IR 05000313/1979016
| ML19257B761 | |
| Person / Time | |
|---|---|
| Site: | Arkansas Nuclear  |
| Issue date: | 11/13/1976 |
| From: | Blackwood E, Shafer W, Woessner J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION IV) |
| To: | |
| Shared Package | |
| ML19257B751 | List: |
| References | |
| 50-313-79-16, 50-368-79-14, NUDOCS 8001180274 | |
| Download: ML19257B761 (60) | |
Text
U.S. NUCLEAR REGULATORY COMMISSION OFFICE OF INSPECTION AND ENFORCEMENT PERFORMANCE APPRAISAL BRANCli Report Nos.
50-313/79-16 and 50-368/79-14 Docket Nos.
50-313 and 50-358 Licensee:
Arkansas Power and Light Company P. O. Box 551 Little Rock, Arkansas 72203 Facility Name: Arkansas Nuclear One License Nos.
OPR-51 and NFP-6 Inspection at: Arkansas Nuclear One Plant, Russellville, Arkansas, and Arkansas Power and Light Company General Offices, Little Rock, Arkansas InspectionD$ t t Ju 0 through August 10, 1979 U
Inspectors:
,,
JWE. Gagjiardo Date li),1)Shmby)
11-7-7 9 W. "D'.
Sha fer
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Date N,
//-7-77 o
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M. V. Sinkule Date W =-
ll-/5'?$
(). Woessner iTate Accompanying Personnsel:
W. D. Johnson
- G.
L. Madsen
- T. F. Westerman
- K. W. Whitt
- Present only during exit interview on August 10, 1979 Approved by:
d4 8 M d,/979 E. 8. Blackwood, Acting Chief, Performance Appraisal Branth Date
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1769 355
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INSPECTION SUMMARY Inspection on July 30 - August 10, 1979 (Report No. 50-313/79-16; 50-368/79-14)
Areas Inspected:
Special announced inspection of the licensee's management controls over licensed activitics.
The inspection involved 156 inspector-hours onsite by four NRC inspectors and 136 inspector-hours in the corporate offices by four NRC inspectors.
Results:
Of the ten areas inspected, no items of noncompliance or' deviations were found in six areas; seven apparent items of noncompliance were found in four areas (infraction - failure to update drawing, paragraph 5; infraction-training plan inadequacies and failure to implement the training plan, paragraph 7; infraction-failure to maintain a code safety valve setpoint within acceptance criteria, paragraph 8; infraction-failure of the Safety Review Committee (SRC)
to audit licensed training and retraining, paragraph 9; infraction-failure of the SRC to perform independent review of changes to equipment and systems, paragraph 9; infraction-failure of the Plant Safety Committee (PSC) to render determinations in writing regarding changes to procedures, paragraph 9; deficiency-failure to instruct employees, paragraph 7).
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1769 356
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-1-DETAILS 1.
Persons Contacted The following lists by title the individuals contacted during this inspection or present at an exit meeting.
The matrix to the right of the listing indicates the areas (number corresponds to paragraph number in the report) for which that individual provided significant input.
Other individuals were contacted during the inspection, but the extent of their input to the inspection effort was not significant to the findings delineated in this report.
Title of Individual -
General Office
4
6
8
10
12
+Vice President, Generation and Construction X
X X
X
+ Director, Generation Operations X
X X
X X
X X
X X
Director, Generation Edgineering X
X X
X X
+ Director, Technical &
Environmental Services X
X X
X X
X X
Director, Administrative Services & Project Support X
- + Manager, Quality Assurance X
X X
X X
X X
X X
+ Manager, Licensing X
X X
X
- Manager, Nuclear Operations X
X X
X Manager, Nuclear Fuel X
Supervisor, Office Services X
Manager, Purchasing &
Stores X
Manager, Generation &
Construction Training X
+ Production Engineers (5)
X X
Quality Assurance
.
X X
X X
Engineers (3)
X Nuclear Buyer X
X
+ Licensing Engineers (3)
X X
X X
+ Training Coordinator
+ Manager, Electrical Engineering
+ Director, Generation Technology
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1769 357
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-2-
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Title of Individual On-Site
4
6
8
10
12
+* General Manager X
X X
X X
X X
- Engineering & Technical Support Manager X
X X
X X
X X
X X
X
- 0perations & Maintenance Manager X
X X
X X
X X
X X
X
- Plant Administrative Manager X
X X
X X
X X
- Health Physics Supervisor X
X X
X X
X Plant Performance Supervisor X
X X
X
- 0perations Superintendent X
X X
X X
X X
X X
Maintenance Superintendent X
X X
X X
Instrumentation & Controls Superintendent X
X X
X X
X X
X
- Technical Analysis Superintendent X
X X
X X
Plant Engineering Superintendent X
X X
X X
X Security Coordinator X
X Nuclear Support Supervisor X
- Training Supervisor X
Nuclear Engineer X
- Quality Control Engineer X
X X
X X
X X
X X
X Storekeeper X
X Shift Supervisors (4)
X
'X X
X X
X Plant Operators (5)
X X
X X
X X
Auxiliary Operators (2)
X X
Quality Control Inspectors (3)
X X
X X
X X
Quality Assurance Engineer (1)
X X
Planning & Scheduling Coordinator X
X Quality Assurance Auditor X
X Production Engineers (2)
X Instrumentation & Controls Supervisor X
Assistant Maintenance Super-intendent (Electrical)
X Assistant Maintenance Super-intendent (Mechanical)
X X
X Plant Electrician (1)
X Plant Repairmen (2)
X X
Records & Administrative Supervisor X
X X
1769 358
J Re:
50-313/79-16 T/C PAGE 3 TO IE IrlSPECTI0f1 REPORT f40S.
50-368/79-14-3-50-313/79-16 and 50-368/79-14 WAS IllADVERTEtlTLY LEFT OUT OF YOUR COPY.
.
4
6
8
10 'll
HP Technicians (5)
X X
X Radiochemistry
-
Technicians (3)
X X
.,
Security Force 1.ieutenant X
X
.
'
Records Clerk X
X
~~
-
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.
,
- Attended the exit meeting at the site on August 3, 1979.
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+ Attended the exit meeting at the General Offices on August 10, 1979.
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2.
Insnection Scone and Objectives This report documents the inspection by the NRC/IE Performance Appraisal
,
Branch (PAB) of the licensee's management controls of licensed activities.
The objective of the inspection was to determine how the licensee performs licensed activities, the results of which will provide input to the PAB evaluation of licensees'from a national perspective.
The inspection effort covered licensed activities in selected functional In each of the functional areas the inspectors reviewed written areas.
policies, procedures, and instructions; interviewed selected personnel and reviewed selected records and documents to determine whether:
the licensee had written policies, procedures, or instructions to a.
provide management controls in the subject area; b.
the policies, procedures, and instructions of (a) above, were adequate to assure compliance with regulatory requirement,s; the licensee personnel who had responsibilities in the subject area c.
were adequately qualified, trained, and retrained to perform their responsibilities; d.
the individuals assigned responsibilities in the subject area under-stood their responsibilities; and the requirements of the subject area had been implemented to achieve.
e.
compliance and activities sampled had been appropriately documented.
,
The inspection findings in each of the selected areas are presented in subsequent numbered paragraphs.
The findings in each area are presented in two parts. The first part contains the enforcement findings which document any identified items of noncompliance, deviations, or unresolved items.
The corrective action for these findings will be evaluated by the Region IV office, which will also process enforcement action and close out the items.
The second part of each area addresses other lesser inspection findings and is entitled " Observations". These are observa-tions that the inspectors believe to be of sufficient significance to be considered in the subsequent evaluation of the licensee's performance.
The observations include the perceived strengths and weaknesses in the
,
1769 359
-4-licensee's management controls for which there may be no well-defined regulatory requirement or guidance.
The observations also include information about the licensee or his management controls which cannot be categorized as a strength or weakness, but are items which could be of significance in evaluating management control systems if they are later found to be generic to licensees having success in the subject area, or to those licensees having problems in the area.
The observations in this report have been classified into one of the above three categories.
The classification is indicated at the end of each observation by a code letter in parentheses.
The code letter "S" is used to indicate a perceived strength, the code letter "W" is used to indicate a perceived weakness, and the code letter "I" denotes an informational item.
Since there is no regulatory basis for most of these observations, enforcement action relative to the observations is not appropriate, and the licensee is not required to take any action regarding them.
The licensee is requested, however, to review the observations, with particular emphasis to those categorized as weaknesses, to determine their applicatien to his management controls and quality assurance program in maintaining or improving his organizational effectiveness regarding the safety of his operation.
3.
Review and Control of Licensed Activities The objective of this portion of the inspection was to determine the ade-quacy of the licensee's management controls over licensed activities and the adequacy of the program for reviewing, monitoring, and auditing the performance of licensed activities by all levels of management.
a.
Documents Reviewed (1) G oeration and Construction (G&C) Department Procedures Manual.
,
(2) Company Policy and Procedures Manual.
(3) Quality Assurance Topical Report, APL-TOP-1A, rev. 4, Sections 15 and 16.
(4) Unit 2 FSAR Chapter 13, Conduct of Operations, through Amendment No. 48.
(5) Unit 1 FSAR Chapter 12, Conduct of Operations, through Amendment No. 44.
(6) Quality Assurance Administrative Manual - Procedares QAA-1 through -17.
(7) Quality Assurance Procedures-ANO 1 through 22.
(8) Plant Administrative Procedures.
.
f769 360
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-5-1005.01, rev. 3, Administrative Controls Manual (ACM)
.
1005.04, rev. 3, Control and Use of Bypasses and Jumpers
.
1005.06, rev. 1, Administrative Inspection
.
1005.12, rev. 2, Standing Orders
.
1005.13, rev. 1, Special Orders
.
(9) Quality Control Procedures.
1004.02, rev. 3, Initiation and Processing of Trouble
.
Reports 1004.08, rev. 5, QC Inspection
.
1004.13, rev. 4, Nonconformance and Corrective Action
.
1004. d rev. 5, Operational Test Control, Unit 1
.
1004.128, rev. O, Operational Test Control, Unit 2
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1004.17, rev. 3, Onsite Contractor / Constructor / Vendor Control
.
1004.19, rev. 4, Hold, Caution and QC Tagging Procedures
.
1004.21, rev.
P., Handling of Procedures
.
1004.22, rev. 1, Document Control
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1004.24, rev. O, Plant Records Management
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1004.25, rev. 1, Document Retention and Disposition
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(10) Position Descriptions.
Director, Engineering, G&C
.
Manager of Nuclear Operations, G&C
.
(11) Summary of Position Impacts.
Quality Control (QC) Engineer
.
QC Inspector
.
(12) Position Impact Questionnaires.
Manager, Electrical Engineering, G&C
.
Manager, Instrumentation and Control, Engineering, G&C
.
Manager, Civil Engineering, G&C
.
(13) Station Log, Unit 1, June 28 - July 17, 1979.
(14) Quality Assurance Audit Reports PQA 1089, PQA 1098, PQA 1325, SQA 551, SQA 556, and SQA 542.
(15) Surveillance Test Procedures.
1304.04$ Pressurizer Relief, Spray and Header Test
.
13.04.01, Reactor Coolant System Temperature Instrumentation
.
Test b.
Findings
.
.
177000I
-6-(1)
Items of Noncompliance None.
(2) Deviations None.
(3) Unresolved Items (a) 10 CFR 50.59 states that the licensee may make changes to the facility as described in the safety analysis report without Commission approval providing that a record of a written safety evaluation be maintained to provide the bases that the change did not involve an unreviewed safety question.
Procedure 1005.04, Control and Use of Bypass and Jumpers, allows the use of jumpers on operating systems without providing consideration of these requirements.
This item is unresolved pending further examination to determine if requirements were being met (313/7916-01; 368/7914-01).
(b) During a tour of the Unit 2 control room on August 3, 1979, the shift supervisor could not produce results of the primary system water chemical analysis for chlorides, florides, and oxygen for samples required on August 1, 1979.
This item is unresolved pending further examination to determine if sampling requirements were being met (368/7914-03).
_
c.
Observations The following observations include the perceived strengths and weaknesses in the licensee's management controls.
No specific regulatory requirements relate to many of these observations which will be used for subsequent performance evaluations (Reference paragraph 2).
(1) The Operations organization was as shown on Figures 6.2-1 and 6.2-2A of Unit 1 TS and Figures 6.2-1 and 6.2-2 Unit 2 TS.
The Plant Manager stated that the approximate turnover rate of non-supervisory personnel from January 1,1978 to July 1,1979 was as follows.
a)
Operations
-
11%
b)
Maintenance
-
12%
c)
Instrument and Control
-
22%
d)
Health Physicist / Chemist -
18% (I)
(2) Procedure 1005.04, Control of Jumpers and Bypasses, did provide controls for jumpers and bypasses to mechanical systems.
The procedure also provided for independent verificat. ion of instal-ling and removing all jumpers. (S)
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1770 002
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(3) The Director, Engineering, G&C, stated the size of the corporate engineering department had increased from 17 to 74 in the past 18 months.
