results Of the seventeen areas inspected, no items of noncompliance or deviations were identified in eight areas; eleven items of noncompliance were found in nine areas (Infraction -Failure to Follow Technical Specification Procedures, Para-graphs 9.a., 9.c., 13.a., 19.; Infraction - Failure to Perform Corrective Actions, Paragraphs 13.c., 14.b., 14.d.; Infraction - Failure to Control Vendor;s Manuals, Paragraph 13. b.; Infraction -
Failure to Perform/Document Safety Evaluation, Paragraph 17. a.; Infraction -Failure of SyNSOC Alternates to Have Required Qualifications, Paragraph 18.a.; Infraction - Failure to Perform Required SyNSOC Reviews, Paragraph 18.b.; Infraction - Failure to Correctly Perform QC Inspection, Paragraph 9.b.; Deficiency - Failure to Have Proper Record Storage, Paragraphs 12.a., 20., 20.; Deficiency -Failure to Identify External Interfaces - Design Control, Paragraph 9.f.; Deficiency - Failure to Follow QA Procedure - Warehouse, Paragraph 11.a.; Deficiency - Failure to Perform Audits, Paragraph 14.a.)
DETAILS Persons Contacted Licensee Employees
'i',, *l,, ;', *k 'i'(, ;', ;',..,*, 'i', ;', i'\\ * Alligood, Jr., Director, Nuclear Project Engineering Baum, Executive Manager, Licensing and QA Berryman, Director, Technical Analysis and Control DeWandel, Staff Assistant Ferguson, Executive Vice President Ferreria, UEA Representative Helm, Supervisor, QA Engineering Johnson, Superintendent Maintenance Kane, Superintendent Operations Kildoo, Station QC Martin, Jr., Supervisor, QA Operations and Maintenance Perkins, Director, QA Price, Director, Employee and Labor Relations Rhodes, Manager, Nuclear Technical Services Roberts, Warehouse Supervisor Saunders, Assistant Station Manager-Surry Smith, Jr., Director, Safety Evaluation and Control Stewart; Director, O&M Services Sylvia, flanager, Nuclear O&M Tower, Staff Engineer Wilson, Manager, Surry Power Station Woods, Secretary, SyNSOC Other licensee employees contacted included technicians, operators, mechanics, office personnel, QC personnel and offsite technical personne NRC Resident Inspector irD. Burke
- Attended exit intervie Exit interview The inspection scope and findings were sununarized on May 23, 1980, with those persons indicated in Paragraph 1 abov At the conclusion of each of the two previous weeks of inspection (May 9 and 16, 1980), site personnel were briefed on the results of the inspection activities conducted through those date The May 23, 1980, meeting included a summarization of all three weeks of activity and was held at the Richmond offices of the license *
-2-The following items. are defined and used throughout this report:
"Accepted QA Program and TQAP means VEPCO Topical Report Quality Assurance Program, Operation Phase, VEP-1-3A
"SySNOC" means System Nuclear Safety and Operating Cornmi ttee
"SNSOC" means Station Nudear Safety and Operating Cornmi ttee
"NPSQAM" means Nuclear Power Station Quality Assurance Manua The licensee was informed of items of noncompliance as discussed in Para-graphs 9.f., II.a., 13.b., 14.a., 17.a., 18.a., 18.b., 9.b.; those items that contributed to noncompliance as discussed in Paragraphs 9.a., 9.c.,
12.a., 13.a., 13.c., 14.b., 14.d., 19. and 20.; unresolved items as discussed in Paragraphs 6. a. and 7. a.; inspector identified. i terns as discussed in Paragraphs 3.c., 5.a., 5.b., 5.c., 11.b., 11.c., 12.b. and 14.c.; open items and proposed completion dates as applicable are discussed
~n Paragraphs 6.b., 7.b., 7.c., 9.d., and 19.; and licensee action on previously identified inspection findings as discussed in Paragraphs 3. and 22. The licensee acknowledged the inspectors' finding.
Licensee Action on Previous Inspection Findings (Closed) Infraction (280/79-08-01, 281/79-09-01): Faiiure to provide identification and control of materials, parts and component This matter was addressed in the VEPCO response dated May 24, 197 An inspector walk-through of the warehouse and supply room did not reveal any uncontrolled materials in storage. This item is close (Open) Deficiency (280/79-08-02, 281/79-09-02):
Failure to maintain records of activities affecting qualit The licensee's letters of June 6, 1979 and January 8, 1980, stated that a receipt inspection tag system would be used to provide the required traceability of materials used in safety-related systems and that full compliance would be achieved by January 31, 198 The inspector reviewed four maintenance reports (MRs):
MR S2003281356, Installation of New Reactor Coolant Instrumentation MR SI003251004, Replacement of Reactor Protection System Relay MR SI003030520, Replacement of Oscillator-Amplifier in Seal Differential Pressure Instrument MR SI003121531, Installation of New Body to Bonnet Bolts on Safety Injection System Valve MOV-1867 * *
-3-Documentary evidence that material and equipment conformed to procure-ment requirements sufficient to identify the specific requirements met by the material could not be produced for MRs S1003030520 and S1003121531 by the warehouse supervisor. Although full compliance with the licensee's stated corrective action appears to have been met, this corrective action alone is not sufficient in that items in the warehouse received prior to January 31, 1980, are not always tagged and can be issued lacking the required traceability as evidenced by the two examples abov Appropriate corrective action must include accounting for traceability of these item The licensee committed to attaching tags to all untagged items as they are issued from the warehouse commencing on May 23, 198 The licensee stated that response to this item of noncompliance would be revised and would include the date by which all warehouse items would be tagge This item will remain open pending future inspections of these additional corrective action (Closed) Deficiency (280/79-08-03, 281/79-09-03):
Failure to cap pipes, perform required inspections, and establish controlling procedure This matter was addressed in the VEPCO response dated May 24, 197 Observations by the inspector indicate that the licensee is capping required piping and performing periodic inspections of items in storag The licensee has established procedures for the care of motors in storage. The inspector observed that one of these procedures, Preventa-tive Maintenance Procedure 0-EPH-E-N3, was utilized in January 1980 to place recirculation pumps RS-1 and RS-2 into storag The associated procedure, 0-EPH-E-Ml, monthly inspection of stored motors, had never been performe This previous inspection item is considered closed but the failue to perform monthly maintenance checks is considered an example of lack of management attention. Since the failure to implement the monthly meggering of a motor in storage would have little safety or quality significance for the period noted, no citation is issue However, the lack of management attention which allowed this failure will be reviewed during subsequent inspections and will be tracked as Inspector FollQwup Item (280/80-10-14, 281/80-11-14).
Other examples of management. 'inattention are discussed in Paragraphs 5. a., 5. b.,
5. c., 11. b., 11. c., and 12. (Closed) Unresolved Item (280/79-08-04, 281/79-09-04):
Use of labels and tape which may not have met the requirements of ANSI N45. The licensee had stated that a study would be conducted to determine the acceptability of the labels and tap As an alternative, the licensee has discontinued use of these labels.and tape. This item is close A similar concern identified during this inspection is documented in Paragraph 1 Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve noncompli"ance or deviation New unresolved items identified during this inspection are discussed in Paragraphs 6.a. and *
-4-M~nagement Inattention to Items During the review of the various areas covered by this inspection, several cases were noted where actions had been taken by individuals but, due to lack of overall coordination and tracking, certain tasks had not been completed. In such cases, since no safety or quality problems were. identified and since the major development work had been completed, no citations were issue In other cases, certain managers had information available to them which they had not completely reviewed or acted upo In some cases, this was because the information was not in a form which facilitated revie These examples include items previously identified by internal audits or the NRC which, while the specific finding had been corrected, was repeated in the essential elements during a later inspectio Repeat items which were noncompliances have been cited either in this report or in previous NRC report In still other examples, lack of attention to detail was identifie In these cases, the collection of inattention was not significant enough to be citable during this inspection, but such inattention could lead to problems during subsequent activitie Seven items were identified that fit into one or more of the above categories.
