IR 05000313/1975015
| ML19326C620 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 04/09/1976 |
| From: | Madsen G, Rich Smith, Westerman T NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19326C599 | List: |
| References | |
| 50-313-75-15, NUDOCS 8004230720 | |
| Download: ML19326C620 (17) | |
Text
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J U. S. NUCLEAR REGULATORY COMMISSION 0FFICE OF INSPECTION AND ENFORCEMENT
REGION IV
i=: IE Inspection Report No. 50-313/75-15 Docket No. 50-313 Licensee: Arkansas Power & Light Company License No. DPR-51 .... Sixth ~& Pine Streets Pine Bluff, Arkansas Category C Facility: Arkansas. Nuclear One, Unit 1
==. Location:.Russellville, Arkansas
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Type of License: B&W,~PWR, 2568 Mwt Type of Inspection: Routine, Unannounced Dates of Inspection: December 3-5, 1975 and December 8-9, 1975 Dates of Previous Inspection: November 10-14, 1975 Reactor Inspector: /) 32-76 ' T. F. Westerman, Reactor-Inspector Date ,'0 } - ' Accompanying ,[' ) '>- ..; Personnel: 01 - <M}N-U /,) / ~~ R. Smith, Reactor Inspector Date h . @M n/,g>r Ji E. Gag'11ardo, Reactor Inspector late , ;., Reviewed By: . b;. _ /2 /> r/-> <- - _ ~ G. L. Madsen, Chief, Reactor Operations and Date Nuclear Support Branch / 800 M , .. . .
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-2 ~ "g;;;G SUMMARY OF FINDINGS 'A.
' Enforcement Action au_ 1.
' Items of Noncompliance Infractions a.
Contrary to 10 CFR 50, Appendix B, Criterion A and Section 2 of the Arkansas Power and Light Quality Assurance Manual Operations (APL QAMO) and QCP 1004.08, the inspector did not find that inspection of Job Orders, Preventative Maintenance, and Preservice Inspection was performed.
(DETAILS, paragraphs 13.b.1 and 13.b.2) b.
Contrary to 10 CFR 50, Appendix B, Criterion V and Section 5 of the APL QAMO: (1) Subsequent revisions to the initial issue of procedure 1304.58 were issued without review by the Plant Safety Conmittee (PSC) as required by Section 5.2 of 1304.58.
(DETAILS, paragraph 13.b.3) (2) The final Preservice Inspection Report was not revi. cad by the PSC as required by section 5.6 of 1304.58.
(DETAILS,' paragraph 13eb.3) (3) Departmental Test Control Charts were not being maintained by the Technical Services Department and were not ~oeing maintained current by the Maintenance Department as required by QCP 1004.12, Section 3.1.2.
(DETAILS, _ paragraph 3.b.2) - c.
Contrary to Criterion IV, Appendix B, 10 CFR 50, primary and secondary coolant chemicals were not specified as "Q" items and controlled as required by ANO Unit l's Quality Assurance Manual.
(DETAILS, paragraph 9) d.
. Contrary to Technical Specification 6.7, a change to a main-tenance procedure for venting the control rod drive cechanisms was cade without reviaw by the Plant Safety Committee and approvc1 by the Plant Superintendent.
(DETAILS, paragraph 8) 5.
Licensee Action on Previously' Identified Enforcecent Itecs Not inspected.
(continued)
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Design Changes .... None.
D.
Unusual Occurrences - de E+: E None.
E== == E.- Other Significant Findings c.;.
- 1. - Current Findings a.
Unresolved Items (1) -7515-01 In-service Inspection An approved plan and schedule have not been issued.
(DETAILS, paragraph 13.b.3) -(2) 7515-02 10 CFR 50.59 and Tests and Equipment - The inspector could find no procedure requirements for safety analysis or report for tests and experiments in accordance with 10 CFR 50.59.
(DETAILS, paragraph 3.b.3) (3) 7515-03 Calibration Control The licensee was in the process of establishing require-ments for as found as left calibration data.
The inspector found no procedural requirements for segregation of nonconforming test equipment.