This increase included engineers, technicians, and administrative personnel. He also stated that approximately 80-85% of these employees were involved in Arkansas Nuclear One (ANO) activities.
(S)
(4) The Director, Technical and Environmental Services, G&C stated that the size of this technical support department had increased from 14 to 45 in the past eighteen months. (S)
(5) Corporate managers interviewed appeared to be aware of operating activities at ANO. (S)
(6) G&C Procedure 505 required a review of the Station Logs which included a review for adverse trends.
The Manager of Nuclear Operations had performed a documented review of the Station Log as delineated in this procedure. (S)
(7) A QC procedure had been developed for control of activities performed on-site by contractors, constructors, and vendors. (S)
(8) The Vice F esident, G&C, stated that he had recently requested that the ANO training effectiveness be evaluated by a task group.
(see paragraph 7.c.(1)). (S)
(9) The Vice President, G&C, stated that he received a daily verbal update of facility problems and status, and weekly and monthly written reports concerning facility operation.
He also stated that he received copies of all NRC correspondence and QA General Audit Reports. (S)
(10) During a meeting with the inspection team, the Manager of Nuclear Operations summarized an improvement program study that Arkansas Power and Light had instituted with the aid of consultants. The results of the study indicated that additional review and evalua-tion would be required in a number of areas.
The Manager of
' Nuclear Operations stated that a plan had been formulated to do this.
Responsibilities had been assigned, the scope of work had been defined, and a schedule for ccmpletion of the review and partial implementation had been established.
The Manager of Nuclear Operations stated that the review was scheduled to be completed by October 25, 1979.
(S)
A summary of the scope of work specified in the improvement plan was as follows.
(a) Organization Evaluate management practices.
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R70 003
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Define the ANO organization.
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Develop detailed job descriptions for ANO organization
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and key general office interface positions.
Evaluate the internal and externa' communication
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,
requirements and methods.
(b) AND Staffing Identify functional areas requiring manpower
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evaluations.
Establish priority for filling open positions.
.
Establish best method to recruit / hire necessary
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people.
Provide written instructions describing organizational
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responsibilities and procedures to keep staffing current.
Obtain approvals for any "special" conditions
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necessary to recruit people.
,
Implement programs to document manpower utilization
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and efficiency.
(c) Conduct of Operations Conduct a detailed review of control room operations.
.
Develop and implement recommendations based on this
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review.
(d) AN0 Procedures Review and evaluate all published policy regarding
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procedure execution.
Review and evaluate existing training regarding
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procedures and procedure adherence.
Perform a sampling review of Maintenance, Operating,
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and Periodic Test Procedures to ensure procedures are definitive, adequate reviews are required, and content is understandable.
(e) ANO Training Review and evaluate existing train.ing. programs and
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methods used at ANO.
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1770 004
-9-
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Review other utility training programs.
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Review training pro 0 rams used by other industries or
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professions.
Develop an action plan to formalize and expand the
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training program.
(f) ANO Human Awareness Identify current prob;ams that may be contributing to
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human errors.
Provide an on going measurement of the effectiveness of improvement programs.
The manager of Nuclear Operations stated that the completion schedule of the review and evaluation was as follows.
Organization, October 25, 1979
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AN0 Staffing, August 30, 1979
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Conduct of Operations, September 13, 1979 (Including Imple-
.
mentation of Recommendations)
AN0 Procedures, October 25, 1979
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AND Training, October 25, 1979
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ANO Human Awareness, August 30, 1979
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(11) The Policy and Procedures Manual, Section F, contained corporate policy regarding internal communications.
During interviews the inspector determined the following.
The Vice President, G&C, stated that he conducted meetings
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with the directors that reported to him every two weeks.
The Director of Operations, G&C, stated that he had conduc-
.
tea weekly meetings with the corporate managers in Opera-tions, G&C, conducted monthly meetings with all corporate employees in Operations, G&C, and conducted monthly meetings with the plant managers in Operations, G&C.
The Manager of Nuclear Operations stated that he had not
.
held regularly scheduled meetings with the employees that reported to him; however, he had conducted meetings with the managers and all supervisors at ANO, had attended meetings with several employee groups at ANO,.and was in daily com-munications with ANO management.
1770 005
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The General Manager, ANO, stated that he conducted daily
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meetings with his managers and that he had conducted meetings with all supervisors a.1d employees in the Quality Control and Health Physics groups.
The Operations Superintendent, ANO, stated that he had
.
recently initiated monthly shift supervisors meetings.
He also stated that he had conducted two shift supervisors meetings to date.
.
The Operations and Maintenance Menager, ANO, stated that he normally conducted daily meetings with the Superintendents that reported to him. (I)
(12) A written program had not been established requiring corporate management visits to ANO to observe licensed activities; however, the inspector determined that visits to the site had been con-ducted by corporate officials as follows.
The Vice President, G&C, stated that his goal was to visit
.
ANO monthly; however, he had nat met this frequency.
He stated that he did manage to visit the site 3 or 4 times per year and that the last visit was in June 1979.
He also stated that he encouraged his managers to visit the site.
The Director of Generation Operations, G&C, stated that he
.
performed 2 to 3 visits per month to the site, ome of which were visits during the off-shift to obseree licensed activities and that the visits were documented in expense accounts.
The Manager of Nuclear Operations, G&C, stated he normally
.
conducted weekly visits to ANO.
The Director of Engineering, G&C, stated that he performed
.
two audits of plant operations per year as a member of the Safety Review Committee (SRC).
He also stated that he had made other visits to the site; however, these were usually problerr, related.
All managers and supervisors at the site interviewed
.
stated that they made tours of the plant to observe icensed activities.
The Plant Manager's tour to the c;ntrol rooms was documented by his initials in the S'ation Log. (I)
(13)
Incoming and outgoing mail distribution lists had been estab-lished to assure that Directors and Managers at the. corporate office were appraised of licensed activities. (S)
1770 006
-11.
(14) Surveillance and audit distribution lists had been established to assure that managers at the corporate office were appraised of audit and surveillance findings. (S)
(15) The licensee's distribution system at ANO proviaed NRC inspection reports, QA Audit and Surveillance Reports, and Licensee Event Reports (LER's) to all site managers.
Distribu-tion below this level was at the discretion of the appropriate manager.
Generally, these documents were not made available to nonsupervisory personnel, with the exception of operations personnel, unless the document identified a problem specifically related to the employee's area of responsibil'ty. (I)
(16) The Licensing Section in the corporate offices controlled changes to FSAR's and Technical Specifications.
The site document control section received a specified number of copies from licensing and provided updating of the manuals.
A copy of the change was also placed into the control room reading file.
The Licensing group received a verification memorandum from ANO subsequent to updating individual controlled copies of Technical Specifications. (S)
(17) The licensee had established a mechanism to assure management review for correspondence going to the Commission.
NRC corre-spondence was signed by the Manager Licensing Section or the Vice President, G&C.
Reports concerning nuclear fuel were signed by the Manager of Nuclear Fuel. (S)
(18) Corporate Policy and Procedures Manual contained a policy statemeat regarding the employees accessibility to management in the event of a concern that the employee may have which was not resolved by the employees' immediate supervisor.
Interviews with management at the site indicated that employees were instructed as to management's open door policy during initial employee training.
Employees interviewed did not indicate that this was a problem area. (S)
(19) The Superintendent of Operations reviewed all operating records and logs.
Records distribution to managers above this level of supervision consisted of the Station Log, operating summaries, Abnormal Condition Reports, and Licensee Event Reports. (I)
(20) Mechanisms had been established to obtain and distribute copies of changes to the Regulations, Regulatory Guides, Codes, Standards, Vendor Manuals and Print?- however, tnese documents were not controlled to assure that the documents were current.
During a tour of the Unit 2 control room the inspector observed that a copy of 10 CFR was not available in that area. (W)
(21) A review of Standing Order No. 41 regarding shift turnover requirements did not require the oncoming shift supervisor to review the shift turnover sheet until after he had relieved the off going shift supervisor. (W)
1770 007
-12-(22) The inspector learned the following through interviews and examination of administrative controls:
The Plant Operations Section had the responsibility for
.
administering Reactor Operator licenses.
The Corporate Nuclear Fuel Section had the responsibility
.
for activities affecting the utilization of nuclear fuel. (I)
(23) Functional responsibilities of various departments, sections, and individuals had been delineated in the Unit 1 FSAR, the Unit 2 FSAR, Quality Assurance Topical Report, rev. 4, and site administrative procedures.
These documents did not reflect the functional responsibilities of the current organization described in the facility Technical Specifications.(W) Standing Order 30, however, had been issued at the site correlating old job titles with job titles in the new organization.(S) During the exit intervie's licensee representatives stated that rev. 5 to the Quality Assurance Topical Report also contained functional responsibilities of the current organization and was awaiting NRC approval.
The inspector was also told that programs had been established for upgrading of these documents.
In additica, licensee representatives stated that a program had been instituted for updating both FSAR's. (S)
(24) The Quality Assurance Manual stated that the General Manager was responsible for assuring that the plant was operated in a safe, reliable and efficient manner in accordance with the TS and in compliance with all regulatory requirements.
The Company Policy and Procedures Manual Section 0 provided general philosophy concerning responsibility for industrial safety.
The Vice President, G&C, stated that.he had issued directives to ANO management concerning the conduct of operations regarding specific problems.
Other than the above statements, corporate policy had not been provided in the following areas:
Conduct of Operations to include philosophy of operations.
.
Control of equipment such as placing of jumpers, or
.
(25) The licensee had a writtea system for evaluating the performance of supervisory personnel,(S) but had not established a formal system for evaluating the performance of nonsupervisory personnel. (W)
(26)
Interviews with personnel indicated that there was a manpower shortage in the operations area of Unit 2, facility maintenance, and in plant engineering.
Interviews with licensee management personnel indicated that this problem was caused by the reorganization which became effective in 1978, turnover of personnel [ reference 3.c.(1)], inability to obtain replacements, 1770 008
-13,
delays encountered in the licensing process, and additional requirements imposed by the Commission as a result of the Three Mile Island incident and other generic reviews.
Although manpower requirements of the TS and Inspection and Enforcement Bulletin 79-05C and 79-06C, were being met on August 3, 1979, the situation had an adverse effect on supervisory and employee we.'k loads, scheduling of work, training, and employee initiatives.(W)
The Manager of Nuclear Operations stated that the Company was aware of the situation arid was actively pursuing minimizing turnover.(S)
(27) Interviews with supervisory personnel generally indicated the communications from management had improved during the past 6 months.
Interviews with other personnel indicated that they would like to see improvement in this area.
For instance, one of three plant operators and auxiliary operators in+erviewed stated that better communications were necessary from management on events that occurred on other shifts.
Four of five opera-tions personnel interviewed including shift supervisors, operators, and auxiliary operators, indicated that better communications were needed in the area of informing operations personnel of the extent of design changes prior to performing the change.(W)
(28) The licensee had developed written " Summary of Position Impact" forms, which generally specified the worth of the various positions to the Company.
These summaries were developed from a " Position Impact Questionnaire" where key persannel provided a position summary of specific contributions in the areas of unit profitability, human resources management, quality of service to public, budgetary responsibility, coordinating independent line and staff operations, providing administrative services, external communications, planning, education, and experience.
Job descriptions and responsibilities had not been established to assure that individuals understood their respon-sibilities regarding regulatory requirements.(W) Currently, individual responsibilities were scattered throughout the administrative procedures.
The improvement plan presented by the Manager of Nuclear Operations [ reference 10.c.(10)]
indicated that this area was being evaluated.(S)
4.
Management of Safety and Security Controls The objective of this portion of the inspection was to determine the extent and adequacy of management's overview of safety and security areas including (1) Plant Security; (2) Radiation Protection; and (3) Fire Prevention / Protection.
1770 009
-14-a.
Documents Reviewed (1)
Industrial Security Plan, January 11, 1979.
(2) Security Procedures.
1204.04, rev. 4
.
1204.06, rev. 7
.
1204.07, rev. 9
.
1204.09, rev. 6
.
1204.10, rev. 3
.
1204.15, rev. 1
.
(3) Radiation Protection Manual, Procedure 1601.25, rev. 2.
(4) Radiation Protection Procedures.
1602.04, rev. 6, Radiatior. Work Permits (RWP) and Special
.
Work Permits (SWP)
1602.01, rev. 1, Controlled Access Area Entry and Exit
.
Procedure 1602.07, rev. 2, Radiological Posting Requirements
.
1601.02, rev. 1, Anticontamination Clothing, Minimum
.
Requirements 1601.12, rev. 2, Air Monitoring with Portable Instruments
.
(5) ANO Fire Protection Plan, rev. 2, November 14, 1978.
(6) Fire Protection Procedures.
1202.38, rev. 4, Fire or Explosion
.
1005.17, rev. O, Control of Combustibles
.
1005.18, rev. 1, Control of Ignition Sources
.
1005.19, rev. O, Fire Brigade Training
.
1005.20, rev. O Fire Brigade Organization and Responsibilities
.