Each item will be tracked as an Inspector Followup Item to assure that future items of noncompliance or deviations do not occu These items are either desrribed below or references are made to other paragraphs of this repor a. * Tracking System The licensee has a computer based system for entering items and commit-ments for tracking. However, the system is not equally implemented at both nuclear plant sites, is not uniform in data entry or format, and does not have a set of defined responsibilities for assuring proper trackin While there is no requirement for such an integrated, computer-based, data handling system, there are requirements in Title 10 of the Code of Federal Regulations and in commitments in the licensee's accepted Quality Assurance Program to assure that specific problem areas are identified, followed up, and correctly implemente At the exit interview the licensee stated that the current system would be more clearly defined and would consider such requirements as source of item (i.e., NRC Bulletin or Circular, internal audit, commitment),
description of action required, assignment of responsibility for completion, and a required or target completion dat As an example of the need for such a system, the inspector noted that a preliminary VEPCO report to the NRC (5D.55(e)-79-35) had identified that a followup report would be submitted on November 1, 197 An internal audit of the area identified that the report had not been submitted (but did not make the observation a finding) as of November 28, 197 The report was submitted on January 23, 198 This is assigned Inspector Followup Item (280/80-10-15, 281/80-11-15).
- Trend Analysis Program - Plant Equipment and Systems The licensee's TQAR contains a commitment to ANSI N18.7. This standard requires a program for analysis of equipment failures to detect trends and to allow for replacement programs or other corrective actions when adverse trends are detecte The licensee issued a QC Local Guidance Procedure 9.5.1 dated May 20, 1980, which appears to describ~ a program which would meet the applicable requirement However, since this procedure had not been in effect for a sufficient period of time to allow evaluation of its implementation, this area will be reviewed during a subsequent inspectio For tracking purposes this item is designated Inspector Followup Item (280/80~10-16, 281/80-11-16).
The item is placed in this section as an example of management inattention because the item was identified at the licensee's other nuclear facility in January 1979 as an area where upgrading was neede In-Depth Review of Audit Findings SyNSOC Audit 1979, Part F, Question 5, identified in the audit that QA monitor technicians were assigned to the drumming areas to assure control of radioactive shipments. However, it also states that QA has no one with health physics (HP) background or with expertise concerning the regulations concerning shipments for radioactive wast This statement was not classified as an audit finding because it did not violate any accepted QA Program or technical specification requirements.
A more in-depth review of this audit statement by management may have averted a violation of waste packaging/shipping regulations. which later, 'occurred. This area will be reviewed during a subsequent inspec-tion to determine if this is an isolated incident, or if it is indica-tive of a failure to adequately review audit reports. This is designated Inspector Followup Item 280/80-10-17, 281/80-11-17.
. Quality Assurance Program Review (35701B)
The inspector reviewed changes made to the Nuclear Plant Quality Assurance Manual from Change 23 dated January 18, 1977 through Change 64 dated May 8, 198 The review was to assure that the changes continued to implement the accepted Quality Assurance Program, applicable Regulatory Guides and ANSI Standards as contained in that progra The inspectors verified during the conduct of other portions of the inspection that personnel responsible for implementing these changes understood the significance of specific selected changes. Although lower tier documents are seldom generated, the inspectors verified that where used they contained appropriate revisions to reflect the changes in the Quality Assurance Manua No items of noncompliance or deviations were identified as a result of this revie However, one unre-solved item and one open item were identified as discussed below in Paragraphs 6.a. and Station Nuclear Safety and Operating Committee (SNSOC) Review of Jumpers In reviewing the Quality Assurance Manual (QAM), the inspector noted that SNSOC review of jumpers is required only when the jumper is to be
-6-installed in a system or component that is "operable or capable of being made operable." The inspector could find no defined controls to assure that jumpers installed in these systems, while they were shut down and not required, were subsequently either removed or reviewed by the SNSOC before the system or component was placed in the status of being "operable or capable of being made operable." Discussions with plant personnel indicated that, generally, all jumpers are removed before systems are upgraded to the "operable" status; however' such removal is not mandator Current controls maintain the status of all installed jumper Prior to returning from a shutdown or extended outage, the Shift Supervisor is required to review the jumper lo Again, there are no requirements that the SNSOC review any installed jumper that is to remain installed after the systems' status becomes
"operable or capable of being made oper*able."
In a report dated May 6, 1980, station QA audit S80-02 had identified a similar, although not identical, concer Replies for this audit were not due until May 28, 198 Until the station's reply to the S80-02 audit has been reviewed and evaluated, this item is designated as unresolved (280/80-10-12, 281/80-11-12). Conflicting Wording Between the TQAP and the NPSQAM Section 17.2.0.1 of the accepted QA Program (TQAP) states that the Program applies to preoperational activitie Section 2, Paragraph 2.1 of the NPSQAM states that the Program applies to operational activitie The licensee's current practices phase in the operations QA Program, during the preoperational activities. The licensee stated that the next revision of the TQAP and/or the NPSQAM would include appropriate changes to assure compatibility between the two documents and also an accurate reflection of the current VEPCO practices. Until the required revisions have been made and reviewed, this is designated Open Item 280/80-10-22, 281/80-11-2.
QA/QC Administration Program (35751B)
References:
(a)
Nuclear Power Station Quality Assurance Manual (b)
System Nuclear Safety and Operations Committee (SyNSOC)
Audit SyNSOC-79 The inspector reviewed the licensee Program documents to verify that they define the structures, systems, components, and activities to which the Program applies and that procedures exist for making changes to these document The inspector also reviewed the Program to assure that admini-strative controls for QA/QC Department. procedures, inspection and audit activities, and manuals exist to:
provide review and approval prior to issuance; methods and procedures for changes and revisions; and, methods and controls for distribution and recal Since the licensee uses the SyNSOC as the agent for reviewing the overall effectiveness of the QA Program, the referenced SySNOC audit was reviewe Followup of audit findings was also conducted to verify that, where the need was indicated, methods exist for and actions were taken to modify the QA Program to provide
-7-increased emphasis in defined "weak" or "problem" area As a result of this review, one unresolved item and two open items were identified as discussed in Paragraphs 7.a. and Unacceptable Response to SySNOC-79 In a memorandum dated March 17, 1980, the lead auditor for SyNSOC-79 informed the Chairman of the SyNSOC that the response by the site to Audit Finding SBE-N-01 was unacceptabl In a companion memorandum to the Chairman of the SyNSOC from the Supervisor, QA Operations and Maintenance dated May 23, 1980; the original memorandum was made applicable to Audit Finding SBE-S-01 (S" stands for "Surry" while "N" stands for "North Anna").
