IR 05000280/1982002

IE Insp Repts 50-280/82-02 & 50-281/82-02 on 820419-23 & 26-30.Noncompliance Noted:Failure to Calibr Boric Acid Tank Level Instrument L-1-163 During Refueling Shutdown

ML20055A149
Person / Time
Site:	Surry
Issue date:	05/20/1982
From:	Belisle G, Fredrickson P, Skinner P, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20055A111	List: IR 05000280/1982002 ML20055A110 ML20055A121 ML20055A132 ML20055A138
References
50-280-82-02, 50-280-82-2, 50-281-82-02, 50-281-82-2, NUDOCS 8207150521
Download: ML20055A149 (18)

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1. ~g i UNITED STATES 8 n NUCLEAR REGULATORY COMMISSION

• a REGION If Y * 101 MARIETTA ST., N.W., SulTE 3100

'4 8 ATLANTA, GEORGIA 30303

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g*****p Report Nos. 50-280/82-02 and 50-281/82-02 Licensee: Virginia Electric and Power Company P. O. Box 26666 Richmond, VA 23262 Facility Name: Surry 1 and 2 Docket Nos. 50-280 and 50-281 License Nos. OPR-32 and DPR-37 Inspection at Surry site near Surry, Virginia and at corporate offices in l Richmond, Virginia ,

Inspectors: _t h BelisT I 8/74 D6te $1gned 7-

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zo a Sign $nts2-d Approved by: /hM[/ [ R [ 2 86 C ."M .' Up r i g h t , ,- cti Chief /Date/ Signed Engineering ( pec on Branch Division of Engineering and Technical Programs SUMMARY j Inspection on April 19-23 and 26-30,1982 Areas Inspected

! This routine, announced inspection involved 128 inspector-hours on site and at

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the corporate office in the areas of licensee action on previous enforcement matters, QA program review, design changes and modifications, onsite review committee, audits and audit implementation, training, requalification training, procedures, calibration, surveillance, maintenance, qualification and personnel, nonroutine reporting program, organization and administration, offsite review committee, offsite support staff, and licensee actions on previously identified inspection item Results Of the 17 areas inspected, no violations or deviations were identified in 16 areas; cne violation was found in one area (Failure to perform Technical Spect-fication calibration, paragraph 12.a).

8207150521 820700 PDRADOCK05000g G

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REPORT DETAILS 4 Persons Contacted

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Licensee Employees F. A111 good, Jr. , Manager, Nuclear Technical Services J. Artigas, Senior QC Insp or

• R. Bailey, Supervi sor Instri v.er,'s E. Baum, Executive Manager Qc3' , w Assurance

• D. Christian, Superintendent Teu..nical Service

• 0. Costello, Staff Assistant D. Coupe, Design Control Engineer

• L. Curfman, Performance Engineer

• E. DeWandel, Records Manager

• R. Driscoll, Manager Quality Assurance

• L. Edmonds, Supervisor Nuclear Training L. Gardner, Training Instructor

• E. Grecheck, Engineering Supervisor

• H. Kibler, Superintendent Maintenance

• R. Leasburg, Vice President Nuclear Operations

• R. Mudd, Station Services Supervisor i

• F. Rentz, Supervisor Quality Assurance

• D. Rickeard, Engineering Supervisor

• W. Runner, Supervisor Administrative Services D. Sanderson, Training Instructor

• S. Sarver, Supervisor Health Physics

• R. Saunders, Assistant Station Manager D. Smith, QC Inspector E. Smith, Director, Safety Evaluation and Control D. Staats, Senior QC Inspector S. Stevens, Shift Supervisor W. Stewart, Manager, Nuclear Operations and Maintenance

• 0. Vogstbarger, Training Coordinator

• J. Wilson, Station Manager Other licensee employees contacted included technicians, operators, and office personne NRC Resident Inspector

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• D. Burke, Senior Resident Inspector

• M. Davis, Resident Inspector

• Attended exit interview

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l Exit Interview l The inspection scope and findings were summarized on April 30, 1982, with those persons indicated in paragraph 1 abov The licensee acknowledged the inspection finding . Licensee Action on Previous Enforcement Matters (92702)

The following terms are defined and used throughout this report:

