IR 05000305/1983009
| ML20024D415 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 07/19/1983 |
| From: | Hawkins F, Schulz R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| To: | |
| Shared Package | |
| ML20024D413 | List: |
| References | |
| 50-305-83-09, 50-305-83-9, NUDOCS 8308050003 | |
| Download: ML20024D415 (6) | |
Text
{{#Wiki_filter:. . U.S. NUCLEAR REGULATORY COMMISSION
REGION III
Report No. 50-305/83-09(DE) Docket No. 50-305 License No. DPR-43 Licensee: Wisconsin Public Service Corporation P. O. Box 1200 Green Bay, WI 54305 Facility Name: Kewaunee Nuclear Power Plant In.spection At: Kevaunce, WI Inspection Conducted: June 6-8, 1983 hl$ C* Y[ O Inspector: R. D. S'chulz- ' Date ' I /[[[})' Approved By: F. C. Ha'wkins,' Chief Management Programs Section Date Inspection Summary Inspection on June 6-8, 1983 (Report No. 50-305/83-09(DE)) Areas Inspected: Followup on Performance Appraisal Inspection findings identified in Inspection Report No. 50-305/81-27 and training of maintenance personnel identified as an open item in Inspection Report No. 50-305/82-22.
The inspection involved a total of 22 inspector-hours onsite by one NRC inspector.
Results: Four violations were identified (Failure to establish a program to audit the provisions contained within the Technical Specifications - Paragraph 2.b; insufficient certifications for quality control personnel - Paragraph 2.f; lack of procedures for controlling activities - Paragraphs 2.g and 2.h; and failure to establish a formalized training program for specific job-related activities - Paragraph 2.1).
8309050003 830720 PDR ADOCK 05000305 G PDR
, . . DETAILS 1.
Persons Contacted Wisconsin Public Service Corporation (WPSC)
- D.
Berg, Q. C. Supervisor
- D. Hintz, Plant Manager C. Luoma, Manager, Nuclear Power
- M. Marchi, Technical Supervisor J. Mueller, Supervisor of Nuclear Training
- J. Richmond, Plant Services Superintendent
- R.
Ruege, Q. A. Supervisor K. Weinhauer, Nuclear Services Supervisor U. S. Nuclear Regulatory Commission
- B.
Fitzpatrick, Resident Inspector
- Indicates those present at the exit interview conducted on June 8, 1983.
2.
Licensee Action on Previous Inspection Findings a.
(Closed) Unresolved Item (305/81-27-01): Audit report s did not contain an evaluation of the program elements audited.
Fourteen audits were reviewed for 1983 and all contained evalua.: ion state-ments regarding the effectiveness of the elements audited, b.
(Closed) Unresolved Item (305/81-27-02): Audits did not encompass conformance of plant operation to the provisions contained within the Technical Specifications as required by Technical Specification Section 6.5.3.8.
Provisions contained within the Technical Specifications have been randomly audited with no program estab-lished to audit all the provisions in a specified time period. For example, the licensee neither audited the minimum frequencies for testing the following instrument channels in 1981 nor established a time period for auditing instrument channels as specified in Technical Specification Table 4.1-1: - Nuclear Power Range Instrument Channel Test - Reactor Coolant Temperature Instrument Channel Test - Reactor Coolant Flow Instrument Channel Test - Pressurizer Level Instrument Channel Test - Pressurizer Pressure Instrument Channel Test - Steam Generator Level Instrument Channel Test - Steam Generator Pressure Instrument Channel Test - Steam G.
3rator Flow Mismatch Instrument Channel Test - Containment Pressure Instrument Channel Test
, . . This failure to establish a program to audit all the provisions contained within the Technicsl Specifications over a predetermined time period is considered an item of noncompliance with Technical Specification Section 6.5.3.8 and 10 CFR 50, Appendix B, Criterion XVIII (305/83-09-01).
c.
(Closed) Unresolved Item (305/81-27-03): Lack of a periodic review of Quality Assurance Program effectiveness. A review of Quality Assurance Program effectiveness was performed on July 26-30, 1982.
d.
(Closed) Unresolved Item (305/81-27-04): Procedures were not developed establishing the flow and review of technical data.
Engineering Control Directives 4.1 (" Design Change Control," Revision 7) and 4.2 (" Power Plant Design Group / Corporate Nuclear Staff DCR Interface," Revision 1) established the procedures for the flow and review of technical data.
e.
(Closed) Unresolved Item (305/81-27-05): Safety evaluations did not assess the effect of performing modifications on the facility.
The effect of performing the modification is assessed by the shift supervisor, technical supervisor, quality control supervisor, and maintenance coordinator as specified in Administrative Control Directive 5.4, Revision H.
f.
(Closed) Unresolved Item (305/81-27-06): Certifications for quality control inspectors were not adequate. The WPSC Operational Quality Assurance Program committed to Regulatory Guide 1.58, Revision 1, Position 6, on September 15, 1982. This was in response to Generic Letter 81-01 arl delineated specific education and experience requirements for personnel performing inspection, examination and testing activities. Licensee commitments required that personnel performing inspection, examination and testing activities be certi-ficd Level I and that the individual be a high school graduate with one year experience in quality control.