The inspector did find that three pieces of test gear had been tagged out of service
.with unofficial tags.
(DETAILS, paragraphs'4.b.2 and 4.b.3) (4) 7515-04 Hydrostatic Test Procedures Licensee did not have available for the inspector's review a Hydrostatic Test Procedure for the Building Spray and Residual Heat Removal Systems.
(DETAILS, paragraph 8) 2.
Status of Previously Reported Unresolved Items 7514-1-Plant Safety Committee Review of Temporary Precedure Changes The inspector verified that all of the temporary procedure changes which were identified in inspection 75-14 as being in effect for more than one year have been reviewed by the Plant Safety Committee.
This item is closed.
(continued) 7 * _ -- _ , .v~ -
. . . w- . -4- . 7514-2 Preventative Maintenance Activities The' inspector found no preventative maintenance activities involv- = ~7 ing safety related components which had been accomplished without an' approved procedure. Several items were considerably overdue, .ne but the licensee-plans extensive changes to the program to make it - sar more workable. This item remains open.
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F.
' Management Meetings _.. . 3::,- 1.
Entrance Interview _ An entrance interview was held with Mr. J. W. Anderson at the beginning of each portion of this inspection on December 3 and egain on December 8, 1975.
The inspectors stated that the purpose of this inspection was to continue the Quality Assurance Program implementation inspection whir.h was begun on November 10, 1975.
..= The inspector outlined the scope of their planned inspection efforts.
_ =. = - 2.
Exit Interview
== , An exit interview was conducted with Mr. J. W. Anderson and = embers of his staff at the conclusion of each portion of the inspection on December 5 and December 9, 1975.
The inspectors discussed the scope of the inspection and the findings as summarized above.
Licensee representative said that the review and revision of the preventative maintenance program would be completed by June 1, 1976.
The inspector stated that the program would be reviewed after the revisions have been completed.
(ccntinued) I ,
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DETAILS E= ' Persons Contacted , .:.[ [[ Arkansas Power & Light Conpany-(AP&L)
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s ...... J. W. Anderson, - Jr.,. Plant Superintendent. _ G.-H. Miller, Assistant Plant Supervisor = =5. ~ B. A._ Terwilliger, Supervisor of Plant Operations T. Baker, Chemistry & Environmental Supervisor.
.... _ ' V. Kinsey, Secretary, PSC iff= T. Martin, Maintenance Supervisor L'. W. Humphrey, Quality Assurance Engineer C. N. Shively, Performance Engineer .C.~ A. Halbert, Technical Support Engineer P. Jones, Instrument and Controls Supervisor "iri B.' Baker, Assistant Maintenance Supervisor J. Crowe, Store Room Supervisor __.
== L. Alexander,-Quality Control Inspector J. L. Orlicek, Quality Control Engineer T. Green, Assistant Training Coordinctor , =:;. Subjects Inspected 1.
Purpose of Inspection This inspection was conducted as a follow-on inspection to Inspection No. 75-14 to ascertain that the staff of AP&L has developed and is implementing the Quality Assurance Program as outlined in their manual approved by. KRC letter, Vollmer (NRC/DRL) to Phillips (AP&L), dated May 12, 1975.
Control of Special Process . , a.
Scope of Inspection E.4 : The inspector reviewed the licensee's Quality Assurance Program to deter =ine that the controls of special processes, commensurate with 10 CFR 50 App _endix B, Criterion IX, and Section 9 of the AP&L Quality Assurance Manual-for Operations, has been delineated.
b.
Inspection Findings-1. - Quality Control Procedure 1004.07 Control of Special Processes was found by the inspector to establish requirements consistent with'the_above licensee commitments. The licensee has, for the , i present, employed outside contractors to perform activities ~ relating to special. processes, i.e., welding and nondestructive
== - testing. The> licensee has not developed a program or procedures ._ .. , for' company personnel.
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The licensee stated that outside contractors are qualified in .. _ . ::n '" 2.
accordance with ANO-3 Surveillance Audits.
The inspector found that this procedure does provide for qualifications of outside contractors in the area of special processes.
