IR 05000324/1985002
| ML20127J762 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 02/13/1985 |
| From: | Belisle G, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20127J709 | List: |
| References | |
| 50-324-85-02, 50-324-85-2, 50-325-85-02, 50-325-85-2, NUDOCS 8505210571 | |
| Download: ML20127J762 (16) | |
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UNITE] STATES
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REGION 11
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- 101 MARIETTA STREET, N.W.
- ATLANTA, GEORGI A 30323
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Report Nos.: 50-325/85-02 and 50-324/85-02 Licensee: - Carolina Power and Light Company
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- 411 Fa.yetteville
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Raleigh, NC 27602
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- Docket - Nos. :
50-325 and 50-324-License Nos.: DPR-71 and DPR-62 Facility Name: - Brunswick 1 and 2
- Inspection Conducted: January 7-11, 1985 Z!/3kf Inspector:
G. A. Be'11sie c>>
/Date Signed lAccomkanyingPersonnel:
R. M. Latta, Region II L. R. Moore, Region II M. A. Scott, Region II Approved by: M/ N
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C..M. Uprightj fectieff Chief Jate 61gned Division of RMctorMafety SUMMARY L
Scope: This routine,: unannounced inspection involved 130 inspector-hours on site
'in the -areas of licensee actions-on previous enforcement ~ matters, QA program
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review, surveillance testing and calibration control, records ~, document. control,
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-measuring and test equipment, and licensee action on previously identified inspection findings.
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.Results:
Of the seven areas. inspected, no violations or deviations were identified in six areas; one apparent violation was found in one area (Failure to provide environmentallcontrol in the E/I&C calibration laboratory).
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8505210571 850409 u'
PDR ADOCK 05000324 G
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r REPORTLDETAILS l
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[ Persons Contacted
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Licensee Employees-
~*M. Allen,: Regulatory _ Compliance Technical Aide
- W.JAllen,. Store Issue Foreman
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- L.-Boyer,jDirector,; Administrative Support
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- R. Creech, I&C/E Maintenance-Supervisor
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-*C.;Dietz, Plant General' Manager
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. *W."Dorman,.QA Supervisor-
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E.' Enzor,_ Director, Regulatory Compliance
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- GL English,.I&C : Technician -
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- M.: Hill, Manager Technical and Administrative Support R.'Johnstone,'QA/QC Specialist
'*L.. Jones, Director'QA/QC
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-*M.;Kesmodel, Document Control: Supervisor B. Mack, _ Regulatory Compliance: Specialist
- D./Novotny, Regulatory Compliance Senior, Specialist
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- J. O'Sullivan,-Manager, Maintenance R. Paulk,1 Regulatory Compliance Specialist?
M. Robinson,. Document Control Specialist M. ? Rogers, Jr.," QA/QC Specialist t
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- A; Sharif, I&C: Planner
--J.' Smith, I&C Technician
- B.: Simms, Hot Shop Foreman t E. '-Thorndyke,; QA Project Specialist -
- E.l Wall', 1st. Class Mechanic-
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R. White, Senior.QA/QC Specialist.
Other l'icensee. employees ' contacted included-technicians -and office personnel.
- NRC Resident Inspectors J
- *D.!0. Meyers, Senior Resident Inspector
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- T. E. Hicks,: Resident Inspector
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- Attended exit interview
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-Exit Interview-
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cThe inspection scope and' findings were' summarized on January 11, 1985, with
.those-persons indicated in paragraph 1 above. The licensee. acknowledged the
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- following-inspection findings
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. Violation,' Failr e to = Provide Environmental Cont'rol in the - ' E/I&C ~
. Calibration Laboratory, paragraph 9.a.
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' Inspector _ Followup Item, Review Performance Evaluation Unit (PEU) Audit?
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- QAA/21-33. Checklist,; paragraph 9.b.
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Liconsee: Action on Preyious' Enforcement Matters:(92702)
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3(Closed) Violationi 324,- 3J5/82-28-02:
Failure to Establish' Measures Eto '
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" Assure Conditions Adverse'to Quality are=Promptly Identified and Corrected.'
