IR 05000280/1986017
| ML18149A244 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 08/07/1986 |
| From: | Belisle G, Will Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18149A243 | List: |
| References | |
| 50-280-86-17, 50-281-86-17, NUDOCS 8608190365 | |
| Download: ML18149A244 (8) | |
Text
UNITED STATES NUCLEAR REGl)LATORY COMMISSION
REGION II
101 MARIETTA STREET, ATLANTA, GEORGIA 30323 Report Nos.:
50-280/86-17 and 50-281/86-17 Licensee:
Virginia Electric and Power Company Richmond, VA 23261 Docket Nos.:
50-280 and 50-.281 Facility Name:
Surry 1 and 2 Inspection Conducted:
July 7-11, 1986 License Nos.:
DPR-32 and DPR-37 Inspector:C~,)[.,l Approved by:-0/4-. -~
G. KBeiisi~1:ting Section Chief Quality Assurance Programs Section Division of Reactor Safety SUMMARY 8"'"- 1'- ~
Date 1igned cP-1-lk Date Signed Scope:
This routine unannounced inspection was conducted in the areas of licensee action on previous enforcement matters, QA program review, management oversight of performance indicators, and licensee action on previously identified inspection finding Results:
No violations or deviations were identified.
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- REPORT DETAILS Persons Contacted Licensee Employees J. Artigas, Staff Specialist-Quality
- N. Clark, Manager, Quality Assurance (QA)
- R. Collins, Supervisor, QA
- W. Craft, Licensing Coordinator E. DeWandel, Supervisor, Records Management D. Grady, Supervisor, QA Auditing D. Hayes, Supervisor, Administration Services R. Hardwick, Manager, Nuclear Programs & Licensing E. Kopanski, Supervisor, QA Surveillance
- H. Miller, Assistant Station Manager F. Mone, Supervisor, QC Inspections
- J. Waddill, Executive Manager, QA NRC Resident Inspectors
- M. Davis
- Attended exit interview Exit Interview The inspection scope and findings were summarized on July 11, 1986, with those persons indicated in paragraph 1 abov The inspector described the areas inspected and discussed in detail the inspection finding No dissenting comments were received from the license Inspector Followup Item:
Revise Upper-tier and Lower-tier Program Documents to Assure Compliance with Nuclear Operations Department Standard Manual (NODSM) and Station Quality Assurance/Quality Control (QA/QC) Organization, paragraph The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio Licensee Action on Previous Enforcement Matters (Closed) Severity Level V Violation (280, 281/85-03-01):
Failure To Follow Audit Procedure The licensee response dated April 4, 1985, was considered acceptable by Region I The inspector discussed this item with the Supervisor, QA surveillance, and was informed that corrective action had
been complete Objective evidence of a computer printout sheet listing open audit findings was reviewed by the inspecto The inspector concluded that the licensee had determined the full extent of the violation, taken action to correct current conditions, and developed corrective actions needed to preclude recurrence of similar problem Corrective actions stated in the licensee response have been implemente.
Unresolved Items Unresolved items were not identified during the inspectio.
QA Program Review (35701)
Reference: CFR 50, Appendix B, Qua 1 ity Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plant CFR 50.54(a)(l) Conditions of License The inspector reviewed the QA program required by the above references to determine if these activities were conducted in accordance with regulatory requirement The following criteria were used during this review to assess overall acceptability for the established program:
Personnel responsible for preparing implementing procedures understand the significance of changes to these procedure Licensee procedures are in conformance with the QA progra The documents listed below were reviewed to determine the status of the QA program and to verify that NRC approved changes to the QA program had been incorporated into the program procedure VEP-1-SA NODPS-QA-01 NODPS-QA-02 NODS-ADM-06 NODS-ADM-09 NODS-QA-01 NODS-QA-02 NODS-QA-03 VEPCO Topical Report Quality Assurance Program, Operations Phase Quality Assurance/Quality Control, dated 5/3/85 Corrective Action Policy, dated 5/3/85 Organizations Responsibilities, Interfaces, Revision 0 Preparation and Control of Procedures, Revision, 0 Corrective Action, Revision 0 Audits, Revision 0 Inspection/Surveillance, Revision 0 Quality Assurance Department Instruction Nuclear Manual
Section 1.0, Section 2.0,
Organization, Revision 1 QA Operations and Maintenance, QA Program, Revision 0 Section 1 Audits, Revision 1 ADM-1. 0 ADM-111 Station Organization and Responsibility, dated 6/10/86 QC Inspection and Nonconformance Reports, dated 1/7/86 The VEPCO Topical Report, QA Program Operations, Revision 5 was approved by the NRC on February 13, 198 The synopsis of changes that accompanied this revision listed among others, changes to the QA program delineated in Section 17. These changes to the QA program involved the deletion of the Nuclear Power Station Quality Assurance Manual (NPSQAM) and its replacement by the Nuclear Operations Department Standard Manual (NODSM).