Accepted QA Program Topical Report, Quality Assurance Program, Opera-tions Phase, VEP-1-3A dated 3/77 HP Health Physics

ISI Inservice Inspection Program NPSQAM Nuclear Power Station Quality Assurance Manuals QA Quality Assurance QC Quality Control SEC Safety Evaluation and Control SNS0C Station Nuclear Safety and Operating Committee (Closed) Unresolved Item (280, 281/78-19-01): Documentation of Purchase Specifications. The inspector reviewed several 1981 and 1982 purchase requisitions and determined that the QA category and storage criteria had been properly annotate (Closed) Infraction (280/79-08-02, 281/79-09-02): Failure to Maintain Material Record Traceability. This item was reviewed with respect to the licensee's correspondence dated May 24, 1979. The inspector reviewed ADM 79, Maintenance Reports, revised 2/82. This procedure requires that parts used and the material control tag be annotated with the maintenance report numbe Several maintenance reports were reviewed to verify this requirement.

i (Closed) Deficiency (280/79-23-01, 281/79-35-01): Failure to Main-

! tain Control of Drawings. This item was reviewed with respect to the i licensee's correspondence dated June 29, 1979. The Steam Generator

Replacement Project has been completed. Both referenced ETAs have i

been completed. A drawing task force is reviewing design changes and updating drawings as necessar .

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, (Closed) Deficiency (280/79-30-01, 281/79-47-01): Failure to Estab-lish Security. Corrective actions to prevent recurrence were completed prior to the conclusion of the original inspection; therefore, no response was requeste A review of this area verified that records

security is being maintained.

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~ (Closed) Unresolved Item (280/79-30-03, 281/79-47-03): Inadequate Vault Facility. With respect to a proposed QA topical report change and a review by the inspector, the vault meets records storage cri-teri . The following items from inspection reports 50-280/79-65 and 50-281/

l 79-85 were reviewed with respect to the licensee's correspondence dated i' Janua ry 25, 1980.

I (1) (Closed) Infraction (280/79-65-01): Failure to Follow Periodic Test. A review of several periodic tests completed in 1981 and I 1982 verified that station deviations were being submitted when

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require (2) (Closed) Deficiency (280/79-65-02, 281/79-85-01): Failure to Properly Conduct Periodic Tests. A review of periodic tests did not identify any discrepancies with respect to technical review The following items from inspection reports 50-280 and 281/81-15 were reviewed with respect to the licensee's correspondence dated August 13, September 1, and September 28, 1981.

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(1) (Closed) Violation (280,281/81-15-01): Failure to Establish Measures to Assure Conditions Adverse to Quality are Promptly Corrected. The inspector reviewed NPSQAM, Section 18, Audits, Revision 6 and verified that this procedure clearly delineates

actions to be followed in the event corrective actions recommended in audit reports cannot be resolved by station personnel or when corrective actions are not accomplished satisfactorily by the

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specified implementation dat The inspector also reviewed the licensee's tracking system for items identifie The tracking system is maraged by a coordinator whose function is to assure corrective actions for identified items are accomplished by their established completion dates. The tracking system includes LER's, IE Report items, bulletins, circulars, notices, INPO findings, QA

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audit findings, corporate items, and vendor correspondence items.

(2) (Closed) Violation (280,281/81-15-02)

Failure to Conduct Fire Detection Instrument Checks. A Technical Specification change has been submitted to delete the calibration requirement. Also, the inspector verified that a Technical Specification surveillance review had been conducte i I

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4 5 (3) (Closed) Violation (280,281/81-15-03): Failure to Maintain Procurement Records. Copies of repeating purchase requisitions

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are now being maintained in station records.

i (4) (Closed) Violation (280,281/81-15-04): Failure to Follow Proce-

! dure ADM-51. The inspector reviewed department procedures which

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controlled the use of each department's unused procedure deposi-

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(5) (Closed) Viola + ion (280,281/81-15-05): Failure to Follow Proce-dures (Part il 11ete Instruments From QC Program. The inspector verified that missing instruments are removed from the QC progra (Part 2) VEPC0 Policy Development Manual. The inspector reviewed various personnel training records. All records that contained sections of the VEPC0 Policy Development Manual were completed as require i (6) (0 pen) Violation (280,281/81-15-06): Failure To Review Proce-i dures. In licensee correspondence dated September 1,1981 (Serial I

