IR 05000335/1979021
| ML17207A534 | |
| Person / Time | |
|---|---|
| Site: | Saint Lucie  |
| Issue date: | 09/10/1979 |
| From: | Ford E, Robert Lewis, Ruhlman W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML17207A529 | List: |
| References | |
| 50-335-79-21, NUDOCS 7911080170 | |
| Download: ML17207A534 (24) | |
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UNITEDSTATES NUCLEAR REGULATORY COMMISSION
REGION II
101 MARIETTAST., N.W., SUITE 3100 ATLANTA,GEORGIA 30303 Report No. 50-335/79-21 Licensee:
Florida Power and Light Company 9250 Vest Flagler Street Miami, Florida 33101 Facility Name:
St. Iucie Docket No. 50-335 License No. DPR-67 Inspectors:
W. A. Ruhlman f77 Date Signed E. J. Ford Approved by: Z D.
R.
C. Le is, Acting Chief, RONS Branch Date igned 7/ro Date Signed SUMMARY
Inspection on August 20-24, 1979 Areas Inspected This routine, unannounced inspection involved 56 inspector-hours onsite
-'n the areas of licensee action on previous inspection findings~~ Bulletin 79-10, personnel qualification program, QA/QC administration, QA program review, maintenance, emergency drill, document control, and records.
Results Of the nine areas inspected, no apparent items of noncompliance or deviations were identified in eight areas; one apparent item of noncom-pliance was found in one area (Deficiency - Failure to Follow Procedures-Paragraph 9.b).
911080
> 7
-3)ETAILS 1.
Persons Contacted Licensee Employees R. Adams, Senior Plant Technician
>A. Baitey, Quality Assurance Operations Supervisor R. Ball, Senior Plant Technician
+J. Barrow, Operations Superintendent
+J. Bowers, Maintenance Superintendent
+J.
Brown, Manager-Quality Assurance Applications H. Buchanan, Health Physics Supervisor-A. Collier, Instrument and Control.Supervisor
'T.
Dillard, Jr., Assistant Superintendent-Mechanical
- P. Pincher, Training Supervisor
+R. Frechette, Plant Coordinator R. Jackson, Senior Plant Technician
>R. Jenning, Technical Supervisor S. Kingsbury, Radiological Emergency Plan Administra J. Lenz, Plant Supervisor I-J. Lewis, Senior Plant Technician T. Lyons, Plant Supervisor II-H. Mercer, Plant Coordinator R. Mehew; Associate Plant Coordinator B. Mikell, Outage Coordinator-C. Moore, Chemistry Supervisor
+N. Roos, Plant Supervisor II
+D. Sager, Senior Plant Engineer R. Vallentine, Jr., Senior Plant Technician C. Wells, Operations Supervisor N. West, Plant Supervisor-Nuclear-C. Wethy, Plant Manager C. Wilson, Plant Supervisor II
. Windecker, Plant Supervisor-Nuclear Maintenance tor Other licensee employees contacted included Plant Coordinators, Nuclear Watch Engineers, Nuclear Control Center Operators, mechanics, technicians, document control and office staff personnel.
Other Organizations P. Rodi, St. Lucie County Disaster Preparedness Coordinator
="J. Wray, USNRC, Region II (Exit Interview Only}
+R. Zavadoski, USNRC, Region II (Exit Interview Only)
Attended exit intervie.
Exit Interview The inspection scope and findings were summarized on August 24, 1979, with the persons identified in Paragraph 1 above.
The inspec-tor informed,the licensee that inspector followup items identified in Paragraphs 6, 7, 9.d, 9.e, 9.f, 9.g, and ll.d would be reviewed during a subsequent inspection.
The licensee stated that a related problem with the calibration of METE equipment had been identified by the plant QC Department and that the item of noncompliance (Paragraph 9.b) was therefore inappropriate since it was already identified by the plant staff.
The inspector reviewed the licensee's item and stated that, while the problem identified by QC was related to the citation, it was not the same type of failure.
With the exception of statements regarding the completio'n dates for the unresolved items as identified elsewhere in this report, the licensee acknowledged the inspector's statements without comment.
3.
Licensee Action on Previous Inspection Findings a.
