IR 05000280/1981015
| ML18139B602 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 07/09/1981 |
| From: | Belisle G, Bemis P, Fredrickson P, Skinner P, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18139B595 | List: |
| References | |
| 50-280-81-15, 50-281-81-15, NUDOCS 8111050770 | |
| Download: ML18139B602 (23) | |
Text
e UNITED STATES e
NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTA ST., N.W., SUITE 3100 ATLANTA, GEORGIA 30303 Report No /81-15 and 50-281/81-15 Licensee:
Virginia Electric and Power Company Richmond, VA 23261 Facility Name:
Surry 1 and 2 Docket Nos. 50-280 and 50-281 License No DPR-32 and DPR-37 VA and Company offices in Approved SUMMARY Inspection on May 11-15 and 18-22, 1981 Areas Inspected 7/dr; Da1te I 7/CJ/H Daie D~7'f/rf 7/r/g; Date ~
This routine, announced inspection involved 170 inspector-hours on site and at the Company offices in the areas of licensee action on previous inspection findings, QA program annual review, training, requalification training, procedures, surveillance, surveillance testing and calibration control program, maintenance program, measuring and test equipment program, calibration, independent inspection effort and licensee action on previously identified inspection item Results Of the 12 areas inspected, no violations or deviations were identified in five areas; nine violations were found in seven areas (Failure to maintain procurement records, paragraph 3.h(3); Failure to conduct 8111050770 811019
PDR ADOCK 05000280 G
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audits, paragraph 3.k(2); Failure to follow procedure, paragraph 7.a and 12; Failure to conduct fire detection instrument checks, paragraph 9; Failure to review procedure, paragraph 11; Failure to develop shelf life program, paragraph 14.f; Failure to take prompt corrective action, paragraph 15.a; Failure to follow procedure-ADM 51, paragraph 15.c; Failure to comfirm corrective action, paragraph 15.d). Three deviations were found in two areas (Failure to meet NPSQAM change commitment date, paragraph 3.b(3); Failure to meet design interface procedure commitment date, paragraph 3.i; Failure of STA's to complete training, paragraph 15.b(l)).
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DETAILS Persons Contacted Licensee Employees
- D. Christian, Superintendent Technical Services
- W. Clark, Quality Control
- O. Costello, Staff Assistant
- L. Curfman, Performance Engineering Supervisor f. Dewandel, Supervisor Station Office Services
- L. Edmonds, Supervisor Nuclear Training M. Griffin, Supervisor Electrical Maintenance J. Horhutz, I&C Supervisor
- D. Johnson, Quality Control G. Kane, Operations Supervisor
- J. Martin, Jr., Manager, QA Operations R. Mudd, Mechanical Supervisor W. Murray, Engineer
- J. Patrick, Supervisor Mechanical Maintenance
- F. Rentz, Quality Control R. Roberts, Stores Supervisor e
- W. Runner, Jr., Supervisor Administrative Services
- S. Sarver, Supervisor Health Physics
- R. Saunders, Assistant Station Manager T. Swindell, Chemistry -Supervi~or
- M. Tower, Staff Engineer
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D. Woods, Secretary SyNSOC Other licensee employees contacted included technicians, operators, mechanics,* and office personne NRC Resident Inspectors
- D. Burke
- M. Davis
- Attended exit interview Exit Interview The inspection scope and fi~dings were summarized on May 22, 1981 with those persons indicated in paragraph 1 abov The licensee acknowledged the inspection finding.
Licensee Action on Previous Inspection Findings (92702)
The following abbreviations are defined and used throughout this report:
Accepted QA Program ADM VEP-1-3A, Amendment 3 dated 3/77 Administrative Procedure
IS I NOE NPSQAM Inservice Inspection Non-destructive Examination Nuclear Power Station Quality Assurance Manual OLB PT QA QC SNSOC STA Operating Licensing Branch Periodic Test Quality Assurance Quality Control Station Nuclear Safety and Operating Committee Shift Technical Advisor SyNSOC System Nuclear Safety and Operating Committee Items of noncompliance from inspection reports 50-280/80-10 and 50-281/80-11 were reviewed with respect to the licensees response letter dated August 1, 1980. (Closed) Infraction (280/80-10-01, 281/80-11-01):
Failure to follow Technical Specification procedur (1)
The inspector verified that terminals had the correct cables attached and that no other cables were improperly ins ta 11 e (2)
The Superintendent of Operations has assigned an individual to ensure that the required reading is signed off within the specified tim The material placed in the book is reviewed with the intent to limit necessary informatio Also, the time limit for the reading has been reduced to emphasize the importance to complete the required reading as soon as possibl (3)
All recipients of controlled drawings have been reinstructed as to the importance of drawing control and that the correct drawings have been redistribute The QC staff has been requested to audit the files on a peri6dic basis to insure complianc Audits thus far have found full complianc (4)
Specific procedures were written and approved to remove and return to service a motor or steam driven auxiliary feedwater pump.