No. 466) the licensee admitted the violation and gave a date when full compliance will be achieved as December 31, 198 The NPSQAM, Section SA, Nuclear Power Station Quality Assurance Manual, Revision 4 and ADM 13, Review of Procedures, dated January 21, 1981 define personnel responsibilities to review

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, procedures every two years as required by ANSI N18.7 - 1976 which is endorsed by the accepted QA Program. These procedures are currently being reviewed. This item remains open until the date stated by the licensee when full compliance will be achieved and this area can be reinspected by the NRC to determine that l compliance has been achieved.

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(7) (0 pen) Violation (280, 281/81-15-07): Failure to Develop Shelf j Life Program. Although the committed implementation date of this t

item is June 30, 1982, the inspector did review the progress being

! mad The shelf life program is now underway and a consummable/

! expandable program is being integrated with this progra Both programs will be reviewed during a subsequent inspection.

I (8) (Closed) Violation (280, 281/81-15-08): Failure To Confirm Corrective Action. The inspector reviewed a memo from the Resident QC Engineer (dated May 29, 1981) to the lead auditor of audit 580-13 reinstructing him that audit items are to be closed by the review of objective evidence that verifies that corrective action has been completed.

! (9) (Closed) Violation (280, 281/81-15-09): Failure to Conduct Audit The inspector verified that both a record and document control audit had been conducted at the corporate office. With

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the relocation of much of the quality assurance audit function to the site, the amount of corporate quality records and documents has been drastically reduced.

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(10) (Closed) Deviation (280, 281/81-15-10): Failure to Meet NPSQAM Change Commitment. The computerized tracking system is now in place at the site as discussed in paragraph (11) (Closed) Deviation (280, 281/81-15-11): Failure to Meet Design Interface Procedure Commitment Date. The computerized tracking system is now in place at the site as discussed in paragraph (12) (Closed) Deviation (280, 281/81-15-12): Failure of STAS to ,

Complete Training. A review of training records indicates that all STAS have completed the required training, or where this

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training was not required by an individual, that waiver docu-mentation was recorded and justification for the waiver was provide '

(13) (Closed) Unresolved Item (280, 281/81-15-13): Requalification Examination Criteria. A memorandum from Paul' Collins, NRC, OLB, to R. C. Lewis, NRC Region II clarifying the NRC position on requalification examination criteria was provided to the training supervisor. He will assure that his program is revised as neces-sary to agree with the clarifications provide (14) (Closed) Unresolved Item (280, 281/81-15-14): Qualification of Personnel Prior to NRC Examinatio See comment in paragraph 3.(13) abov . Unresolved Items Unresolved items were not identified during this inspectio . QA Program Annual Review (35701)

References: (a) Accepted QA Program (b) NPSQAM, Section 1, Organization, Revision 4 (c) NPSQAM, Section 2, Quality Assurance Program, Revision 7 (d) NPSQAM, Section 5, Instructions, Procedures and Drawings, Revision 20 (e) NPSQAM, Section SA, Nuclear Power Station Quality Assurance Manual, Revision 4 (f) NPSQAM, Section 10, Inspection, Revision 4 The inspectors reviewed references (b)-(f) as well as other references listed throughout this report to verify they met the requirements of reference (a) and the ANSI Standards endorsed by said reference. The licensee has not submitted any changes to reference (a) since the date of the last inspection in this functional area (IE Report 50-280, 281/81-15 dated July 22, 1981). Based on the results of that inspection; an inspec-tion at the North Anna Facility (IE Report 50-338/81-07, 50-339/81-08); and an enforcement conference conducted in Region II, (IE Report 50-280/81-23, 50-281/81-23, 50-338/81-24, 50-339/81-21) the licensee has determined to implement the following changes to their QA Program:

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6 Reference (a) has been totally reviewed and updated where necessary to reflect current organizational changes as well as commitments to ANSI Standards. Part of this review was performed by an independent con-tractor as stated in the licensee's correspondence dated October 7, 1981. This revised QA Program is scheduled to be submitted to the NRC for approval by May 1,198 The NPSQAM is being totally rewritten to reflect current methods of operation by the QA/QC organization. This rewrite also incorporates changes reflected by reference (a). All procedures are being deleted from the NPSQA Implementation of the NPSQAM is pending the develop-ment of administrative procedures to reflect the current practice This rewrite is tentatively scheduled for July 1,198 The licensee has written and implemented a QA Operations and Mainten-ance Instructions Manual . This manual includes sets of QA and QC instructions that delineate specifically day-to-day operational acti-vities performed by these groups. A partial list of subjects includes the certification program for QC personnel; material inspections; audits; rigging equipment; mechanical, electrical and weld inspections; and inspection of the day's activitie The North Anna OC instruc-tions, although similar, are not identical to the QCIs at Surry due to different conduct of operations at the North Anna facilit The licensee has established a QC inspector of the day. This person's function, delineated in QCI 10.11, inspector of the day, Revision 0, is to monitor and conduct surveillances of station activities and to establish an effective means of assuring compliance with the require-ments of reference (a) and the NPSQA QA/QC personnel are being sent to General System Training Classe These classes provide instructions in plant systems and the interre-lationship between plant systems. To date, approximately 75*; of QA/QC personnel have attended these classe ,

The inspector interviewed QA/QC personnel and key supervisory personnel to verify that personnel are aware of changes in the QA/QC program Based on this review, one inspector followup item was identified. The licensee is in the process of developing a method to assure that plant personnel are aware of changes to the QA Program. Until this method is fully implemented and plant personnel are aware of changes to the program, this area is identified as an inspector followup item (280,281/82-02-02). Design, Design Changes and Modifications (37700)

Reference: NPSQAM, Section 3, Design Control, Revision 13 The inspector reviewed the above reference and verified that it met the

, requirements of the accepted QA Program and ANSI N45.2.11 as endorsed by

! that Program. The inspector verified the following aspects of the licen-l see's design change program:

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that design changes are reviewed and approved as required I -

that design changes are controlled by established procedure The inspector reviewed several design changes to verify implementation of the previously mentioned aspect Based on this review, one irispector followup item was identifie The design change review revealed that the licensee had an ongoing review of all design changes conducted during and subsequent to the steam generator replacement project (SGRP) in order to revise all drawings affected by the design changes. Apparently during the SGRP, a large number of design changes had been made operable without drawing revisions being completed or even proposed. The inspector noted that although the control room copies of the valve operating drawings were being annotated with design changes pending a drawing revision,no other copies of controlled drawings were marked up with actual design changes or at least annotated with design change numbers to insure that drawings used at the work location are adequate as required by 10 CFR 50 Appendix B Criterion VI. No violation for failure to establish measures to control drawing is identified due to the drawing task force now in operation. The licensee committed to October 31, 1982, for revising those drawings identified by the task force and in the interim committed to developing and implementing a drawing control procedure to annotate all controlled copies of these drawings with the design change number by May 30, 1982. The inspector reviewed a proposed procedure to accomplish this function. The licensee also stated this procedure would be used on design changes implemented in the future. This drawing activity is identified as an inspector followup item (280,281/82-02-03) and will be reviewed during a subsequent inspectio . Onsite Review Committee (40700)

Reference: ADM 2, Station Nuclear Safety and Operating Committee, dated 3/82 The inspector reviewed the above reference and verified that.it met require-ments of the Technical Specifications. The inspector reviewed SNSOC acti-vities during 1981 and 1982 (Meetings 107-81 thru 182-81 and 1-82 through 51-82) and verified that membership, review process, frequency of meetings and qualifications of personnel are in accordance with Technical Specifi-cation requirement Based on this review, no violations or deviations were identifie . Audits, Audit Implementation (40702, 40704)

References: (a) NPSQAM, Section 18, Audits, Revision 6 (b) NPSQAM, Section 16, Corrective Action, Revision 13 (c) QAI, Section 18, Audits, Revision 0

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! The inspector reviewed the references listed and verified that they met l requirements of the accepted QA Program and ANSI N45.2.12 as endorsed by i that Program. The inspector verified the following aspects of the audits and audit implementation program:

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Methods have been defined for taking corrective action when defi-ciencies are identified during audits

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responses have been defined

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Audits are conducted by trained personnel not having direct respon-sibility in the area being audited

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Responsibilities have been assigned in writing for the overall manage-l ment of the audit program To verify implementation of these aspects, the inspector reviewed results of

audits conducted during 1981 (audits S 81-01 thru S 81-25). The inspector j reviewed the qualifications of five lead auditors.