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Thellicensee, response idated -May 2, 1983,: was considered acceptable by
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1 Region.II. 'This item was identified. in NRC' correspondence to Carolina Power l
and Light?(CP&L) dated February '18,1983. The licensee L respon'se 11ncluded-
'short term corrective action, intermediate. term" actions, and an action: plan
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' that was instituted on" July 19, 1982.- ThisJ plan -' encompassed commitments
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imade byJCP&L 'and - confirmed 'in i NRC. Confirmation of Action Letters dated
- July 2 land July-20,_1982. The action plan included intermediate term and
- long Vterm Jitems.
Included in corrective action was a-pre-startup review and QA! reviews. Other corrective action was ~ undertaken by QA involving six:
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specific actions'. The. inspector reviewed these : six -: actions for, completeness -
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.and effectiveness. :These~ actions included reviewing : two videotapes: on-QA.
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' included inithe General Employee Training-Program,. procedure development
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tcovering', inservice inspection and other commitments' (Technical Specifica-
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'tions'.L(TS) and Appendix J requirements),1 additional staffing, QA monitoring j
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- 1TS -and other ' regulatory. requirements'~,. and modification. of Corporate (QA -
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'The-inspector-reviewed - QA-surveillances' conducted from :
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- September 1983'to January 1985. The 'following - a're the specific surveil-
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lances reviewed:
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sTS Verification TS' Amendments Commitments-
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'83-107 84-063 83-102.
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83-120
- 84-065 83-104
,83-130 84-070 83-109-
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E84-020 t
J84-035 _
184-071 83-119 84-072,
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84-040 84-082~
84-057:
'84-055 84-086 84-066
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..'84-056 84-091 84-079
e 84-059-84-094 84-093 184-087 84-096'
b 84-095;84-101
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84-110-84-107:
'84-113'
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84-115
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,;84-119
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84-129 J
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3-During L QA. Surveillance 83-107 performance,. three nonconformance reports (NCR S-83-078, 079,.080) were written for. failure 'to perform a TS surveil-lance.within_ required timeframes. The corrective action for these NCRs has been: adequately addressed. The resident inspectors also identified untimely surveillance testing.which was documented in Inspection Reports 50-324/84-13
- and 50-325/84-13. Two violations were issued. Corrective action completion
'for these violations was performed by the licensee. The resident inspectors
- -verified corrective actions and subsequentij closed the violations in i
Inspection Reports 50-324/84-27 and 50-325/84-27.
The inspector. concluded'that the licensee had determined the full extent of the violation,' taken. action to correct current conditions, and developed corrective actions needed to preclude recurrence of similar problems.
. Corrective actions stated in the licensee response have been implemented.
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Unresolved Items Unresolved items were not identified during this inspection.
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.QA Program Review (35701)
Reference:
10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants The Linspector reviewed the licensee - QA Program required by the above reference and verified that: these activities were conducted in accordance-with regulatory requirements. The following criteria were used during this review to assess overall acceptability of the established program:
. Personnel responsible for preparing implementing procedures understand
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the significance of changes to these procedures.
Licensee procedures are in conformance with the QA Program.
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The procedures discussed throughout-this report and those listed below were reviewed to verify conformance with the QA Program:
Corporate Quality Assurance Department Quality Assurance Manual, Revision 7.
Corporate Quality Assurance Program, Revision 7.
QAP-102, Quality Assurance Document Control, Revision 6.
QAP-104,'QA/QC Records, Revision 1.
The inspectors discussed Quality Assurance Program implementation and other topics with three QA/QC Specialists, a QA Project Specialist, the Director of Regulatory Compliance, and the Document Control Supervisor. Although the
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QA office interfaces effectively with other plant functionaries, it was established Lthat' QA. personnel work sufficiently independent of other: site -
groups.. It was established-that the QA personnel are working with written procedures. in lieu of memorandum or guidelines which could be transitory or ineffective in-- nature. ~QA personnel utilize expertise within -their group
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during performance of procedure ' reviews, surveillances, and other job-
specific functions. QA personnel actively oversee that regulatory require-
. ments-such~as TS changes are incorporated into lower tier documents.