(7) Records of recent fire protection inspections and records of fire extinguisher and fire hose inspections for May and June 1979.
(8) AND Training Plan (File 0380.10.1 PR), August 4,1978.
b.
Findings (1) Items of Noncompliance None.
1770 010~
-15-(2) Deviations None.
(3) Unresolved Items None.
c.
Observations The following observations include the perceived strengths and weaknesses in the licensee's management controls. No specific regulatory requirements relate to many of these observations which will be used for subsequent performance evaluations (Reference paragraph 2).
(1) The licensee had developed detailed written procedures [ refer-ences 4.a.(2) and 4.a.(6)] to implement their commitments in the Security Plan and the Fire Protection Plan.(S)
(2) The licensee's Radiation Protection Manual had been issued as a procedure [ reference 4.a.(3) above}. They had also issued a set of procedures (1602 series) which provided detailed instruc-tions for implementing the manual.(S)
(3) The G&C organization had established a position entitled " Fire Protection and Safety Coordinator". The individual in this position reviewed fire protection and safety activities at the site and submitted monthly reports to management.
The site organizatien had a Safety and Fire Protection Coordinator who reported to the Administrative Manager. His responsibilities were to review the records of the monthly inspections of fire extinguishers and hoses and to participate in the monthly inspection of the facility with the Fire Protection Inspector.(S)
(4) The Security Coordinator routinely reviewed the daily log, visitor records, and records of vehicle inspections which were maintained by the guard force.(S)
(5)
In January 1979, the guard force implemented a shift schedule which included a training shift for the guards. The training shift included two days of self-study of procedures and two days of classroom training and practice on the firing range.
The guard force training plan was not written. (W) A guard force representative said that a training plan was being developed and would be issued in late August 1979.(S)
(6) The guard force had a program for reporting violations of security requirements by licensee personnel. They used a form letter which was forwarded to the individual's supervisor via the Security Coordinator and was then placed in.the individual's personnel file.(S)
011
.
.
.
.menoOO
.,
_
_
WWv
^ -., _,
-16-(7) Emergency drills had been performed with the guard force, but written instructions specifying the frequency of drills had not been developed.(W)
(8) The Safety Review Committee (SRC) periodically reviewed the Security Plan and audited its implementation.
The Security Coordinator had no responsibilities to periodically review the plan or the security procedures.(W)
(9) The Licensing Section in the corporate offices was responsible for gathering and disseminating information regarding problems that had been identified at other plants.
It was noted during the interviews that the Licensing Section had fallen behind in this area and had not disseminated this information for several months.(W)
(10) Top level corporate management had issued no policy statements or directives to provide guidance in the performance of activities in the following areas:
Radiation Protection
.
.
Dlant Security Fire Protection / Prevention (W)
.
(11) According to the site and corporate individuals interviewed, corporate management had very little involvement in the areas of radiation protection or plant security.
There was no corporate manager specifically assigned to provide overview of these areas.
The extent of corporate's overview was the periodic audits by the SRC.(W)
(12) Specific responsibilities in the areas of Fire Protection, Security, and Radiation Protection had not been defined in the position impact summaries or in the job descriptions (in the QA Manual or Procedure 1005.01) for the following managers / supervisors:
General Manager (job description did address radiation
.
protection responsibilities)
Administrative Manager (job description had very generalized
.
responsibility in security)
Operations Superintendent
.
Shift Supervisor (job description had very generalized
.
responsibility in security)
Engineering and Technical Support Manager
.
Manager of Nuclear Operations (W)
.
1770 012'
-17-(13) The QA organization audited the procurement aspects of the fire protection program under the 1004 series procedures.
They had not audited fire protection activities under the 1005 series procedures nor had they audited the implementation of the Radiation Protection or Security Programs.(W)
(14) The Security Coordinator did not roucinely review the results of the periodic testing of the security systems.(W)
(15) The Security Coordinator and the guard force official who were interviewed said that they currently had no written program for appraising the performance of the guard force.
They did have a system for reporting security violations [see (6) above].
Fur-thermore, there was no written system for documenting and fol-louing deficiencies identified during tours, tests, and inspections.(W)
(16) Procedure 1005.19, Fire Brigade Training, November 10, 1978, stated that the fire brigade would annually practice extin-guishing fires using " Plant Fire Fighting Equipment." According to the licensee individuals interviewed, the fire brigade or emergency fire team had not yet extinguished an actual fire during their practice s' sions.(W)
(17) Procedure 1005.19 stated that an " attempt" would be made to hold one of the four annual fire drills of the fire brigade with the Fire Team and the Russellville Fire Department.
The Fire Team had not drilled with the Russellville Fire Department in the past year, but members of the fire department had been given a tour of the facility.(W)
(18) Five of the site employees who were interviewed (including one supervisor) were not aware of the fire protection plan or the fire protection procedures.
Two of them said that they did recall receiving some instructions in fire protection during a safety meeting.
The remaining three said that they had received no fire protection training.(W)
(19) One of the health physics (HP) technicians who was interviewed said that the HP group was working an excessive amount of over-time which was causing a serious morale problem and a large turnover of personnel.
Site management acknowledged that the HP group had averaged about 660 hours0.00764 days <br />0.183 hours <br />0.00109 weeks <br />2.5113e-4 months <br /> per man of overtime to date in
.
1979.(W)
(20) Site managers who were interviewed said that an employee's per-formance in the safety and security areas was not considered in his annual or semiannual performance appraisal unless it was his principle area of responsibility such as the HP in radiation protection.(W)
1770 013
-18,
(21) The Training Plan (reference 4.a(8)) required annual retraining of plant employees in the areas of radiation protection and security.
This retraining had not been completed.(W)
5.
Desian, Engineerina, and Modifications The objective of this portion of the inspection was to determine the adequacy of management controls associated with engineering, design changes, and modifications.
a.
Documents Reviewed (1) Selected portions of the Unit 1 FSAR.
(2) TS 6.0 for both Units 1 and 2.
(3) Selected portions of the QA Manual, Sections 1, 2, 3, 5, and 10, rev. 4.
(4) QA Audit Reports and Surveillances:
ANO-17 Design Change Request, Unit 1, November 1978
.
ANO-17 Design Control, Unit 2, June 1979
.
ANO-17 Drawing Control, Unit 2, December 1978
.
Review of Valve Alignments, Unit 2 Diesel Oil Transfer, July
.
1979 AN0-18-4 Design Change Control,. Unit 1, January 1979
.
ANO-18-5 Design Document Control, Units 1 and 2, March and
.
April 1979 ANO-18-6 Drawing Control, Units 1 and 2, April 1979
.
(5) QA Procedure ANO-17, Operating Plant Surveillance Audits.
(6) Procedure 1005.01, Administrative Controls Manual.
(7) QC Procedures:
1004.01, Design Control, rev. 4
.
1004.08, QC Inspection, rev. 5
.
~
1094.17, Onsite Contractor / Constructor / Vendor Contro1,
.
rev. 3 1770 014
.
-19,
1004.14, Initiation and Process of Job Orders, rev. 4
.
1004.23, Drawing Control, rev. 4
.
(8) Design Change Request (DCR) packages and affected drawings:
DCR 1-79-30, Modify Override on Emergency Feedwater MOVs,
.
Unit 1, drawing E-318 DCP 79-1001, Small Break ECCS Redesign, Unit 1, drawing
.
M-231 DCR 2-55, Installation of Vent Valves on the Steam Generator
.
Condensing Pots, Unit 2, drawing M-2206 DCR 2-25, Facilitate Redundant Boration Path Line-up from
.
Control Room, drawings M-2417 and E-2222 (9) DCR logs for Units 1 and 2.
(10) Operator's Routing Book.
(11) Engineering Coordinctor's List for the third refueling outage.
(12) SRC Audits:
Discrepancies and Plant "odifications, June 1979, Units 1
.
and 2 (12) Generation and Construction (G&C) Procedures:
GCP201, Design Change Package Control, rev. 0
.
GCP202, Design Process Procedure, rev. O
.
b.
Findings (1) _ Items of Noncompliance 10 CFR 50, Appendix B, Criteria V, Instructions, Procedures, and Drawings, and Section 5 of the Quality Assurance Topical Raport (APL-TOP-1A, rev. 4) requires that activities affecting quality be prescribed by documented procedures and accomplished in ac-cordance with those procedures.
The licensee's procedure controlling the issuance and revision of drawings, procedure 1004.23, Drawing Control, required in para-graph 4.5 that, " Drawings shall be revised and issued indicating as a minimum all system changes which have been made which affect system alignments or procedures.
Such drawings should be issued and distributed even though changes may not be complete by and distributed by at least seven days prior to placing the altered
'
177O 015
-20-system.
e.
If system changes are incomplete, these a f fectu.
.s of such drawings will have notations to that effect".
Four completed design change packages were selected and examined for compliance to this procedure.
On one of these, DCR 79-1001, Small Break ECCS Redesign, the associated drawing M-231 had not been revised and issued either during or following implementation of the chango.
This change involved the r.ddition of several valves and new piping on the combined makeup and high pressure injection system, resulting in both a procedure revision and a new system alignment.
The installation and acceptance testing was completed in May 1979.
Operation of the plant recommenced in Jane 1979 following completion of the refueling outage.
This constitutes an apparent item of noncompliance (313/7916-02).
(2) Deviations None.
(3) Unresolved Items (a) Two DCRs examined by the inspector were implemented without safety evaluations being performed in accordance with the provisions of 10 CFR 50.59.
In both cases, licensee repre-sentatives stated that the change did not represent a change as described in the safety analysis report, and therefore did not require a safety evaluation to provide the basis for the determination that the change did or did not involve an unreviewed safety question.
The inspector could not reach the same conclusion during the inspection with the available information, and therefore left the issue unresolved (313/7916-02).
The DCRs in question were as follows:
DCR 660, Unit 1, Delete the group 7 in-limit for the
.
CRDCS sequencer.
DCR 633, Unit 1, Replace the RCP lube oil level
.
switches.
Both the sequencer in-limits and the level switches were described in the safety analysis report.
The functions of the sequencer in-limits, which would have been affected by the change, did appear to be described.
However, the spe-cific type of lube oil level switch, that aspect being changed by the DCR, was not described.
This issue will be submitted to the NRC management for resolution.
.
1770 016
-21-
,
(b) Procedure 1004.01, Design Control, paragraph 5.1.10, re-quired that "during the design change implementation process, the appropriate drawings will be ' yellow lined'
as specific items are completed. This should be done on a daily basis and is the responsibility of the design change coordinator".
Interviews with several licensee representa-tives indicated that this requirement was not being met.
This could not be resolved by an examination of design changes in progress during the inspection and was therefore left unresolved (313/7916-04; 368/7914-03).
c.
Observations The following observations include the perceived strengths and weaknesses in the licensee's management controls. No specific regulatory requirements relate to many of these observations which will be used for subsequent performance evaluations (Reference paragraph 2).
(1) An Action Idea Program was used as an incentive program to encourage licensee employees to submit proposals for design changes which would save monev or enhance safety.(S)
(2) The licensee had developed detailed, step-by-step procedures
[ reference 5.a. (13)] to initiate, process, review, and approve design changes.
The procedures appeared to be well written and well understood by the engineers who worked daily with them.(S)
They did not appear to be as well understood by supervisory personnel at the plant site and in the corporate offices.
An example was the confusion over who made the determination on the requirements for post modification testing.
Procedure GCP202 stated that the discipline engineer did it.
Procedure 1004.14, Initiatic and Processing of Job Orders, which applied to design changes as well as maintenance, stated that the cog-nizant supervisor had this responsibility. Responses from interviews varied widely, including the cognizant supervisor, shift supervisor, Planning and Scheduling, and Plant Engineering.(W)
(3) An observation regarding the GCP200 series procedures [ref-erence 5.a.(13)] was that they required QA to review DCRs, but did not specify their review responsibilities.
Interviews with QA personnel at the corporate offices indicated that an adminis-trative procedure within the QA Section was being developed which would delineate their specific responsibilities in reviewing DCRs. They currently reviewed the packages to verify the Q designation, to determine whether all forms and required documents were included, test requirements were specified, and all required signatures were made.(W)
,
1770 017
-22-(4) The in-line review of all DCRs by QA appeared to be less than adequate in one significant aspect.
By practice and procedure, QA reviewed the DCR before the Licensing Section had made their 10 CFR 50.59 review, issued a safety evaluation (if required),
and determined whether a TS change was required.
Furthermore, the QA audits of the DCRs following the processing of them in the corporate offices did not evaluate the actions and decisions of the Licensing Section.(W)
(5) As indicated in Observation (4) above, QA performed routine audits of all completed DCR packages prior to issuing them for implementation.
This audit verified compliance with the GCP200 series procedures.(I)
(6) Interviews and examinations of QA audit reports indicated that QA did not routinely perform an audit or a review of completed DCRs following implementation which included verification of installation and acceptance test results.
A licensee representa-tive stated that this type of audit had been performed once and that more were planned.