(Closed)
Infraction (280/80-10-02, 281/80-11-02};
Failure to perform or notify management of corrective actio '
C.
(1)
Quality Assurance, Operations and Maintenance personnel have been reminded of the necessity to report all non-conforming conditions found on audit The licensee stated it would specifically be included in the annual audit of station records 11 later this year
- This audit was conducted as require (2)
The Supervisor - QA, Operations and Maintenance, has acknowledged by memorandum to the Chairman, SyNSOC, the r~quirement to review audit reports for trends with specific response to the SyNSOC-1979 audit. Also, a formal program has been established for the review of audit reports for trend (3)
Responses to audits, including corrective action planned or taken, are being distributed the same as the audit report. A change to the NPSQAM has been initiated to require distribution of audit responses and other pertinent documentation to be distributed to recipients of the audit repor The licensee stated that full compliance would be achieved by January 1, 1981, but full compliance was not achieved until March 5, 198 This failure to meet the commitment date is identified as a deviation (280, 281/ 81-15-10).
(Closed) Infraction (280/80-10-03, 281/80-11-03}:
Failure to control vendor manual All departments which have vendor manuals used for safety related reference have compiled a list of them so that these manuals can be controlle The vendors have been contacted to notify them of the licensee intent to keep a copy of the manual up to date and asking for past revisions and any new revision A controlled copy of each of the identified manuals i,s kept by the individual department and another copy is kept by the Technical Support Center Reference Library (TSCRL). * (Closed) Infraction (280/80-10-04):
Failure to perform/document safety evaluatio A safety evaluation has been performed for the specific identified proble The research indicates a mistake was made on the original drawings which had the valves torqued ope The valve vendor recommends the valve be torqued closed and limit ope This was the p~rpose of the installed jumper A change request has been submitted. to insure that the requirement to perform a safety evaluation has been addressed for compliance with NPSQAM-Section 1 A design change has been installed on Unit 2 changing the subject valves a~d the same change will be installed on Unit 1 during the steam generator replacement outag A memo to the approver of jumpers and shift supervisors emphasizes that this evaluation is to be accomplished as necessar \\
e 4 (Closed) Infraction (280/80-10-05, 281/80-11-05):
Failure to meet qualification requirements One alternate member met the experience requirement on June 5, 198 Prior to that time he had not acted as a voting member in any meeting in which he was needed to form a quoru Therefore, no items he voted on need to be re-reviewe The other alternate member has not been used as a voting member since the inspectio The licensee had identified all items approved by the committee when the second alternate member acted as a* voting member and whose presence was necessary to form a quoru Each of these items has been re-reviewed by the committe The licensee has requested the NRC to review this individual 1s qualifications and grant a waiver which will allow him to serve as an alternat Until receipt of this waiver, this a 1 terna te wil 1 not serve as a voting member of the SyNSO. (Closed) Infraction (280/80-10-06, 281/80-11-06):
Failure to perform required SyNSOC reviews of NRC report The licensee has taken measures to insure that IE reports containing viola-tions or deviations are reviewed during the SyNSOC meeting The inspector reviewed three items to insure that they were carried in the committee minutes. (Closed) Infraction {280/80-10-07):
Failure to correctly perform a QC inspectio QA Personnel were instructed to ensure that proper field changes are submitted when a proce-dure or design is accomplished without using the exact method described in the procedur * (Closed) Deficiency (280/80-10-08, 281/80-11-08):
Failure to implement records storag (1)
QA training records are now being maintained in duplicate storage facilities at the site ~nd at corporate headquarters in Richmon *
(2)
QA Medical records are now being maintained in duplicate storage facilities at the site and at corporate headquarters in Richmon (3)
Purchase requisitions--the area of concern was the record storage of purchase requisitions and repeating purchasing requisition cards (on which each line is an individual purchase requisition}.
The licensee replied that 11copies of the required purchase records would be maintained in station records pending a revision of the accepted QA Program, for clarificatton of purchasing record storag Copies of the repeating purcha~ing requisition cards are*
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not being stored in plant record Failure to provide adequate record storage for repeating purchase requisi-tion cards is identified as a repeat violation (280, 281/81-15-03}. (Closed) Deficiency (280/80-10-09, 281/80-11-09):
Failure to document external design interface The licensee prepared and issued procedures which describe the interface, responsi-bilities, lines of communication and flow of design informa-tion between VEPCO and its architect-engineer and between VEPCO and all other vendor VEPCO stated full compliance would be achieved by October l, 198 Full compliance was *not achieved.until February 1, 1981; therefore, this item is identified as a deviation (280/281/81-15-11). (Closed) Deficiency (280/81-10-10, 281/81-11-10):
Procedural complianc The inspector verified, by selecting several different QA category items, that the proper category from purchase orders is being annotated on the item in storag (Closed) Deficiency (280/80-10-11), (280/80-11-11):
Failure to completely audit three area (1)
The licensee changed the NPSQAM to perform procurement audits annuall An audit of procurement was performed on January 6, 1981.