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The~ inspectors reviewed general onsite QA Program implementation as a'part of the inspection.
Each specific area is detailed in other _ paragraphs of this report.
Problem areas,-if identified, are detailed in the specific area inspected.
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- Surveillance Testing and Calibration Control Program (61725)
References:
(a)
10 CFR 50, Appendix B,. Quality Assurance Criteria for Nuclear. Power Plants and Fuel Reprocessing Plants.
' (b) - Regulatory Guide 1.33, Quality Assurance Program Requirements-(Operation), Revision 2.
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1(c) ANSI.18.7-1976, Administrative Controls and Quality
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Assurance for the Operational Phase of Nuclear Power Plants.
~(d)~ 10 CFR 50.55(a), Codes and Standards.
(e) Technical Specifications, Section 3 and 4, Limiting _
Condition of. Operation / Surveillance Requirements.
.The inspector reviewed 'the licensee surveillance program required by reference (a) - (e) to verify that the _ program had been established in accordance with regulatory requirements, industry guides _and standards-and Technical Specifications. The following criteria were used during this reviewL to determine overall acceptability of the established program:
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A master schedule ' for surveillance testing :nd calibration was established which included - frequency, rc consibilities for performance, and testing' status.
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The master -schedule was updated to reflect Technical Specifica-
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Responsibilities were assigned to maintain the master-schedule-
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up-to-date.
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Requirements-were established for. conducting surveillance testing in accordance with approved procedures which include appropriate acceptance criteria.
. Responsibilities were assigned for review and evaluation of test
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data.
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Responsibilities were assigned for assuring -that required-
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schedules for surveillance were satisfied.
The documents listed below were reviewed to verify.that these criteria had been incorporated into the surveillance testing and calibration control program.
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RCI 02.1,-Request For and Processing Of Operating License Including Technical Specification Changes, Revision 3 RCI 02.4, Surveillance Test. Scheduling ~ and Tracking System, Revision 3.
RCI 02.6, Regulatory Related Instrumentation, Revision 0 Responsibility for preparing and maintaining a master schedule is assigned to the Regulatory Compliance Group. Guidance and instruction
. is provided by Regulatory Compliance Instruction (RCI) 02.4.
The licensee incorporates a computer data system with algorithms to provide biweekly schedules ~ assigning department responsibility for upcoming-surveillance requirements.
The biweekly schedule additionally designates the performance test procedure required to perform the y
surveillance test.
The following procedures were reviewed to verify that appropriate acceptance criteria was provided - to insure Technical Specifications were adequately met:
P.T. 416 PC, Containment Radiation Monitors Channel Calibration
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P.T. 4.1.12, Charcoal Absorber System Effluent Radiation Monitor IMST-PCIS-22M, PCIS Main Steam Line Flow Trip Channel B-2-Completion of a surveillance test is reviewed on the departmental supervisory level and by the QA Group. Documenution is on a Surveil-lance-Test Completion / Exception Report which is collected by the Regulatory'_ Compliance group and used to update the master. schedule.
The inspector-also verifie'd that similar controls have been established for calibration of instrumentation not specifically identified in the Technical Specifications.
Regulatory related instrumentation not a
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specifically required in the-Technical Specifications is surveillance tested through instruction in RCI 02.6. Responsibility for maintaining-the master ~ schedule.for this instrumentation _is assigned to th'e
. departmental planners.
-The _ inspector selected Technical Specification-3/4.5.3a, Core Spray Pump Flow Verification to sample the implementation of this program.
Reviewo of associated P.T. c07.2.4a data sheets revealed satisfactory -
calibration requirements have been met.
The inspector-reviewed Amendments 74 and 76^to the Unit-1 Technical Specifications to verify updating and ame.1 ding surveillance test requirements and associated performance tes c procedures. The inspector verified: that a program exists, RCI 02.., _ and that NRC approved technical specification changes are incorporated into the licensee surveillance and calibration program.
Within' this area, no violations or deviatior,s were identified.
