IR 05000338/1979008
| ML19247A095 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 03/23/1979 |
| From: | Ashenden M, Jenkins H, Kellogg P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19247A091 | List: |
| References | |
| 50-338-79-08, 50-338-79-8, NUDOCS 7907300018 | |
| Download: ML19247A095 (28) | |
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UNITED STATES
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Report No.: 50-338/79-08 Licensee: Virginia Electric and Power Company Post Office Box 26666 Richmond, Virginia 23261 Facility Name: North Anna Power Station Docket No.: 50-338 License No.: hTF-4 Inspection at North Anna Site and VEPC0 Corporate Headquarters, Richmond, Virginia dA
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Date Signed M. C. Ashenden
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SUMMARY Inspection on January 29 through February 2,1979 Areas Inspected in This routine, unannounced inspection involved 77 inspector-hours onsite the areas of QA program periodic review, QA audits, procurement, design changes / modifications, records and aaintenance, ljh
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-2-Results Of the six areas inspected, no apparent items of noncompliance or deviations were identified in one area; 12 apparent items of noncompliance were found in five areas (infraction-failure to initiate prompt corrective action-paragraph 6.b; infrac'. ion-inadequate or non-existent auditing procedures paragraph 6.c; infraction-failure to perform and evaluate testing paragraph 8.b; icfraction-failure to perfo rm safety analysis-paragraph 8.d; infractien-failure to review required procedures paragraph 9.b and 10.b; infraction-failure to complete required retraining-paragraph 9.c; infraction-failure to follow 7.c., 8.e, 8.f, and 10.c; deficiency-failure to review procedure-paragraphs rd procedure-QC Engineer-paragraph 9.d; deficiency-failure to establish requi receip controls-construction documents paragraph 9.e; deficiency-f ailure tc, record paragraphs 6.d and 8.c; deficiency-f ailure to protect materials paragraph 7.b; deficiency-failure to establish equipment inspection program-paragraph 7.d.
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DETAILS 1.
Persons Contacted Licensee Employees E. A. Baum, Manager-Licensing and Quality Assurance
- W. R. Cartwright, Station Manager S. B. Eisenhart, Quality Assurance Engineer L. G. English, Stores Supervisor L. O. Goodrich, Mechanical Supervisor
- J. W. Green, Administrative Services Supervisor J. H. Harper, Instrument Supervisor G. A. Helm, Supervisor, Quality Assurance Engineering D. Hopper, Health Physics Supervisor W. C. Hughes, Receiving QC Inspector G. Kann, Design Control Engineer
- J. D. Kellams, Operations Superintendent R. P. Kimsey, Electrical Supervisor
- J. W. Martin, Jr., Quality Assurrace-Operations and Maintenance Supervisor
- J. L. Perkins, Director of Qualit) Assurance R. G. Sidle, Maintenance Coordinator
- D. L. Smith, Resident QC Engineer
- E. R. Smith, Technical Services Superintendent C. R. Swope, Senior Engineering Technician
- B. R. Sylvia, Director-Nuclear Operations M. D. Tudor, Staff Engineer
- D. C. Woods, VEPCO-NRC Coordinator Other licensee employees contacted during this inspection included technicians and office personnel.
NRC Resident inspector M. S. Kidd, North Anna Power Station
- Attended exit interview.
2.
Exit Interview The inspection scope and findings were susraarized or February 2,1979 with those persons indicated in Paragraph I above.
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-2-Licensee Action on Previous Inspection Findings 3.
(Open) Unresolved Item (338/78-27-01): Develop and Implement a System with Outstanding E&DCR's. The inspector found for Updating Drawings that a procedure had been developed for accomplishing this activity and However, the updating that updating of the Unit 1 drawinEs was underway. completed and instructions of all prints and drawings is not yet Record's File Room personnel on evaluation of revisions to assure that all outstanding E&DCR's have been included or annotated had not been approved. This item will remain unresolved.
4.
Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve noncompliance or New unresolved items identified during this inspection are discussed in Paragraphs 6.e through 6. i, 7.e, 7.f, 8.g, 8.h, 8.1, 8.j, 9.f, deviations.
9. g,10.d and 10. e.
5.