(2)
The licensee did not make the required changes or perform audits in the two areas of records or document control at the company office The failure to make the required changes or perform these audits constitutes a violation (280, 281/81-15-09}. (Closed) Unresolved (280/80-10-12, 281/80-11-12): Station nuclear safety and operating committee (.SNSOC} review of jumpers.. The inspector reviewed the control of jumpers as described in the NPSQAM, Section 1 Based on this* review, this item is resolve (Closed) Unresolved (280/80-10-13, 281/80-11-13):
Awaiting SyNSOC action on unacceptable audit respons The SyNSOC has made the requirement for corporate QA to audit both SNSOC and Technical Specification complianc The first audit of this function was S80-14, dated October 16, 198 Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve noncompliance or deviation New unresolved items identified during this inspection are discussed in paragraphs 7.b and 7.c.
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QA Program Annual Review (35701)
This particular activity was inspected during April 27-May 1, 1981 at VEPC0 1s North Anna facility and is documented in IE Report No /81-07, 50-339/81-07, paragraph The Surry and North Anna facilities have a common accepted QA Program and NPSQA All items identified in IE Reports 50~338/81-07, 50-339/81-07 are applicable to Surr Completion of the corrective action regarding the North Anna facilities will automatically be corrected for the Surry facilitie *
Based on this review, no additional violations or deviations were i denti fi ec.
Training (41700)
References:
(a)
Technical Specifications 6.0 Administrative Controls (b)
ANSI N18.1, Selection and Training of Nuclear Power Plant Personnel, dated 3/71 (c)
(d)
Regulatory Guide 8.13, Instruction Concerning Prenatal Radiation Exposure, Revision 1, dated 11/75 Quality Assurance Manual Section 2, Quality Assurance Program, Revision 6, dated 6/79 *
(e)
ADM-12, Qualification and Training, dated 4/78 The inspector reviewed the training program which provides general employee training for station.personnel with respect to the licensee 1s commitments and requirements (references (al through (e)}.
The training program was reviewed to verify that the program covers training in the areas of general station administrative control, quality assurance policies and procedures, radiological health and safety, industrial safety and first aid, housekeeping, fire preven-tion and protection, emergency plan and procedures, station security plan and procedures, the use of protective clothing and prenatal radiation exposure training for females and supervisor The inspector reviewed approximately 46 training ~ecords of station personne *
Based on this review one inspector followup item was identifie The inspector reviewed a listing of station personnel identifying dates by which retraining should be performe This list identified 10 people out of approximately 500 that had exceeded the required retraining perio The training department supervisor will conduct retraining for these personnel by July 1, 198 This item will be carried as an ~nspector fo~l?wup item (280, 281/81-15-15} pending subsequent review of retra1n1ng of station personne '
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Requalification Training (41701)
The inspector reviewed the licensee's requalification program for documentation of required lectures being scheduled and taught, adequacy of lesson plans and depth of material and review of the most recent annual examinatio The inspector reviewed the records of four shift supervisors and four reactor operators to insure individuals attended the required lectures, the annual examinations were administered, documentation existed for additional training in deficient areas, and procedure reviews were being accomplishe The inspector also reviewed classes being taught, both in the classroom and on the simulato Based on this review, one item contributing to a violation, two unresolved items and one inspector followup item were identified and are discussed in the following paragraph Failure to Follow the VEPCO Policy Development Manual The "end of step" exami nati ans for the auxiliary operators are not always being signed off by the four individuals required by the VEPCO Policy Development Manua This failure to follow procedure iscombined with another finding discussed in paragraph 12 to collectively constitute a violation (280, 281/
81-15-05).
. Requalification Examination Criteria An individual making below eighty percent is not being administered an enhrely new exam which appears* contrary to NRC criteria for passing initial examination This item is unresolved (280, 281/81-15-13) pending further review by NR Qualification of Personnel Prior to NRC Examination When an individual is undergoing initial licensing training and is not passing licensee written examinations, the licensee requests an NRC examination for the individual on the basis of his operational capabilities. This item is unresolved (_280,.
281/81-15-14) pending further review by NRC concerning the basis for examination applicatio Auxiliary Operator Training The adequacy of formal training is questionable in that auxiliary operators are left almost entirely on their own to learn the plan The licensee is in the process of developing a formal program for the auxiliary operators. This item will be carried as an inspector followup item (280, 281/81-15-16), until the new program has been implemented and reviewed by the NRC.