Both findings were essentially the same and dealt with the failure of the QC organizations to audit Station Nuclear Safety and Operation Committee (SNSOC) functions as well as several specific technical specification provision However, the Chairman of the SyNSOC had not taken action on these memoranda as of the completion of the inspectio Until action is taken and evaluated, this is designated Unresolved Item 280/80-10-13, 281/80-11-1 Lack of Defined Procedures For Unacceptable SyNSOC Audit Responses Although the Chairman of the SyNSOC had been notified that a site response to a SyNSOC audit finding was unacceptable approximately two months prior to this inspection, no action had been taken to obtain an acceptable response or to escalate the matter to higher authority for resolutio Although the licensee has a well defined system for timely handling and escalation of QA audit findings, this system does not apply to SyNSOC activitie Since the licensee is replacing the SyNSOC with other groups to perform current SyNSOC functions as well as additional required activities based on review of the incident which occurred at Three Mile Island in 1979, the licensee stated that appropriate systems and controls for inadequate or overdue responses would be developed, documented, and included in the procedures to be used by the group(s) which will be chartered to perform this audit function in the futur This reorganization is scheduled to be com-pleted by September 1, 198 Until these activities have been reviewed during a subsequent inspection, this is designated Open Item 280/80-10-23, 281/80-11-2 Need for Updated and Better Defined "Q" List In his review of SyNSOC-79, the Supervisor-QA Operations and Maintenance noted a conclusion that a more clearly defined "Q" list was neede This item is related to a previously identified item (NRC Item 280/79-08-05, 281/79-09-05) which is discussed in Paragraph 22 of this repor In a memorandum from the Supervisor-QA Operations and Main-tenance to the Chairman of the SyNSOC dated February 27, 1980, the validity of the need for an expanded, updated, and more clearly defined
"Q" list was acknowledged, but there was no commitment for actio At the exit interview the licensee stated that the "Q", list would be
-8-revised to take into account both the NRC and the SyNSOC finding The revised list will be completed by January 31, 1981, according to the current projection. This item will remain open until this action is completed (280/80-10-24, 281/80-11-24). Organization and Administration (36700B)
References:
(a)
Letter, C. M. Stallings.(VEPCO) to H. R. Denton (NRC dated March 31, 1980, Serial No. 297 (b)
Letter, C. M. Stallings (VEPCO) to H. R. Denton (NRC)
dated March 31, 1980, Serial No. 298 The inspector reviewed the organizational changes in both the onsite and offsite organizations which had been made since January 197 The changes in assignments are summarized belo Since all the changes in the onsite organization were essentially in-line promotions, no interviews with these personnel were conducted; only their documented qualifications were reviewe Personnel changes in the offsite organization changes that were not in-line promotions were interviewe These included the Director of Safety Evalua-tion and Control and the Director of Operations and Maintenance Service The Manager of Nuclear Technical Services was the most senior individual contacted and i_nterviewe The purpose of the interviews was to assure that the assigned personnel conceived of their position personally as the licensee had described that position in writin The qualifications of all personnel were reviewed to assure that they met the requirements set forth in the technical specifications and the Quality Assurance Progra The Director of Technical Analysis was also interviewed because the inspector was unable-to determine that the promotion was in-line prior to the intervie Changes within the onsite organization were discussed with the NRC prior to implementation. All changes associated with the April 1, 1980 reorganization, including position descriptions and qualifications, were transmitted to NRC in references (a) and (b). Onsite changes reviewed included:
T. L. Baucom, promoted and transferred to Richmond 01/01/79; W. L. Stewart, promoted to Station Manager 01/01/79; J. L. Wilson, promoted to Superintendent of Operations 01/01/79; G. E. Kane, promoted to Operating Supervisor 01/01/79; R. F. Sanders, promoted to Superintendent of Maintenance 01/01/79; R. L. Baldwin, promoted to Supervisor of Administrative Services 01/01/79; R. E. Nicholls, promoted and transferred to Richmond 02/16/79; H. W. Kibler, promoted to Electrical Supervisor 02/16/79; W. L. Stewart, promoted and transferred to Richmond 04/01/80; J. L. Wilson, promoted to Station Manager 04/01/80; G. E. Kane, promoted to Superintendent of Operations 04/01/80; R. L. Baldwin, promoted and transferred to Richmond 04/01/80; W.R. Runner, Jr., promoted to Supervisor of Administrative Services 04/01/80
-9-Offsite changes reviewed included:
J. H. Ferguson, Executive Vice President-Power, 02/01/80; B. R. Sylvia, Manager-Nuclear Operations and Maintenance, 04/01/80; W. L. Stewart, Director-Maintenance and Operations Services, 04/01/80; J. T. Rhodes, Manager-Nuclear Technical Services, 04/01/80; E. R. Smith, Jr., Director-Safety Evaluation and Control, 04/01/80; R. M. Berryman, Director-Technical Analysis, 04/01/80; and W.W. Cameron, Director-Chemistry and Health Physics, 04/01/8 No items of noncompliance or deviations were identifie.
Design Change Program (37702B)
References:
(a)
VEPCO Nuclear Power Station Quality Assurance Manual, Section 3, Design Control, Revision II, dated September 27, 1979 (b)
Periodic Test (PT) 18.2, Safety Injection System Testing, revised January 3, 1980 (c)
Administrative Procedure 29, Conduct of Operations, revised February 7, 1979 (d)
Nuclear Engineering Services Project Manual, Revision 6, dated March 1980 The inspector reviewed the licensee's procedures for conducting the design change program to verify inclusion of appropriate requirements for:
reviews and approv;als, unreviewed safety question examination, fire protection, controlling design interfaces, controlling changes to design documents and plant procedures, post-modification acceptance testing, and operator trainin The following safety-related design changes were reviewed to verify implemen-tation of these requirements:
DC-78-S35, Low Head Safety Injection and Outside Recirculation Spray Pump Bell Mouth Modifications, implemented in Unit DC-79-S22, Containment Sumps* and Steam Drain Isolation on SI, implemented in Unit DC-79-S42, Modification to 480V Safety Bus-Surry Power Station Unit 2, implementation in progres DC-79-S54, Direct Indication of Pressurizer Safety Valve Position, implementation in Unit 1 in progres As the results of this inspection two items contributing to one item of noncompliance, Paragraphs 9.a. and 9.c.; two items of noncompliance, Para-graphs 9.b. and 9.f.; and two open items, Paragraphs 9.d. and e., were identified by the inspector. Failure to Follow Procedure Sections 4.2.12 and 4.2.16 of Final Design Controlling Procedure DC-79-S22, collectively required cable IVB45 conductor MS 110C4 and
-10-cable IVB43 conductor MS 110C4 to both be connected to Terminal 8 of Terminal Board 6J in compartment 6 of Unit 1 SI (Safety Injection)
Rack The inspector observed both cables connected to Terminal 9 rather than Terminal 8 as required. This failure to follow procedures with other examples in Paragraphs 9.c., 13.a. and 19. constitutes an item of noncompliance (50-280/80-10-01).
Both terminals had previously been unused, therefore the circuit functioned as designed. It was also noted that Drawing 11448-ESK-6CD4, Elementary Diagram Containment Isolation Trip Valves, was revised to reflect connection at Terminal 8 and no revisions to or deviations from the Final Design Controlling Procedure were mad Failure to Perform Proper QC Verification Section 4.2.18 of Final Design Controlling Procedure DC-79-S22 required QC verification that the wiring and tagging accomplished under this design change was correc Though this step was initialed and dated for Unit 1, the installation of the design change was not in accordance with the referenced drawin Two conductors were improperly landed as discussed in Paragraph 9. This example of failure to properly inspect to assure quality constitutes an item of noncompliance (50-280/
80-10-07).
Failure to Read Items in Required Reading File Admintstrative Procedure 29, Section 29.8.3 requires all shift personnel to read items in a required reading file within a period specified on each item and to initial the Required Reading Cover Shee In a sample of thirty-six items, these requirements were routinely missed by two licensed operator From a sample of seven items, approximately twenty percent of all operators had not completed these requirements by the due dates. The items missed by one Control Room Operator were noted in the Required Reading File by serial number and due date as follows:
Serial II Due Serial ff Due Serial ff Due Serial :fl Due
10/2/79
8/16/79
8/7 /79
10/22/79
8/9/79
8/17/79
6/7 /79
10/16/79
8/17 /79
- 8/ 14/79
8/3/79
10/3/79
6/29/79
6/29/79 2 /16/79
8/28/79
7 /3/79
8/13/79
8/9/79
7 /9/79
7 /28/79
7/31/79 The items missed by one shift supervisor were:
Serial ff Due Serial ff Due Serial ff Due Serial fl Due
10/2/79
8/17/79
8/13/79
8/3/79
8/9/79
8/16/79
8/7 /79
8/16/79
9/11/79
8/17 /79
5/7 /79
8/9/79
9/14/79
8/14/79
6/7 /79
-11-The following seven requirements applicable to twenty-three licensed operators were overdue and not yet initialed a total of thirty-one times:
Serial ff Due Serial ii
Due* /1/80 2/15/80 1/31/80 12/31/79
57 1/31/80 12/31/79 2/22/80 This failure to follow procedures has been combined with similar examples in Paragraphs 9.a., 13.a., and 19. to collectively constitute an item of noncompliance (50-280/80-10-0l, 50-281/80-11-0l).