Items of Noncompliance (Closed) Infraction (335/79-01-03):
Failure to have calibra-tion procedures (Calibration Information Sheets)
approved by the Facility Review Group (FRG).
Instrument and Control (ISC)
Procedure 1400067, Revision 0 was approved by the FRG on August 20, 1979, in meeting 79-21.
This procedure included all of the issued Calibration Information Sheets.
This item is closed.
(Closed) Deficiency (335/79-15-01):
Failure to follow procedures AP 0005720 and QI 2-PR/PSL-3.
As stated in the licensee's response to this item, the affected personnel had taken an examination on the material presented in the lectures which they had failed to attend as required by AP 0005720; each had scored greater than 80/ on the examination.
Records for each individual in the current requalification program had been annotated to indicate the lectures for which attendance was required and when that lecture had been attended.
With respect to QI 2-PR/PSL-3, the Mechanical, Electrical and ISC departments have now issued a qualification standard as required that indicates personnel must meet or exceed the requirements of ANSI N18.1-1971.
This item is closed.
b.
Deviation (Closed) Deviation (335/79-15-02):
Failure to meet the require-ments stated in the NRC letter dated December 9, 1977, with respect to documentation of inadequate program participation on applications for license renewals.
As stated in the response, the identified individuals'pplications had been resubmitted with the corrected information included.
The Training Supervisor was interviewed, and he is now aware of the requirements for
-3-this type of documentation in the renewal applications.
This item is closed.
4.
Unresolved Items Unresolved items are matters about which, more information is required to determine whether they are acceptable or may involve noncompliance or deviations.
New unresolved items 'identified during this inspec-tion are discussed in Paragraphs S.b, 9.c, ll.b, 11.c and 12.b.
5.
Bulletin 79-10 Reference:
Licensee's response to Bulletin 79-10 dated May 24, 1979 During the followup on previous items (Paragraph 3), the inspector reviewed the licensee's records for the data submitted in the referenced response to Bulletin 79-10.
Daring discussions with the licensee, it was determined that the data for item 2.B was not completely responsive to the request in the Bulletin.
While the licensee had established an equivalency between attending the lectures and successful completion of the end of lecture examination on a given topic, the Bulletin requested data on those actually attending the lectures.
The licensee stated that a supplemental response would be submitted with the data requested by the Bulletin.
This additional response was received in the RII offices on August 31, 1979.
This additional information was evaluated with the original response and no additional action is required on this item.
6.
Personnel Qualification Program References:
(a)
QI 1-PR/PSL-1, Revision 5, "Plant Organization" (b)
QI 1-PR/PSL-2, Revision 0, "Operations Organiza-tion" (c)
QI 1-PR/PSL-3, Revision 2, "Maintenance Organi-zation" (d)
QI 1-PR/PSL-7, Revision 1, "Quality Control Organization" (e)
QI 9-PR/PSL-2, Revision 3,""Control of Non-Destructive Examination" (f)
QI 9-PR/PSL-l, Revision 1, "Special Process Control" (g)
QI 9-PR/PSL-3, Revision 0, "Welding Control" (h)
Electrical Maintenance Training Program, Revision
-4-(i)
Mechanical Maintenance Qualification Standard (j)
IRC Department Training Standard (k)
Appendix B to Topical Quality Assurance Report, Revision 0 dated 1/23/76 The inspector reviewed the referenced documents to assure that minimum educational, experience, or qualification requirements had been specified in writing for the following:
principal operating staff positions; first level supervisory positions; onsite technical engineering staff positiohs; plant craft personnel positions; plant operator positions; and, QA/QC, NDE, chemistry, receipt inspector positions.
Responsibilities have been assigned in writing to assure that these specified requirements are met by personnel employed in those positions.
No items of noncompliance or deviations were identified.
The qualifications of the Offsite Review Committee were not reviewed during this site inspection.
This area will be reviewed during a subsequent inspection at the Company offices.
For tracking purposes this is designated inspector followup item (335/79-21-07).