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Procedures References:
e (42700)
(a)
(b)
(c)
(d)
(e)
ANSI N18.7-1972, Administrative Controls for Nuclear Power Plants Technical Specifications Regulatory Guide 1.33, Revision 1, Quality Assurance Program Requirements (_Operation)
Final Safety Analysis Report NPSQAM, Section 5 Instructions, Procedures and Drawings, Revision 19 dated 9/80 The inspector reviewed selected plant procedures in accordance with the guidance and requirements provided in references (a) through (e) to ascertain whether overall ~rocedures are in accordance with regulatory requirement The following criteria were used during this review:
Required review and approval of procedures and temporary changes is being performed Overall procedure content is consistent with references (b)
and ( d)
Records of changes in procedures are being maintained Safety reviews pursuant to 10 CFR 50.59 are being performed The training department is being appraised of changes to procedures Administrative procedures are being observed in the preparation and handling of procedure The following specific procedures were reviewed ADMINISTRATIVE PROCEDURES (_ADM)
ADM-13.0, Review of Procedures, dated 10/78 ADM-25.0, Operation of the Station During Hazardous Times, dated 4/77
ADM-51.0, Control of Procedures, dated 1/77 ADM-28.0, Reactor Shutdown or Trip Shutdown, dated 8/76 ADM-40.0, Station Housekeeping, dated 4/77 SPECIAL TESTS (ST)
ST-114, Reactor Coolant Pump Vibration Testing, dated 3/81 ST-116, Pressurizer Relief Tank, dated 3/81 *
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ABNORMAL PROCEDURES (AP)
AP-9, Reactor Coolant Pump Vibration, Unit 1, dated 8/79 AP-9, Reactor Coolant Pump Vib.ration, Unit 2, dated 8/79 AP-43, Loss of Reactor Coolant Flow, Unit 1, dated 5/80 AP-43, Loss of Reactor Coolant Flow, Unit 2, dated 5/80 OPERATING PROCEDURES (OP)
OP-5.2, Reactor Coolant Pump Operation, Unit 1, dated 4/80 OP-5.2, Reactor Coolant Pump Operation, Unit 2, dated 4/81 OP-5.8, Reactor Vessel Level Adjustment Unit 1, dated 1/77 OP-5.8, Reactor Vessel Level Adjustment Unit 2, dated 9/76 OP-7.1, Safety Injection, Unit 1, dated 4/81 OP-7.1, Safety Injection, Unit 2, dated 3/81 OP-14, RHR System, Unit 1, dated 1/80 OP-14, RHR System, Unit 2, dated 1/80 Comments on the above procedures were of an editorial nature and were provided to the Operations Supervisor and with the Supervisor, Station Office Service Based on this review, no violations or deviations were identifie.
Surveillance (61700)
References:
(a)
NPSQAM, Section 11, Test Control, Revision 11 dated 8/79 (b)
NPSQAM, Section 12, Control of Measuring and Test Equipment, Revision 8 dated 9/80 (c)
Section XI of ASME Boiler and Pressure Vessel Code, 1974 Edition with Addenda through summer of 1975 (d)
Master Index of Unit 1 and Unit 2 Periodic Tests The purpose of this review was to ascertain whether the surveillance of safety related systems or components was being conducted in accordance with approved procedures as required by the Technical Specifications and the !SI program for pumps and valve The inspector selected twelve Technical Specification surveillances and two IS! surveillances to determine whether PTs or other implement-ing procedures had been written to conduct these surveillance This selection produced nine Technical Specification PTs and two IS! PT Three of the Technical Specification surveillances were not documented by PT The identified PTs were then reviewed to verify that they covered the specific surveillance and that they contained prerequisites and preparations for the test specified, acceptance criteria for the test and instructions for restoration of the syste The inspector reviewed selected completed copies of these PTs to verify the fo 11 owing for each performance of the test:
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Tests were in conformance with surveillance requirements Tests had been reviewed as required by reference (a)
Tests had been performed within the required time frequencies Appropriate action had been taken for any item failing the acceptance criteria Tests had been performed by qualified individual The PTs provided which performed the required surveillances and the selected completed copies reviewed are listed as follows:
PT.N.4 2.9A.0 1.11 1. 7 2.7 3 Dates Title Reviewed Pressurizer Pressure Protection (P-2-455)
1-5/81,.. Unit 2 Steam Flow (F-1-485)
4/16/81, Unit 1 Full Length Control Rod Assembly Drop Time 8/8/80, Unit 2 Reactor Coolant Loop Leakage 3/81, Unit 1 Main Steam Trip Valves and Main Steam Non-Return Valves SI Check Valve Leakage-Primary Coolant System Pressure Isolation Valves Monthly Testing of Safety Related MOVs Charging Pump Operability and Performance Fire Protection Systems-Smoke Detectors Fire Protection-Deluge System Primary Coolant and Steam Generator 5/11/81, Unit 1 4/25/81, Unit 2 1-5/81, Unit 2 1-5/81, Unit 2 3/25/81, Unit 1&2 1-5/81, Unit 1 2/81, Unit 2 Based on this review, one violation was identifie The three surveillances that did not have respective PTs involved the performance of heat detection instrument functional tests, heat detection calibration tests and smoke detection calibrati~n test Technical Specification 6.4.A.2 requires that written procedures shall be provided for the calibration and testing of instruments involving nuclear safety of the station. Technical Specification 4.18.A.1 requires that fire detection instruments listed in Table 3.21-1 be demonstrated operable: At least once per six months by channel function test, and
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11 At least once per twelve months by performance of channel calibration Heat and smoke detectors are included in Table 3.21-PT 24.38, Low Pressure CO2 System-Puff Test, dated 4/80 operationally checks the low pressure CO2 system (which uses heat detectors) in accord-ance with Technical Specification 4.1 PT 24.5 functionally tests the smoke detectors in accordance with Technical Specification 4.18..