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

! Nonlicensed Personnel Training (41/00)

References: (a) Technical Srecifications, Section 6, Administrative Controls (b) ANSI N18.1. Selection and Training of Nuclear Power Plant Persennel, dated 3/71 (c) NPSCAM, Se: tion 2, Quality Assurance Program, Revision 7

! (d) ADM 12, QL.alification and Training, dated 4/82

The inspector reviewed the training program which provides the required training for the facility staff personne This program was reviewed to

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verify that: the program complies with requirements contained in references (a) through (d) above; the program covers training in the areas of admin-istrative controls and procedures, radiological health and safety, L

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industrial safety, security procedures, emergency plan and quality assur-ance training, and pre-natal radiation exposure training for females; non-licensed operators are trained in functions which they perform; related technical and on-the-job training are provided to applicable personnel where required. The inspector reviewed approximately 65 training records of plant staff and of f-site personne Based on this review, no violations or deviations were identifie . Licensed Operator Requalification Training (41701)

References: (a) Technical Specifications, Section 6, Administrative Controls (b) NPSQAM, Section 2, Quality Assurance Program, Revision 7

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(c) ANSI N18.1, Selection and Training of Nuclear Power Plant Personnel, dated 3/71 (d) ADM '.?, Qualification and Training, dated 4/82

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The inspector reviewer' the requalification program to determine conformance to references ( a )-(r;) . The training records of eleven licensed reactor operators and senir e reactor operators were reviewed. The following areas were reviewed: .itraining conducted in 1981; annual written examinations and the individual's responses; documentation of attendance at requalifi-cation lectures; documentation of required control manipulations; and records of eight licensed operator Based on this review, no violations or deviations were identifie . Procedures (42700)

References: (a) ANSI N18.7-1972, Administrative Controls for Nuclear Power Plants (b) Technical Specifications (c) Regulatory Guide 1.33, Revision 1, Quality Assurance Program Requirements (Operation)

(d) Final Safety Analysis Report (e) NPSQAM, Section 5, Instructions, Procedures and Drawings, Revision 20 The inspector reviewed selected plant procedures in accordance with the guidance and requirements provided in references (a) through (e) to ascer-tain whether overall procedures are in accordance with regulatory require-ments. The following criteria were used during this review:

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Required review and approval of procedures and temporary changes is being performed

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Records of changes in procedures are being maintained

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Administrative procedures are being observed in the preparation and l handling of procedure ,

The following specific procedures were reviewed:

ADM 12, Qualification and Training, dated 4/82 ADM 1, Station Organization and Responsibility, dated 9/81 ADM 13, Review of Procedures, dated 1/82 OP7.2, Unit 1, Containment Spray System, dated 6/81 OP7.2, Unit 2, Containment Spray System, dated 8/80 l

OP7.2A, Unit 1, Valve Sheet Checkoff Containment Spray Pumps, dated 6/81 OP7.2A, Unit 2, Valve Sheet Checkoff Containment Spray Pumps, dated 6/81 Based on this review, one inspector followup item was identified. During

review of OP7.2 and OP7.2A for both units, several minor procedure discrep-ancies were noted. The items were discussed with the Shift Supervisor. A i revision to these procedures will be performed to correct these items by July 1,1982. This item will be tracked as an inspector followup item (280,

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281/82-02-04) pending subsequent review of these procedure . Calibration (56700)

References: (a) NPSQAM, Section 12, Control of Measuring and Test Equipment, Revision 9

(b) Surry Unit 1 and 2 Refueling Calibration Schedule Utilizing the licensee's calibration program as described in the references,

the inspector verified that selected instruments and measuring and test equipment (M&TE) had received proper calibration according to the following

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For completed calibrations, documentation was complete, acceptance criteria met, proper revision used, and calibration conducted by qualified individual's

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For calibration procedures, reviews are as iequired by Technical Specifications, controls are established to meet limiting conditions

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for operation, equipment is returned to service, calibration equipment is traceable, and acceptance values are within required limits