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Records (39701)
References:
(a)
10 CFR 50,- Appendix B, ~ Quality Assurance Criteria ' for Nuclear: Power Plants and Fuel Reprocessing Plants.
(b) Regulatory Guide 1.88, Collection, Storage, and Maintenance ' of_ Nuclear Power. Plant Quality Assurance Records, Revision 2.
(c) ANSI N45.2.9, Requirements. for Collection, Storage, and Maintenance of Quality Assurance Records for Nuclear F
Power Plants.
(d) Technical Specification, Section 6.
The inspector reviewed the licensee records management program required by references' (a) through (d) to verify that the program had been. established in accordance with regulatory requirements, industry guides and standards, and Technical Specifications. The following criteria were used during this review to determine the overall acceptability of the established program:
Requirements and _ provisions were established to maintain essential
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qual _ity assurance records.
Responsibilities were assigned in writing for overall management of tile
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Records storage controls were established in -accordance with FSAR
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commitments.
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Records storag'e facilities were described in writing.
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. Provisions had been made to establish the retention oeriods for all
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Methods. 'had. been specified for the ' disposal of records no longer
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- The following documents were reviewed to verify that these criteria had been incorporated into the records program:
FSAR Section 17.2.17, Quality Assurance Records
.QAM Section 17, Quality Assurance Records, Revision 7 QAP-102, Quality Assurance Document Control, Revision 6
'QAP-104, Quality Assurance / Quality Control Records, Revision 1 RMI-01, Capture and Indexing of Correspondence and Plant Records, Revision 19 RMI-02, Records Receipt and Storage, Revision 17 RMI-03, Reproduction, Distribution and Accountability of Plant Documentation, Revision 19 The inspector reviewed the following CP&L surveillance report.and internal audit 'to determine if problems identified by the licensee in the records and. document control area were being corrected. The f aternal audit was requested by the licensee - document control section and performed by an independent consultant.
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Surveillance Report No. 84-97, Document Control,-Drawing and Procedure s
Control Internal Audit File:
B10-10010, Document Control Activities Inspection results indicate that the licensee had taken corrective action on the findings identified in the surveillance report and internal audit.
The inspector reviewed records involving normal reactor operation, principal'
maintenance activities, design changes and modifications, reportable
- occurrences, procurement documents, receipt' inspection and testing, QA audit reports, personnel training records, safety related (non-Technical Specifi-
- cation) calibration results, personnel qualification records, special reactor test-and experiments,'and defects and noncompliances. All of the above mentioned documents were on file, had been approved, and were easily retrievable.
The inspector' interviewed personnel responsible for the crecords. program and verified that the responsibilities and requirements of the program were understood and were being followed.
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Within'this area, no. violations or deviations were identified.
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Document Control. Program.(39702)
References:
(a). 10 CFR 50, Appendix B, Criterion VI, Document Control.
(b) ANSI N45.2 -1977, Quality Assurance Program Requirements for Nuclear Facilities.
(c) Regulatory Guide 1.28, Quality Assurance Program Requirements.
(d) Technical Specification, Section 6, Administrative Controls.
(e) Corporate Quality Assurance Program Manual, Section 6, Instructions, Procedures, and Drawings and Document ~
Control, Revision 7.
The inspector reviewed the licensee document control program required by references (a) through (e) to verify -that the program had been established in accordance with regulatory requirements, indu;try guides and standards, and Technical Specifications. The following criteria were used during this-review to determine the overall acceptability of the established program:
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Administrative controls have been established for issuance, updating, and recall of_ outdated drawings.
Master indicies are maintained for drawings, manuals, and procedures.
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_ Ad.aini strative controls have been established for distributing,
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updating and recall-of outdated documents.
Administrative controls have been established for distribution of
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as-built drawings and P& ids in a timely manner.
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Administrative controls have been established to control discrepancies between as-found conditions and as-built drawings.