Revise Procedures at the Time Design Changes are Made Operational Measures have been recently established in Subsection 5.8.1 of NPSQAH, Section 3.0, Design Cont{ol which assure revisions to operating procedures, drawings, and training *programs are effected at the time a design change is made operational. However, there are no formal requirements to assure that periodic testing and periodic maintenance programs are in place at the time the design change is made operationa The periodic test noted as Reference (b) was not revised until January 3, 1980, to reflect the implementation of Design Change DC-79-S22 on Unit 1 in August 197 No periodic testing was missed; however, this was rrot the result of administrative control Until the licensee revises procedures to assure that periodic testing and periodic main-tenance programs are in place at the time design changes are made operational, this item is open (50-280/80-10-25, 50-281/80-11-25).
The Station Manager committed to revising these procedures prior to May 30, 198 Include Specification Standards in Design Change DC-79-S22 The Final Design and Final Design Implementing Procedures for Design Change DC-79-S22 did not contain specifications standards for the performance of the wiring including cable rerouting accomplished under this design chang Until these specifications are incorporated in DC-79-S22, this item is open (50-281/80-11-27).
The Station Manager committed to correction of this item prior to May 15, 1980 and imple-mentation of DC-79-S22 on Unit Failure to Identify External Design Interfaces The inspector reviewed Sections 2.3, 2.6, 8.1, and 8.13 of the Engineering Services Project Manual to determine if these sections met the require-ments of ANSI N45.2.11-1974 as committed to by the accepted QA Progra ANSI N45.2.ll-1974, Sections 5.1.1 - 5.1.4 requires in part for the
-12-identification of interface, responsibilities to be def.ined and documented, lines of communications to be established and procedures for documenta-tion to control the flow of design information betweeµ organization CFR 50, Appendix. B, Criterion III requires in part that measures shall be established for the identification and control of design interfaces and for coordination among participating design organization Collectively Sections 2.3, 2.6, 8.1 and 8.13 of the Engineering Services Project Manual do not establish these measure This constitutes an item of noncompliance (280/80-10-09, 281/80-11-09).
However, since no problems with the control of these interfaces were found and only documentation was lacking a lower level of severity is assigne.
Test and Experiments (37703B)
Reference:
NPSQAM Section 11, Revision 11, dated 8/2/79 Program Review The inspector verified that a formal method has been established to handle request or proposals for conducting special tests involving safety-related components, systems or structures; that provisions have been made to assure special test will be performed in accordance with approved written procedures; that responsibilities have been assigned for reviewing and approving special test procedures; that a system, including assignment of responsibility, has been established to assure that all special tests will be reviewed to determine whether they are described in the FSAR and that responsibilities have been assigned to assure that safety evaluations as required by 10 CFR 50.59 will be developed to assure that it does not involve an unreviewed safety que~tion or a change in the technical specification Implementation The licensee's program for special test was reviewed at the Surry Site with respect to the referenced documen The specific special test reviewed were:
S.T. 35 Inside Recirculation Spray Pump Test
- Completed 1/23/80 S.T. 52 RCS Flow Measurement Data
- Completed 6/6/79 S.T. 58 Emergency Generator Neutral Inspection - Completed 9/20/79 S.T. 64.1 Proving Preliminary Procedure for Implementation of HSD and Monthly ISI Testing
- Completed 9/14/79 S.T. 77 Testing of Gaseous Waste Valves
- Completed 12/21/79 S.T. 82 Overtravel Test on Westinghouse BFD Relays
- Completed 3/25/80 During the review the inspector identified that the 10 CFR 50. 59 evaluation for S.T. 58 was not included in the completed test package; however, the licensee was able to produce evidence that the evaluation had been performed and this evaluation was put in the special test packag *
-13-No items of noncompliance or deviations were identifie.
Receipt, Storage and Handling of Equipment and Material (38702B)
References:
The references listed under Paragraph 10. above are also applicable to this sectio The inspector reviewed the licensee's program for the receipt, storage, and handling of equipment and material with respect to selected elements of the licensee's TQA The inspection was to verify that administrative controls had been established concerning receipt inspection of safety-related materials; preparation and retention of required documentation; control of acceptable, nonconforming and conditional release items; control of items in storage including levels of storage, identification of items, inspections and maintenance; and control of handling activitie Implementation of the licensee's program was verified by observing the licensee's control of several safety-related item The inspector selected three safety-related items which required special environmental controls and verified that they were maintained in accordance with administrative controls. The specific items selected were:
card assembly for full length rod control system regulation, stock number 2280177 card wssembly for full length rod control system firing circuit, stock number 2280172 card assembly for full length rod control system failure detection, stock number 228017 The inspector selected nine items in storage to verify that tagging/marking allowed traceability of the items to purchase, receipt and procurement documents. The specific items selected were:
seal kit from ITT-Grinnell Corp., stock number 2273502 rectifier assembly from C&D Batteries, stock number 0715793 control unit, diode section from C&D Batteries, stock number 0715358 control unit, regulator section from C&D Batteries, stock number 0715357 deflector discharge in-board from Bingham-Williamette Company, stock number 2938825 deflector, discharge out-board from Bingham-Williamette Company, stock number 2938827
-14-1.25-inch tee, stock number 3871126 ASCO solenoid valve from Industrial Supply Company, stock number 076091 The inspector selected six items in storage that had been identified to be in a "hold" status to verify that administrative controls on these items were being implemented. The specific items selected were:
3/4-inch pipe,' schedule 40 and schedule 80, and three-inch pipe, schedule 160 from Roy Miller of West Virginia, purchase order 34369 -
hold tag 8140 ASCO solenoid valve from Industrial Supply Company, purchase order 29261 - hold tag 8130 locknut from Baily Meter Company, purchase order 27979 - hold tag 2592 relay from Westinghouse Electric Corporation, purchase order 75542 -
hold tag 1365 timing relay from Southern Controlls, purchase order 27002 - hold tag 2645 As a result of the inspection, one example of noncompliance discussed in Paragraph 11.a., and two inspector followup items, discussed in Paragraphs 11. b., and 11. c., were identifie Procedural Compliance 10 CFR 50, Appendix B, Criterion V, and the TQAP, Section 17. 2. 5, require that activities affecting quality be prescribed by documented instructions and procedures, and that these activities be accomplished in accordance with these instructions and procedure The TQAP, Section 8.5.1, requires, in part, that storeroom personnel, at the time of receipt inspection, attach a tag to the item recording the Quality Category (QC) of the ite Quality Assurance personnel are also required to verify the information recorded on the ta The inspector observed five items stored in the warehouse which were incorrectly marked as QC I items. These items were all QC II components:
Deflector, discharge in-board manufactured by Bingham-Williamette Company, P/N 8320-A -33740, stock number 2938825 Deflector, discharge in-board manufactured by Bingham-Williamette Company, P/N 8320-A-38434, stock number 2938826 Deflector, discharge out-board manufactured by Bingham-Williamette Company, P/N 8320-A-33741, stock number 2938827 Control unit, diode section manufactured by C&D Batteries, stock number 0715358
-15-Control unit, regulator section manufactured by C&D Batteries, stock number 071535 These examples of failure to follow approved procedures constitute an item of noncompliance with respect to 10 CFR 50, Appendix B, Criterion V (280/80-10-10 and 281/80-11-10).
Due to the unique use of the above components and the low probability of their use in a safety-related system, this item is assigned a lower severity leve Use of Tape on Pipe Ends The inspector observed the use of tape on the ends of two pipes located in the storeroom:
two-inch pipe ASTM A312-TP312, purchase order 83445 two-inch pipe ASTM TP316, purchase order 29042 The warehouse supervisor could not determine if this tape met the requirements of ANSI N45.2.2, Appendix A3.5.2 which requires that the tape contain less than 0.10 percent by weight of halogen and sulfu The licensee has committed to determining if the subject tape meets the above requirements. This item will be reviewed during a subsequent inspection (280/80-10-18 and 281/80-11-18). Establishment of Shelf Life Program ANSI N45.2.2-1972 requires that proper maintenance of items during storage be documented and written procedures or instructions be estab-lishe The licensee had identified, under this requirement the need for a system to remove from storage items that had reached the end of their effective shelf life. An inventory of applicable items had been generated and inquiries of associated vendors made to determine each item's shelf life. This program had halted at the time of a change in warehouse supervisor Establishment of a shelf life program will be inspected at a future date to determine whether the licensee has implemented an effective program (280/80-10-19 and 280/80-11-19).