Technical Specification 6.4.A.2 is not being followed in that PT 24.38 does not perform the heat detector function tests or channel calibrations for those detectors in the cable tray rooms, the cable tunnel or the cable vault area and PT 24.5 does not perform the smoke detector.calibratfons in these area This failure.to provide adequate procedures for the performance of these surveillances is identified as a violation (280, 281/81-15-02}.
Prior to the com-,
pletion of the inspection, satisfactory functional tests were performed on a 11 the untested heat detector.
Surveillance Testing and Calibration Control Program (61725)
References:
(a)
NPSQAM, Section 11, Test Control, Revision 11 dated 8/79 (b)
NPSQAM, Section 12, Control of Measuring and Test Equipment, Revision 8 dated 9/80 (c)
Section XI of ASME Boiler and Pressure Vessel code, 1974 Edition with Addenda through Summer of 1975 The.referenced documents were reviewed with respect to the licensee 1s accepted Quality Assurance Program. The review was concerned with surveillance testing and calibration of in-plant safety-related instruments not specifically controlled by Technical Specification The licensee 1s practices were reviewed to verify the following:
A master schedule for surveillance testing/calibrations/inservice inspections was developed which included frequency, responsibility and status for each test/calibration/inspection Responsibilities are assigned for maintaing the master surveillance schedule and for assuring that all scheduled tests/calibrations/
inspections are performed Formal requirements, methods and responsibilities are established and defined for conduct, review and evaluation of tests/calibra-tions/inspections
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A master schedule for component calibrations had been established that included frequency, responsibility and status of safety-related components Responsibilities are assigned to assure that the schedule is maintained and schedules are satisfied Formal requirements have been established for performing calibrations in accordance with approved procedures Based on this review, no violations or devfations were identifie.
Maintenance Program (62702)
References:
(a)
(b)
(c)
(d)
(e)
( f)
(g)
(h)
NPSQAM, Section 16, Corrective Action, Revision 12 dated 4/80 NPSQAM, Section 14, Inspection, Test and Operating Status, Revision 6 dated 4/80 NPSQAM, Section 5, Instructions, Procedures and Drawings, Revision 19 dated 9/80 ADM-56, Special Processes Involving Ignition Sources, dated 3/79 ADM-40.0, Station ~ousekeeping, dated 8/76 QC Local Guidance 9.5.1, Trend Analysis Program, dated 5/80 QC Local Guidance 9.6.2, Inspections at 11 QC Ho.l d'
1 Steps, dated 4/77 VEPCO Welding Procedure and Qualification Manual (i)
VEPCO Nondestructive Test Manual (j) ADM~13, Review of Procedures, dated 10/78 The inspector reviewed the references listed to insure they met the requirements of the accepted QA Program and ANSI N18.7-1972 as committed to by that Progra The inspector reviewed the following aspects of the maintenance program:
Written procedures have been established for ;Initiating requests for preventative maintenance, routine corrective maintenance and special corrective maintenance Criteria and responsibilities for review and approval of work requests and maintenance reports have been established
Criteri'a and responsibilities for designating the activity as safety-related have been established Responsibilities have been designated for performing work inspections of maintenance activities Responsibilities have been established for identification of appropriate hold points related to maintenance activities Responsibilities have been designated for performing functional testing of components following maintenance activities prior to their being returned to service Controls for maintenance activities require that records be prepared, assembled and reviewed prior to transfer to records storage A program has been established for reviewing maintenance records to assess the adequacy of the maintenance program Maintenahce reports require identification of special authorization for use of flame permits Responsibilities for equipment control such as releasing and returning to service and status have been defined A written preventative maintenance program has been established Controls have been established for special processes such as welding and flushing of systems Controls have been established for cleanliness The inspector reviewed 10 mechanical and electrical maintenance procedures for inclusion of hold points and cleahliness requirement Based on this review, one violation was identifie During a review of periodic tests the inspector identified that some had not been recently revise Many had not been revised since the 1974, 1975 time frame and some had not been revised since 197 The NPSQAM, Section 5, Paragraph 5.1 defines 18 types of procedures that have been established to assure safe and orderly operation of the statio The inspector reviewed a samplfog of procedures from this listing and identified many had not been revised or reviewe The accepted QA Program endorses ANSI N18.7-197 Section 5.4 of this standa!d requires procedures to be reviewed periodically and that the frequency of this review shall be specifie Reference (j) i denti fies four types of procedures that are reviewed and states the frequency of this review but does not address the other 14 types of procedures use This failure to periodically review procedures and to specify the frequency of reviews is a violation (280, 281/81-10-06).