= Further inspection of the AP&L in-house program for special 3.
processes will pend the development of such a program by the %+;: :ibi.
==- licensee.
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Test Control a.- Scope of Inspection
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The inspector reviewed the licensee's Quality Assurance Program to determine that Test Control requirements, commensurate with 10 CFR 50, ' Appendix B, Criterion X1 and Section 11 of the AP&L Quality Assurance Manual for Operations, have been delineated.
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b.
Inspection Findings - Requirements for naster schedules have been specified for 1.
1004.12 surveillance testing and inservice inspection in QCP Operational Test Control. A master schedule for inservice This item will be subject 79. inspection had not yet been provided.
to further inspection.
2.
During review of QCP 1004.12, the inspector fcund that item 3.1.2 rn of this procedure requires that, "To ensure that the required tests are performed within the specified interval each Plant Supervisor designated on the Master Test Control List shall be responsible for establishing and maintaining a Departmental Test The Test Control Chart shall list all required Control Chart.
the test interval, tests under the cognizance of that department,
schedule date and actual date ptrformed." The inspector reviewed the Department Test Control Chart maintained by the Maintenance, I&C, Operations, and following departments: The inspector found no Department Test Control Technical Support.
Chart for Technical Support to include schedule date and date Technical Support is responsible for annual filter performed.
testing, reactor building leakage, pressurizer code safety valve and inservice setpoint, main steam snfety valve setpoint, The Maintenance inspection of the reactor coolant system.
Departmental Test _ Control Chart was found to be incomplete in that completion dates for station batteries and switch yard batteries (Surveillance Precedure 1405.01) quarterly tests were indicated only once during the four tests performed in 1975.
-Schedule dates, or completion dates, were not shown for Reactor 1304.87) and the Building Tendon Integrity (Surveillance Procedure Main Feedwater lines at the Reactor Building Penetration Gap Measurement between the pipe and annulus for which no . (continued) - - . A
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~ . surveillance procedure had been prepared and which was found-by the inspector to be due in December 1975. This is con-sidered an item of noncompliance.
== -3.
The inspector.did not find that procedural requirements had
==E been established to assure that proposed teste and experiments '= Lwill be reviewed (safety analysis) and reported in accordance with 10 CFR 50.59.
This is considered an unresolved item.
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4.
Control of Measuring and Test Equipment a.
Scope of Inspection The inspector reviewed the licensee's Quality Assurance Program to determine rhat Control of Measuring and Test Equipment was commensurate with 10 CFR 50, Appendix B, Criterion XII and Section 12 of the AP&L Quality Assurance Manual for Operations.
~~ b.
Inspection Findings 1.
The inspector found that QCP 1004.10, Calibration Control, does in general conform to the above commitments.
, 2.
One area was identified by the inspector that will be followed up on during subsequent inspections.
This item deals with the as found and as left condition of test equipment during calibration. The licensee was in the process of revising on-site data sheets to assure that this data is provided. The most. current purchase order (P016140/12-3-75) requesting out-side calibration of AP&L standards was also found by the inspector to request a "before and after calibration report."
Procedural requirements have not been established.
This item is censidered unresolved.
3.
The inspector could find no procedure for segregation and identifying nonconforming test equipment.
Section 5.5 of QCP 1004.01 does require evaluation of out of calibration equip-ment and. reporting to appropriate management of such conditions; however, there are no apparent requirements for segregation to prevent the inadvertent use of nonconforming test equipment as required by 10 CFR 50, Appendix B, Criterion XV and Section 15 of the AP&L Quality Assurance Manual Operations. 'This is considered en' unresolved item.
.5.
Handline, Storace and Shipping a.
Scope'of Inspection The inspector. reviewed-the licensee's Quality Assurance Program to determine that requirements for handling, storage and shipping (continued) , p...., - ,-
! . .. . ~ " = " -8-commensurate with 10 CFR 50,' Appendix B, Criterion XIII and Section 13 of'the licensee's Quality Assurance Manual Operations ~ have been established.
. - b.
Inspection' Fin' dings The inspector found that the licensee was in apparent compliance =? with the above commitments.