The DCR which had been verif'ed in this manner concerned a
.
modification to the supply air manifolds on the control room dampers.
This audit [ reference 5.a.(4), ANO-17 Design Change Request)] was a comparison of the DCR to the as-built condition.
It did not verify that drawings had been revised, or that procedures, if required, were modified.(W)
(7)
In addition to the single post-implementation audit described in Observation (6), one other atypical audit had beea conducted at the plant site.
This was a " surveillance" audit on the valve line-up of the Diesel Oil Transfer System performed as a result of requirements imposed by the incident at Three Mile Island [see reference 5.a(4), Review of Valve Alignments].(I)
(8) Several of the licensee's procedures [ references 5.a.(3) and 5.a.(7)] required revisions to reflect job titles and position responsibilities changed as a result of the reorganization which became effective in December 1978.
Some of these also referenced procedures which had since been extensively revised and re numbered.(W)
(9) Procedure 1004.01, Design Control, read in part as follows:
5.1.10, During the design change implementation process, the appropriate drawings will be ' yellow lined' as specific items are completed.
This should be done on a daily basis and is the responsibility of the design change coordinator.
5.1.11, Following implementation of the design change, the design change coordinator will assure the appropriate DCR requirements following implementation,.which may consist of drawing update...are initiated.
1770 018
-23-
.
These requirements appeared to conflict with the instructions of procedure 1004.23, Drawing Control, which required the following:
4.5, Drawings shall be revised and issued indicating as a minimum all system changes which have been made which affect system alignments or procedures.
Such drawings should be issued and distributed even though changes may not be complete by at least seven days prior to placing the altered system to service.
If system changes are incomplete, these affected portions of such drawings will have notations to that effect.
Interviews with licensee personnel confirmed that there was confusion and disagreement over the process by which drawings were changed due to design modifications.(W)
(10) Quality Assurance Manual, Section 5, paragraph 5.5.2, required that, " applicable nstructions, procedures and drawings shall i
be reviewed, and retised as necessary, following any modifica-tions to the plant".
This was further amplified by procedure 1004.01, paragraph 5.1.13, which requ Sed that, "after a DCR has been incorporated on a system which is required by the Limiting Conditions for operation in Tech. Spec.'s, those procedures associated shall be changed to incorporate the DCR (if a procedure change is required) prior to declaring the system operable".
This latter requicement appeared too restrictive to ensure that all procedures associated with safety systems or systems affecting safety would be revised accordingly.
As written, the requirement pertained only to procedures which related to systems required for an LCO.
One other procedure applicable to this area, GCP202, required in paragraph 5.3.2 that, "the Discipline Engineer shall review Attachment E to determine which documents will have to be revised for the design change".
The only procedures listed on Attachment E were, " Plant Operations Picc~ fores".
This would not necessarily include, at the Discipline Engineer's " ;cre-tion, procedures on maintenance, surveillance testing, mer-gency procedures, valve line-ups, or other areas.
There was no method to ensure that all procedures, which could be affected by a design change, would be identified and subsequently revised.(W)
(11) Quality Assurance Manual, Section 5, paragraph 5.2.4, stated that in addition to QA audits, " periodic surveillance by the Manager, Quality Assurance ensures ccmpliance with approved instructioris, procedures, and drawings".
This was apparently done to a limited extent by the onsite QA representatives; however, there were no written guidelines on what to survey 1770 019
-24-
&
and the persons interviewed were unclear on how to interpret this requirement.(W)
(12) The semi-annual QA audits of design changes and drawing control by the onsite QA representatives appeared inadequate both in the format used and the manner in which they were conducted.
Audits failed to disclose a significant problem with design change drawing revisions, as described in the apparent item of noncompliance in this section, which appeared to be common knowledge among most of the individuals interviewed at the plant site.
The two QA representatives stated that they were unaware of any problems in this area.
For audits in this area they used checklists, which were limited to specific require-ments and from which they apparently did not deviate.
They did not interview key personnel.
The requirement to temporarily update, issue, and distribute a drawing "by at least seven days prior to placing the altered system to service" (procedure 1004.23, " Drawing Control), was never examined since QA audited only " completed" design changes.
It was the concensus of persons interviewed at the plant site, both supervisory and non-supervisory, that QA had little impact on site activities related to desion changes.(W)
(13) There appeared to be a significant lack of training for engineering personnel at the plant site who were assigned responsibilities related to the processing and implementation of design changes.
Specifically, there was either inadequate (as determined from interviews) or no training in regulations and standards, definition of unreviewed safety question (10 CFR 50.59), procedures, use of hold tags and clearances, radiation controls, and position and organizat.ional responsibilities.(W)
(14) Communications which involved the initiating and processing of design changes appeared to be largely informal.
This applies both to communications between the corporate offices and the plant site and between the licensee and outside contractors.
An exception to the informality was communications dealing with contractual commitments.(I)
(15) Communications between plant management and the operations personnel regarding the descriptions and status of design changes, prior to their implementation, appeared less than adequate.
Interviews with operators and shift supm /isors, and examinations of plant drawings indicated that sufficient informa-tion was not being transmitted to the operating staff prior to putting the design change into effect. The Planning and Scheduling Department transmitted information on the design changes to the operator training personnel prior to implementa-tion; however, the appropriate training was not given to the operators in a timely manner.
They also transmitted brief 1770 020
-25-summaries of the design changes to the Operator's Routing Book, but only after the change had been completed. There were no written administrative controls in this area.(W)
(16) There existed a large backlog of outstanding DCRs. The number varied depending on the type of sample taken (i.e., safety-related or not, low or high priority) and who was interviewed.
The number was by most accounts well over 100, most of a low priority nature. Tracking of DCRs was less than adequate and had recently been assigned to the Plant Engineering Group for them to follow and correct.(W)
(17) The establishment of the Plant Engineering Group at the site had apparently worked well to speed and make more effective the communications between the site and corporate offices on the processing of DCRs. They prepared design changes originating at the site and reviewed the feasibility of those originating at the corporate offices. They were working on eliminating the backlog of outstanding DCRs and trying to identify drawings which needed revision due to design changes.(S) This group, however, suffered from a lack of manpower. The group was established at the reorganization in December 1978. At the time of the inspection only three of ten nonsupervisory engineering positions were filled.(W)
(18) DCRs were not routed through QC for the establishment of QC hold points. The only opportunity by procedure that QC had to place hold points was when the job order implementing the change was routed through QC.
Procedures used to install design changes were not reviewed by QC and did not have hold points written into them.(W)
(19) The only written administrative controls on the actual monitoring of contractor work by licensee personnel was in procedure 1004.17, Step 5.1, which required that "the QCE verifies that the contractor has approved written procedures, as necessary for the work, and is performing the work in accordance with these procedures".
Interviews indicated that safety-related modification work by outside contractors was always monitored when in progress by a licensee representative.(I)
(20) The documentation for the review of generic design problems (i.e., NRC Bulletins, industry correspondence, component or system problems within the plant) was not administrative 1y controlled by procedure.
If such a review resulted in action being taken, such as correspondence to the NRC, a DCR, or maintenance job order, then the documentation for that action documented the review.
Conversely, if no action was required, then no record was made to document it.(W)
~
'
1770 021
-
-26-6.
Corrective Action System and Management of Generic Issues The inspector conducted a review of the licensee's corrective action system and management of generic issues to determine the adequacy of this program and to verify implementation.
a.
Documents Reviewed (1) Quality Assurance Topical Report APL-TOP-1A, Sections 15 and 16, rev. 4.
(2) Quality Control Procedure (QCP) 1004.13, Nonconformance and Corrective Action.
(3) Quality Assurance Administrative (QAA) Procedure, QAA-3, Punch List.
(4) Quality Controls Nonconformance Report Log.
(5) Quality Assurance Punch List.
(6) Plant Safety Committee, Outstanding Items List for NRC Items.
(7) Plant Computer Listing of Incoming Mail.
(8) Administrative Procedure 1005.01, Administrative Contral Manual.
(9) Administrative Procedure, 1005.11, rev. 2, Nuclear Plant Reliability Reporting.
(10) General Manager's Tracking System.
(11) Generation and Construction Procedures Manual.
(12) Nonconformance Report (NRC) Log.
(13) Licensing Section Punch List.
(14) Unit 1 Station Log, June 28 to July 17, 1979.
(15) Unit 2 Station Log, June 13 to July 6, 1979.
(16) Monthly Status Report of NCR's.
(17) Abnormal Condition Reports.
1770 022
-27-
.
b.
Findings
'
(1)
Items of Noncompliance None.
(2) Deviations None.
(3) Unresolved Items None.
c.
Observations The following observations include the perceived strengths and weaknesses in the licensee's management controls.
No specific regulatory requirements relate to many of these observations which will be used for subsequent performance evaluations (Referenced paragraph 2).
(1) Abncrcal operating conditions were reported to site management on tt.e Abnormal Condition Report, (ACR), as specified in Apperdix "D" of procedure 1005.01.
This report could be initiated at any level of management where a deficiency or abnormal condition became apparent.
It was routed through appropriate management for review and determination of reporta-bility.
All ACR's were routed through the General Manager and the Plant Safety Committee for review and approval.
The report was then transferred to a performance engineer who completed the evaluation and prepared a Licensee Event Report (LER) for transmittal to the NRC.(S)
(2) Procedures were established at the corporate office and at the site for identification, evaluation, and reporting of items reportable p r 10 CFR 21.(I)
(3) The Quality Assurance Section tracked followup items identified in audit reports as delineated in QAA-3.
The inspector reviewed the action tracking activities delineated in this procedure.(S)
(4) G&C Department Procedure 300, Nuclear Licensing Document Control, had been established to assure that licensing informa-tion submitted to the NRC received the appropriate review.
The procedure specifically applied to preparation of licensing document changes, review and control of Final Safety Analysis Reports, Environmental Reports, Technical Specifications, review and control of Q-List changes, and review and control of licensing calculations.(S)
1770 023
-28-(5) GSC Department Procedure 301, Licensing Reports and Evaluatien for Nuclear Plants, established written controls for Licensing Reports and evaluations of these reports. The procedure specifically included reportable occurrences, significant deficiencies, general investigative reports, periodic reports required by regulatory agencies, failure analysis, and system performance evaluations. (S)
(6) G&C Department Procedure 204 had been developed to assure that deficiencies in design changes and design-related documents for which Generation Engineering was responsible were identified, documented, classified, and corrected.(S)
(7) Core performance data was reviewed monthly and core performance was compared against predicted values and graphs in the areas of fuel burnup, power distribution (both axial and radial),
boron concentration and primary system activity. The licensee had established G&C Procedure 311, Nuclear Fuel Management Report, to assure that fuel performance and/or operating condi-tions were reviewed and documented.(5)
(8) Procedure 1004.13 discussed the process of documenting sat re-porting of nonconformances. The procedure assigned the 1C Engineer the responsibility for issuing sequentially numt +c; Nonconformance Report (NCR) forms and for maintainin; a log of NCR's in numeric sequence. The cognizant supervisor was respon-sible for determining the need for an NCR.
Section 5.0 of the procedure discussed the use of Trouble Tickets, Job Orders, Receiving Inspection Reports, and Failure Disposition Reports.(S)
The procedure did not discuss the requirements for when an NCR should be used, but it did discuss the instructions for processing the form.(W) The QC Engineer issued a monthly report to the General Manager-regarding the status of outstanding NCR's.(I)
(9) The Licensing Section in the corporate office maintained a punch list and card system for tracking all items which required an NRC response. The Manager of Licensing stated that he normally notified personnel responsible for action approxi-mately one veek before the response due date. He also stated that this management control was not delineated in an adminis-trative procedure.(W)
(10) Procedure 1005.01, Administrative Control Manual, specified the licensee management and NPC reporting requirements subsequent to an abnormal operating event.(S) Administrative procedures did not, however, provide guidance delineating the extent of evaluation required during the followup of an event.(W)
(11)
Incoming mail from vendor or NRC which identified generic problems was sorted, entered into a computer, and distributed to the General Manager and the three managers reporting to him.
The General Manager assigned responsibility'for~ corrective
.
1770 024
-29-i actica and entered the action in his tracking file. The responsible department manager assigned corrective action and used his own mechanisms to follow corrective progress. Two of the department managers stated that they tracked corrective action by use of the computer printout for incoming mail by making additional entries after the responsibilities were assigned.
If the item was transmitted through the PSC and further action was required, the item was listed on a computerized punch list generated by the PSC.(S) This action tracking system appeared to be working, however, it was noted that no written administrative procedure had been established to describe the tracking of externally identified items.(W)
The General Manager stated that administrative controls at the site were being upgraded to include delineation of the corrective action tracking systems at the plant.(S)
(12) Trending of nonconcompliance, licensee events, or component failures, was not being accomplished beyond the cognizant supervisor's daily awareness of plant activities.(W) Personnel interviewed stated that failure history was being accumulated and that the licensee did participate in Nuclear Plant Reliability Data System (NPRDS).
Personnel interviewed at corporate offices also stated that the Company was performing research into the feasibility of trending.(I)
7.