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- 1 Measuring and Test Equipment Program (61724)
References:
(a)
VEP-l-3A, Section 17.2.12 (b)
NPSQAM, Section 12, Control of Measuring and Test Equipment, Revision 8 dated 9/80 (c)
NPSQAM, Section 11, Test Control, Revision 11 dated 8/79 (d)
NPSQAM, Section 13, Handling, Shipping-Storage and Shipping, Revision 3, dated 6/80 The referenced documents were reviewed with respect to the licensee's accepted QA Program and ANSI N18.7-1972 as endorsed by that Progra The licensee 1i practices with respect to the test and measurement equipment program were reviewed to verify the following:
Criteria and responsibility for assignment of calibration frequency have been established An equipment inventory list has been established which identifies the calibration frequency, standards and procedures for all equipment to be used on safety-related structures, systems or components
Formal requirements exist for marking the latest inspection(
calibration on each piece of equipment or otherwise identifying the status of calibration A method has been provided for assuring that each piece of equipment is calibrated on or before the date required and that new equipment will be added to the list and calibrated prior to use Controls have been established to prohibit the use of equipment which has not been calibrated within the prescribed frequency Controls have been established to. ensure that when a piece of equipment is found out of calibration, the acceptability of items previously tested with that equipment will be evaluated and dbcumented and the cause of that e~uipment being out of calibration will be evaluate * *
The inspector interviewed cognizant personnel in the instrument, electrical, and maintenance shops and the QC, Operations and NOE departments to verify controls established for use of test and measuring equipmen The inspector also randomly selected various equipment in the previously listed shops and departments to verify the calibration status of equipment being used.
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Based on this review one violation was identifie The NPSQAM, Section 12, Paragraph 5.4(b) requires that if an instrument is not located for one year after having missed a required calibration date, it shall be removed from the QC Progra The inspector identified the following equipment that missed the required calibra-tion date by more than a yea QC Identification Calibration Due Date SQC-P-1501 5/1/80 SQC-P-1504 1/22/80 SQC-P-1514 9/7/79 SQC-P-1515 5/1/80 SQC-P-1517 5/1/80 SQC-P-1570 5/2/80 SQC-P-1788 5/1/80 SQC-P-1755 2/7 /80 SQC-P-1749 2/7/80 SQC-1743 12/17/79 SQC-1724 3/12/80 SQC-1722 3/12/80 SQC-1721 3/12/80 SQC-1718 3/12/80 SQC-M-1685 9/7/79 SQC-M-1672 9/7 /79 SQC-M-1671 9/7 /79 SQC-M-1661 7/28/79 SQC-M-1032 8/7/79 This failure to rem*ove equipment from the QC program as required by the NPSQAM is combined with another finding discussed in paragraph 7.a to collectively constitute a violation l280, 281/81-15-05}.
This list is not intended to be all inclusiv.
Calibration (56700)
Reference:
(a) Technical Specifications The inspector reviewed the following aspects of the licensee*s calibration program:
Procedures have been reviewed and approved Calibration will be to the required accuracy Calibration equipment used will be traceable Based on this review, no violations or deviations were identified.
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1 Licensee Action on Previous Inspection Items (92701)
~* (Closed) Inspector Followup Item (280/80-10~14, 281/80-11-14):
Evaluate implementation of large motor meggering pro-cedur The licensee has instituted three procedures for the meggering of motors:
0-EPL-E-Nl for motors less than 125 H.P, 0-EPL-E-N2 for motors greater than 125 H.P. _(these two proce-dures are performed when the motors are placed in storage)
and 0-EPL-E-Ql for all motors on a quarterly basis. A check of the electrical department records show that the procedures were implemented on the following dates:
8/14/80, 12/11/80, and 4/30/81, respectivel (Closed) Inspector Followup Item (280/80-10-15, 281/80-11-c.