6.
-Inspection, Test and operating Status . .a.
Scope of Inspection The inspector reviewed the licensee's Ouality Assurance Program to determine that requirements lfor Inspection, Test, and Operating Status, commensurate with 10 CFR 50, Appendix B, Criterion XIV and Section 14 of the licensee's Quality Assurance Manual Operations, have been established.
b.
Inspection Findings The inspector found the licensee in apparent conformance with the above commitments with exception of status of the inspection of preventative maintenance activities.
(See DETAILS, paragraph 13 of this report with. regard to inspection of preventative maintenance.)
7.
Calibration a.
Scope of Inspection The inspector verified program implementation with rdgard to test equipment calibration as specified in QCP 1004.10.
Four pieces of test equipment were selected (DRS-01/ Decade Resistor, TC Ol/ Timer-Counter, PAS-01/Piccampere Source, DVM-04/ Digital Voltmeter) and reviewed to determine: Each piece was identified on the master inventory.
Calibration procedures had.been provided.
Calibration schedule being met.
- ' Calibration accuracy traceable to NBS or equivalent.
< Storage of test equipment.
The-inspector verified.by-direct questioning of plant technicians their knowledge of plant controls' relating to the following: ' Contrels which' prohibit'use of out of specification test and. measuring: equipment.
Controls which require review of out of specification . equipment.
Controls which require documentation of out of specification equipment.
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- -9-The inspector verified the qualifications of two technicians who perform calibrations.
b.
Inspection Findings 1.
The inspector found the handling of_the four pieces of test equipment identified above to be consistent with QCP 1004.10 in the areas identified.
2.
During the direct questioning of plant technicians, the inspector did not find that plant technicians apreared aware of the existence of Quality Control Procedures relating to administrative control for test and measuring equipment. The plant technicians did, in all cases, respond that out of specification or damaged test and measuring equipment are referred to the appropriate supervisor. At the exit meeting, the licensee stated that training lectures had been presented to plant personn'el which summarized the licensee's QC Program.
The licensee stated that lectures were not intended to be given to personnel on the specific QC procedures.
3.
Three pieces of test equipment, SN 67260 - Dead Weight Testor/ Instrument Shop, DPG-02 - Differential Pressure Gauge / Instrument Shop, and TES-61/SCR Testor/ Meteorology Laboratory, were identified to the inspector as being out of specification. The inspector found that unofficial paper tags with out-of-service had been placed on each. The inspector found that the licensee's QA Program provides no requirements for segregating or otherwise identifying out of specification equipment.
(See DETAILS, paragraph 4.b.2.)
The licensee did indicate, with regard to these particular test instruments, that the calibration tags had been removed.
8.
Review of Maintenance Job Orde,rs A detailed review of the following job orders was accomplished to determine if "Q" listed related jobs were being inspected as required by Quality Assurance Procedure 1004.08 - QC Inspection, and 1004.14 - Initiation and Processing of Job Orders.
Job Order No.
Job Order Title 0951 Replace Gaseous Waste Discharge Filter 0952 Hydro Bui? ding Spray Crossover Line 0953 Se,al Supply Drain Lines 0954 Valve Packing 0955 Sluice Cate //1 0956 Reactor Coolant System Leaks 0958 Packing Leak (continued) . L,.
r .0 s-10- . Job Order No.
Job Order Title 0960 Replace Handle Pin 0961: ' Replace Reactor Coolant Pump Seals 0962 Replace Relay and Test 0963 Hydrostatic Test of Decay Heat System and Reactor Building Spray System
== 0965 "B" Core Flood Tank Valve Packing Leak 0966 Reactor Coolant System Flow Transmitter Root Valve Leak 0967.
Replace Spring in Check Valve in Reactor Building Spray System '0968 Valve CV 1428 Circuit Breaker Trip Investigation 0969 "B" Makeup Pump Drain Line 0970 Vent Control Rod Drive Mechanism 0922 Spring Holder Repairs 0974 Repair Valve CV 1213 0975 Repair Counter for Circulation Pumps 0977 Level Transmit er Isolation Valves A cursory review of Job Orders from 0851 to 0990 was conducted and the . characteristics. inspected were not documented on Form QC 2 as required in Quality Assurance Procedure 1004.08. Greater than 75% of the Job Orders reviewed were designated "Q" related work.