Quality Assurance/Quality Control Administration References:
(a)
QC-4, "Procurement Document Review", Original (b)
FSAR Sections 3.2, 7.1, 7.4, 7.5, 7.6 and 8.3 (c)
QI 5-PR/PSl-l, "Preparation, Revision, Review/
Approval of Procedures,"
Revision ll The licensee's program was reviewed to verify that QA Program documents:
clearly define those structures, systems, components and activities to which the Program applies; establish procedures and responsibilities for making,changes to such documents; and, establish procedures and responsibilities for QC Department procedure writing and revision.
References (a) and (b) define the safety-related structures, systems, components, services and consumable items to which the Program applies.
A documented method exists, and has been used, to add items to or remove items from the list of Program coverage.
While the mechanism employed to accomplish these changes was well under-stood by those persons responsible for its use at the plant, it was not obvious to an outside reviewer such as.this inspector.
No items of noncompliance or deviations were identifie Two other items, the verification of establishment of responsibility and methods to assure review of the overall effectiveness of the QA Program and the verification that methods exist to modify the QA Program to provide additional emphasis in "identified problem areas" were Company office functions which were not directly verifiable at the site; these will be reviewed during a subsequent inspection at the Company offices.
For tracking purposes these items are designated, respectively, inspector followup items 335/79-21-08 and 09.
8.
Quality Assurance Program Review References:
(a)
QI 1-PR/PSL-3, "Instructions for Maintenance Organization," Revision 2 dated 3/13/79 (b)
QI 2-PR/PSL-2, "Indoctrination and Training of St. Lucie Plant Personnel,"
Revision 6 dated 6/21/79 (c)
QI 4-PR/PSL-l,
"Procurement Document Control,"
Revision 2 dated 12/19/78 (d)
QI 5-PR/PSL-1,
"Preparation, Revision, Review/
Approval of Procedures,"
Revision ll dated 10/17/78 (e)
QI 6-PR/PSL-l,
"Document Control," Revision
dated 5/31/79 (f)
QI 7-PR/PSL-2,
"Receiving Inspection," Revision 6 dated 1/30/79 (g)
QI 8-PR/PSL-l, "Identification and Control of Materials, Parts and Components," Revision 2 dated 1/30/79 (h)
QI 9-PR/PSL-2,
"Control of Non-Destructive Examination," Revision 3 dated 5/13/79 (i)
QI 10-PR/PSL-3.,
"Quality Control Inspection,"
Revision 5 dated 5/31/79 (j)
QI 11-PR/PSI-1,
"Test Control," Revision
dated 6/21/79 (k)
QI 11-PR/PSL-4,
"Instrumentation and Control Test Control," Revision 5 dated 1/25/79 (l)
QI 12-PR/PSL-2,
"Calibration of Instrument and Control Department Measuring and Test Equipment,"
Revision 5 dated 6/13/79
-6-(m)
QI 12-PR/PSL-,5,
"Chemistry Measuring and Testing Equipment," Revision 1 dated 5/2/79 (n)
QI 12-PR/PSL-6,
"Health Physics Measuring and Test Equipment," Revision 6 dated 3/6/79 (o)
QI 13-PR/PSL-1,,"Handling, Storage and Shipping,"
Revision 3 dated 5/31/79 (p)
QI 14-PR/PSL-1,
"Inspection, Test and Operating Status," Revision 3 dated 5/31/79 (q)
QI 15-PR/PSL-l,
"Nonconforming Materials, Parts and Components," Revision 2 dated 5/31/79 (r)
QI 15-PR/PSL-2,
"Deficiencies and Modifications During Construction and Testing," Revision
dated 5/31/79 (s)
QI 16-PR/PSL-1,
"Corrective Action," Revision 4 dated 5/31/79 (t)
QI 18-PR/PSL-2,
"Quality Control Surveillances,"
Revision 5 dated 3/13/79 (u)
QI 18-PR/PSL-3,
"Quality Control Monitoring,"
Revision 2 dated 5/31/79 a.
Program Review No changes had been approved to the licensee's accepted QA Program since the last inspection in this area (October 1978).
The changes made onsite in Quality Instructions since that date were reviewed to verify that they continued to implement the accepted QA Program.
Reference (e) was reviewed as part of the inspection of Document Control activities as documented in Paragraph ll of this report.
Only the changes were reviewed in the remaining documents referenced above since the implemen-tation and adequacy of the specific procedure is reviewed during the inspection of the activities covered by that procedure.