The documents listed below were reviewed to verify that these criteria had been incorporated into the document control program:
RMI-03,. Reproduction, Distribution, and Accountability of Plant Documents, Revision 19 RMI-04, Plant and Maintenance Libraries, Revision 7 RCI-01.0, Regulatory Compliance Policy, Responsibilities, and Interface, Revision 0 RCI-02.0, Compliance with Technical Specifications and other Regulatory
. Requirements, Revision 0
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RCI-04.1,LFSAR Changes,. Revision 0
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ENP-03, _ Plan't-Modification Procedure, Revi sion 26
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-ENP-25," Plant Drawings Correction Procedure, Revision 1 RCI-03.1, 10'CFR-50.59 Safety Evaluation, Revision 0 Administrative ProceduresfBSEP/Vol I, BK I, Revision 9
'Th'e documents-listed below were reviewed to verify that the Document Control Program was functioning acceptably.
' Drawing D2020,~ Piping D'iagram, Main _ Steam Turbine Bypass and Reheater 1 Protection Steam ~ System,. Revision 23.
Drawing D2348, Piping and-Instrumentation Diagram, Integral. Groove-Tubesheet Pressurization and Leak Detection System, Revision 2.
3 OP-11,- Radiation Monitoring System Operating Procedure,- Revision 21 8 E&RC-0412, Readings TLD Badges,-Revision 9.
12 MI-16-035B, Maintenance of GE HFA Relays Models 12 HFAS4E 187 and 12-HFA'54E 249, Revision 0
~10 PT-04.3.4PC, EX0 Sensor Hydrogen Analyzer Channel Calibration, Revision.8:
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SD-09.2, Traversing in Core Probe system,= Revision 1 TI-401, Newly Appointed Shift Foreman Training, Revision 0
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GP-03, Unit Start-up, Synchronization, Revision 2 A
OG-03, Primary Containment : Access Control, Revision ~ 2 PPP-06.2, Forced Outage Control Guidelines, Revision 0 E0P-01-LEP-01, Alternate Coolant, Injection, Revision 0 FP '8701, Post accident Sampling Station, Revision C. (technical manual)
Technical Specifications, Unit 2, Revision 106-
!The above drawings, procedures, manual, and Technical Specifications located at the Maintenance Library, the _ Document: Control Vault, Operations, Control
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Room, and Assistant _ Operator's Room' were checked for correct revision number.
Randomly ; selected documents were checked for correct copy number.
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110 Ten documents revised in December 1984 (onsite distribution of the revisions should'have been completed) were also checked for correct revision numbers-at the locations indicated above. Of all documents checked (either revision or. copy number), only one document had an. incorrect. revision in the
- controlled file copy.
In that the. clerk involved stated that the correct
document. revision -had been filed, a signed and dated document transmittal sheet for the correct revision had been returned to Document Control (ie, no programmatic error evident), and the possibility existed that person (s).
unknown may-have inadvertently removed the correct revision, a violation was not warranted.
In addition, an onsite QA surveillance (Report number 84-097, dated September 4,1984) was performed in - the area of Document
. Control which indicated several. nonconforming items.
Document Control had responded to the report (CP&L letter file: 810-10010, serial: BSEP/84-2013,
~ dated September 20, 1984) and rectified the. problems identified in the report. Additionally and as a result of the report, the licensee hired an independent consultant to audit the Document Control Program.and the results of 'that audit (CP&L letter file: B10-10010, serial:
BSEP/85-0049, dated
' January.8, 1985),were. implemented or.in the. process of being implemented at the time of this inspection.
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Within this area, no vioiations or deviations were identified.
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. Test and Measurement Equipment (61724)
References:
(a) 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (b) Regulatory - Guide 1.33, Quality Assurance Program Requirements (Operations), Revision 2.
(c) ANSI 18.7-1976, Aaministrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants.
(d) Regulatory Guide 1.30, Quality Assurance Requirements for the Installation, Inspection, and Testing of Instrumentation and Electric Equipment.
(e) ANSI N45.2.4-1972, Installation, Inspection, and Testing Requirements for Instrumentation and Electric Equipment During the Construction of Nuclear Power Generating Stations.
(f) IEr Std.