1 Procurement (38701B)
References:
(a)
Nuclear Power Station Quality Assurance Manual (NPSQAM),
Section 2, Quality Assurance Program, Revision 6, dated 6/4/79 (b)
NPSQAM, Section 4, Procurement Document Control, Revision 4, dated 3/4/80 (c)
NPSQAM, Section 7, Control of Purchased Material, Equipment and Services, Revision 4, dated 7/23/79
(d)
-16-NPSQAM, Section Materials, Parts 11/23/76 8, Identification and Control of and Components, Revision 1, dated (e)
NPSQAM, Section 13, Handling, Storage and Shipping, Revision 2, dated 5/11/7 The inspector reviewed the licensee's procurement program with respect to-selected elements of the licensee's TQA The inspection was to verify that administrative controls had been established for the preparation, review, approval and revision of procurement documents and for the qualification and audit of supplier Implementation of the procurement program was verified by reviewing the procurement documents of several safety-related items and verifying that they were prepared in accordance with administrative controls, that they were purchased from qualified vendors, and that they required the vendor to supply appropriate documen-tation of quality. The specific items selected were:
developer and dye penetrant from Deteck, Inc., purchase order 35310, dated 5/9/80 male connection from Dibert Valve and Fitting Company, purchase order 34871, dated 5/2/80 two-inch tee from Industrial Piping Supply Company, purchase order 28866; dated 5/1/80 thermostat from Richmond Industrial Sales, purchase order 28825, dated 3/17/80 35-inch long aluminum bronze stock from Federal Bronze Products, Inc.,
purchase order 25318, dated 2/1/80 Agastat relay from Control Products Division, purchase order 24872, dated 2/5/8 As a result of the inspection, one example contributing to an item of noncompliance, discussed in Paragraph 12. 1., and one inspector followup item, discussed in Paragraph 12.b., were identifie Failure to Establish Record Control Program The inspector observed that purchase requisition forms were not. being maintained at the site and that repeating purchase requisition cards were being kept in filing cabinets located in the site warehous CFR 50, Appendix B, Criterion II, requires the licensee to establish a quality assurance program which complies with Appendix This program is described by the licensee in the TQA Section 17.2.7 of the TQAP requires that a copy of the purchase requisition and other pertinent documentation become a part of the station record Section 17.2.0.2 of the TQAP states that records will be controlled as required by ANSI N45.2.9-197 Section 5.6 of this standard requires either a
- storage vault or separate dual storage facilitie This example of failure to establish a QA program for the control of records, collec-tively with Paragraph 20, constitutes an item of noncompliance with respect to 10 CFR 50, Appendix B, Criterion II (280/80-10-08 and 281/80-11-08).
Inattention to Detail Several minor discrepancies in the licensee's administrative controls were observed:
The purchase order or requisition number was not included on the certificate of conformance associated with purchase order 3531 The stores department and purchasing department sections of the repeating purchase requisition and associated with purchase order 28825 were not complete The storeroom, stores department and purchasing department section of the repeating purchase requisition cards, associated with stock numbers 2938825, 2938826, and 2938827, were not complete These items indicate a possible lack of attention to detail by licensee managemen This matter will constitute an inspector followup item and will be reviewed during a subsequent inspection to better determine licensee performance (280/80-10-20 and 281/80-11-20).
.
1 Document Control (39702B)
References:
(a)
NPSQAM, Section 5, Instructions, Procedures and Drawings, Revision 17, dated June 4 1979 (b)
NPSQAM, Section 6, Document Control, Revision 7, dated April 17, 1978 (c)
ADM 37, Station Drawing, Revision Distribution, dated January 19, 1977 (d)
ADM 51, Control of Procedures, dated April 30, 1980 The referenced documents were reviewed with respect to the licensee's accepted Quality Assurance Program and ANSI N18.7-1972 as committed to by that progra The inspection was to verify* that administrative controls have been established; that required current drawings will be provided to the plant site in a timely manner; that provision for the control of obsolete drawings and that master indicies are maintained for drawings and manual The inspector selected a representative sample of safety-related drawings and procedures and verified that the record file and issued copies were
-18-consistent with the master index. Documents selected and locations inspected are as indicated:
Unit 1 Drawings:
FM21A, 21B, 22A, 22B, 22C, 22D, 22E, 22F, ESKIOAT, FPllA and l lB were reviewed at the following locations; Operations Coordinator, Resident QC, Technical Services, Electrical Maintenance, Instrumentation Shop, Mechanical Maintenance, Engineering Services and Station Record Unit 2 Drawings:
FM105A, 105B, 105C, ESK6BN, 6AC, FPllA and llB, were reviewed at the same locations as for Unit Unit 1 Procedures:
AP 52, OP IA, 1. 4, 7. 5, 2. 1, 2. 2 and 8. 6 were reviewed at the following locations:
Control Room, Operations Coordinator and Station Record Unit 2 Procedures:
AP 5.2, 13, 29, 30, 4, OP lB, 2.1 and 5.1 were reviewed at the same locations as for Unit Jhe following procedures were reviewed at the following locations:
Procedure IMP-C-lFM-20 IMP-C-CR-029 IMP-C-RP-9 '
IMP-C-NI-19 IMP-C-NI-17 MMP-P-CS-022 MMP-C-RC-038 MMP-C-H55-076 MMP-P-G-013 MMP-P-FW-004 EMP-C-MOV-11 EMP-C-PE-21 EMP-C-EPCR-34 EMP-C-EPH-03B EMP-C-EPH-02A Electrical Shop X
X X
X X
Mechanical Shop X
X X
X X
Instrument Shop X
X X
X X
Station Records X
X X
X X
X X
X X
X X
X X
X X
As the result of this review one item of noncompliance Paragraph 13.b. and two examples of two additional items of noncompliance Paragraphs 13.a. and 13.c. were identifie Failure to Maintain Drawings During review of the drawings listed above, the inspector identified the following:
Drawing FM22E in the technical services office was the wrong revision; Drawings FPllA and llB in the engineering services office were missing; Drawing FM105B in the mechanical maintenance office was the wrong revision; and Drawings FMIOSA, 105B and 105C in
-19-the resident QC offices were missin These three drawings were part of a stick file containing approximately twenty-two. drawing The stick file could not be locate The Technical Specifications Section 6.4.A states in part that detailed written procedures... shall be provide Section 6.4.D states in part that all procedures... shall be followe Contrary to the above, ADM 37, Section 37. 1. 2, which requires that supervisors shall assure that these controlled drawings are updated to reflect the latest revision reviewed was not followe This failure to follow procedures is one example of an item of noncom-pliance (280/80-10-01, 281/80-11-01).
Other examples are given in Paragraphs 9.a., 9.c., and 1 Failure to Control Vendor Manuals The NPSQAM, Section 10, Paragraph 4.2 states in part that personnel so assigned shall become familiar with the procedure being used and other pertinent documents such as technical manuals....
The NPSQAM, Section 16, Paragraph 6.5.4.b.(6) states in part that references should be made to vendor manuals... as applicabl If vendor manuals provide the necessary detailed steps, it shall not be necessary to reproduce these in the procedure, but they can merely be referenced. The NPSQAM, Section 6, Paragraph 5.1.2 has no provisions for the control of vendor manuals. 10 CFR 50, Appendix B, Criterion VI requires in part that measures be established to control the issuance of documents... which.prescribe all activities affecting qualit The inspector ascertained by direct questioning of licensee personnel that vendor manuals are not controlle The inspector examined two procedures for safety-related systems and ascertained that references were being made to perform actions as required by vendor manual The procedures reviewed were:
CAL-SW-039 IMP-C-NI-17 Channel F-SW-106D Return from Recirc. Spray HXlO, dated 6/30/77 Replacing the Intermediate Range Nuclear Instrumentation Detector, dated 8/17/77 The use of non-controlled vendor manuals in procedures which prescribe activities affecting quality constitutes an item of noncompliance (280/80-10-03, 281/80-11-03). Failure to Perform Corrective Action ADM 51, Control of Procedures, Section 51. 3. 2 and 51. 3. 3 requires in
-20-part that each supervisor who maintains an unused procedure depository shall establish procedures that:
(1)
Insure only current and approved procedures are in the unused depositor (2)
Insure that adequate supplies of unused procedures are in han QA Audit S79-27 conducted on March 12, 1980, Conclusion 4 identifies these lack of procedures by supervisors and concludes that due to a low error rate the existing "system" is working, consequently this is not an open ite CFR 50, Appendix B, Criterion XVI requires in part that measures be established to assure conditions adverse to quality are promptly identified and correcte The lack of corrective action in regards to Conclusion 4 of QA Audit S-79-27 constitutes one example of an item of noncompliance (280/80-10-02, 281/80-10-02).