As a result of this review, two areas were identified where the procedures do not reflect the current practices; these are discussed in Paragraph 8.b below.
No items of noncompliance or deviations were identified.
b.
Need to Document Current Practices Procedure QI 13-PR/PSL-l, Revision 3 dated June 1979, Item Q.3 requires QC to surveil handling, storage and shipping practices of Power Resources in accordance with QI 18-PR/PSL-2.
In procedure QI 18-PR/PSL-2, Revision 5 dated March 197),
Item'.0 lists the scope of surveillance activities.
While Item.
3.1 indicates that the ins'truction is not limited to the listed surveillance items (3.1.1 through 3.1.12),
the responsi-,
bility of the gC Supervisor in directing QC surveillances is limited (Item 4.1.1) to those activities delineated in the scope of the instruction.
Appendix A of gl 18-PR/PSL-2 also lists various procedures and practices for gC Surveillance; procedures and practices for handling, storage and shipping are not included for items other than nuclear fuel.
No inade-quate activities were disclosed during the inspection.'ased on a review of documents and on discussions with gC personnel, the handling, storage, shipping and receiving activities are being,surveilled.
In a similar mannner, (}I 16-PR/PSI-l, Revision 4 dated May 1979, Item 4.1.4 assigns the gC Supervisor the responsibility for review of corrective action proposals (by audited/surveilled groups) for adequacy.
The current procedure does not detail the process currently used to escalate matters, when necessary, to assure that adequate proposals are implemented.
In discus-sions with a Plant Coordinator in the gC Department, a process that had been used was orally described.
No inadequate or inappropriate corrective actions were found; therefore, the currently =used but undocumented process appears adequate.
Since in both of these cases the current practices are acceptable and only the documentation of these practices was lacking, no citation is issued for inadequate procedures because the licensee stated that the current practices will be documented.
This documentation will occur by September 30, 1979, or within ten days after receipt of this report, whichever is later, based on a statement by the Plant Manager.
Until the required documentation has been completed, this item (335/79-21-02) is unresolved.
9.
Maintenance References:
(a)
Administrative Procedure No. 0010432,
"Plant Work Orders," Revision 12 dated May 1, 1979 (b)
QI 12-PR/PSL-4,
"Mechanical Maintenance Measuring and Test Equipment," Revision 3 dated February 16, 1978 a ~
Program Review The inspector selected two safety-related maintenance activities (listed below) performed in connection with each of the following systems:
reactivity control/reactor distribution; instrumentation;
/'
-8-reactor coolant system; emergency core cooling systems; containment systems; and, plant and electrical power systems.
For each activity selected, the inspector verified that, as applicable:
the limiting conditions for operations were met while components were removed for maintenance; required adminis-trative approval(s)
were obtained prior to initiating work; approved procedures were used; provisions were made for fire protection, cleanliness, and housekeeping; required gC inspec-tions were conducted; functional testing was performed; and, they were performed by qualified personnel.
The inspector also inspected to assure that gC records were available for items listed below.
The technical content of four procedures (M 0008, M 0009, M 0010 and M 0016) associated with item (5)
and (6) below was evaluated.
The items reviewed were:
(1)
PWO 3942, Open and close primary manway and install nozzle dams on steam generator; (2)
PWO 3909, Replace block on "C" charging pump; (3)
PWO 6438,
"B" S/G level channel; (4)
PWO 6390, Auxiliary feedwater pump overspeed trip; (5)
PWO 3960, Replace hydraulic with mechanical snubbers; (6)
PWO 3964, RCP mechanical seal replacement; (7)
PWO 3883, Work on "A" Containment Spray valve V07145; (8)
PWO 3874, Install SS nipple on all 3 HPCI pumps; (9)
PWO 3997, Work on RCB equipment. hatch; (10)
PWO 3990, Remove and test SR-14329 on "1C" Containment Cooler; (ll)
PWO 5008, Monthly battery check; (12)
PWO 5123, Work on Auxiliary Feedwater Pump steam valve.
As a result of the above review, one item of noncompliance, one unresolved item, and four items needing additional inspec-tor followup were identified.