Training The objective of this portion of the inspection was to determine the ade-quacy of the licensee's management of training activities, both on-site and in the corporate offices.
a.
Documents Reviewei.
(1) Unit 1 FSAR, Section 12.2 (Training).
(2) Unit 2 FSAR, Section 13.2 (Training Program).
(3) ANO Training Plan (File:
0380.10.1 PR), August 4, 1978.
(4) Procedure 1005.01, Administrative Cortrols Manual, rev. 3, Section 2.2.4 (Operator Training).
(5) Procedure 1004.03, Quality Control Training and Indoctrination, rev. 1.
(6) AP&L Production Department, Nuclear Services Organization Proce-dure NSP-I-3, Nuclear Services Training, rev. O.
(7) Corporate Orientation Program for Assistant Engineers in Production Department, January 17, 1975.
1770 025
=
-- -
- - -
. -. -. - -.. -. -
-30-(8) Skills Training Curriculum for White Bluff S.E.S., Memorandum -
Fred Holland to W. G. Shurgar III, August 9, 1979.
(9) Training Needs Assessment for Generation and Construction, G&C Training Section. 1979.
(10) Training records for the following site personnel:
Six (6) Operators and Senior Operators from Units 1 and 2
.
Three (3) Health Physics Technicians
.
Four (4) Maintenance Mechanics
.
Two (2) Electricians
.
One (1) I&C Technician
.
.
Two (2) Radiochemistry Technicians (11) Training records for the following corporate personnel:
Five (5) Managers / Directors
.
.
Three (3) Production Engineers Two (2) QA Engineers
.
(12)
Position Impact Summaries for three (3) corporate level managers.
(13) Quality Assurance Topical Report, APL-TOP-1A, rev. 4, Section 2, Quality Assurance Program.
(14) ANO Unit 1, Fire Protection Plan, rev. 2.
(15) Procedure 1005.19, Fire Brigade Training, rev. O.
b.
Findings (1)
Items of Noncompliance (a) TS 6.4.1 for both Unit 1 ard Unit 2 requires the licensee to maintain a retraining and replacement training program for the facility staff which meets or exceeds the require-ments and recommendations of Section 5.5 of ANSI N18.1-1971.
Section 5.5 of ANSI N18.1-1971 stated that a " training program shall be established which maintains the proficiency of the operating organization through periodic training exercises, instruction periods, and reviews covering those items and equipment which relate to safe operation of the facility and through special training sessions for replace-ment personnel.
Means should be provided in the training programs for appropriate evaluation of its effectiveness."
The licensee had issued a Training Plan [ reference 7.a.(3)]
to meet the above requirements.
Section 5.0 of this L770 026
-31-Training Plan stated that the training for the Maintenance Group would consist of lectures, programmed self study, classroom courses and on-the-job training in basic maintenance skills, and training on specific equipment or tasks as r.eeded.
Section 12.1 of the Training Plan required that upon completion of a training evolution, a document package would be assembled and sent to the files.
The package would contain the following:
Appropriate attendance sheet or record
.
Copy of any exam given with answer key and graded
.
answer sheet Lesson outline
.
Document scheduling the training
.
The inspector reviewed the training records in the records vau!t and in the OS/6 computer files for selected mainten-ance department individuals [ reference 7.a.(10)].
Three experienced maintenance mechanics had received only four or five technical training lectures in 1978 and 1979.
A fourth mechanic who had begun employment with the licensee in January 1979 had received no technical training.
The two maintenance electricians had received only six and eight technical training lectures, respect.ively, in 1979.
There was no documentation of on-the-job training (0JT)
for any of the six maintenance personnel.
Maintenance department personnel who were interviewed said that there was no written OJT program in the department.
Section 3.2 (General Employee Training) of the Training Plan established a training flow path for new employees which included a Quality Assurance Indoctrination if the individual's duties affected QI The training records indicated that one of the health physics technicians and one of the maintenance mechanics had not received the QA indoctrination.
Section 3.4 (Plant Systems Training) of the Training Plan stated that employees would be provided instruction on plant systems to give them a broader understanding of overall plant operations.
In the training records reviewed, the inspector could not find any evidence of system training for three of the maintenance mechanics and one of the maintenance electricians.
The Training Plan contained the following retraining requirements:
1770'027-
~
-32-General employee retraining (Section 3.5) in general
.
safety, radiological controls, plant changes, problem areas, security system and procedures, first aid, and respirator training Operator and senior operator retraining (Sections 4.2
.
and 4.4) per 10 CFR 55, Appendix A Waste control operator annual retraining exam
.
(Section 4.6)
Annual refresher training for special visitors
.
(Section 6.2)
Annual refresher training for security personnel
.
(Section 9.2)
The Training Plan specified no retraining requirements for the following:
The Maintenance Group
.
The Technical Support Group
.
Auxiliary Operators
.
QC Engineers and Inspectors
.
Plant Engineers
.
Supervisors
.
Retraining for the I&C Group was not defined in the Training Plan.
Section 8.3.2 of the plan stated that the supervisor would determine the required retraining for deficient areas and include this in his periodic training schedule.
The Training Plan did not provide any means for evaluating the effectiveness of the training program.
The licensee failed to implement (maintain) fully the Training Plan for the maintenance group, to establish in the plan means for maintaining the proficiency (retraining)
of the maintenance group and the other groups of employees listed above and to provide the means in the plan for evaluating training effectiveness.
This constitutes an apparent item of noncompliance (313/7916-05 and 369/79-14-04)
against the requirements of TS 6.4.1 as summarized above.
(b) Section 19.12 of 10 CFR 19 requires that employees be in-structed in their responsibility to report promptly any condition which may result in a violation of regulatory requirements or unnecessary exposure to radiation or radicactive material.
10 CFR 19.16 describes.the employee's rights to request an NRC inspection in an area which he believes is in violation of regulatory requirements.
1770 028
-33-During interviews with licensee representatives, the inspector found only one individual out of fourteen who recalled receiving such instructions.
The inspector asked the Training Supervisor how the instructions were given.
The Training Supervisor said that the Part 19 instructions were given in the Health Physics Indoctrination (HPI) to all new employees by video tape.
The inspector reviewed the HPI video tape.
In this presentation, the employee received the ins?. ructions listed on Form NRC-3 which included:
Responsibility to become familiar with NRC Regulations
.
and applicable Operating Procedures Adherence to the provisions of the regulations and
.
procedures The employees' right to request an inspection by NRC,
.
or to bring to the attention of an NRC inspector, during an inspection, past or present violations.
The video tape did not, however, instruct the employee of nis/her responsibility to report promptly to the licensee any condition which may result in a violation of regulatory requirements or unnecessary exposure to radiation or radioactive material.
The licensee's failure to adequately instruct his employees constitutes an apparent item of noncompliance (313/7916-06 and 368/7914-05) against the requirements of 10 CFR 19.12.
(2) Deviations None.
(3) Unresolved Items None.
c.
Observations The following observations include the perceived strengths and weaknesses in the licensee's management controls.
No specific regulatory requirements relate to many of these observations which will be used for subsequent performance evaluations (Reference paragraph 2).
(1)
In 1978, the licensee's G&C Department established a Training Section for the department.
The G&C Training Section had per-formec n extensive assessment of the training needs for this depart nent which was based on completed questionnaires, inter-views of employees and visits to other utilities.
1770 029'
-34-The Training Needs Assessment Report [ reference 7.a.(9)]
identified many of the training weaknesses contained in this inspection report.
The report prioritized the following training needs based on urgency, availability of personnel and hardware /
space, and impact on the system:
Emergency contingency
.
White Bluff Plant
.
Motivation and morale
.
.
Orientation program
.
Supervisory training
.
Training for trainers
.
Basic skills
.
Individuals interviewed said that it would take about two years to implement fully the needed training.
It was noted that the White Bluff Plant training was in progress at the time of this inspection.(S)
(2) The licensee had established a Curriculum Advisory Committee to review and approve the curriculum of the G&C Training Program.(S)
(3) The licensee's Training Plan for site training contained training requirements for the following:
Operators and senior operators, including their retraining
.
Waste control operators, including their retraining
.
Maintenance group
.
Technical Support group
.
I&C group
.
Security personnel, including their retraining
.
Emergency team and fire brigade
.
Engineering and supervisory staff (S)
.
The Plan did not contain the features cited in paragraph 7.b.(1)(a) nor did it contain the following:
Programmed self-study for the retraining of reactor oper-
.
ators and senior reactor operators Training requirements for auxiliary operators
.
Training requirements for QC Engineers and Inspectors
.
Training for engineers in the applicable codes, standards
.
and regulations Retrainina requirements for the Fire Brigade in~ addition
.
to participation in periodic fire drills l'770 03'O
-35-Responsibilities for the preparation and review of lesson
.
plans and OJT checklists Requirements for the accelerated retraining of individuals
.
other than operators, based on unacceptable levels of performance Provisions and responsibilities for identifying and effec-
.
ting program changes based on changes in regulatory requirements / guidance, the facility, and procedures; or, as a result of employee suggestions.(W)
(4) The responsibilities and authorities of individual managers (site and corporate) were outlined in the QA Manual, procedure 1005.01, and in position impact summaries. The inspector reviewed a selected sample of each and found that specific training responsibilities were not identified in the following:
Position impact summaries for the Manager of Nuclear
.
Operations and the General Manager QA Manual, Section 1, responsibilities for the Health
.
Physics Supervisor, Radiochemistry Supervisor, Chemistry and Environmental Supervisor, I&C Supervisor, and Technical Support Engineer Procedure 1005.01, responsibilities for the Nuclear Plant
.
Administrator, Shift Operating Supervisor, Technical Support Engineer, Health Physics Supervisor, and I&C Supervisor.(W)
(5) G&C management had implemented a program under which individual canagers annually identified the goals and objectives of their organization. The current goals and objectives of the Generation Operations Department included an item which called for all non-bargaining unit personnel to receive some supervisory or management training. A second item called for improvements in the supervisor development program for corporate office employees.(I)
There were, however, no goals or objectives which identified and committed resources to correcting the training deficiencies detailed in this report.(W)
(6) The licensee had no written training program which covered all corporate office employees. The inspector was told that the Generation Engineering Department was using an outdated procedure
[NSP-I-3, reference 7.a.(6)], but the engineers who were inter-viewed were not aware of this procedure and said that no written training requirement had been established. The QA organization had implemented a training program for QA auditors which was consistent with the guidance of ANSI N45.2.23 (W)
19'70 031
-36-(7) The licensee had a written qualification / certification program for the following:
.
Technicians in the Technical & Environmental Services
.
Departcient Welders
.
QC inspectors
.
Waste control operators
.
901 helpers (S)
.
No other qualification / certification programs had been imple-mented on-site or in the corporate offices.(W)
(8) Licensee representatives noted that the training required by Criterion II of 10 CFR 50, Appendix B, and Section 2 of the QA Manual was given in a QA indoctrination presentation on video tape or by a recently completed slide-tape presentation. The above presentations were given as part of the new employee orientation program.(I) There were no requirements for periodic retraining in this area, but a licensee representative said that they planned to have all employees participate in the new slide-tape presentation. (W)
(9) The site Training Supervisor was on the distribution for the following:
License amendments and Technical Specifications changes
.
Facility design changes
.
Procedure changes
.
Inspection reports and Inspection and Enforcement
.
Bulletins (IEB)
He did not, however, routinely receive changes to the regula-tions, regulatory guidas and standards, nor did he routinely receive information regarding problems experienced at other facilities or suggestions from employees regarding needs for additional training or program revisions.(W)
(10) Top level management had issued no policy statement or directive which defined the goals and objectives of site and corporate training programs.(W)
(11) QA had provided no overview of site training activities and individual supervisors who were interviewed said that there was.
no apparent overview of training by corporate management other than the SRC which audited only operator training.(W)
1770 032
-37-(12) The licensee had developed no incentive system to assure that employees would be motivated to participate in training activi-ties, and supervisors would be encouraged to send their people to training sessions.(W)
(13) Retraining requirements had not been established for corporate personnel, other than QA Lead Auditors.(W)
(14) 0JT for corporate personnel was not routinely documented in the training files.(W)
(15) Means had not been established to evaluate the effectiveness of the training of corporate level personnel.
Individuals who were interviewed indicated that this would be done by the G&C Training Section.(W)
(16) The operators and supervisors who were interviewed stated that the site training group was understaffed and insufficient training had been provided to the operating staff.
The training shift on Unit 1 had devoted the majority of its time performing routine operating activities instead of training.
It was noted that the sita organization chart contained two unfilled training positions.(W)
(17) Several of the lectures which were required based on the results of the annual requalificatinq examination of licensed operators, had not been given.
This was identified and cited by RIV in report 50-313/79-15.(W)
(18) No specific training requirements had been established for the contract health physics technicians who were utilized during the recent outage.(W)
(19) Many of the site employees who were interviewed said that they believed more cross-training (training in the responsibilities and activities of other groups) was needed.
They also expressed a need for training in administrative procedures by all employees and more supervisory training for the supervisors.(W)
(20) Corporate production engineers had received no training (formal or informal) in the applicable codes, standards, and requirements necessary to their job.