Job Order number 0970 Vent Control Rod Drive Mechanis=s, Step 5.14 of the included procedure _ states, "obtain a new vent plug "O" ring, lubricate it with an appropriate lubricant as in Step 3.2 of this attachment." This section of the procedure had a line drawn through it: and a note on the procedure stated, " replaced on last venting."
These changes were made to this caintenance procedure without having been approved as required by Technical Specification 6.7.
This is considered an item of noncompliance.
Job Order 0963 Hydrostatic Test of Decay Heat System and Reactor Building Spray System did not require or include, as part.of the Job Order, a caintenance procedure for accomplishing the Hydrostatic tests.
In , interviews with the licensee personnel it was stated by the licensee that the evolution was performed to a procedure.
This item is considered unresolved pending recovery of the procedure for these hydrostatic tents.
9.
Procurerent Control, Receiving Inspection and Storage 'The procurement, storage, handling and receiving of safety related equipment and materials was inspected to verify conformance with the requirements of-the following: Arkansas Nuclear One Quality-Assurance Manual ~for Operatiens (continued) ,t4 w " $ .. . -11- - 10 CFR 50, Appendix B, Criteria IV, VI, VII, VIII and XIII as related to the subject of this section.
Arkansas Nuclear One Quality Assurance Procedures 1004.05 - Purchase Requisition Preparation and Processing 1004.06 - Material Receiving and Inspection 1004.18 - thterial Identification The inspection effort consisted of the following: Interviewed selected licensee personnel responsible for procure-a.
ment and control of safety equipment and material to determine their level of urderstanding of their related responsibilities, and under-standing ANO-Unit 1 procedures.
Randomly selected recently purchased safety-related items and some b.
long time stored components to determine that: Approvals of procurement documents were in accordance with 1.
Quality Assurance Procedures.
2.
The items were purchased from qualified vendors.
Procurement documents contain or reference the component and 3.
naterial identification requirements, drawings, specifications, codes and industrial standards, test and inspection require-cents, and special process instructions for such activities as welding, heat treating, nondestructive testing, and clean-ing.
Procurecent documents also identify the documentation (e.g., drawings, specifications, procedures, inspection and fabrication plans, inspection and test records, personnel and procedure qualifications, and caterial chemical and physical test results) to the to be prepared, naintained, and submitted, as applicable, purchaser for review and approval.
That these docunents contain the procuripg agency's right of access to supplier's facilities and records for source inspection and audits.
These requirements were cet by invoking the Archit'ectural Engineer's procure =ent specifications on the supplier.
Ite=s relens.ed to store and use are identified as to their acceptance status.
That the itets have been properly dispositioned in accordance 5.
with the Quality Assurance Procedure 1004.06 - Materials Receiv-ing and Inspection.
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Supplier records, es required by the purchase docu=ent, are available and complete.
= 7.s Inspection at receipt is completed and signed off as required by procedures.
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Items can be traced to the procurement document and inspection records.
== Primary Coolant and Secondary Steam Generator chemicals, such as Boric Acid,-Hydrogen,; Nitrogen, Hydrazine and Amonium Hydroxide, were not ,, identified and controlled as "Q" list items.
"Q" list ite=s are defined in ANO-1 Quality Assurance Manual as a list of items which specifically identifies those structures, systecs, and components whose failure could cause an uncontrolled release of radioactivity, or those essential for the safe shutdown and ic=ediate and long-term operation following a loss of coolant accident.
The following was not accomplished in the procurement control and use of primary and secondary chemicals: 1.
Vendor / Suppliers were not qualified.
2.
Source inspections were not performed.
3.
Purchase documents do not have product specifications listed.
4.
Receiving inspections were not performed to written instructions.
5.
Storage requirements were not documented.