The change in upper-ti er program documents became effective on June 30, 1986, and was authorized by a memorandum signed by John Waddi 11, Executive Manager, QA, with the concurrence of Vice President Nuclear Operation Nuclear Operations Department (NOD) Policy Statement NODPS-ADM-07 describes the hierarchical relationship between policies, standards, and procedures concerning their implementation and administration at the corporate and station leve Implementation of these program documents ensures that commitments delineated in the Topical Report are performe Policies are established by senior management and associated standards, which enumerate policies and guidelines, are subsequently develope Lower-tier procedures which implement requirements of the NODSM are next developed at either the corporate or station level within NO Pursuant to the change in 1 i cen see upper-ti er QA program documents, the inspector interviewed license personnel and reviewed lower-tier program documents to verify that commitments de 1 i neated in the NODSM have been addresse The inspector reviewed the organi zat i ona 1 structure of the stations quality assurance department as delineated in the Topical Report to ascertain its functional responsibilities, levels of authority, and lines of internal and external interfac Reviewing section 2.0° of the Quality Assurance Department Instruction Nuc 1 ear Manua 1 rev ea 1 ed discrepancies between the existing site organization and the description provided in the Topical Repor The inspector determined that the reporting chain for the Executive Manager, QA had been transferred from the Executive Vice President-Operations to the Senior Vice President Engineering and Constructio Additionally, a reorganization of the site QA organization had been implemented and a
new Manager-QA had recently assumed responsibility for the on-site QA/QC activitie *
Discussions with licensee management were conducted concerning the impact of the change in reporting requirements of the Executive Manager-QA and its impact on the Technical Specifications (TS).
The inspector was informed that a TS change request was being prepared for submittal to NRR to incorporate the change to Section 6.0 of the TS caused by the abov Based on interviews with the Manager-QA and her staff, the inspector determined that a qualified and trained on-site QA/QC organization had been established by licensee managemen The inspector reviewed the following license internal documents in connection with assessing the status of QA program changes:
Schedule for Administrative Procedures Implementation (Proposed).
Memorandum from R. F. Saunders to all Department Heads/All Section Supervisors, Subject:
Nuclear Operations Department Standards Manual, Station Administrative Procedures, dated 5/5/8 Memorandum from E. P. DeWandel to Chairman, Station Nuclear Safety and Operating Committee, Subject:
Renumbering Administrative Procedures, dated 6/4/8 Memorandum from John W. Waddi 11, Executive Manager, QA to NPSQAM Distribution, Subject: Cancellation of Nuclear Power Station QA Manual (NPSQAM), dated 6/30/8 The schedule for administrative procedure implementation deli.neated a proposed schedule for implementation of the NODSM, conduct of initial employee awareness training sessions, and reviews by supporting departments to identify minor discrepancie The memorandum from R. F. Saunders established firm dates to assure that station administrative procedures conform with the NODS The following dates were listed:
June 30, 1986:
July 1, 1986:
Responsible sponsors of administrative procedures comp 1 ete reviews to determine those that contain major ( programmatic inconsistencies)
discrepancies or noncompliance with the Nuclear Operations Department Standards Manua These reviews will be documented by memos to the Supervisor Records Management stating the completion dates and results of the administrative procedures review/revisio Beginning this date, all new administrative procedures shall be submitted in compliance with the NODS In addition, each existing administrative procedure shall be thoroughly reviewed at the time of its regular scheduled review cycle for compliance with the NODS August 30, 1986:
July 1, 1988:
All identified major discrepancies or non comp 1 i ances with the NODSM sha 11 have been correcte All administrative procedures shall be in compliance with the NODS In discussions with licensee management concerning the above dates, the inspector was informed that all activities required to be completed by June 30 had been accomplished. Objective evidence of this was presented by 1 i cen see management in the form of memorandums from support departments which the inspector reviewe Based on this review and discussions with licensee management, the inspector determined that minor discrepancies identified by supporting departments are of minor safety significance (i.e.,