They had also received no ANO systems training since 1975.(W)
(21) Several of the health physics technicians interviewed were not fully aware of their authority to suspend or terminate a Radia-tion Work Permit (RWP) or a Special Work Permit (SWP) if con-ditions charged and presented a safety hazard.
Site managers said that additional training would be given in,this area.(W)
1770 033
-38-8.
Inservice Inspection and Testing of Pumps and Valves The objective of this portion of the inspection was to determine the adequacy of management's controls over the Inservice Inspection (ISI)
program and the Inservice Testing (IST) of Pumps and Valves.
a.
Documents Reviewed (1) ANO Unit 1 TS 4.1 (Operational Safety Items); 4.2 (Reactor Coolant System Surveillance); 4.15 (Augmented Inservice Inspec-tion Program for High Energy Lines Outside of Containment); and 4.18 (Steam Generator Tubing Surveillance).
'
(2) ANO Unit 2, TS 4.0.1, 4.0.2, 4.0.3, 4.0.4, 4.0.5, 4.4.5 (Steam Generator Surveillance), and 4.4.10.1 (RCP flywheel).
(3) 1979 Inservice Inspection Manual for Arkansas Nuclear One Unit 1, rev. 7.
(4) Report of 1979 Inservice Inspection for ANO Unit 1.
(5) Program for Incervice Testing (IST) of pump and valves for Unit 1 which included the following:
(a) AP&L letter, W. Cavanaugh III (AP&L) to D. K. Davis (NRC/NRR), September 19, 1977 (b) AP&L letter, D. H. Williams (AP&L) to R. W. Reid (NRC/NRR), December 15, 1978 (c) AP&L letter, D. H. Williams (AP&L) to R. W. Reid (NRC/NRR), January 15, 1979 (6) Unit 1 procedure 1005.08, ASME Code Section XI Operational Readiness Testing Program, rev. O.
(7) Unit 2 Procedure 2005.08, ASME Code Section XI Operational Readiness Testing Program, rev. O.
(d) QA Audit Reports (3) covering ISI and Eddy Current Testing during the period March 30 through April 27, 1973.
(9)
IST Records for eleven (11) Unit 1 and Unit 2 valves and two (2) Unit 2 pumps.
(10) Procedure 1304.58, Inservice Inspection, rev.
4.
(11) Procedure 1005.01, Administrative Controls Manual, rev. 3.
(12) Quality Assurance Manual, rev. 4, Section 1.
1770 034
-39-b.
Findings (1)
Items of Noncompliance During the review of the IST records (reference 8.a(9) above),
the inspector found that on March 24, 1978 one of the Unit 1 pressurizer code safety valves (PSV-1002) was lift tested in accordance with procedure 1401.03.
The " Test Copy" of this procedure showed that the second and third (final) lifts of the safety valve were at a pressure which was greater than the acceptance criteria (2500 1% psig), which was given in the procedure and was specified in the Bases of TS 3.1.
The individual who was performing the test and documenting the test results indicated that the results were acceptable because of the excessive temperature in the area.
The inspector discussed this problem with licensee representa-tives and was told that they believed the valve had been reset and retested after the above test and before the subsequent reactor startup.
The licensee representatives later indicated that tt.ese records could not be located and in fact acknowledged that they had erred and had not reset the valve.
Unit 1 TS 3.1.1.3A states that the reactor shall not remain critical unless both pressurizer code safety valves are operable.
TS 1.3 defines the term " operable" for a component or system as being capable of performing its intended function within the required range which includes being tested in accordance with Specification 4 and meeting its performance requirements.
The licensee's operation of the Unit 1 reactor subsequent to the testing of PSV-1002 on March 28, 1978 constitutes an apparent item of noncompliance (313/7916-07) against the rw:Jirements of TS 3.1.1.3A as detailed above.
(2) Deviations None.
(3) Unresolved Items None.
c.
Observations The following observations include the perceived strengths and weaknesses in the licensee's management controls.
No specific regulatory requirements relate to many of these observations which will be used for subsequent performance evaiuations (Reference paragraph 2).
1770 035
-40-(1)
ISI outage plans were prepared by the contractor who performed the inspections.
The plans were reviewed by licensee management, including the Plant Safety Committee (PSC).
ISI data received the following reviews:
Authorized Inspector (AI) reviews and signs data sheets
.
Plant Performance Supervisor
.
Independent Level II examiner of the contractor (S)
.
(2) The ISI contractor prepared the ISI Report. The report was reviewed by the Plant Performance Supervisor, PSC, and the AI.(S)
(3) QC's responsibilities for providing overview of ISI activities included the following:
Verifying that QA had approved the contractor's QA Program
.
Verifying that all equipment used was calibrated
.
Verifying that all inspectors were qualified
.
Witnessing selected inspections
.
Reviewing selected inspection records (S)
.
(4) The IST of pumps and valves was performed in accordance with a written program for each unit (reference 8.a. (6) for Unit 1 and 8.a.(7) for Unit 2).
The testing was performed by the operations staff and the results were reviewed by the Shift Supervisor and the Operation Superintendent. Test aheduling was conducted as follows:
Unit 1
-
Scheduling was done by a designated shift
.
supervisor. A folder was maintained in the control room with the last test performed on each valve and pump to enable trend determinations.
Unit 2
-
Scheduling was done by the Assistant Opera-
.
tions Superintendent. He retained the past month's tests for comparison to determine trends.(S)
(5) Sections 11.2, 11.3, and 11.4 of the Quality Assurance Manual (QAM) provided detailed directives and guidance on the perfor-mance of surveillance testing. The program for IST of pumps and valves was covered by the above requirements.(I) It was not apparent, however, that the above QAM Sections applied to the ISI Program and the program did not fully comply with the QAM requirements.(W)
(6) The corporate Generation Engineering Department was involved,in the initial development of the ISI Programs.
Their current involvement was only to resclve problems identified during the inspections.(W)
1770 036
-41-(7) Specialized training in ISI activities had been given as follows:
Two weeks of training in NDE for the Qt. Inspector assigned
.
to overview ISI activities and the Plant Performance Supervisor who coordinates ISI activities Two day short course by ASME on Section XI for the Produc-
.
tion Engineer who was involved in the program development (S)
No other training had been given to the individuals involved in ISI activities.(W)
(8) For the most recent outage (early 1979), QA had audited the contractor's QA Program, and during the ISI inspections they performed three audits of ISI activities which included the following:
A review of equipment calibration records
.
A review of inspector qualifications
.
Observations of inspection activities
.
Review of selected data sheets (S)
.
QA did not, however, review the following:
The outage plan
.
Inspection procedures
.
The ISI Report (W)
.
(9) The ISI and IST responsibilities of the following individuals were not documented in their written job descriptions in the QA Manual, procedure 1005.01, or in their position impact summaries:
Director, Generation Operations-
.
Manager of Nuclear Operations
.
General Manager
.
Operations and Maintenance Manager
.
.
Operations Superintendent Plant Performance Supervisor
.
QC Engineer
.
QC Inspector (W)
.
(10)
Implementing procedures for the ISI Program did not assign re-sponsibilities for the following:
Reviewing and approving inspection procedurcs, inspector
.
qualifications, and equipment calibration rec rds Reviewing equipment to be used for the ISI to assure its
.
compatibility with that used during previous inspections 1770 037
-42-Witnessing ISI activities
.
Verifying the qualifications of the Authorized Inspector
.
Documenting identified deficiencies (indications, flaws,
.
etc.)
Determining appropriate corrective action and repairs in-
.
cluding subsequent pressure tests Performing the required visual inspections and maintaining
.
the qualifications of the visual inspectors Changing the program based on identified problems at the
.
plant or at other facilities, changes in codes and regula-tions, and new inspection techniques / equipment.(W)
(11) Implementing procedures for IST of pumps and valves did not include the following:
Responsibilities for the review and approval of testing
.
procedures beyond those requirements already established for surveillance procedures Responsibility for verifying the equipment calibration
.
records prior to performing the tests Responsibility for periodically calibrating test equipment
.
Provisions for changing the program or procedures based on
.
identified problems at the plant (or other facilities) or new techniques / equipment Responsibilities for determining any adverse trends in
.
test data.(W)
(12) The programs for the IST of pumps and valves did not include requirements for testing the relief valves in Code Class 2 and Code Class 3 systems.(W)
(13) The site QC organization had provided no specific overview of activities in the IST Program.
This may have contributed to the problem identified above [ reference 8.b.(1)].(W)
(14) The Plant Safety Committee (PSC) had reviewed the inspection procedures and the report of previous ISI activities.
They had not routinely reviewed any other aspect of the ISI Program or its implementation.(W)
(15) The Safety Review Committee (SRC) had not reviewed any,of the ISI Program or implementing activities.
An SRC member said 1770 038
-43-that the committee would only get involved if a problem were identified.(W)
(16) No special training had been provided to the individuals in the operating staff who were involved in IST activities.
One of the site supervisors interviewed said that they would generally have a vendor representativo present when they were testing relief valves.(W)
(17) The visual inspections of the reactor vessel internals and the hydraulic snubbers were performed by licensee personnel, but none of these individuals was certified as a visual inspector.(W)
9.
Committee Activities The inspector conducted a review of the licensee's program to determine the extent and adequacy of licensed activities conducted by the Plant Safety Committee (PSC) and by the corporate Safety Review Committee (SRC).
a.
Documents Reviewed (1) Unit 1 FSAR, Section 12.
(2) Unit 2 FSAR, Chapter 13.
(3) Charter, Safety Review Committee, Arkansas Power and Light Company (AP&L).
(4) Unit 1 TS C.O.
(5) Unit 2 TS 6.0.
(6) Administrative Controls Manual, 1005.01, rev. 3.
(7) Quality Assurance Topical Report, APL-TOP-1A, rev. 4.
(8) PSC meeting minutes, 79-1 thru 79-122.
(9) SRC meeting minutes, June 1, 1978, through April 16, 1979.
b.
Findings (1) Items of Noncompliance (a) TS 6.5.2.1 requires the SRC to provide independent review and audit of designated activities.
TS 6.5.2.7.a requires.
the SRC to review the safety evaluations for changes to equipment or systems completed under the provisions.of 10L CFR 50.59 to verify that such actions did not constitute an unreviewed safety question.
1770 039
-44-During the inspection, the inspector determined that the SRC had assigned the review of the safety evaluations conducted on design changes to the Manager of the Licensing Section.
Further review indicated that he had direct respcasibility for the initial safety evaluations.
This assignment requiring the Manager of the Licensing Section to review the adequacy of his own work is contrary to TS 6.5.2.1.
This is an apparent item of noncompliance (313/7916-08; 368/7914-06).
(b) Unit 2 TS 6.5.2.8.b requires SRC audits to encompass the performance, training, and qualifications of the entire unit staff once a year.
By record review and discussions with SRC members, the inspector determined that training of nonlicensed personnel was not audited by the SRC.
This is an apparent item of noncompliance (368/7914-07).
(c) Unit 1 and Unit 2 TS 6.5.2.7 requires the SRC to review the safety evaluations for changes to procedures, completed under the provisions of 10 CFR 50.59 to verify that such actions did not constitute an 'anreviewed safety question.
During interviews with licensee personnel, the inspector was informed that the SRC accomplished this review by reviewing the Plant Safety Committee minutes.
While reviewing the PSC minutes, the inspector noted that the minutes addressed only the fact that certain procedures were reviewed and approved, but did not render determina-tion in writing with regard to whether or not the proce-dures constituted an unreviewed safety question as required by Unit 1 TS 6.5.1.7.1.b and Unit 2 TS 6.5.1.7.b.
This was identified as an apparent item of noncompliance (313/7916-09 and 368/7914-08).
(2) Deviations None.
(3) Unresolved Items None.
c.
Observations The following observations include the perceived strengths.and weaknesses in the licensee's management controls.
No specific regulator-j requirements relate to many of the observatioas which will be used for subsequent performance evaluations (Referenced paragraph 2).
1770 040
-45-(1) The SRC conducted many more meetings than required by the TS.(I)
(2) PSC (,.
4'ce for committee review responsiblities was not adequately described in the PSC administrative procedures.
In order to determine how the PSC performed their responsibilities, interviews were held with PSC members and alternates.
The interviews indicated that PSC members did not fully understand their responsibilities.(W)
(3)
In discussions with PSC members the inspector determined that the PSC did not review QC inspection reports, QA audit reports, or logbooks and records of operations as a method of reviewing facility operations.
The inspector was informed that review of inese items was accomplished by supervisory personnel directly responsible for the area being reviewed.(W)
(4) A review of PSC minutes indicated that the PSC had not reviewed the emergency plan in the last year.
In discussions with the Region IV Resident Inspector, it was determined that this concern had been identified previously by the Resident Inspector, and that the licensee had corrective action in progress.(I)
(5) While reviewing PSC minutes, the inspector noted that the PSC apneared to spend the majority of their time reviewing procedures and procedure changes.(I)
(6) The SRC charter provided minimal guidelines and directivas to SRC members as follows:
SRC committee meetings appeared to be conducted periodically
.
by telephone communications, a method not described by the charter.