Other examples are given in Paragraphs 14.b. and 1.
Audit Program (40702B)
References:
(a)
NPSQAM, Section 18, dated 6/4/79 (b)
VEPCO QAM, Section 18 (c)
TQAP, Section 17.2.18, Amendment 3, dated 3/1/77 The referenced documents were reviewed with respect to the licensee's accepted Quality Assurance Program and ANSI N45.2.12 (Draft 3, Revision 4 1974) as committed to by that progra The inspection was to verify that the scope of the audit program has been defined and is consistant with technical specification and QA Program requirements; that responsibilities have been assigned in writing for the overall management of the audit program; that administrative channels have been defined for taking correc-tive actions when deficiencies are identified during audits; that the audited organization is required to respond in writing to audit findings; that distribution requirements for audit reports and corrective action responses have been defined; that checklists are required to be used in the performance of audits; that the long-range audit schedule areas to be audited are consistent with the QA Program commitments; and that the audi~s were conducted by trained personnel not having direct responsibility in the areas being audite The inspector reviewed audits at the Company offices and at the Surry 1 and 2 site. The audits reviewed were:
QAE 79-68 QAE 79-65 S-79-17 S-79-2 S-79-4 Power Station Engineering conducted 5/2/79 Production Technical Support Group Conducted 2/14 and 2/21/79 Operator Training and Qualification conducted 9/27/79 Verification of Input Data for the Piping Stress Reanalysis conducted 4/11/79 Fire Protection Surry Power Station conducted 9/28-11/27/79
S.-79-6 S-79-22 S-79-27 SYNSOC-21-General Employee Training and Retraining, * Technical and Maintenance Training and Qualifications conducted 7/5-7/9/79 Engineering conducted 10/24-26/79 Station Procedures conducted 2/27/80 - 3/10/80 1979 conducted 12/17-19/79 As a result of this review one item of noncompliance, Paragraph 14.a., two items contributing to two items of noncompliance, Paragraphs 14. b. and 14.d. and one inspector followup item Paragraph 14.c. were identifie Failure to Perform Audits 10 CFR SO, Appendix B, Criterion XVIII requires in part that compre-hensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance progra The TQAP, Section 17.2.18 states in part that provisions are established requiring that audits be performed in those areas where the requirements of Appendix B to 10 CFR 50 are being implemented. ANSI N45.2.12, Revi-sion 3, Draft 4, as endorsed by the TQAP, requires in part that a comprehensive audit system which shall be planned, documented and imple-mented to verify compliance with the elements of a quality assurance progra It further states that applicable elements of the quality assurance program shall be audited at least annually or at least once within the life of the activity, which ever is shorte At the corporate offices in Richmond, Virginia, audits are not conducted in the areas of procurement, records or document contro This was ascertained by direct questioning of members of the QA/QC organizatio This failure to perform audits to verify all aspects of the quality assurance program constitutes an item of noncompliance (280/80-10-11, 281/80-11-11).
Major activities in each of these areas are conducted on site and have been audited on site, therefore a lower level of severity has been assigne Failure to Notify Management of Corrective Action 10 CFR SO, Appendix B, Criterion XVI, requires in part that measures shall be established to assure that conditions adverse to quality are promptly identified and corrected. It further states that identi-fication of significant conditions adverse to quality and the corrective action taken shall be documented and reported to appropriate levels of
. management. The NPSQAM, Section 18, Paragraph 5. 2. 2 states in part that a listing of open outstanding items shall be prepared monthly and routed to interested parties.
Audit results are distributed to appropriate levels of management (NPSQAM, Section 18, Paragraph 5.4.7) and these personnel are informed of outstanding open audit items monthly (NPSQAM, Section 18, Paragraph 5.5.2); however, they may not be aware of an audited organization's response to an item or QA's evaluation of the adequacy of the respons *
-22-This lack of management review of the response can limit the quality of the corrective action as required by Criterion XV The inspector reviewed the results of four audits, S-79-17, S-79-2, S-79-4 and S-79-6, and ascertained by direct questioning of QA personnel that management was not informed of the responses to the audit finding These audits were four of approximately twenty-three held at the Surry Site during 1979, and may not represent the most significant findings of all audits conducte This failure to notify appropriate levels of management of significant audit findings is one example of an item of noncompliance (280/80-10-02, 281/80-11-02). Other examples are discussed in Paragraphs 13.c. and 1 Expanded QA Responsibilities The VEPCO Quality Assurance Manual is currently under revisio Section 18.1, Paragraph 4.1 outlines the responsibilities of the Supervisor, Quality Assurance Engineering to assure that audits are conducted at stated interval The areas of the audits that are being performed has been enlarged to include audits as directed by the Supervisor, Quality Assurance Operations and Maintenance. Until these additional responsibilities are delineated in writing this will be identified as inspector followup item (280/80-10-21, 281/80-11-21).
Failure to Initiate Corrective Action - SyNSOC Audit 10 CFR 50, Appendix B, Criterion XVI, states in part that measures shall be established to assure that conditions adverse to quality are promptly identified and correcte The accepted QA Program, Section 17.2.18, states in part that the responsibility for the analyzing of audit reports for trends and effectiveness lies with the Supervisor, QA Operations and Maintenanc The SyNSOC-1979 audit, Part C, Item 5, identified that no formal program exists for analyzing trends but it was not called a finding, nor has any corrective action been take This failure to identify or take correc-tive action constitutes an item of noncompliance (280/80-10-02, 281/80-11-02). Other examples are,identified in Paragraphs 13.c. and 1.
Off site Support Staff (40703B)
References:
(a)
Administrative and Procedures Manual (b)
Procurement Policy Manual (c)
Nuclear Engineering Services Project Manual (d). Nuclear Power Station Quality Assurance Manual The referenced documents were reviewed to verify that the licensee estab-lished administrative controls to describe the responsibilities, authority
-23-and lines of communications available for personnel who perform the following offsite support functions:
Production Operations Technical Support Quality Assurance Procurement Power Station Engineering The inspector interviewed one manager, one group leader and one staff member in the disciplines mentioned with the exception of the technical support section where only the manager was interviewed and verified they understood their responsibilities and authorities and that they were qualified for their related wor The inspector reviewed the results of two QAE audits; QAE 79-68, Power Station Engineering, conducted May 2, 1979, and QAE 79-65, Production Technical Support Group, conducted February 14 and 21, 197 No items of noncompliance or deviations were identifie.
Housekeeping/Cleanliness Program (54701B)
Reference:
ADM-40, Station Housekeeping, dated 8/27/76 The referenced document was reviewed to insure that the licensee is implementing adequate housekeeping and cleanliness controls to assure that the quality of safety-related systems is not degrade The inspection was to verify that administrative controls for general housekeeping and for cleanliness practices at the facility have been establishe The inspector toured the Units 1 and 2 auxiliary building and Unit 2 reactor vessel head are No items of noncompliance or deviations were identifie.
Temporary Modifications (37702B)
References:
(a)
NPSQAM, Section 14, dated 8/2/79 (b)
NPSQAM, Section 3, dated 9/27/79 The referenced document was reviewed with respect to the requirements of 10 CFR 50.59 and the licensee's accepted Quality Assurance Progra The inspection was to verify that controls require:
the review and approval of temporary modifications in accordance with 10 CFR 50.59; the use of detailed approved procedures when performing temporary modifications; that a formal record be maintained of status of temporary modifications; that functional testing of equipment following installation or removal of temporary modifi-cations be performed and that periodic reviews of jumpers be performed.
