IR 05000324/1986009

Insp Repts 50-325/86-08 & 50-324/86-09 on 860310-14.No Violation or Deviation Noted.Major Areas Inspected:Offsite Support Staff & Audit Program Implementation

ML20138C330
Person / Time
Site:	Brunswick
Issue date:	03/26/1986
From:	Belisle G, Casey Smith NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20138C328	List: IR 05000324/1986009 ML20138C322
References
50-324-86-09, 50-324-86-9, 50-325-86-08, 50-325-86-8, NUDOCS 8604020461
Download: ML20138C330 (8)

Text

UNITED STATES g p2 LE!nq*o

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NUCLEAR REGULATORY COMMISSION

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Report Nos.: 50-325/86-08 and 50-324/86-09 Licensee: Carolina Power and Light Company P. O. Box 1551 Raleigh, NC 27602 Docket Nos.: 50-325 and 50-324 License Nos.: DPR-71 and DPR-62 Facility Name: Brunswick 1 and 2 Inspection Conducted: March 10-14, 1986 Inspector: [ /'& err ;

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w- 2 4 /8 C. Smith / Date Signed-Approved by: [" /I "s p'

G. Belisls, Act:1 rig Section Chief

. P[rg/EX Date' Signed Division of. Reactor Safety" SUMMARY

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Scope: This routine, announced -1'nspection' involved 34 inspector-hours at the corporate office in the . areas of ,offsite support staff and audit program implementatio *

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Results: No violations or deviations were identified'.

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REPORT DETAILS Persons Contacted Licensee Employees

• H. Banks, Manager, Corporate Quality Assurance (QA)

R. Baldwin, Senior QA Specialist, Performance Evaluation Unit R. Black, Jr., Manager, Emergency Preparedness

• R. Connolly, Project Engineer, Nuclear Engineering and Licensing Department (NELD)

• B. Ford, Director, Construction Procurement

• J. Hammond, 91 rector, Nuclear Safety Review, Corporate Nuclear Safety Section

• R. Heatherengton, Supervisor, Engineer.ing Administration I. Johnson, Project QA Specialist

• H. Lovc, Jr. , Principal QA Specialist R. Lumsden, Manager, QA Services Section

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• S. McManus, Director, Nuclear Engineering Safety Review R. Mayton, Jr., Manager, Corporate Health Physics

• C. Moseley, Jr. , Manager, Operations QA/QC

• J. Nevill, Section Manager, NELD

• J. Rice, Manager, Purchasing - Materials, Management Department

• C. Rosenberger, Principal'QA Specialist, Performance Evaluation Unit

• H. Shamblin, Director, Construction Contracts S. Simely, Senior Buyer, Materials Management Department R. Starkey, Jr., Manager, Nuclear Safety and Environmental Services

• J. Zaalouk, Manager, Nuclear Engineering Projects

• S. Zimmerman, Manager, Nuclear Licensing

• Attended exit interview Exit Interview The inspection scope and findings were summarized on March 14, 1986, with those persons indicated in paragraph 1 abov The inspector described the areas inspected and discussed in. detail the inspection finding No dissenting comments were received from the licensee. The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspectors during this inspectio Inspector Followup Item; Revision of program docunents to reflect organizational changes, paragraph . Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspection.

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. 2 Unresolved Items Unresolved items were not identified during the inspectio . Offsite Support Staff (40703)

References: (a) 10 CFR 50.54(a)(1), Conditions of Licenses (b) 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (c) BSEP 1 and 2 Updated FSAR, Section 17.2.1, Organization (d) Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation)

(e) ANSI N18.7-1976, Quality Assurance for the Operational Phase of Nuclear Power Plants (f) Regulatory Guide 1.146, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (g) ANSI N45.2.23-1978, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (h) Technical Specifications, Section 6.2, Organization The inspectors visited the corporate office to determine whether the offsite support staff functions were performed by qualified personnel ~in accordance with licensee approved administrative controls, regulatory requirements, and industry guides and standards. The-following criteria were used during this review to assess the adequacy of the offsite staf Administrative controls were established to assign departmental responsibilities, authorities, and lines of communication in conformance with the requirements of 10 CFR 50 Appendix B, and the licenses's approved QA progra Managers, group leaders, and staff members were cognizant of their responsibilities and authoritie ;

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The above personnel were qualified for the related wor Quality assurance audits of offsite support staff activities were conducted satisfactorily and corrective actions for identified

deficiencies were completed in a timely manner.

l The following documents were reviewed to determine if these criteria had been incorporated into the program for providing support to licensed facilities by the offsite support staff:

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. 3 CP&L Corporate Quality Assurance Program Manual, Section 2.0, Organization and Responsibilities, Revision 7 CP&L- Corporate Organization Manual, October 1985 Power Supply Engineering and Construction Organization Manual, Revision 6 CP&L organizations responsible for the safe operation of the Brunswick Steam Electric Plant (BSEP) Units 1 and 2 are described in Section 2.0.of the Corporate Quality Assurance Program Manual. The Corporate Quality Assurance Program Manual is the implementing document of the updated FSAR Section 17.2, and defines the QA program requirements for activities performed by various offsite support groups. The licensee accepted QA program requires each offsite support organization to have a QA program documented by written policies, procedures, and instructions which control activities performed by the offsite support organization Additionally, each offsite support group's organizational structure, functional responsi-bilities,~ levels of authority, and lines of internal and external interface are required to be documented in writin The inspector determined that on September 18, 1985, CP&L's senior manage-ment made a presentation to NRC senior management to address significant personnel and organizational changes in Cp&L's Nuclear Operations Progra The scope of the presentation covered the following topics:

Primary Reason for Change Present Organization Change Present Key _ Criteria / Conditions for the Change Present Benefits of the Change The inspector conducted interviews with licensee menagement concerning the above organizational changes. Additionally, a review of the following documents was performed to ascertain the activities implemented to establish conformance of program documents with the new organizational structur Memorandum from E. E. Utley to all Department.and Section Managers, Subject: Personnel and Organizational Change, dated September 20, 1985

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Memorandum from R. B. Starkey, Jr., to Bill Stocks, Subject: Corporate Organization Manual (COM) Revision, dated January 27, 1986 Memorandum from R. B. Starkey, Jr. , to Bill Stocks, Subject: Revision to PSE&C Organization Manual, dated January 27, 1986 Anticipated QA program changes were discussed with licensee personnel from the Quality Assurance Services Section. The inspector was informed that revision 9 to the Corporate QA Program Manual had been prepared to incorporate the recent organizational changes. This document.is presently being reviewed for approval by CP&L's management. In further discussions with personnel from the ~0perations QA/QC section, the inspector determined

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. 4 that changes were being made. to quality implementing procedures at all nuclear site These changes are being made in anticipation of the licensing of the Shearon Harris facility, and to introduce identical QA/QC programs at all~ three plants, i .e. Brunswick, Robinson, and Harri The following document was reviewed by the inspector in connection with this program change:

CP&L Memorandum, CQAD-86-438, from Moseley, Jr., Subject:

Operations QA/QC Procedure Additional discussions were held with . licensee ' management in various organizational units to ascertain the adequacy of each organizational unit's documented procedures and instructions which control activities performed by that organization. The following are the f unctional areas eviewed during this effort:

Procurement and Purchasin Nuclear Safety, with emphasis on off-site review Health Physics and Radiological Support, including Emergency Preparedness involvemen Corporate level design activitie Corporate level activities associated with nuclear plant tecnnical specification Selected licensee personnel interviewed were knowledgeable of the charter and mission of the organization to which_ they belonged. They were also cognizant of their job responsibilities, authority, -and were qualified for the positions they hel For the most part the organizational unit's program _ procedures accurately reflected the organizational structure and lines of internal and external interfaces. A few documents were in the process of being revised to agree with.recent organizational changes. Other documents were being developed to provide better guidance to staff members in the performance of their duties. These outstanding documents will be

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identified as an Inspector Followup Item which is discussed later in the repor Documents reviewed during this part of the inspection are listed below:

NELD/BSEU Inter-face / Cooperation Agreement, dated March 29, 1985 Health Physics Interface Agreement Procedure No. NPCD-P-0066, CP&L Nuclear Plant Construction Department, Fossil' Plant Engineering and Construction Department, Nuclear Plant Engineering Department, Brunswick Nuclear Project Department, Standard Procedure for Construction Procurement, Revision 1.

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PSQA-1-03, Materials Management Department, Purchasing Section QA Manual l Nuclear Engineering & Licensing Department (NELD) Procedure No. 4.1, l Procurement of Engineered Items, Revision 14 l

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Conduct'of Operations Manual, Revision 0 NELD, Engineering Support, Nuclear Plant Section Guides, Revision 1 A request to the NRC for a license amendment caused by changes to the Technical Specifications is presently being prepared by licensee managemen These changes include the significant personnel and organizational changes to the Operational QA Program previously presented to NRC senior managemen ,

Other changes concern revision to part of Section 3/4 of the Technical Specification The inspector reviewed the following audits of selected offsite support staff activities, and verified that appropriate corrective actions were initiated for identified deficiencie Audit Activity: Materials Management Department Purchasing Section Report No: QAA/0117-85-01 Date of Audit: December 2, 1985