498-1975, IEEE Standard Supplementary Rm,sirements-for the Calibration and Control of-Measuring and Test Equipment Used in the Construction and Maintenance of Nuclear Power Generating Stations, a
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The ' inspectors reviewed the licensee measurement and test equipment (M&TE)
. program required by references (a) through (f) and verified that these activities were conducted in accordance with regulatory requirements and industry guides and_ standards. The following criteria were used during this review to assess-overall acceptability of the~ established program:
Criteria and responsibility for assignment of the calibration or
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adjustment-frequency have been established.
An equipment inventory list has been prepared which identified equip-
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ment used on safety-related structures, systems, or components and the calibration frequency of each piece of equipment.
- Requirements exist for marking the latest calibration date on each
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piece of equipment.
A system has been provided for assuring that equipment is calibrated
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before the date required.
Requirements have been established which prohibit use of equipment
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which has not been calibrated within the prescribed frequency.
_ Calibration controls have been established which require evaluation of
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the cause of equipment found out of calibration and.he acceptability of items calibrated using such equipment.
New equipment will be added to the inventory list and calibrated prior
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to being placed in service.
The following documents were reviewed to verify _that the previously listed criteria had been incorporated into licensee administrative proced;res for test and measurement activities:
Corporate Quality Assurance Program, Section 9, Calibration Control, Revision 7.
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MP-10A Control of Measuring and Test Equipment for Mechanical Maintenance, Revision 2
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MP-01B Control of Measuring and Test Equipment I&C and Electrical, Revision 0 MP-04 General Maintenance Procedure, Revision 11-MP-10 Preventive Maintenance Program, Revision 25 E&RC-30 General Instrumentation Checkout, Revision 3
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i AI-21 Nontechnical Specification Surveillance Test and Preventive
, Maintenance Test Scheduling, Revision 6 The inspector conducted interviews with plant personnel responsible for tracking M&TE calibration status. The inspector also interviewed mechan-ical, instru'nentation and electrical, and health physics personnel responsible for calibrating their specific M&TE.
The inspector toured these ' storage areas and verified that M&TE was being stored, marked, and calibrated' as required by' licensee administrative controls.
The inspector reviewed one QA surveillance (QASR 84-058) and one QA audit (QAA/21-33)
pertaining to M&TE activities.
One nonconformance (NCR S-84-070). was
~ dentified during QASR 84-058 performance.
M&TE audit items were not i
identified during QAA/21-33 performance. The inspector verified corrective action for NCR S-84-070.
To verify M&TE implementation, the inspector randomly selected instrumenta-
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tion in two of the three areas previously mentioned and verified that equipment history cards were being maintained, instrumentation was properly identified, calibration stickers were attached and plainly visible, rejected equipment was plainly marked and segregated to prevent inadvertent issue, and calibration procedures were available for calibrations in progress.
The following instrumentation was selected for review:
-Maintenance Calibration Shop and Tool Issue Storeroom DM 005
- IM 020 MPL 003
- EM 001 SGB 003
- 0M 154 TWT 005
- 0M 145
- DM 015
- IM 017
- 0M 028
- IR 053
- TM 004
- IR 077
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- Tool Issue Storeroom Electrical and Instrumentation Shop G 100A SAC 2 G 127 AT 3 G 33A HYD 17 V 070 S-1 B 018 LPRMC 4 G 171 The inspectors verified that all instruments reviewed in the electrical and instrumentation shop, except LPRMC 4, were calibrated at required frequen-cies. -The inspectors selected the following maintenance work orders and verified that M&TE used during work performance were in calibration:
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Maintenance Work Order-M&TE 2M-84-5752 TR 129 2M-84-5730 TR 049 2M-84-5462.
TR V30 2M-84-5415 TR 095 2M-84-5219 TR 029 2M-84-7102 TR 038 2M-84-7007 TR 100 2M-84-5352 TR 119 2M-84-6610 TR 060 2M-84-6609 TR 136 The. inspector discussed calibration and storage of contaminated M&TE. with plant personnel.
Contninated M&TE is cleaned the same day it enters the hot shop. Once clean, it is returned to the respective shop storage areas.
Within this area, one violation and one inspector followup item were identified and are discussed in the following paragraphs.
a.