This is considered an item of noncompliance to 10 CFR 50, Criterien IV, which states, " Measures shall be established to assure that applicable regulatory requirements, design bases, and other requirements which are necessary to assure adequate quality are suitably included or referenced in the docu=ents for procurement of material equipment, and services, whether purchased by the applicant or by its contractors or subcon-tractors."
10.
Licensee's Action Following the Bomb Threct of recerber 8 At approximately 7:30~a.m. on December 8, 1975, the licensee received a bomb ~ threat frcm an unidentified individual.
The threat was received Ly telephone in the guard shack at the construction entrance of Unit 2.
The caller said that a bomb is set to go off in the turbine building at 10:05 a.m.
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.= , The licensee's initial action was to begin the recall of personnel and the assembly.of emergency teams in accordance with Emergency ..."" Procedure 1202.34, Personnel Response and Accountability.
The four emergency teams designated in this procedure were assembled and each _ ' team was given instructions to search specific. areas of the facilities of Unit 1.
Operations personnel who were not assigned to the emergency ,=.:;;;.; = teams were assigned areas in Unit 2 which they were to search.
After the emergency teams had been dispatched, the Plant Superintendent called the following offices in accordance with the requirements of the above procedure: a.
Arkansas Power and Light supervisory personnel in Little Rock.
.b.
QA and Startup Group personnel at the Unit 2 site, c.
Local Sheriff's department.
d.
Local FBI agent.
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Region IV Office of Inspection and Enforcement, US NRC, Arlington, Texas.
The licensee's records indicated that the above calls were made within the time interval of 8:15 a.m. to 8:50 a.m.
A licensee representative stated that all of the search teams reported negative findings before the physical plant evacuation which was initiated at 9:35 a.m.
All Operations, QA and Startup Testing personnel were accounted for at 9:40 a.m. and all Construction personnel were accounted for at 9:51 a.m.
" The inspectors arrived on-site a few moments before the evacuation and verified that the plant had been evacuated.
Since no bomb was found, the licensee sounded the "all clear" af 10:30 a.m.
A licensee representative told the inspector that they planned to evaluate possible changes in their emergency procedure which-were indicated by this event.
No discrepancies were noted in the licensee's handling of this event.
11.
Preventative Maintenance During the previous inspection (75-14), the inspector reviewed the licensee's controls of preventative maintenance (PM). The inspector found that the'11:ensee had a computer controlled PM program which was being used to schtdule and record the preventative maintenance activities for the facility. The inspector had found that the licensee had no (continued) . W
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l' 'o ' A..-.. Y G-14-is;;; . > procedures for administering the PM program and licensee represen-tatives had stated.that there existed no procedures for conducting PM maintenance items because the maintenance was not safety related.
._"' The inspector had identified this matter as an unresolved item and = stated that he would, during a future inspection, review the list of PM items to determine if maintenance is included in the PM gg.
program which involves nuclear safety of the facility.
...m . k 2. - During this inspection, the inspector reviewed the list of PM items for the following areas:
Operations Mechanical Electrical Instrumentation and Control Health Physics From the above lists of PM items the inspector selected 22 maintenance ++ items which appeared to be safety related. The inspector found that most of the PM items selected did reference a maintenance procedure which was also reviewed and found to be adequate.
Of the remaining PM items, the inspector found that only two of them involved safety related maintenance.
Licensee representatives said that there was no procedure for these two maintenance items.
They noted, however, that the subject maintenance had not been accomplished, and an approved written procedure would be issued for these items prior to initiation of the work.
The two maintenance items discussed above are: Annual' disassembly and inspection of Reactor Building Spray Pumps a.
b.
Semiannual disassembly and inspection of the Emergency Diesel Air Compressors.
The inspector expressed concern that*the above maintenance items had been scheduled by the licensee's program and had not been accomplished. The inspector also noted that in his review he had discovered other maintenance items which had been scheduled but had not been acco=plished.
Licensee representatives told the inspector that the PM program had been developed by a consultant and contained many maintenance requirements which'they did not believe to be necessary or which could not be accceplished within the frequency specified by the program.