These items are discussed in Paragraphs 9.b through 9.g belo Failure to Follow Procedure QI 12-PR/PSL-4 During the review of Item 9.a (9) above, the inspector noted that an entry was made on 5/29/79 that the mechanics had
"finished torquing." No mention was made of the torquing value, the procedure used, nor the serial number of the torque wrench used.
The inspector then reviewed the Measuring and Test Equipment (MME) checkout -log; no entry was made to indicate that a calibrated torque wrench had been used on this particular job.
To establish the satisfactory torquing of the hatch, the inspector then inteviewed the mechanic involved.
He stated that he had used a calibrated torque wrench and that he had followed the required torquing procedure and had torqued the hatch to the required value.
While the safety aspects of the closure were established, the failure.to enter the number of the MME wrench used on either the PWO or the MME logbook is contrary to procedure QI 12-PR/PSL-4 and is an item of noncompliance (335/79-21-01).
Processing of Standing Plant Work Orders (PWOs)
The current PWO procedure, AP 0010432, does not recognize a
special method for processing standing PWOs which are those covering recurring outage items and preventive maintenance activities.
The current controls for these PWOs, while differ-ent prom those specified in the procedure, appear to be adequate based on the discussions with plant personnel and a review of items covered.
Neither the review nor the discussion identi-fied any cases where work was started without the knowledge and consent of those identified as responsible for authorization of the activities.
However, the additional controls which are applied to these PWOs when the authorization block signatures are mechanically reproduced is not described in any instruction or procedure.
Further, since a Plant Change/Modification (PCM) could affect the conduct of a particular standing PWO, these PWOs need to be reviewed when a PCM is issued to assure that no change to the PWO is required.
Again, the personnel
- responsible for maintaining these standing PWO's stated that such a review was conducted under the "other" required reviews listed on the PCM review form.
While the current procedures do not specifically require review of PCMs with respect to standing PWOs, and while standing PWOs aie not handled in strict accordance with the current procedure, no citation is issued because the current practices are acceptable and only the documentation of these practices is lacking and the Plant Manager stated'that current practices and procedures would be brought into'agreement by September 30, 1979, or within ten days after the receipt of this report, whichever is later.
This item (335/79-21-03) is unresolved pending completion of the licensee's action "
Cleanliness Levels In Work Areas The licensee's current procedures specify four different cleanliness levels for various activities conducted during maintenance and operations.
In the area of maintenance, these levels are not specified on the PWO. In each case reviewed by the inspector, the QC Department was able to produce a document showing that a
QC inspection had been conducted that verified cleanliness requirements before system closure.
The cleanliness level of the maintenance area could not be shown by documenta-tion but was described by QC orally based on their coverage of the specific PWOs questioned by the inspector.
The mechanics are trained on what levels are required by what activities according to the licensee and, therefore, ao additional guidance or requirements are needed on the PWOs.
Since the inspector did not have an opportunity to observe actual work in progress during this inspection to verify the suitablity of this type of control, a review of this aspect of maintenance will be conducted during a subsequent inspection.
For tracking purposes this inspector followup item is designated 335/79-21-10.
Classification of Control Element Assemblies (CEAs)
In reviewing PWO 6513 on replacement of a coil in the drive assembly for a CEA, the inspector found that no QC was required.
Further review indicated that FSAR Table 3.2.1 specifically exempts the Control Rod Drive Mechanisms and the CEAs from the controls of the QA Program.
This matter will be reviewed with NRC management for adequacy.
No action is required by the
.licensee on this question, but for tracking purposes this inspector followup item is designated 335/79-21-11.
Illegible Copies of PWOs In reviewing the PWOs that are filed, the inspector noted that some copies were illegible.
These copies resulted from the failure to remove the carbon fr'om between the sheets of the PWO and then writing on the back of one of the sheets.
This process places the same words on the front side of the sheets, in mirror image symetry.
This issue was discussed with the licensee who stated that the problem had already been identified.
To resolve the issue, the licensee is depleting his current stock of forms which employ carbon paper and then will replace them with a form which is not subject to this problem.
In every one of the twelve specific PWO's that the inspector had selected for review, at least one legible copy was found.
However, since only a small portion of all of the PWOs available were reviewed, this area will be reinspected to assure that appropriate documentation is available.
For tracking purposes this inspector followup item is designated 335/79-21-1 "11-g.