QA Program-Periodic Review NPSQAM, Section 2, Quality Assurance Program, Revision 5, References:
a)
dated 11/78 NPSQAM, Section 3, Design Control, Revision 8, dated b)
8/78 c)
NPSQAM, Section 4, Procurement Document Control, Revision 2, dated 1/78 d)
NPSQAM, Section 5, Instructions, Procedures and Drawings, Revision 16, dated 11/78 e)
NPSQAM, Section 6, Document Control, Revision 7, dated 4/78 Section 7, Control of Purchased Material, NPSQAM, f)
Equipment and Services, Revision 2, dated 2/78 g)
NPSQAM, Section 10, Inspection, Revision 3, dated 3/78 h)
NPSQAM, Section 11, Test Control. Revision 8, dated 8/78 Section 12, Control of Measuring and Test i)
NPSQaM, Equipment, Revision 6, dated 11/78
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NPSQAM, Section 13, Handling, Storage and Shipping, Revision 2, dated 5/78 k)
NPSQAM, Section 14, Inspection, Test and Operating Status, Revision 4, dated 7/78 1)
NPSQAM, Section 16, Corrective Action, Revision 10, dated 7/78 m)
NPSQAM, Section 17, Quality Assurance Records, Revision 3, dated 3/78 a.
Inspection Items The changes made to the licensee's QA procedures during the period (October 1977 through November 1978) were reviewed with respect to the implementation of the accepted QA 1,rogram.
The maintaining licensee's current "Q" List has been reviewed for consistency with items used in the safety-related operations of the facility.
the In addition, selected personnel vere interviewed during the conduct of other areas of the inspection as documented in this report to assure that changes in procedures were understood and available for The accepted QA program was changed during the period since use.
the last inspection of this area, so that aspect of revision control was inspected.
The specific changes reviewed are those listed under references above.
The inspector found no ites-of nonce gliance or deviations in this area.
,A Audits 6.
Q References:
a)
NPSQAM, Section 18, Revision 2, dated 12/76 b)
SYP-3, SYNSOC Manual, Revision 0, dated 1/78 c)
SYNSOC-Bylaws, dated 2/2/76 d)
QA-0&M Inst. 7.1, Training I'lan, Revision 1, dated 11/78 e)
D. R. Arter Memo, Annual SYNSOC Review of Station Operatiens, dated August 31, 1978 6,% Niegjg 488 251
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-4-a.
Inspection Items completed Quality Assurance audits for the period since the The last inspection of this area (January 1978 through December 1978)
were reviewed. Se~enty-nine (79) audits had been completed for the activities related to North Anna Power Station. The audits reviewed were designated N-77-24, N-77-54, N-77-68, N-79-01, N-7 7-139, N-77-44, N-78-50, N-78-11, N-78-13, N-78-60, N-77-71, and N-78-18.
These audits were reviewed with respect to the requirements of the accepted QA program to assure that they were conducted in accordance with written checklists / procedures, by trained personnel not having direct responsibility in tbe area being audited, with the results documented and reviewed by the managers responsible for the audited with a frequency as area and by those directing the QA program, stipulated in the accepted program, and, with timely corrective action taken and reported.
As a result of these reviews, two (2) items of noncompliance and an example contributing to one (1) additional iteu of noncompliance are documented in Paragraphs 6.b, 6.c and 6.d.
Five (5) unresolved items were also found as set forth in Paragraphs 6.e through 6.i below.
b.
Failure to Initiate Prompt Corrective Action The inspector reviewed eleven (11) of approxicately one-hundred and sixty (160) audit reports which covered the period April 1977 to January 1979 and within these reports he identified 30 of 51 indivi-dual items which received either a slow response or no response, or The slow or no the estimated completion date was exceeded therein.
response items were:
N-77-71-1 through 4
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N-77-71A-3
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N-78-18-1 through 9
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N-77-44-1 through 6
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Those items exceeding estimated corrective action completion dates were:
Length Exceeded Item (As of 2/79)
N-77-24-2 5 Months N-77-54-1 and 2 19 Months N 78-13-8a 11 Months 488 252
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-5-11 Months N-78-13-1 N-78-13-5 5 Months N-78-13-3 6 Months N-78-60-1 and 2 2 Months N-78-60-3 3 Months The audit program made no provision to follow-up on the slow /no response short of conducting a re-audit.
Additionally, of the fifty-one (51) items reviewed, fifteen (15) were responded to inadequately with no action initiated by the QA organization to The items for which the tesponses were obtain proper responses.