typos or editorial) and do not impair effective implementation of the QA progra A review of licensee management established programs for monitoring regulatory/safety performance indicators was performed by the in specte Licensee management has established the following programs which provide NOD management and upper level management with overview information related to the operation of the nuclear units:
Nuclear Performance Monitoring Management Information Report Power Operations Management Report The Nuclear Performance Monitoring Management Information Report is prepared monthly by Nuclear Operations with assistance from Performance Service This report provides an overview of nuclear plant performance through the tracking of selected performance indicator The Power Operations Management report is prepared by the Power Operations Management Services Department based on information and data submitted to it each month from all power operations department It also provides management the opportunity to review and compare major events and selected performance indicators from all power operations departmen The Nuclear Performance Monitoring Management Information Report provides the capability to monitor 34 performance indicators, and is organized in accordance with the recommendations contained in INPO good Practice OA-10 Based on the review of the program documents describing the above management information systems and copies of prepared reports, it is apparent that management is involved in assuring quality for nuclear safety related activitie The inspector a 1 so determined that 1 i censee management has deve 1 oped and implemented a program for managing and tracking commitments in the NO A trending program for use by the QA Department is also presently being deve 1 ope This program is intended to provide management with the following information:
".
Systematically present to senior management an overview of adverse findings identified by the Quality Assurance Departmen Create an independent data base of adverse findings and other discrepancies determined to be pertinent by the Quality Assurance Departmen Evaluate performance trends in selected functional areas and recommend to management appropriate corrective actio The establishment of these management tools provides additional indications of management's attention to assure that activities are conducted in a quality manne Within this area, one Inspector Followup Item was identified. The following memorandums identified major nonconformances with the NODSM and are required to be corrected by August 30, 1986:
Memorandum from B. R. Parkhurst to E. P. DeWandel, Subject:
ADM Procedures Review to NODSM, dated 6/26/8 Memorandum from D. A. Christian to E. P. DeWandel, Subject:
Nuclear Operations Department Standards Manual Station Administrative Procedures, dated 6/27/8 Memorandum from E. S. Grecheck to E. P. DeWandel, Subject:
Nuclear Operations Department Standards Manual Technical Services Review Administrative Procedures, dated 6/30/8 Additionally, the inspector determined that activities associated with revising and implementing the Procurement Process Standard (NODS-MM-01) is still ongoin Licensee position statements concerning requirements of Regulatory Guide 1.26, Quality Group Classification and Standards for Water, Steam, and Radioactive Waste Containing Components of Nuclear Power Plants, states that the company does not use the specific A, B, C, and D levels as delineated in the guide. It further states that specific listing of items to which the operational QA program applies is described in more detail in station administrative procedure A resolution is required between the licensee position regarding Regulatory Guide 1.26 and the three categories (Category I, II, and II) referenced in station administrative procedures for procurement and desig The inspector also identified discrepancies between the description of the onsite QA/QC organization delineated in the Topical Report, and the organization structure and reporting requirements that is being implemente Until licensee management corrects major nonconformances in the support department's procedures identified above, and resolves discrepancies between upper-ti er program documents and the on-site QA/QC procedures, this is identified as Inspector Followup Items 280/86-17-01 and 281/86-17-0.
Licensee Action on Previously Identified Inspection Findings (92701)
(Closed) Inspector Followup Item (280/82-02-03):
Update and Control of Drawing The inspector reviewed ADM-37, Station Drawing Revision and Distribution dated May 6, 198 This procedure, paragraph 37.4, requires that the following actions be taken by Records Management upon receipt of a 11 Drawing Annotation Check List 11 *
All identified drawings located at on-site controlled drawing depositories shall be annotated with the design offsite holders of controlled change numbe Station drawings are also required to be notified in writing by Records Management to make the necessary annotat i an The inspector determined that provi s i ans had been made to assure the control of drawings which have been impacted by design change I IJ