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Evaluate licensee's upgrade commitment tracking syste The inspector evaluated the manual tracking system the licensee had instituted and found that even though the system had been developed it was not.functioning properly to assure that specific problem areaS, are followed up and corrected in a timely manner, as shown by the violations and deviations issued by NRC from prior inspection reports. This item is closed for record purposes and is escalated to a violation as discussed in paragraph 1 (Closed) Inspector Followup Item (280/80-10-16, 281/80-11-16):
Evaluate licensee's trend analysis program-Equipmen The inspector reviewed several areas which had been previously reviewed by the licensee for adverse trends and identified no problems with the trend analysis progra (Closed) Inspector Followup Item (280/80-10-17, 281/80-11-17):
Licensee's depth of review of audit report The licensee has instituted an in-depth program in Health Physics and radiological waste shipment regulations for the QC technicians responsible for these area (Closed) Inspector Followup Item (280/80-10-18, 281/80-11-18):
Use of tape on pipe end The inspector observed that tape meeting the requirement of ANSI N45.2.2-1972 was in use at the site and had been chemically analyze (Closed) Inspector Followup Item (280/80-10-19, 281/80-11-19):
Establishment of shelf life progra The inspector noted that the implementation of a shelf life program had not been implemented and also was no closer to compl~tion then during the previous inspectio This failure to establish measures to control the storage and preservation of material to prevent deterioration is identified as a violation (_280, 281/81-15-07).
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(Closed) Inspector*Followup Item*(280/80-10-20, 281/80-11-20):
Inattention to detail. Several repeating purchase requisitions and purchase orders were reviewed for proper completion; interviews with several stores personnel were conducted to verify knowledge of VEPCO purchase requisition requirement (Open) Inspector Followup Item (280/80-10-21, 281/80-11-21):
Verify documentation of expanded QA Audit area Delineation of additional responsibilities will be made in the VEPCO NPSQAM which is still under revisio (Open) Open Item (280/80-10-22, 281/80-11-22):
Wording conflict between TQAP and NPSQA Until the new revisions of the TQAP (the accepted QA Program) is approved for use and the NPSQAM is revised, this item will remain ope (Closed) Open Item (280/80-10-23, 281/80-11-23): Define controls for handling unacceptable responses to SyNSO Changes were made to the Technical Specifications, Section 6.1.13 such that the company QA organization will be charged with performing the audit and followup on the audit responses and deletes the SyNSOC from this proces (Open) Open Item (280/80-10-24, 281/80-11-24):
Expand and update 11Q 11 list. The licensee stated the 11Q 11 list has been expanded and more clearly defined, but it is part of the new
- proposed revision to the accepted QA Program and will not be available until the revision is returned from NR This item remains open pending the decision on the revisio.
(Closed) Open Item (280/80-10-25, 281/80-11-25):
Revise procedures for testing following modification There has been no revision to subsection 5.8.1 of NPSQAM section 3.0 to insure revisions to periodic testing and periodic maintenance procedures reflect the design change when a design change is made operabl This matter is addressed in the transmitted letter for these reports, 280/81-15 and 281/81-1 (Closed) Open Item (280/80~10-26, 281/80-11-26}:
The inspector reviewed PT 15.1 and ADM 29 for changes to correct the procedure for removing the steam driven auxiliary feedwater pump from service and did not identify any problem area (Closed) Open Item (281/80-11-27):
Need specifications to DC-79-2 The licensee included the necessary specification standards for the performance of the wiring including cable rerouting accomplished under this design change.. *
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Independent Inspection Effort (92706) Failure to Establish Measures to Assure Conditions Adverse to Quality are Promptly Correcte During the closeout of items identified in IE Reports 50-280/80-10, 50-281/80-11 other enforcement action was require Items identified during this report and answered by the licensee in their correspondence dated August 1, 1980 apparently were not followed up by the licensee to assure that the corrective action was totally complete Several deviations were identified due to missed commitment dates and in one instance a violation was generated since the original problem was not correcte The inspector also determined that the lack of an adequate commitment tracking system contributed to this proble This failure to assur~ that conditions adverse to quality are promptly identified and corrected is identified as a violation (280, 281/81-15-01). The inspector reviewed the licensee's commitments to NUREG 0737 Clarification of Three Mile Island Action Plan Require-ments II a_nd the fo 11 owing items were identified:
(1)
(2)
Failure of STAs to Complete Training In the VEPCO response dated December 10, 1980 to NUREG 0737 the licensee committed to training STAs at the Surry Station in a variety of fundamental course Contrary to this commitment, one of the STAs did not attend any of the fundamental courses and, according to the letter from the professor who taught the courses, none of the STAs took the exam on heat transfer~ fluid flow and thermo-dynamic This failure to complete the training is identified as a deviation (280, 281/81-15-12).