Additional Review of Maintenance As part of this inspection, a review is normally made of the circumstances associated with the maintenance of six,safety-related pieces of major equipment to ascertain if their removal or maintenance or failure was reportable under the Technical Specifications.
However, this facet of the inspection could not be completed during this visit.
This area will be reviewed during a subsequent inspection and, for tracking purposes, this inspector followup item is designated 335/79-21-13.
10.
Emergency Drill The licensee
'conducted an emergency drill on August 23, 1979.
The offsite local and state response was observed by members of the Interagency Regional Advisory Committee.
The portion of the drill observed by this inspector consisted of:
review of the security practices associated with the entrance and exit of the ambulance used to remove a simulated patient; the communications and coordina-tion of the local, county and State activities from the St. Lucie County Emergency Operations Center in Ft. Pierce, Florida; monitoring over a car radio the message given over station WIRA (which included a live discussion between the WIRA News Director and the St. Lucie County Disaster Response Coordinator on the conduct and purpose of the drill); the observation of the Aerial Radiation Monitor overflight of the site; and, observation of officers of the St. Lucie County Sheriff Department who were involved in making announcements to residents who would have required evacuation during an actual event.
No items of noncompliance or deviations were observed.
Document Control References:
(a)
QP 6.2, "Control of Documents," Revision 2 dated ll/77 (b)
(}I 6-PR/PSL-1,
"Document Control," Revision
dated 6/79-a ~
Program Review The referenced documents were reviewed with respect to the licensee's accepted QA Program.
The inspection was to verify that administrative controls had been established for the indexing, issuance, retrieval and revision of documents.
The inspector selected a representative sample of documents (listed below) for review at the locations specified with respect to the controls listed above.
Documents selected and the location(s)
where each was reviewed are:
(1)
P.O.
NY - 422295 I/M 8770 6631 "Charcoal Absorbers for HVE 1, 2, 9A, 9B and 16-MSA," Mechanical Maintenance files
"12-(2)
P.O.
MY-4222265 I/M 8770 6130 "Turbine Driven Auxiliary Feedwater Pump," Mechanical Maintenance and Master files.
(3)
P.O.
CE-2851 I/M 8770 4272 "Sigma Instruments Co.
Indicating Controls," Master files (4)
P.O.
CE-128 I/M 8770 8588 "Internals Vibration Monitor System," Master files (5)
G-228 "Fuel Handling Building Instrument Arrangement,"
Mechanical Maintenance and Master files (6)
B-327, "Control Wiring Diagrams",
Sheet 372, Revision
of 12/4/75 and Sheet 251, Revision 9 of ll/28/77, IRC and Master files (7)
B-326, "Schematic Diagrams",
Sheet 237, Revision 4 of 12/2/75 and Sheet 251, Revision.3 of 12/2/75, ISC and Master files (8)
G-226, "Reactor Building Instrumentation Arrangement",
Sheet 3, Revision 9 of 12/7/78, Control Room and Mechanical Maintenance files (9)
Diesel Generator manual, Copy 8, Revision 0, Nuclear
- Watch Engineer's Office (10)
Diesel Generator Engine manual, Copy 7, Revision 0, Nuclear Watch Engineer's Office (ll) Excitation Switchgear manual, Copy 7, Revision 0, Nuclear Power Supervisor's Office (12)
Technical Specifications, Copies 28 and 30, Nuclear Power Supervisor's Office and Control Room (13)
Safety Injection System PAID, Copy 6, Revision 12,
sheets - 8770-87 and 8788, Control Room (14)
Off-Normal/Emergency Procedures, Loss of Condenser Vacuum, 0610031, Copy 9.
Revision 2 and Condenser Tube leak, 0610030, Copy 9, Revision 3, both at the Control Room.
As a result of the review, one inspector followup item and two unresolved items were identified as discussed in Paragraphs ll.b, ll.c and ll.d below.
No items of noncompliance or deviations were identified.
b.
Illegible Print Based on the finding of one illegible print (a CWD index sheet),
the need for action to provide replacements for such
-13" documents was identified...No cases were found where a system print was illegible or where an illegible print was used or referenced for safety-related activities but no system was documented for obtaining legible copies when illegible copies were issued to the field.