Responsiblity for tracking open items identified in SRC
.
audits was not prescribed by written administrative controls.
This function was performed by the SRC secretary.
The SRC charter included all audit responsibilities as
.
identified in Unit 2 TS 6.5.2.8, except the audit require-ment for training.
The audit responsibility for training was taken from Unit 1 TS which was less restrictive than the Unit 2 TS.(W)
(7) The SRC had not performed ar
.dit of the Qt, department.
The requirement to perform this u mit once every two years had been in effect for one year.(I)
(8) A SRC followup audit of open items from previous audit findings was unclear in that the present status or progress towards resolution was not indicated.(W)
1770 041
.
-46-(9) SRC audit findings appeared not to be closed in a timely manner.
One example of this was an audit finding on August 14, 1978, which indicated that emergency team makeup training had not been performed.
The next two aedits (12-78 and 6-79), in this area indicated these findings were still open.(W)
(10) SRC auditors were not required to comply with ANSI N45.2.23, Qualifications of Quality Assurance Program Audit Personnel for Nuclear Power Plants.
However, the QA organization did take credit for SRC audits to avoid duplication.(W)
(11) While reviewing Section 6.0 of Unit 1 and Unit 2 TS, the inspector noted that PSC and SRC committee responsibilities were not the same even though the committees were the same for both units.
For example, Unit 2 TS 6.5.2.7.h required SRC review of all recognized indications of an unanticipated deficiency in some aspect of design or operation of structures, systems, or components that could affect nuclear safety.
Unit 1 TS 6.0 did not have this requirement.
The SRC charter addressed this requirement to Unit 2 only, instead of applying it to both units.(W)
10.
Maintenance The objective of this portion of the inspection war to determine the ade-quacy of management controls over corrective and preventive maintenance activities.
a.
Documents Reviewed (1) TS 6.0 for both Units 1 and 2.
(2) Selected portions of the QA Manual, Sections 1, 2, 5, 8, 9, 10, 12, 14, and 15.
(3) QA Audit Report ANO-17, Job Orders and Trouble Reports, Unit 2, March 1979.
(4) QA Procedures.
ANO-17, Operating Plant Surveillance Audits
.
ANO-10, Calibration of Measuring and Test Equipment,
.
rev. 2 ANO-17, Review of Handling of Nonconformances, rev. 3
.
(5) Procedure 1005.01, Administrative Controls Manual, rev. 3.
1770 042
.
-47-(6) QC Procedures.
1004.02, Initiation and Processing of Trouble Reports,
.
rev. 3 1004.07, Control of Special Processes, rev. 2
.
1004.08, QC Inspection, rev. 5
.
100a.09, Control of Welding, rev. 0
.
1004.10, Caiibration Control, rev. 5
.
1004.14, Initiation and Processing of Job Orders, rev. 4
.
1004.15, Control of Welding Rod, rev. 0
.
1004.17, Onsite Contractor / Constructor / Vendor Control,
.
rev. 3 1004.19, Hold, Caution and QC Tagging Procedure, rev. 4
.
(7) Station Procedures.
1005.02, Preventive Maintenance, rev. 0
.
1005.04, Control and Use of Bypasses and Jumpers, rev. 3
.
(8) Maintenance Procedures.
1401.06, Repair of Pressurizer Code Relief Valves, rev. 1
.
.
1401.09, RCP Seal Dismantling, Inspection, Reassembly, and Testing 1402.08, Emergency Feedwater Pump (P-78) Motor Preventive
.
Maintenance, rev. 0 1405.02, Preventive Maintenance, Emergency Diesel
.
Generator, rev. 1 2401.05, RCP Shaft Seal Removal and Replacement, rev. 0
.
2405.13, Fire Detection Instrumentation Operability, rev.
.
(9) Selected Maintenance Records (listed by job order).
3423-R3
.
4404-R3
.
.
.
1770 043
-48-3465-R3
.
5513-R3
.
5659-R3
.
5428-R3
.
(10) SRC Audit Repc.ts.
Maintenance and Housekeeping, Units 1 and 2, June 1979
.
b.
Findings (1)
Items of Noncompliance None.
(2) Deviations None.
(3) Unresolved Items (a)
Interviews with several licensee representatives indicated that some Level III category maintenance had been conducted without reviewed and approved procedures as required by TS 6.8.1.a, Section 5 of the QA Manual, procedure 1005.01, and procedure 1004.14.
These activities had allegedly been performed by using previous maintenance check sheets, or no instructions at all.
The activities included the calioration of various gauges, maintenance on MOVs, and maintenance on small electrical motors.
One example, procedure 1406.05, Preventive Maintenance Inspection of Motors, was reportedly so general that it was worthless as a guide for repairmen and was eventually deleted.
This procedure had been assigned for use on MOVs and small electrical motors.
According to interviews and records, which accounted for procedure status, a replacement procedure for 1406.05 for work on MOVs had not been written.
This item is unresol"ed pending further examination (313/7916-10; 368/7914-09).
(b) Quality Control had the responsibility for reviewing all job orders and associated documentation following the completion of a maintenance activity or design modification.
Procedure 1004.14 required in step 4.17 that "the job order (complete with all documentation)* is then forwarded to Quality Control for QC review and approval".
Interviews indicated that this was not done as required.
.
1770 044 1770 042
-49-The results of operations post maintenance tests, when required to demonstrate operability following a completed maintenance act M or design change, were not attached to the job order package but sent through a separate routing to file storage in the records vault.
Quality Control representatives stated that they typically checked only the administrative sign-off on the job order form that such a test had been conducted.
They did not exc.nine the tests or verify the results.
This item is unresolved pending further examination (313/7916-11; 368/7914-10).
- The parenthetical phrase belongs to the original quotation as stated.
c.
Observations The following observations include the perceived strengths and weaknesses in the licensee's management controls.
No specific regulatory requirements relate to many of these observations which will be used for subsequent performance evaluations (Reference paragraph 2).
(1) The Maintenance Superintendent reported that he met with all of his subordinate supervisors in a staff meeting at least once per week.(S)
(2) QC periodically verified the qualifications of nuclear welders used on site and maintained records of their qualifications.
The licensee employed no nuclear qualified welders and had contracted with Bechtel Power Corporation to supply them.
Qualifications of contractor employee; who performed maintenance work, other than welders, were not examined by the licensee.(I)
(3) The only written administrative controls on the actual monitoring of contractor work by licensee personnel was procedure 1004.17, step 5.1, which required that "the QCE verifies that the con-tractor has approved written procedures, as necessary for the work, and is performing the work in accordance with these pro-cedures".
Interviews indicated that safety related maintenance work by outside contractors was always monitr. red when in progress by a licensee representative.(I)
(4) Hold points for QC inspections of maintenance activities were utilized, but not frequently or effectively, as described below.
Supervisors in maintenance areas and QC persons gave different-interpretations in the use of hold points.
This was due in part to the written administrative controls on hold points being unclear and conflicting.
Procedure 1004.08, QC Inspection, 1770 045
.
-50-stated that "if hold points are necessary for complete inspection of the activity, these hold points shall be identified by the Cognizant Supervisor" on the Job Order Form.
This supervisor was ic.entified as the person responsible in the appropriate maintenance area.
In contrast to this, procedure 1004.14, Initiation and Precess of Job Orders, stated that the QC Supervisor was responsible "for directing all Quality Control activities related to those Job Orders" and that the cognizant supervisor shall complete specific portions of the job orders, none of which involved the designation of hold points.
Management support for the use of hold points was not uniform.
Several supervisors stated that for various reasons they were not in favor of expanding the role of hold points in maintenance procedures.
Hold points were not permanent in any procedures, but selected at the time the job order was written on the specific activity.
Other licensee representatives stated that they intended to eventually make hold points a fixture in procedures which required them.
Hold points were inspected without any preplanned checklists or procedures in use by the QC inspectors.
The records of these inspections consisted of a " Form QC-3", which essentially de-scribed where the hold points came in the activity, indicated the results as " satisfactory" or not, and provided a place for inspector comments.
The inspector examined six safety related maintenance activities [ reference 10.a.(9)] which were conducted during the past year.
Daly one of these contained a hold point.
The QC Engineer stated that less than forty hold points had been established and inspected since the commencement of the third refueling outage in March 1979.
A QA audit findings report (AFR LA-187) stated that "upon review of approximately 200 Q Job Orders which relate to equipment repair, modification, or test, only one contained a hold point requiring QC involvement".(W)
(5) General surveillances of maintenance activities by QC persons were not performed with any preplanned checklists or procedures.
This appeared to be a significant observation, particularly after the inspection revealed the relatively few number of inspection hold points utilized.
Logs of the activities inspected were maintained.(I)
(6) QC performed inspections on Q surveillance activities on an infrequent and random basis.
The procedure on QC inspections, 1004.08, did not address these activities and the procedure on job orders.
Procedure 1004.14 stated that such activities did not require a job order if they were performed under an' approved 1770.046
-51-surveillance procedure.
Since all job orders were routed through QC and nore were written on surveillance, there were no written administrative controls to alert QC persons to scheduled surveillance activities.(W)
(7)
Interviews indicated that from ten to fifty percent of the QC inspections of maintenance activities (the percentage dependent on the area) were performed by " peer" inspectors.
These were individuals from the same maintenance group as the persons doing the work, but with equivalent or higher qualifications (as determined by the supervisor), and independent of the work performed.
Conversely, fif ty to ninety percent of the QC inspections of maintenance activities were performed by inspectors from the QC group.
Interviews with personnel responsible for supervisory and nonsupervisory roles in maintenance indicated that QC inspectors lacked experience and training in the areas they inspected.
Although recent additions to the QC staff had increased their expertise in the area of Instrumentation and Control (I&C), the I&C Supervisor stated that the previous two hold points in his area had been inspected by QC inspectors without direct I&C experience.(W)
(8) Procedure 1004.14, Initiation and Process of Job Orders, para-graph 4.17, required that " Planning and Scheduling reviews job orders for completeness, appropriate signatures, and documenta-tion" There was not, however, a requirement that Planning and Scheduling sign or initial the job order forms; and there was no provision on the form for their signature.(I)
(9) QA did not routinely audit maintenance activities or records.
The reason given by licensee representatives was that the SRC had the responsibility for suditing this area.
QA had performed periodic audits of job orders to ensure compliance with the procedure for processing them, selected inservice inspections, and at least one surveillance test on the Main Steam Safety Valves.(W)
(10) When the licensee employed outside contractors for maintenance activities, QA involvement was limited to inspecting the con-tractor for addition to the Qualified Vendor's List and per-forming periodic audits of job orders, selected by random sample, which authorized the work.
No audits or reviews of other documentation er administrative controls on maintenance activities were performed by QA.(W)
(11)
Interviews with both supervisory and nonsupervisory persons at the site indicated that QA had very little impact on maintenance activities.
Several persons were unsure of the responsibilities of QA and one supervisor admitted that he was only vaguely 1770 047
-52-familiar with the two QA persons permanently assigned to the site.
All persons interviewed, however, were knowledgeable of the functions and responsibilities of QC.(W)
(12)
Interviews and an examination of records indicated that the preventive maintenance program was ineffective, both in admin-istration and implementation.
A large backlog of outstanding preventive maintenance items had accumulated.
Although Procedure 1005.02, Preventive Maintenance Control Procedure, included a Component Master File Modification Request, the computer program is not changed to reflect delays, rescheduling or cancellation of a scheduled item.
Interviews indicated that the program was incomplete.
Many items needed to be on the schedule and were not.
There was no procedural way to introduce corrective maintenance activities into the computer program to automatically update the schedule to reflect the necessary changes.
Supervisory and nonsupervisory personnel respcnsible for maintenance stated that preventive maintenance was given a low priority, particularly during the startup of Unit 2 and with the additional requirements imposed as a result of the Three Mile Island incident.(W)
(13) There was no trending (i.e., graphs, charts, etc. ) performed on plant aquipment to detect gradual changes in equipment perfor-mance which may indicate patential failure.(W)
(34) Several maintenance procedures [ reference 10.a.(8)] were examined resulting in the following observations:
.
References to vendor manuals or drawings did not contain revision numbers.
The responsibilities and qualifications of individuals
.
were generally not specified.
Several procedures did not contain requirements for clear-
.
ance authorization, work permits, and hold tags.
None of the procedures had quality control hold points
.
established.
No standard format for the procedures was used.
.
None of the procedures examined listed safety precautions
.
for workers, including radiation protection requirements.
Technical content appeared adequate in all the procedures
.
examined.
Several of the procedures required revisions to reflect'
.
job titles and position responsibilities changed as a 1770 048
-53-result of the reorganization which became effective in December 1978.
A licensee representative stated that an outside consulting firm had been hired to assist in revising maintenance procedures.
Two individuals from that firm were working on the task, one on electrical procedures and one on mechanical procedures.(W)
(15) The licensee incorporated the safety-related maintenance in-structions of vendor's manuals into PSC reviewed and approved procedures or work plans.