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For M&TE, equipment is controlled by site procedures, calibration j frequency is maintained, storage of equipment is proper, and accuracy i is traceable to the National Bureau of Standards or other independent t

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The inspector determined that implementation of several program areas had previously been reviewed by the NRC resident inspectors. Discussions with

, the residents revealed that a review of the M&TE program implementation and I a review of the calibration of safety-related installed instrumentation had not specifically been conducted. Consequently, the inspector selected several torque wrenches, micrometers, and electronic test instruments and verified that the required M&TE calibration controls had been implemente The inspector reviewed the calibration of installed instrumentation speci-fically identified as safety-related. Based on this review, one violation

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. Failure to Perform Technical Specification Calibration

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Ouring the review of reference (b) on April 29, 1982, the inspector noted that the periodic tests (PT 2.15) had not been completed during the 1981 Unit 2 refueling outage on three boric acid tank level instruments as scheduled. Further investigation revealed that on all three level instruments (L-1-102, 163 and 165), the indicator and comparators were calibrated during the outage but the transmitters were no The performance of this PT is to satisfy the refueling outage calibration requirement of section 4.1. A and Table 4.1-1 item 14 of the Technical Specifications. On April 6,1982, based on conversations

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with the NRC senior resident, the inspector was informed that two of the transmitters in question L-1-102 and 165 were calibrated on September 3, 1981 during a maintenance operation and also that all the boric acid level transmitters were calibrated satisfactorily on April 30,1982. The final results indicate that when Unit 2 started up in December 1981, two of the three tanks had both instruments cali-brated, but the common tank for both units has only one instrument

calibrated. This failure to calibrate L-1-163 during the Unit 2 outage is identified as a violation (281/82-02-01), but due to the second instrument on the tank being already calibrated, the inspector

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determined that a reasonable assurance exists to judge the level indication on this tank as being correct during the period when j L-1-163 was not calibrated.

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, Identification of Safety-Related Installed Instrumentation

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l The inspector noted that all calibrations scheduled during refueling l outages, both those identified in Technical Specifications and those i not specified in Technical Specifications, were completed on time (except as noted above). Although the non-Technical Specification instrumentation was satisfactorily completed, no distinction was made l between safety-related and non-safety-related installed instruments.

j Regulatory Guide 1.33 as endorsed by the accepted QA Program requires l

that procedure be written and implemented on the calibration of safety-related equipment such as readout instruments, intericck

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permissive and prohibit circuits, alarm devices, sensors, signal i

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conditions, controls and protective circuits and that this equipment be calibrated and adjusted at specified periods. The licensee has made no distinction as to what equipment will be calibrated under this safety-related calibration requirement. The licensee committed to a June 30, DS2 for performing an evaluation of installed instrumentation and categorizing those to be managed under a required safety-related calibration program. This calibration area is identified as an inspector followup item (280,281/82-02-05) and will be reviewed during a subsequent inspectio . Surveillance (61700)

References: (a) Technical Specifications (b) IWV and IWP Inservice Inspection and Test Program l

Utilizing the licensee's survellance program as described in the references, i the inspector verified that selected plant surveillances met the following required criteria:

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tests were covered by approved procedures which contained applicable prerequisites and preparations, acceptance criteria, and instructions to insure that systems or components are restored to operation following testing

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Completed surveillances were reviewed in accordance with facility

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administrative requirements, were performed within the required time

[ frequencies, were properly handled when tested items failed acceptance criteria, and were performed by qualified individual The inspector determined the implementation of these program areas had previously been reviewed by the NRC resident inspector . Maintenance (62700)

References: (a) NPSQAM, Section 14 Inspection Test and Operating Status, Revision 6 (b) NPSQAM, Section 15, Nonconforming Materials, Parts or Components, Revision 3 The inspector reviewed the maintenance program on safety-related systems and components to ascertain whether the activities were conducted in accordance with approved procedures, regulatory guides, and industry codes and in conformance with Technical Specification requirement The following criteria were used during this review:

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Approved procedures were used where the activity appeared to be beyond the normal skills of the craft

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Activity was accomplished by qualified personnel

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The licensee had evaluated system failures and reported them in accord-ance with Technical Specifications

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Written procedures were established for initiating requests for routine and emergency maintenance