The licensee . representatives said that the program was in the process of being reviewed and corrected to establish a program which would satisfy their needs and the. requirements of Regulatory Guide 1.33 and ANSI Standard N 18.7.
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r- - I ~ . ~ . ' = al - L-15- _ s- .c -_ Licensea representatives' stated during the exit interview that the PM . program revisions would be co=pleted by June'1, 1976. The inspector
- .;a gg stated that the above unresolved item would remain open until the
.ss FM program has been revised.and subsequently reviewed by the inspector.
^ . g E6L - 12. - Temporary Psocedure' Changes
im During the previous inspection (75-14), the inspector reviewed temperary F.52h changes which had been issued for several of the licensee's procedures.
.=_ The in'spector found that the temporary changes had been issued in ~ accordance with the approved procedures.
Fourteen of the. temporary _ changes which were reviewed had been in effect for more than one year, and in accordance with the licensee's. Quality Assurance Manual, should have been reviewed by the Plant Safety Committee (PSC).
The inspector ,sn stated that the PSC reviews would be verified at a future inspection and identified this.as an unresolved item.
During this inspection, the inspector verified that the above temporary _.. _ procedure changes had been reviewed by the PSC.
The initial reviews j?? . of temporary; procedure changes are conducted concurrently with the il annual review of all procedures.
The review is conducted by one of mE the facility supervisors who is assigned as a one-man PSC subco=mittee to review selected procedures.
The supervisor reviews the procedures assigned and their associated temporary changes for their (1) compliance - .to the.TS and FSAR commitments; (2) effect on safe operation of the plant; and (3) technical content.
The supervisor then reports the results of his review to the PSC along with his recommendations on the disposition of the temporary changes.
The report is reviewed by the PSC at a future meeting.
! ' The-inspector expressed his cencern about reviewing temporary changes ~ in this canner.
He noted that, by using the above method of review, the PSC cen3ership may not conduct a personal review of each temporary procedure change.
Licensee representatives stated that use of the
above review methods did not preclude individual PSC tembers from personally reviewing the tetporary changes if they so desire. They l noted that the supervisor apsigned to conduct the detailed review of the. procedures and changes was that supervisor having the expertize in , [ .the area covered by the procedures.
lThe licensee representatives also stated that a proposed TS change was in'the process of being subritted which would require that temporary-procedure, changes be. reviewed during the teeting of the PSC immediately .following issuance of the change.
The inspector said that such a change would satisfy his concerns about the licensee's methods of reviewing temporary procedure changes.
13.
-Inspection ~ a.' Scope of Inspection The inspector-reviewed the licensee's Quality Assurance Progra= to . determine that-inspections, cettensurate with 10 CFR 50, Appendix B, ~ . (continued) t , d::': __ -l-
- r.. .. ' -16-p= g >:== ':'* . Criterion X, and Section 10 of the AP&L Quality Assurance Manual L
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a s&s .for Operations have been delineated.
l .. ~ . b.' Inspection Findings _== 1004.08, QC Inspections, - Quality Control Procedure (QCP) 1.
was found by the inspector to provide guidance for inspection ...""' The planning, performance of inspections, and reporting.
' inspector found, however, that inspection hold points are _ EE The required only if post inspection cannot be performed.
inspector did not find that QCP 1004.08 delineates what inspections are mandatory and the basis and depth that irspections are to be performed. The inspector found that Section 10 of AP&L Quality Assurance Manual, item 10.1.3, identifies quality related activities subject to inspection and ~ The inspector found that includes a list of seven activities.
Receipt of Q-List Materials, Parts or Components" only item "4) which is governed by QCP 1004.06, Material Receiving and Maintenance 3g Inspection, requires mandatory inspection.
activities, including repair, replacement and special main-tenance, are initiated as Job Orders in accordance with Initiation and Processing of Job Orders.
The QCP 1004.14, inspector could find no mandatory inspection provisions within this procedure.
Section 4.4 of QCP 1004.14, does require that, "In general, any maintenance work completed requires checkout prior to returning the equipment to service." The inspector did not find that it was apparent that records required by 10 CFR 50, Appendix B, Criterion XVII to include, " type of observation, the results, the'acceptabil.1ty" or that appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished as required by Criterion V are identiff2d. The only documentation of checkout is the initials of the assigned person on Item 15 of the Job Order.