Level II personnel must be a graduate of an accredited engineering or science college or university and have two years experience in quality control or be a high school graduate and have four years experience in quality control.
The inspection effort in this area identified Level II quality control inspectors, whose responsibilities included verification of quality work activities, that were not certified in accordance with the education and experience requirements stipulated in by the licensee's September 15, 1982, response to Generic Letter 81-01.
The basis for certification did not include experience requirements in relation to education, as experience required is dependent on education. The certification referenced general plant experience only, without mention of education. The plant staff was unaware of commitments to Generic Letter 81-01 and Regulatory Guide 1.58, Revision 1.
The certification level was determined solely by the judgment of the QA Supervisor instead of in accordance with
, . . established requirements. Review of Level 11 qualification records indicated that the personnel were qualified for the inspections they had performed but were not properly certified.
Additionally, two quality control inspectors, who had not been certified Level I, were verifying conformance of work activities to quality requirements. One individual had been hired on February 21, 1983 and had accepted safety related work on main-tenance work requests 22209 and 22211. The other had been hired on January 24, 1983 and had accepted safety related work on main-tenance work requests 22076, 22136, and 22151. Although neither were properly certified, each was qualified for the inspections they had performed.
The failure to properly establish the basis for certification of the Level 11 personnel and to certify the two quality control inspectors prior to their conduct of quality inspection activities is considered an item of noncompliance with the Operational Quality Assurance Program and 10 CFR 50, Appendix B, Criterion II (305/83-09-02).
g.
(Closed) Unresolved Item (305/81-27-08): Quality control inspectors reported inspection findings verbally to mechanics to correct adverse conditions. The licensee in their reply to this finding on April 15, 1982 stated that, "Our philosophy is to have QC and main-tenance personnel work as a team to resolve any discrepancies and ensure proper fixes are implemented."
At the time of this inspection, neither procedures nor instructions had been established which prescribed the methods to assure that conditions adverse to quality are identified, controlled, and ' corrected during maintenance or modifications to structures, systems, or components.
This failure to centrol activities affecting quality by way of documented instructions or procedures is considered an item of noncompliance with 10 CFR 50, Appendix B, Criteria V (305/83-09-03).
h.
(Closed) Unresolved Item (305/81-27-09): Forms which were not referenced by procedures or instructions were being used to document the results of inspections, examinations, and tests. At the time of this inspection, no procedures or instructions had been established to control the use, distribution, or retention of the forms. Typical examples of these types of forms included a Hydrostatic Test Report (used to document a hydrostatic test for maintenance work request No. 15032), a Field Fabrication Process and Data Sheet (used to document a weld examination for maintenance work request No. 15032), and a QA Inspection Checklist (used to document inspections of fuel assemblies on January 6-8, 1982).
This is a further example of noncompliance as cited in Section 2.g.
of this report (305/83-09-03).
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. 'O i 1.
(Closed) Unresolved Item (305/81-27-14): There was no training program established related to specific job-re' ed activities < for personnel such as supervisors, engineers, and other professionals.
At the time of this inspection, a training program had not been established related to specific job-related activities for the following types of plant personnel: . - mechanical engineers ! - electrical engineers s - -Level II mechanical quality control inspectors I - department supervisors Specifically, formalized training was not required for these personnel in job-related procedures, instructions, codes and , standards. The lack of a job-related training program for
personnel such as supervisors, engineers, and other professionals i is considered an item of noncompliance with 10 CFR 50, Appendix B, { Criterion II and the Operational Quality Assurance Program j . (305/83-09-04).
I j j.
(Closed) Unresolved Item (305/81-27-19): Failure to review the results of all actions to correct deficiencies. Reviews are ' completed for reportable occurrences, significant events, Part 21 reports,. Technical Specification violations or conditions requiring remedial operator action, security events, maintenance work requests, and audit findings as required by Quality Assurance Directive Nos. 11.2 (Revision 5), 11.3 (Revision 3), and Administrative Control Directive Nos. 2.16 (Revision G), 5.4 (Revision H), and 8.6 (Revision H).
k.
(Closed) Unresolved Item (305/81-27-20): A written trend analysis
' program had not been developed for significant conditions adverse to quality. A trend analysis program was established on
November 10, 1982, through Quality Assurance Directive No. 11.4, ! " Analysis of Failure Trends."
) l' l.
(0 pen) Open Item (305/82-22-01): Failure to develop, schedule, and implement a training program for ma'.aterance personnel. A , ! program has been established and is scheduled for implementation ' in September 1983 through the following procedures: - Mechanical Training Guide, TG-6, Revision A , - Instrumentation and Control Training Guide, TG-7, Revision A l - -Electricians Training Guide, TG-5, Revision A ! ' The training program will be reviewed subsequent to full l implementation.
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. '3.
Exit Interview The inspector met with licensee site representatives (denoted in Paragraph 1) at the conclusion of the inspection on June 8, 1983.
The scope and findings of the inspection were discussed.
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