-24-The inspector reviewed three entries in the jumper log for Unit 1 and Unit 2 and verified by direct observation that they were installed in accordance with the licensee's procedure The entries reviewed were:
1-80-64, 1-79-68, 1-80-34, 2-78-3, 2-78-4, IAN 55 and 55 During this review one additional jumper log entry was reviewed for Unit 1 that installed two jumpers in limit switch compartments of MOV-CS-lOlA and B on limit switch number As a result of this review one item of noncompliance was identified as discussed in Paragraph Failure to Perform/Document Safety Evaluation The Surry Power Station Jumper Log Sheet (Form 888.84A) is required to be filled out if a jumper is installed without an approved procedur A form was filled out for two jumpers that were installed in limit switch compartments of MOV-CS-lOIA and Bon limit switch number These valves, 101A and B, are the Containment Spray discharge valve These jumpers were installed on 7/2/7 The expected date of removal of these jumpers as explained in"step (5) of the form is NEVER:.
10 CFR 50. 59 (a) (1) states in part that changes can be made in the facility without prior Commission approval unless the proposed change involves an unreviewed safety questio The installation of these jumpers was not evaluated by the licensee to meet the requirements of 10 CFR 50.59 (a)(2) in that a safety evaluation was not performed/
documente This failure to perform/ document the required safety evaluation constitutes an item of noncompliance (280/80-11-04).
1 Offsite Review Committee (40701B)
Reference:
SyNSOC, Bylaws and Procedures, Revision 3 dated April 1, 1980 The referenced document was reviewed with respect to the technical specifi-cations and ANSI Nl8.7-1972 as committed to by the accepted QA progra The review was to verify that group membership and qualifications are as required by the technical specifications; that group meetings convened during the previous year were held at the required frequency, that items reviewed included persons who constituted a quorum and had expertise in the areas reviewed and that the review group reviewed activities as required by the technical specification The inspector reviewed SyNSOC minutes from January 1979 through May 198 As a result of this review two items of noncompliance were identified as discussed in Paragraphs 18.a. and 18.b. Failure to Meet Minimum Requirements for SyNSOC Membership The Technical Specifications, Section 6.1.C.2.b states in part that the minimum qualifications for membership to the SyNSOC will be an
- 1 *
-25-engineering graduate or equivalent with combined nuclear and conven-tional experience in power station design and/or operation of eight year Two members were appointed as alternates to the SyNSOC without the required eight years nuclear and conventional experienc One member commenced work at VEPCO in May 1972 and was appointed as an alternate in July 1979 and the other commenced work at VEPCO in June 1975 and was appointed as an alternate in May 197 It should be noted that both men had previous military experience in nuclear weapon These members participated as voting members of the SyNSOC since January 1979. This lack of necessary qualifications as required by the technical specifications constitutes an item of noncompliance (280/80-10-05, 281/80-11-05). Failure to Review Violations of Applicable Regulations The Technical Specifications, Section 6.1.c.2.h.4(a) states in part that the SyNSOC is required to review violations of applicable codes, regulations,....
The SyNSOC does not regularly review all IE reports with,items of noncomplianc Individual members may review these reports by being on the distribution of the report The secretary of the SyNSOC stated during an interview with the inspector that IE reports used to be routinely distributed and reviewed by individual members of the SyNSOC but this practice had been discontinued since May 197 This failure to review violations of applicable codes and regulations by the SyNSOC as required by the technical specifications constitutes an item of noncompliance (280/80-10-06, 281/80-11-06).
Review of Equipment Taken Out of Service (92706B)
The inspector reviewed the control room equipment status board and selected the steam-driven auxiliary feedwater pump to review for implementation of appropriate administrative control The inspector then reviewed the Minimum Equipment List and found that all three auxiliary feedwater pumps were listed as "operable"; there was a note in the block to indicate that the overspeed trip valve was closed on the steam-driven auxiliary feedwater pump (AFW). * The inspector discussed this designation with two licensed operators and one senior licensed operator in the control room and all three agreed that the pump was operabl The inspector then discussed the issue with the Superintendent of Operations who also considered the pump to be operabl The inspector then discussed the definition of operable and reached agreement with those previously interviewed that, with the overspeed trip "tripped", the steam driven AFW pump was not operabl The Minimum Equipment List was changed to reflect that only the two motor-driven pumps were operable with a note that the steam AFW pump could be made operable by resetting the overspeed trip. No Technical Specification action statement was involved as there is currently no limit on how long one AFW pump can remai~ inoperable. The Safety Analysis takes credit for only one AFW pump for purposes of the accident analysi By questioning control room personnel, the inspector determined that the steam-driven AFW pump had been made inoperable between 5:30 and 8:00. on May 11, 1980, during* the plant heatu However, this action was not recorded in either the Control Room Operator or the Shift Supervisor log ADM-29, Conduct of Operations, Paragraph 29.1.5 requires that each signifi-cant event shall be logge This failure to log the removal of the steam-driven auxiliary feedwater pump on May 11, 1980 is an example of failure to follow procedures as required by Technical Specification 6.4. This example has been combined with three other examples of failure to follow procedures given in Paragraphs 9.a., 9.c., and 13.a. of this report to collectively constitute an item of noncompliance (280/80-10-01, 281/80-11-01).
During followup on the above item, the inspector also developed four other areas where possible inadequacies could exist. First, there was no SNSOC approved procedure for the removal from service of the steam-driven AFW by tripping the overspeed sto Second, while the periodic test procedure for the testing of the motor driven pumps (PT 15. IA and 15. IB) contains a Precaution 4.2 to verify that the steam driven AFW is operable, it does not
~tate how this verification is to be accomplishe Operators interviewed by the inspector indicated that they called the control roo As indicated above, those in the control room had, prior to this inspection, considered the pump operable with the overspeed trip valve trippe Third, while there is a Precaution 4.4 which requires stationing a dedicated operator and establishment of communications when "only one" (verified to mean only one other) AFW System Train is available, this step is signed off on every procedure to mean that the operator read and understood the precautio Although ~PCO management stated, and the operators interviewed agreed, that the requirements of Precaution 4.4 would be implemented when and if required, there was no specific signoff blank in the body of the procedure to indicate that the required personnel and communication had been completed or if they were neede The fourth area noted resulted from the wording of a section of ADM-29, Paragraph 29.3.2 dealing with equipment malfunction or failur This section requires a Deviation Form to be generated (to notify the SNSOC of the failure) and the immediate notification of the Operating Supervisor, Superintendent-Operations, or designee anytime a component of any safeguards or safety-related equipment "fails or is found inoperable";
no action is required if the component is "made inoperable".
The licensee stated that these four possible areas of concern would be corrected by revision of PT 15.1 and ADM-29 and issuing a procedure for removing the steam-driven AFW pump from service. This action was given a target completion date of July I, 198 The licensee also indicated that action had been undertaken prior to the completion of the inspection with respect to writing the new procedur This item is designated Open Item (280/80-10-26, 281/80-11-26).