The only exception would be if a maintenance procedure, design or special instruction had been provided which change document, delineates inspection requirements.
The QC. engineer receives the Job Order only after work has been Documentation of inspection is accomplished approved to commence.
1004.08.
The licensee stated by form QC-2 in accordance with QCP that he was not aware that form QC-2's had been completed by any The inspector questioned . personnel other than the QC Engineer.
that a staff.of three could cover all the required insrection of The licensee stated that the inspection safety related activities.
of each Job Order associated with Q-Listed item is not intended by QCP 1004.08. The inspector did find (continued) ,
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== that Section 2 of the AP&L Quality Assurance Manual for 1004.08, .. _ _ Operations, Table 2-2, states with regard to QCP ~ "This procedure provides guidance'for inspection planning ame; -(including inspection hold points), perfor=ance of inspection, "+9? These and reporting for all activities affecting quality.
' inspections are mandatory for-Q-List items and are optionel 5EE for BOP items." The review of Job Orders discussed in '.i.
. _ _ = - Details, Section 8, of this report indicates that form QC-l's " * " This is are not in general prepared for Q-Listed items.
considered an item of noncompliance.. In the area of preventative maintenance, the inspector could z..m., . 2.- find no Operational QA Program requirements including - Preventative maintenance is discussed in the-inspection.
Details, Section 11,' of this report. This is considered an item of noncompliance.
The inspector reviewed the Inservice Inspection Program to " " _ 3.
determine if inspections by the licensee were performed The inspector found that the during preservice inspection.
Contractor's Manurl was, " Reviewed and Accredited by AP&L QA" on September 7, 1973. The licensee also developed a check-list for inspection (Appendix IV to QCP 1004.08) of the auto-catic ultrasonic (UT) examination of the reactor vessel and associated equipment which was implemented during this phase c of inspection (4/10-17/75).
The licensee could produce no documented inspection of Preservice Inspection, with exception This is of that performed for the automatic inspection by UT.
considered an item of noncompliance.
During review of the licensee's procedure 1304.58, Revision 0, dated March 22, 1975, the inspector identified that it was not apparent that the licensee had complied with the procedure requirements for Plant Safety Review Committee review of revisions to 1304.58, (Section 5.2 states in part, "The Plant . Safety Review Cormittee reviews the procedure and any revisions thereto...") and review of the final preservice report (Section 5.6 states in part, "The final report is submitted to the Plant Safety Committee for review."). The Preoperational Inspection Manual for Arkansas Nuclear One, Unit 1, attached to 1304.58.was dated August 12, 1974, inspection procedure BLI-21-Dye Penetrant Inspection, and Acceptance Standards for Base Materials, Section 2.0 - General ASME Section XI Requirements, dated April 19, 1974, and.Section 3.0 - Listing of Welds, dated iby_23, 1974; of above identified canual were found to have '- been incorporated inte 1304.58 subsequent to its March 22, 1975 . issue date, with no apparent review by the PSC. The licensee could produce no record of review by the PSC of the " Base line Inspection Report Arkansas Power'and Light Company, Arkansas Nuclear One, Unit #1" dated August 12, 1974.
This is identified as an item of nonco:pliance.
(continued) e _,
?: - V . -. ^ 95..0.. ^ -18- -- . = - ri + The licensee has not issued an approved plan or schedule =.- The develop-for the present three year inservice period.
ment of an_ approved plan and schedule is_ considered an - r-unresolved ' item and will be subject to further inspection.
9= The licensee stated that an approved plan and schedule The inservice " would'be developed by the latter part of 1976.
.= inspection is to be perforned after an approved plan and schedule is issued.
At the exit neeting, the licensee stated that the wording 4.
" subject to inspection" (as specified in Section 10.1.3 of the AP&L Quality. Assurance Manual for Operations) implied.
should or may with regard to the quality related activities identified in Section 10.1.3.
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