' Audit Activity: Construction Procurement and Contracting Section Audit Report No: QAA/0118-85-01 Date of Audit: December 3-4, 1985 At the exit interview, the inspector stated that organizational changes appear to have been_ adequately developed and implemented by CP&L's manage-m.ent. No adverse impact to the support given to the operating plant because of the reorganizational change was identified by the inspecto On the contrary, the inspector stated that there was a noticeable commitment and dedication to the successful development and implementation of a quality program on the part of all personnel with whom he had interacte He further stated that CP&L's management involvement in assuring quality is further demonstrated by the " Total Quality Plan" which is presently being

develope This concept, which is self imposed by the licensee, will establish - basic policies, objectives, and guidelines to achieve total quality as an internal way of life at CP&L. Assessments of results and

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recognition of achievements in the area of quality is an integral part of this pla .

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Within this area one Inspector Followup Item was identifie On September 18, 1985, CP&L gave a presentation to NRC management wherein a review of significant personnel and organizational change in the Nuclear Operations Program was performe This reorganizational change wa subsequently implemented on October 5, 1985.

Consequent to the above change, the licensee upper tier program documents j and other lower tier quality _ implementing procedures need to be revised to i reflect the new organizational structure, functional responsibilities, levels of authority, and lines of internal and external ~ interface Additionally, section instructions are being developed by the following l

organizational units to better control their work activities:

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. 6 Manager, Engineering Support Nuclear Plants I and I Manager, Nuclear Engineering Project Until all appropriate upper. tier-and lower tier program documents have been revised to reflect the reorganizational changes; and sections instructions for the' above listed organizational - units have been completed, 'this is identified as Inspector Followup Item (50-325/86-08-01, 50-324/86'09-01).

- Audit Program Implementation.(40704)

References: (a) 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plant and Fuel Reprocessing Plants (b) 10 CFR 50.54(a)(1), Conditions of License (c) Regulatory Guide 1.144, Auditing of Quality Assurance Programs for Nuclear Power Plants, January 1979 (d) ANSI N45.2.12 -

1977, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants (e) Regulatory Guide 1.146, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants, Revision 0 (f) ANSI N45.2.23 - 1978,' Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (g) Regulatory . Guide 1.33, Quality Assurance Program Requirements (0peration), November 1972 (h) ANSI N18.7 - 1976, ' Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants

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(i) Technical Specifications, Section The inspector reviewed the licensee audit program implementation required by References (a) through (.1 ) to determine if auditing activities were

conducted in accordance with regu.latory requirements, industry guides and standards, and Technical Specification (TS). The following criteria were used during this review

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The scope of the audit program has been defined and is consistent with TS and QA program requirement Responsibilities have been assigned in writing for overall management

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of the audit progra Methods have been defined for taking corrective action when deficiencies are identified during audits.

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The audited organization ~ is required to respond in writing to audit

' finding Distribution requirements for audit reports and corrective action responses have been. define Checklists are required to be used in the performance of audit QA audit personnel meet minimum eduction, experience, and qualification requirements of the audited activit The inspector verified that the above criteria had been incorporated into auditing activities during an inspection performed on January 27-31, 198 The program. documents and long range audit schedule reviewed along with the results of this inspection are documented in inspection report number 50-335/86-04, 50-324/86-0 The following audits were selected for review to verify procedural compliance with the audit program:

Activity Audited: Materials Management Department, Purchasing Section'

Audit Report No: QAA/0117-85-01 Date of Audit: December 2, 1985 Activity. Audited: Construction' Procurement and Contracting Section Audit Report No: QAA/0115-85-01 Date of Audit: December 3-4, 1985 Activity Audited: Corporate Nuclear Safety and Onsite Nuclear Safety Audit Report No: QAA/0115-85-01 Date of Audit: October 21-24, 1985 Activity Audited: Brunswick Steam Electric Plant Operations Audit Report No: QAA/XX21-85-07 Date of Audit: October 7-10, 1985 Activity Audited: BSEP-Operations (Inservice Inspection, Maintenance and TS/ License Changes)

Audit Report No: QAA/XX21-85-04 Date of Audit: June 3-7, 1985 Based on a review of the audit checklists, the inspector determined that it appeared as if the scope and-depth of the audits were adequately define Previous concerns expressed by the inspector in connection with the review of 10 CFR 50 Appendix B criteria as they apply to the functional area being audited, documented in Inspection Report 50-325/86-04, 50-324/86-05, were discussed with licensee management. Although it is not readily apparent from the checklist, further discussions with licensee management revealed that applicable criteria of 10 CFR 50 Appendix B were reviewed during the performance of the above audits.

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Within this area, no violations or deviations were identified.

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