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Criteria and responsibilities for review and approval of maintenance requests were established

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Criteria and responsibilities that form the basis for designating the activity as safety or non-safety related were established

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Criteria and responsibilities were designated for performing work )

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Provisions and responsibilities were established for the identification of appropriate inspection hold points related to maintenance activities

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Methods and responsibilities were designated for performing functional testing of structures, systems, components following maintenance work and/or prior to their being returned to servic The inspector determined that the implementation of the maintenance program had previously been reviewed by the NRC resident inspector . Personnel Qualification Program (36701)

References: (a) Technical Specifications, Section 6, Administrative Controls (b) NPSQAM, Section 1, Organization, dated 9/81 (c) VEPC0 Quality Assurance Manual, Section 1.1, Organiza-i tion, Revision 10 (d) ADM 1, Station Organization and Responsibility, dated 9/81 The inspector reviewed the qualifications of various personnel within the onsite organization to assure that they met the requirements of references (a) - (d). The following positions and persons assigned to the positions were reviewed:

Station Manager J. Wilson Assistant Station Manager R. Saunders Supervisor Administrative Services W. Runner Superintendent Maintenance W. Kibler Superintendent Operations G. Kane

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l Superintendent Technical Service D. Christian Supervisor Nuclear Training L. Edm.cnds l Supervisor Health Physics S. Sarver Instrument Supervisor J. Horhutz, J Electrical Supervisor M. Griffin Supervisor Chemistry E. Swindell Assistant Health Physics Technician K. Yeattes f

Chemist L. Miller, III Engineer R. Coupe Engineer L. Lobo Based on this review, no violations or deviations were identifie . Nonroutine Reporting Program (90714)

Reference: ADM 48, Outstanding Items List, dated 1/79 The inspector reviewed the above reference ar,d verified the following aspects of the licensee's nonroutine reporting program:

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Administrative controls have been established for reporting safety-related events internally and to the NRC

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Administrative controls have been established for completion of corrective actions relating to safety-related operating events

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Administrative controls have been established for the prompt review and evaluation of vendor bulletins and circular The inspector also reviewed the current status of items being tracked by compute Based on this review, no violations or deviations were identifie . Organization and Administrative (36700)

References: (a) Technical Specification, Section 6, Administrative Controls (b) NPSQAM, Section 1, Organization, dated 9/81 (c) VEPC0 Quality Assurance Manual, Section 1.1, Organi-zation, Revision 10 (d) ADM 1, Station Organization and Responsibility, dated i 9/81  ;

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The inspector reviewed references (b) - (d) to verify they met the require-ments of reference (a). The inspector verified the following aspects of the licensee's organization and administration:

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The licensee's onsite organization structure is as described in the facility Technical Specifications

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Lines of authority and responsibility are in conformance with the facility Technical Specifications

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Changes to the organization have been reported to the NRC as requ; red by Technical Specification Based on this review, one inspector followup item was identified. The inspector identified that certain position titles and lines of authority descriptions are not consistent between the referenced documents. These discrepancies do not appear to degrade the organization structure. The licensee is in the process of submitting a revision to reference (a) as well as updating references (b) through (d) to provide consistency between these documents. This lack of consistency between these documents is identified as an inspector followup item (280,281/82-02-06).

18. Offsite Review Committee (40701)

References: (a) Technical Specifications, Section 6.1.c.2, Revised 5/81 (b) Virginia Electric and Power Company Safety Evaluation and Control Administration Procedures Manual, dated 2/8 The inspector reviewed the Safety Evaluation and Control (SEC) organiza-tion to verify that it is conducting the independent review function as described in the referenced documents. The SEC has replaced the committee type review organization for the performance of offsite independent review The inspector reviewed monthly reports between April 1981 and March 1982 and verified that the SEC was reviewing those activities required by the Technical Specification The qualifications of the SEC staff was also reviewed for Technical Specification adequac In addition to the SEC, the inspector reviewed the operation of the Nuclear Overview Committee, a licensee imposed senior management review group organized to periodically review various aspects of nuclear power plant operation Based on this review, no violations or deviations were identifie . Offsite Support Staff (40703)

References: (a) Technical Specifications (b) Nuclear Power Station Quality Assurance Manual The inspector reviewed the referenced documents to verify that the licensee has identified positions and responsibilities in the company offices to perform the offsite function of Quality Assurance, Design, Engineering and Procurement. The inspector interviewed individuals in each functicnal area at the managerial level. During the interview, the inspector verified that each individual was qualified for his position and was aware of his respon-sibilities and authority in relation to the company organization and the Quality Assurance Progra Based on this review, no violations or deviations were identifie .