, Failure to Provide Environmental Controls in the E/I&C Calibration
. Laboratory During tours of the E/IC calibration laboratory, plant personnel were questioned about maintaining temperature control in the calibration laboratory. Apparently several methods were available. One method was a circular strip chart. recorder but shop personnel stated that this'.
detector 'was not functioning and had not been -functioning -for some period of time. Another method included a temperature sensing strip
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chart recorder ' that recorded temperature by heat tracing on a continuous strip chart recorder.
These recorders were also not functioning.
A third method was by use of calibrated thermometers that were enclosed in a case. When specifically questioned about how temperature was maintained, personnel stated that they could feel the temperature being'too hot or too cold. The inspector talked to the I&C
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supervisor and he stated that in some instances calibration activities
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were suspended due to temperature extremes. At no time during these discussions was the inspector informed of what appeared to be an adequate method of assuring that instrumentation temperature limita-tions were being adhered to. Any method previously mentioned would be adeq'uate if administrative controls were established to verify the temperature prior to performing temperature sensitive calibrations.
This failure to maintain environmental controls in the E/I&C calibra-tion laboratory constitutes a violation 325, 324/85-02-01.
b.
Review PEU Audit QAA/21-33 Upon identification of the violation discussed in paragraph a, the inspector requested to review PEU Audit QAA/21-33. This audit also reviewed plant calibration activities. A review of the audit confirmed
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that problems were not -identified by PEU in this area. The inspector-requested to review the audit checklist to determine if this area was included.in the : audit. 'The audit checklist.was only available at the corporate offices consequently this review could not be conducted by the inspector. Until the inspector can review audit QAA/21-33 check-list this is' identified as an inspector followup item 325, 324/85-
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10.
Licensee Actions on Previously Identified Inspection Findings (92701)
a.
-(Closed) Inspector Followup Item 325, 324/82-16-03: Material Specifi-cation Control Problem.
~This item was originally identified in Reports 50-325/82-16 and 50-324/82-16. Corrective action was reviewed as discussed in Reports-50-325/84-01 and 50-324/84-01. The inspector reviewed NCR P-82-012 and corrective actions associated with this NCR. A letter dated June 22, 1984, from M. Hill to C. Dietz, File 810-12010, Serial: BSEP/84-1122 was reviewed. This letter states in part that Q-listed spare parts identified as susp'ect in response to NCR P-8?-012 have been classified
. based upon available documentation. Any items which were found to lack sufficient documentation to support any level of Q were downgraded ta non-Q or scrapped.
NCR P-82-012.was closed after corrective action verification by QA on August 6, 1984.
b.
(Closed) Inspector Followup Item 325, 324/84-01-01:
Clarification-of Procurement Practices-Vendor Qualification.
The inspector reviewed the Corporate _ Quality Assurance Manual, Revision 6, Section 4,- Procurement Control.
Revision 6 was issued December.30, 1983, with an effective implementation date April 1, 1984.
References to equipment procurement from unqualified vendors has been deleted.
c.
(Closed) Inspector Followup Item 325, 324/84-01-02:
Clarification of Procurement Practices - Distributors.
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.The inspector reviewed Corporate Quality Assurance Program, Revision 7.
Adequate controls have been established to assure agents and distrib-utors control procured items.
d.
(Closed) Inspector Followup Item 325, 324/84-01-03:
Clarification of Role of Regulatory Specialist.
The inspector reviewed ENP-03, Plant Modification Procedure, Revision 24. This revision clarified the regulatory specialist's role relative to exceptions for operability prior to Technical Specification (TS) approval. This exception can only be granted after receipt of.
written approval from the'NRC or upon determination that the modifica-tion requires only the addition of new TS requirements and not the deletion or revision of existing requirements.
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.(Closed)-Inspector Followup Item.325,' 324/84-01-04:. Clarification.PNSC.
e.
-_ Review Responsibilities'.
Theinspector.reviewedENP-03,PlantModiff' cation [ Procedure,
. Revision 24.
The sequence - for performing modification reviews by the
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< Plant Nuclear Safety: Committee and the-Corporate Nuclear Safety Unit i
1 which affects TS is consistent with requirements stated in TS.
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