2 Qualification Practices for Quality Assurance Personnel (72705B)
References:
(a) Letter, J. F. Barcia to W. P. Haass, dated 3/18/80 (b) Letter, W. P. Haass to J. F. Barcia, dated 5/8/80 (c)
VEPCO Topical QA Program, VEP-1-3A (d)
ANSI N45.2.6 as endorsed by VEP-I-3A
' '
-27-In reference (a) the Utility Employees Association (UEA) as the labor collective bargaining representative of the Quality Assurance employees at the Surry plant, brought certain questions to the attention of the Quality Assurance Branch of NRR relative to the licensee's practices with respect to training and qualification of quality assurance personne Reference (b) forwarded to the UEA the applicable portions of references (c) and (d)
in response to these issues. This letter further stated that the Office of Inspection and Enforcement was responsible for assuring that the appropriate requirements were implemente The two main practices questioned by the UEA were:
(1) lack of formal training; and, (2) accepting as the basis for demonstration of proficiency a written test, which those tested had helped to prepar In addition to the routine review of qualifications which was scheduled for inspection prior to the exchange of letters, the inspector also reviewed the two *
specific concerns and conducted interviews with seven different persons employed in the onsite QA grou While training is required by both references (c) and (d), formal training (i.e. structured training with lesson plans, outlines, defined schedules,
~onducted in a classroom atmosphere) is only required for Level III person-nel certified in accordance with ANSI N45. The only Level III in the QA Department at Surry is the Resident QC Engineer who is not represented by UEA. Training for Level I and II personnel is carried out in accordance with a prescribed qualification progra In some cases, as allowed by both references (c) and (d), part or all of this program has been waived based on evaluation of previous training and experienc In addition to self study using written study guides and other material, the current training program makes use of on-the-job trainin Section 2.2.1 of ANSI N45. states that such participation should be included in the training program and further stipulates that emphasis on first hand experience gained through actual performance of examinations and tests is desirabl In addition, the current program includes routing of materials (LER' s, NRC Reports, Bulletins, Notices), discussions on a variety of QA related subjects, and safety meetings and other similar discussion sessions; these activities are all documente The proficiency test, the validity of which was questioned in reference (a), was used by the licensee as part of the evaluation process to provide a basis for recertification, not initial certification. Persons taking the test had provided questions which were in the universe of questions used in preparation of the examinatio The inspector determined that the universe of possible questions consisted of approximately 1200 question There were 64 categories of questions (roughly parallelling the categories in the step qualification program), with an average of 15 to 20 questions per categor In soliciting questions and answers for this universe, 23 QA department employees from Surry, North Anna, and the Richmond offices were contacte Each person supplied the answers for the questions in no more than 5 and no less than 3 categorie *
-28-Questions on the test that was referenced by the UEA were taken from 40 of the 64 categories; no less than one question nor more than four questions were then included from each of the selected categories to makeup the 74 question test. Thus, statistically, an average (x) of 1.93 questions were used from each of 40 categorie Again statistically, each QA employee could expect to find 4.18 questions on the examination which he would have prepare By actual comparison between the questions submitted and the questions given on the examination, the inspector found the following distribution:
3 persons furnished 8 questions; 1 person furninshed 7; 1 furnished 5; 1 furnished 4; 1 furnished 3; 1 furnished l; and, 2 persons had none of their questions on the examinatio Therefore, using either statistical or actual conditions, no person furnished enough questions to affect the outcome of the examinatio This was determined by counting each individual's answer to "his own questions" as incorrect and then determining the grade based on his rema1n1ng answer In each case, the individual would have scored greater than the 70% require The inspector also interviewed seven QA Department employees. Each was asked:
"Have you ever informed your management that you did not feel qualified to perform an assigned activity?" Since each person answered "No" to this question, the inspector then inquired:
"Even if you did not inform your management, did you ever actually have or perceive a lack of training which, to your knowledge, adversely affected either the safety of the plant or the quality of the activity that you performed?" Again, each interviewee answered "No".
In additional responses during the discussions, two of the seven employees did express concern with job inefficiency which resulted when they "had to be trained by the person doing the job" that they w~re inspectin In each specific case used as an example, such training was not required in order to perform the designated inspection function (e.g., the inspector did not understand how a particular valve functioned, but his inspection was for cleanliness of the valve parts).
The inspector also reviewed medical test records required to document completion of testing required prior to certification to meet the licensee's commitment to ANSI N45. No items of noncompliance or deviations were found with respect to training, qualification, or certification activities. However, examples contributing to an item of noncompliance for failure to implement a recordkeeping program as required by the accepted QA Program's commitment to ANSI N45.2.9 were foun First, the documentation of completion of the testing-and other QA training activities were not stored in either*a vault or in defined duplicate storage facilities. Second, the medical records were not stored in either a vault or defined duplicate storage facilitie The additional example contributing to the item of noncompliance is discussed in Paragraph 1 of this report. Collectively these three examples constitute an item of noncompliance (280/80-10-08, 281/80-11-08).
2 Observation of Activities (92706B)
The inspectors monitored three activities by licensee personne One involved a receipt inspection of a thermostat under Purchase Order 3262 The item was put on hold, under hold tag 8144, due to the supplier not
' ; *
-29-being on the licensee's list of qualified vendor The second activity concerned the performance of STF-16, Program for Inspection and Testing of Existing Expansion Anchor Bolts, dated April 25, 198 The inspector observed the performance of this test on hanger PSKK 1031A The third activity monitored was retorquing three studs by the mechanical maintenance departmen accordance with Procedure MMP-C-RC-038, Removal Reactor Vessel Studs, dated January 4, 197 sets of reactor vessel This was preformed in and Reinstallation of No items of noncompliance or deviations were identifie.
Licensee Actions on Previously Identified Items (92701B)
The inspector reviewed licensee actions with regard to previously identified items as follows: (Open) (280/79-08-05 and 281/79-09-05): Failure to place expendables/
consumables under the licensee's, Quality Assurance (QA) Progra The licensee has identified those expendables/consumables which should be placed under the licensee's Quality Assurance Program -
Operations Phase, VEP-1-3A (TQAP) but has yet to change the QA Program to reflect these items. This item will remain open pending revision of the TQA (Closed) (280/79-08-06 and 281/79-09-06): Failure to establish adequate list of items requiring level A storag The licensee had committed to pebforming a review of stocked items to determine which items would require level A storage condition As an alternative, the licensee is using the level A storage list developed at the North Anna facilit A continuing program to place qualified items not presently covered by this list, into level A storage, is being followed by stores personne This item is close (Closed) (280/79-08-07 and 281/79-09-07):
Failure to provide admin-istrative controls to assure that Category I items are not locally purchased without proper technical and QA review. Appropriate controls have been implemented in accordance with NPSQAM, Section 4.5.5.4, as observed by the inspectors. This item is close *
-30-2 Index of Findings for Inspection Reports 50-280/80-10 and 50-281/80-11 Item Numbers 80-10 80-11
02
02
05
Item Description ITEMS OF NONCOMPLIANCE Failure to follow T/S procedure - Design Change Failure to follow T/S procedure-Required Reading Failure to follow T/S procedure-Drawing Control Failure to follow T/S procedure-Logging of Equipment Corrective action, failure to perform Corrective action, failure to perform Corrective action, failure to notify management of Failure to control vendor manuals Failure to perform/document safety evaluation Failure to meet qualification rqrmts.-2 SyNSOC alternates Failure to perform required SyNSOC reviews of NRC reports Failure to correctly perform a QC inspection Report Location.-c 1.c 1.b 1.a 1.b Failure to implement record storage rqrmts.-QA Training
09
11
13
15
17
19
21
23
25
Failure to implement record storage rqrmts.-QA Medical
Failure to implement record storage rqrmts.-Purchase Requisition 1 Failure to document external design interfaces Failure to follow QA procedure-Warehousing Failure to completely audit 3 areas UNRESOLVED ITEMS
Awaiting site's answer to 80-02 audit finding-jumpers 13-Awaiting SyNSOC's action on unacceptable audit response INSPECTOR FOLLOWUP ITEMS
Evaluate implementation of large motor meggerring procedure
Evaluate licensee's upgrade commitment tracking system
Evaluate licensee's trend analysis program-equipment
- Evaluate licensee's depth of review of audit reports
Review licen~see's evaluation of qual. of tape on SS pipe
Verify implementation of Limited Shelf Life Item controls
Evaluate increase in management's attention to detail
Verify doct.nnentation of expanded QA audit areas OPEN ITEMS
Resolve wording conflict between TOAP and NPSQAM
Define controls for handling unacpeDtable answers to SvNSOC
Expand and update "Q" List
Revise procedures for testing following modifications
Revise procedures dealing with steam driven AFW pump
Add needed specifications to DC-79-S22.a 1.a.c.b 5*. C 1.c 1.c.b.d 19 Items 04 and 07 apply only to Unit #1; item 27 applies only to Unit #2.