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2 Licensee Actior. 0n Previously Identified Inspection Findings (92701)' (Closed) Inspector Followup Item (280/79-08-05, 281/79-09-05):

Expendable /Consummable This item i s also identified in violation 280,281/81-15-07 and will be tracked under that identifier.

(Closed) Inspector Followup Item (280/79-30-04, 281/79-47-04)

Tag-ging Record Discrepar.cies. A review did not reveal any tagging dis-

, crepancies, but several tagging records maintained in the electrical I shop were not maintained in the control room storage location. The missing record sheets were not safety-related. A maintenance / opera-tions comparison and correction check was conducted' to update the i operations file and to insure that any other record discrepancies were 1 l corrected.

! (Closed) Inspector Followup Item (280/79-34-01, 281/79-52-01): Incor-

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poration of Bulletin 79-06A Training Into Operation Requalification P rog ram. A review of the licensee's requalification program indicates '

that Bulletin 79-06A requirements have been incorporated into that program.

I (Closed) Open Item (280/79-65-03, 281/79-85-02): Retention of M&TE Information Cards. The inspector reviewed the usage information cards

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and verified that data is retained for sufficient duration to ensure calibration traceability, (Closed) Inspector Followup Item (280/80-10-21, 281/80-11-21):

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Expanded QA Responsibility. The inspector reviewed the NPSQAM, Section 18, Audits, Revision 6. Due to personnel reorganization and title i changes, the Director - Quality Assurance, Nuclear Operations has the responsibility for the overall administration and implementation of the QA audit program. The audit scope and depth are defined in paragraph 5.6.1 of Section 18. The list of audits to be performed is the same as those required by the T/S with the addition of audits in the areas of nuclear fuels, ISI, chemistry, HP and environmental monitorin (Closed) Open Item (280/80-10-22, 281/80-11-22): Conflicting Wording Between the TQAP and the NPSQAM. The inspector reviewed the proposed draf t of the accepted QA Program and the proposed NPSQAM and identified that the conflict relative to the applicability of the NPSQAM has been

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resolved.

j (Closed) Open Item (280/80-10-24, 281/80-11-24): Need for Updated

and Better Defined "Q" List. The inspector reviewed ADM 73, Category and Seismic Class of Components, dated 10/81 and identified that the i licensee has defined those structures systems and components to be covered by the Quality Assurance Program. The inspector also reviewed a memo dated March 8,1982 on the consumable and shelf life progra Although this procedure is in draft form and is scheduled te be issued mid-1982, it contains a list of consumables that are apprcved for use on safety-related structures systems and components.

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17 (Closed) Open Item (280/80-10-25, 281/80-11-25). Revise Procedures for Testing Following Modifications. The inspector reviewed the procedure and data sheet used for design change review. The review sheet assures that all pertinent plant procedures hava been reviewe _ (Closed) Inspector Followup Item (280, 281/81-15-15): GET Training of Personnel: A review was conducted in this area and no significant weak areas were identifie (Closed) Inspector Followup Item (280, 281/81-15-16): Adequacy of Formal Auxiliary Operator Training. Section 10.6 of the 1982 Nuclear Operations Department Training Plan implements a formal training program for auxiliary operator This program is designed to be conducted quarterly and is to consist of approximately 80' hours of classroom instruction (Closed) Inspector Followup Item (280, 281/81-15-17): Personnel Training In Mitigating Core Damage. This program has been developed and presented to health physics, instrument and control, and chemistry managers and technician It is being given annually as part of a continuing retraining progra . (Closed) Inspector Followup Item (280,281/81-15-18): Training Records for STAS. A review of selected records of attendance and grades of STAS indicated documentation is available in the individual's record Old Dominion Univeristy is no longer providing training; therefore, the problem associated with attendance and grades is no longer applicabl '

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