Personnel Training in Mitigating Core Damage The licensee's response dated December 10, 1980 stated that no exception was t~ken to Item II. Part of this requirement was to develop by January 1, 1981 and implement by April 1, 1981 a program in mitigating core damage for health physics, instrument and control, and chemistry manager~ and technicians commensurate with their responsi-bilitie The licensee did not have the program developed by April 1, 1981, but the program was under development by the date of this inspection. This program is identified as an inspector followup item (280, 281/81-15-17) until the program is completely developed; implemented, and reviewed by the NR *
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Training Records for STAs Upon reviewing the licensee's training of STAs the inspector noted that the records of attendance and grades were being maintained at Old Dominion University rather than at the sit ANSI 18.1-1971 requires the licensee to maintain records of training, This.item will. be an inspector followup item (280, 281/81-15-18) until the records are transfered to the site. * Failure to Follow Procedure-ADM 51 During closeout of item 280/80-10-02, 281/80-11-02, the inspector noted while reviewing ADM-51, Control of Procedures, that Sections 51.g.2 and 51.3.3 requires each supervisor who maintains an unused procedure depository shall establish procedures to insure that:
(1) only current and approved procedures are in the unused depos.itory and, (2} adequate supplies of unused procedures are on han Contrary to the above, these procedures have been developed by only the instrument and control and operation department This failure to follow procedure is a violation (280, 281/81-15~04).
Failure to Confirm Corrective Action During closeout of item 280/80-10-02, 281/80-11-02 as dis-cussed in paragraph 3.b, an additional violation was identified as discussed in paragraph 1 The inspector reviewed the circumstances that led to this violation with-plant personne Additional clarification was obtained during telephone conversa-tions with licensee representatives on May 28, 1981 and June 15, 198 Ba~ed on these conversations another violation was identified as described in the foll~wing sequence of events:
IE inspection report 50-280/80-10, 50-281/80-11 issued July 3, 1980 identified the initial problem of failure to correctly identify an audit findin The licensee responded to the infraction (280/80-10-02; 281/80-11-02) in their letter dated August 1, 1980 stating corrective actions to be taken to avoid further noncomplianc An audit was conducted (S~80-13) on September 9, 1980 as required by the licensee's respons In this audit a finding was generated (Finding 1} that stated in part, 11 Unused procedures are not being controlled in accordance with ADM-51 in that cognizant supervisors have not established procedures to ensure that only current and correct approved procedures are in the unused depositories, only procedures in the unused depositories are used, and an adequate supply of unused procedures are in hand
- The corrective actioh of this finding was answered by the Supervisor of Station Services, and accepted by the QA department on October 3, 198 The corrective action was to establish procedures by supervisors
to ensure compliance with ADM-5 The completion date was stated as October 15, 198 On October 3, 1980 station manage-ment issued a letter to all department heads directing the formation of procedures to contol procedure depositories (be in compliance with ADM-51) by October 15, 198 Upon issuance of this memo by the station manager the QA department closed out Finding 1 of audit S-80-1 As discussed in paragraph 15.c, the action has not been complete The closure of this finding by the QA organization without verification that corrective action had been taken as required by 10 CFR 50 Appendix B, Criterion XVI, the accepted QA Program and the licensee's commitment to ANSI N45. 2.12 constitutes a via 1 at ion (280, 281/81-15-08).
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- 1 Index of Findings of Inspection Reports 50-280, 281/81-15 Item Numbers 280/81-15-/281/81-15-Item Description Report Location
01
02
03
04
05
06
07
08
09
10
11
12
13
14
15
16
17
18 VIOLATIONS Failure to Take Prompt Corrective Action Failure to Conduct Fire Detection Instrument Checks Failure to Maintain Procurement Records Failure to Follow Procedure:
ADM-51 Failure to Follow Procedure:
-VEPCO Policy Development Manual-Delete Instrument from QC Program Failure to Review Procedure Failure to Develop Shelf Life Program Failure to Confirm Corrective Action Failure to Conduct Audits DEVIATIONS 1.
3.h(3)
1.a 1.
1.d 3. k (2}
Failure to Meet NPSQAM Change Commitment 3.b(3)
Date Failure to Meet Design Interface Procedure Commitment Date Failure of STAS to Complete Training 15.b(l)
UNRESOLVED Requalification Examination Criteria Qualification of Personnel Prior to NRC Examination INSPECTOR FOLLOWUP ITEMS GET Training of Personnel Auxiliary Operator Training Personnel Training in Mitigating Core Damage Training Records for STAs.c.d 15.b(2)_
15.b(.3)_