The difference between procedures 2.nd work plans was that the latter were more of a temporary nature, such as for a one time use only, and often hand written.(I)
(16) The safety conditions of each maintenance activity were not routinely evaluated by the responsible supervisors.
The only time that safety was addressed on a routine basis in the maintenance groups was at the scheduled monthly safety meetings.
Some interviews, however, indicated that these meetings were often poorly organized and occasionally served as forums for topics other than safety.(W)
(17) There appeared to be differences in interpretation among both supervisory and nonsupervisory personnel at the plant site on who the responsible person was for determining whether a rctest was required following a maintenance activity.
This was probably due, at least in part, to the fact that maintenance activities frequently received two or more tests, from both operations and maintenance groups, and the procedure governing this area was ambiguous.
Procedure 1004.14 stated that the cognizant supervisor specified and documented all post maintenance checkouts or testing, and that the shift supervisor was responsible to assure that any post maintenance surveillance was performed.(W)
11.
QA Audit The objective of this portion of the inspection was to determine the adequacy of the licensee's Quality Assurance Audit Program.
a.
Documents Reviewed (1) Quality Assurance Topical Report, APL-TOP-1A, rev. 4.
(2) Quality Assurance Procedures, AN0-1 through 22.
(3) Quality Assurance Manual Administrative Procedures (QAA), QAA-1 thru QA-17.
(4) Unit 1 FSAR, Section 12.
-
.
1770 049
.
-54-(5) Unit 2 FSAR, Chapter 13.
(6) Administrative Controls Manual, 1005.01, rev. 3.
(7) G&C Procedure 102, Procurement, rev. 1.
(8) QA Audits, AN0-14, 1978 and 1979.
(9) QA Audits, ANO-17, 1978 and 1979.
(10) QA Audits, AND-18, 1978 and 1979.
(11) QA Vendor Audits of Precision Instrument Manufacturing Company, November 1978; Babcock & Wilcox, April 1979; and Lambda Elec-tronics Company, April 1979.
(12) G&C Procedure 205, Technical Bid Evaluation, rev. O.
(13) G&C Procedure 302, 10 CFR 21.21(a) Implementation, rev. O.
(14) Memo to QA Inspectors from L. W. Humohrey, August 10, 1979.
b.
Findings (1) Items of Noncompliance None.
(2) Deviations None.
(3) Unresolved Items Wnile reviewing the licensee's QA Vendor Audit Program the in-spactor noted that as a result of a survey conducted on April 17, 1979 by AP&L, the licensee determined the supplier, Lambda Electronics Corporation, did not have an acceptable QA program that met the 10 CFR 50 Appendix B eighteen criteria for the following reasons:
The vendor's organization chart was last revised in 1971
.
The vendor's QA program was last revised in 1971
.
The vendor had no written design control program
.
They had not audited their suppliers
.
1770 050
-55-They did not have an up-to-date document control system
.
There was no traceability of items to purchase orders or
.
other documents Training was not documented
.
There were no formal documented inspection procedures
.
The vendor had inadequate test reports
.
Additional record review of a " Summary of Telephone Conversation",
conducted on July 19, 1979, indicated that AP&L will place Larida Electronics Corporation on their Qualified Vendors List (QVL) based upon factors such as: Lambda had an excellent quality control prograr.
based on the above AP&L survey, and satisfactory performance of the equipment previously supplied by Lambda Electronics Corporation.
In discusssions with the QA manager, the inspector was informed that Section 4.2 of the QA Topical Report allowed vendor evaluations for QVL selection by four different methods.
The inspector determined that the method stated in 4.2.2.3 of the QA Topical Report was used to qualify the vendor in accordance with ANO-15.
Specifically, this method required the inclusion of review and evaluation of the sup-plier's QA program, manual, and procedures as appropriate, along with confirmation of satisfactory performance.
A licensee representative stated the the lack of an acceptable QA program did not preclude the use of a vendor for purchasing safety related items.
However, the inspector noted that no documented evaluation of the vendor's QA program weaknesses were available for review.
The inspector also noted that no purchase was made from this vendor since AP&L conducted their survey.
The AP&L practice of qualifying vendors was identified as an unresolved item (313/7916-12, 368/7914-11).
c.
Observations The following observations include the perceived strengths and weaknesses in the licensee's management controls.
No specific regulatory requirements relate to many of these observations which will be used for subsequent performance evaluations (Reference paragraph 2).
(1) The inspector reviewed audits conducted pursuant to procedure ANO-18 for 1977, 1978 and 1979, and he noted that the documenta-tion of the 1979 audits were more extensive than previous years.(S)
(2) The inspector found that the licensee's QA manuals did not describe the implementation of audits as outlined in ANSI 45.2.12, Requirements for Auditing of QA Programs for Nuclear Power Plants.(W)
17'70 051
-
-
.
.
..
-56-(3) While reviewing the licensee's audits conducted at the site (ANO-17), the inspector determined that the audits were weak for the following reasons:
The audits were conducted using the checklists identified
.
in ANO-17, requiring the auditor to audit the same items each time an audit was performed. While many of the checklists' items were good parameters for a thorough audit, interviews indicated that management gave no encour-agement to the auditor to deviate from the checklist.
As a result, the audits were narrowly scoped, leading to limited QA findings.
Audite : areas identified on the checklist were marked "S"
.
for satisfactory giving no details to provide a basis for such determination or the size of the sample taken.
ANO-17 audits appeared to be primarily a review of paperwork
.
with very little attention paid to observations of work in progress.
Interviews indicated that QA Audit findings had not gen-
.
erated a single LER.(W)
(4)
In discussions with the QA Manager it appeared that the manager's review of QA program effectiveness was accomplished solely by reviewing ANO-14 audits.
ANO-14 audits were a small part of the total QA program and while they appeared to be a good indication for reviewing program implementation, they could not by themselves indicate the effectiveness of the program.(W)
'
(5) Procedure QAA-15, rev. 2, Sec. 4.1 allowed an auditor-in-training to conduct one man audits as long as a qualified auditor reviewed his/her checklist and findings.
The inspector was assured by management that this provision was not used.
The use of auditors-in-training for one man audits is not allowed by ANSI N45.2.23.(W)
(6) The QA Topical Report, Section 1.4.1.2.1, Organization, identi-fies a QA Supervisor position.
The inspector noted that this position was not on the organization chart and did not exist at the site or the corporate office.(W)
(7) The QA Topical Report identified an SRC membership that was not consistent with the membership described in TS 6.0.(I)
(8) While reviewing the licensee's QA audits the inspector noted that the training of quality control personnel and indoctrina-tion training of new employees was audited.
However, the QA department did not audit training of nonlicensed personnel working in the areas of mechanical maintenance, electrical maintenance, and I&C, where activities affecting quality were performed.
1770 052
-57-The QA Manager stated that AP&L had nnt assigned in writing to the SRC the auditing of all training.
The failure to audit nonlicensed personnel was identified as an apparent item of noncempiiance [ reference 9.b.(1)(b)].(W)
(9) Prior to completion of this management appraisal inspection, a licensee representative acknowledged that their QA organization required several changes, both to correct deficiencies which they had reccgnized but failed to act upon and those disclosed during the course of the inspection.
To that end, the licensee issued a memorandum to all QA Inspectors [ reference 11.a.(14)]
delineating various corrective measures which wJuld go into effect immediately.
These measures dealt principally with the methods in which audits were conducted and apdit findings were handled.(S)
12.
Procurement The objective of this portion of the inspection was to determine the ade-quacy of management controls associated with procurement, a.
Documents Reviewed (1) Quality Assurance Topical Report APL-TOP-1A, rev. 4.
(2) QC Procedures.
1004.03, Quality Control Training and Indoctrination, rev.
.
1004.05, Purchase Requisition Preparation and Processing
.
1004.06, Material Receiving and Inspection, rev. 4
.
1004.08, QC Inspection, rev. 5
.
1004.11, Handling Storage and shipping of Q-List
.
Materials, rev. 2 1004.13, Nonconformance and Corrective Action, rev. 4
.
1004.18, Material Identification, rev. 3
.
1004.19, Hold, Caution and QC Tagging Procedure, rev. 4
.
1004.20, Qualifications and Certifications of Quality
.
Control Personnel, rev. 2 1004.22, Document Control, rev. 1
.
L770 053
.
-58-(3) Procedure 1005.06, Administrative Inspections, rev. 1.
(4) G&C Procedures.
GCP 302, 10 CFR 21.21(a) Implementation, rev. 0
.
GCP 102, Procurement, rev. 1
.
(5) Memorandum to Distribution from J. P. O'Hanlon, July 24, 1979.
(6) Memorandum to Distribution from L. W. Humphrey, December 12, 1978.
(7) Completed Procurement Packages 12894, 13280, 14650, and 13276.
b.
Findings (1)
Items of Noncompliance None.
(2) Deviations None.
(3) Unresolved Items While reviewing the area of procurement, the inspector identified several concerns with regard to the site Quality Control (QC) organization and its impact on site activities.
The QC organization appeared weak based on the following concerns:
QC inspections and Administrative inspections appeared to
.
be mini audits with little or no involvement of observa-tions of work in progress.
The QC organization did not send copies of administrative
.
inspections to the PSC as required by procedure.
The QC supervisor position had been open since December
.
1978.
In discussions with members of management and plant
.
personnel the inspector was informed that QC war too
" paper" oriented and was not conducting effective inspections.
In discussions with the Manager of Nuclear Operations, the inspector was informed that management was aware of the QC program weakness and was taking steps to define clear QC 1770 054
-59-responsibilities (reference 12.a.(5) and 12.a.(6)).
Based on review of the licensee's plans for establishing the QC group's responsibilities and the requirement imposed on the QC group upon implementation of rev. 5 of the QA Topical Report, the f aspector identified the QC concerns as unresolved (313/7916-13; 368/7914-12).
c.
Observations The following observations include the perceived strengths and weaknesses in the licensee's management controls.
No specific regulatory require-ments relate to many of these observations which will be used for subsequent performance evaluations (Reference paragraph 2).
(1)
Personnel interviewed by the inspector appeared knowledgeabic of their procurement responsibilites.(S)
(2) The procurement program appeared adequate with the exception of previously identified QC concerns.
Receipt inspections were performed by stores-persons, and QC group interface was primarily paperwork.(I)
(3)
Examination of procurement packages at the site indicated a potential weakness with regards to record retention.
In one package (PO 12894), the Certificate of Conformance for the item received was missing.
The documentation was later found and returned to the record storage by the QC group.
In another package (PO 09980), a Q item was released for installation based on clearance given by a corporate office engineer over the telephone.
The basis for releasing this item was a letter, Humphrey from Cund, April 30, 1979.
This letter was produced at the corporate office, but was not a part of the record package at the site.(W)
(4) QA audits of procurement were limited in that only Q procurement packades were audited, and non-Q procurement packages were not sampled to determine if Q items were being ordered as non-Q.(W)
(5) The licensee appeared to have excellent storage facilities for Q items.(S) The primary storage area was controlled for temperature and humidity; however, the temperature and humidity recorder charts did not appear to be an audit item for QA or SRC audits. (W)
(6) The licensee used " peer" QC inspectors for QC inspections.
The inspector was informed that this practice was being dropped.(W)
13.
Unresolved Items Unresolved-items are ratters about which more information is required in order to ascertain whether they are acceptable items, items of noncompli-ance, or deviations.
The unresolved items identified in this inspection s
are listed below.
1770 055
-60-Number Subject Paragraph 313/7916-01 Written safety evaluations for 3.b.(3)(a)
368/7914-01 bypasses and jumpers 368/7914-02 Primary system chemical analysis 3.b.(3)(b)
313/7916-03 Written safety evaluations 5.b.(3)(a)
313/7916-04 Drawing revisions 5.b.(3)(b)
368/7914-03 313/7916-10 Use of maintenance procedures 10.b.(3)(a)
368/7914-09 368/7916-11 Following of a quality procedure 10.b.(3)(b)
368/7914-10 and adequacy of QC Review 313/7916-12 Vendor Audits 11.b.(3)
368/7914-11 313/7916-13 Effectiveness of Quality Control 12.b.(3)
368/7914-12 14.
Management Meetings A meeting was held at the site on July 30, 1979, and at the corporate offices on August 6,1979, with licensee management in which the lead inspector summarized the purpose and scope of the inspection.
The inspectors met with the licensee representatives (denoted in para-graph 1) at the conclusion of the on-site portion of the inspection on August 3, 1979, and at the conclusion of the corporate office portion of the inspection on August 10, 1979.
The lead inspector summarized how the findings would be handled.
The inspectors then discussed the enforcec-ent findings of the inspection which are detailed in section b. (Findings) for each of paragraphs 3 through 12 in this report.
The inspectors also dis-cussed the most significant of the observations reported in section c.
(Observations) of paragraphs 3 through 12.
A licensee representative commented that they were aware of many of the inspectors' concerns and that a cur ent study and improvement program was being implemented within the company.
.
1-770 056