The licensee stated that a memorandum, instruction, or other suitable document will be issued to require personnel to notify Document Control - Quality Control when an illegible document is found so that appropriate action can be taken.
According to the Plant Manager, these directions will be issued by September 30, 1979, or within ten days after the receipt of this report whichever is later.
Until these directions are issued, this item (335/79-21-04) is unresolved.
c Assuring Plant Change/Modification Are Annotated The licensee currently checks each copy of a revised print prior to issuance to assure that the PCMs annotated on the current print have been incorporated-into the revision.
Where PCMs have not been incorporated in the revised print, the revised print is annotated with the outstanding PCMs.
This practice is not documented.
Since the current practice is acceptable and only the documentation is lacking, no citation for an inadequate procedure is issued because the licensee stated that the current practices will be documented.
These practices will be documented by September'30, 1979, or within ten Mays of the receipt of this report, whichever is later, according to a statement by the Plant Manager.
Until this practice is documented, this item (335/79-21-05) is unresolved.
d.
Correcting QA/QC Documents During the review of documents, the inspectors found numerous cases where entries were lined through repeatedly, written over, blacked out, or otherwise opaqued out in such a manner as to obliterate or completely cover the original entry.
The Operations Department and the Quality Assurance Department activities at the Company offices are both controlled by a policy which, while permitting the correcting of data, does not obliterate the original entry.
The Plant Manager stated that the policy currently used in the Operations Department will be disseminated and enforced throughout the facility for all QA/QC documents used for official records.
The inspector will examine the results of this action during a subsequent inspection.
For tracking purposes, this inspector followup item is designated 335/79-21-14.
12.
Records References:
(a)
QP 17.1,
"The Collection and Storage of Quality Assurance Records for Nuclear Power Plants",
Revision 4 dated 8/79
(b)
QI 17-PR/PSL-l, "Quality Assurance Records",
Revision 2 dated 9/78 a.
Program Review The referenced documents were reviewed with respect to the licensee's accepted QA Program.
The review.was to verify that administrative controls had been established for the receipt, storage, preservation, retention and retrieval of required QA/QC records and to verify conformance of these records to Technical Specification and QA Program requirements.
The implementation of the requirements of the referenced documents was verified by requesting the documents listed below.
The inspector observed that, as they were retrieved, the storage and maintenance were as required.
Records requested were:
(1)
Reportable Occurence 335-78-37 of 9/19/78, "Ventilation Restraints Update Report No. 1".
(2)
Reportable Occurence 335-78-43 of 11/20/78,
"Technical Specification 3.1.3.1, CEA //62" (3)
Check Sheet gl for 12/14/78,
"Surveillances Performed each Shift" (4)
Check Sheet 7/1 for 12/13/78,
"Surveillances Performed each Shift" (5)
Nuclear Control Center Operator Iog Sheet for 4/20/78 (6)
Nuclear Operator Iog Sheet for 4/20/78 (7)
Auxiliary Equipment Operator Log Sheet for 4/28/78 (8)
Auxiliary Equipment Operator Iog Book for 4/19-21/78 (9)
Nuclear Operator Iog Book for 4/19-21/78 (10)
Nuclear Control Center Operator Iog Book for 4/18-21/78 (ll) Nuclear Plant Supervisor Log Book for 4/20-21/78 As a result of this review, one unresolved item was identified as discussed in Paragraph 12.b below.
No items of noncompliance or deviations were identified.
b.
Need to Revise QI 17-PR/PSL-1 QI 17-PR/PSL-1 as currently issued does not address the requirement of QP 17.1 and the accepted QA Program to verify that documents received are in agreement with the transmittal document.
The current QI also fails to address the system
e
-15-used for the retrieval of records which is also a requirement of the accepted gA Program."
As verified during this inspection, both the required retrieval system and the practice of verifica-tion of received documents against the transmittal document are in place and in use.
Since the current practices are acceptable and only the documentation of these practices was lacking, no citation is issued for inadequate procedures because the licensee stated that the current practices would be documented.
This action will be completed by September 30, 1979, or within ten days of receipt of this report, whichever is later, according to a statement made by the Plant Manager.
Until the procedure is revised, this item (335/79-21-06) is
'nresolved.