inadequate as to form and/or content were:
N-77-24-1 and 2
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N-77-54-3 N-77-68-1 and 2
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N-78-13-2
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N-78-13-6
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N-78-11-1 and 2
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N-77-/1-1
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N-77-71A-4
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N-78-18-8
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N-77-44-3
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N-77-44-5
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N-77-139-3
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Finally, there were eight (8) items improperly closed without review of satisfactory evidence that the solution was implemented correctly. Five (5) improperly closed items later lead to escalated action being initiated by the U.S. Nuclear Regulatory enforcement Cocnission. Those items resulting in soforcement were:
(Open) N-78-13-8b-Three Reports
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USNRC RII 050-338/78-26
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USNRC RII 050-338/78-37
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UShPC RII 050-339/78-37
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(Closed) N-78-13-1, Unresolved Item - (Paragraph 9.g)
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(Closed) N-78-13-2, Item of Noncompliance - (Paragraph 9.c)
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(Closed) N-77-68-1, Item of Noncompliance - (Paragraph 9.c)
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(Closed) N-78-73-E-1, Item of Noncompliance - (Paragraph 10.b)
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-6-The other _ pen items improperly closed were:
N-77-24-2
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N-77-68-2 and 3
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N-78-13-5
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N-78-13-7
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N-78-11-1
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N-77-44-5
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Criterion XVI,10 CFR 50 and Section 17.2.16 of the Accepted Quality Assurance Program requires that corrective at:f on be taken to preclude conditions adverse to quality and that these conditions be promptly identified, corrected and documented, and that the corrective action taken are reported to appropriate levels of both off-site and on-site management.
Upon the items identified above, there were forty-four (44) items which were found to be improper, as identified above, without management above the station level being informed.
These examples of failure of the auditing program to assure prompt, corrective action to include management failing to be informed, collectively, constitute an item of noncompliance (338/79-08-01).
Inadequate or Nonexistent Auditing Procedures c.
The inspector reviewed the 1977 SYNSOC audit of station Quality Assurance and the design change auditing checklist to verify status and adequacy thereof. He identified several deficiencies pertaining to the SYNSOC annual audit and one discrepancy with respect to the design change audit checklist. For SYNSOC there were:
No procedures or checklists by which to conduct the audit
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No qualification requirements of the lead auditor
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No formalized training for the individual auditors
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No reporting requirements
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No response times specified
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No corrective action requirements
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The design change audit checklist was compared to the audit require-sents of ANSI-N45.2.11-1974, as cocnitted to by the accepted QA and found to be inadequate; all items required to be program, included by Section 11 of the standard were not incorporated in the presently utilized checkl
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-7-10 CFR 50, Appendix B, Criterion WIII.nd the accepted Quality Assurance Program specify that the audit be performed with written checklists by appropriately trained personnel.
procedures or (Draf t 3, Revision 4-1974), as comitted to by the ANSI-N45.2.12 program, requires that the auditing organizations submit the completed conference, the report within thirty (30) days of the post-audit audited organization respond within thirty (30) days of receipt of and a system exist to delineate the duties and qualifi-the same, caticas of the auditors, to provide written procedures or checklists, specify reporting requirements and response times of the and to SYNSOC annual audit.
These examples of failures to establish an auditing program for the SYNSOC and to provide adequate checklists for auditing the design collectively, constitute an item of noncompliance change program, (333/79-08-02).
d.
Failu-e to Record Pre-Audit Attendees The inspector reviewed thirteen (13) of the 79 audits conducted by the station QA organization in 1978.
Of the thirteen (13) audits reviewed, only two (2) recorded the persons attending the pre-audit 10 CFR 50, Criterion XVII and the accepted QA program conference.
records of activities affecting qualit y shall he require that Additionally, ANSI-N45.2.12 (Draf t 3, Revision 4-1974),
maintained.
as comitted to by the accepted program, requires in Section 4.4 that a report shall be written to include persons contacted during pre-audit activities.
The licensee stated that the pre-sudit conferences were held, but not documented.
This example of a f ailure to maintain adequate records of acticies af fecting quality has been combined with similar f ailures documented in paragraph 8.c to collectively constitute an item of noncompliance (338/79-08-03).
Failure to Provide an Audit Evaluation Statement e.
Within che review cf the aforementioned audit reports, the inspector identified that, contrary to ANSI-N45.2.12 (Draf t 3, Revision 4-1974)
as comitted to by the accepted program, the required evaluation statement concerning the effectiveness of the quality assurance program elements audited was not utilized. Since the licensee did write a conclusion statement on the audits, there were no problems determined to have arisen from the lack of an evaluation statement.
the use of the required evaluation However, until such time as statement is implemented for every audit report, this unresolved item is designated (338/79-08-04).
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-8-f.
Implementation of a Fomal SYNSOC Review The System Nuclear Safety and Operating Comittee (SYNSOC) is required by the accepted QA program to perform an annual review ofAs the station-level quality assurance / quality control activities.
of February 2, 1979, there were no specific means provided to instruct the SYNSOC as to the scope and depth of the annual review.
A memorandum dated August 31, 1978 entitled " Annual SYNSOC Review promc'eated to address the above of Station Operations" was mentioned review, but was not f c..aa lly implemented.
Until an fomal method is established to reflect the conduct of approved, the required review documented in the above referenced memorandum, this unresolved item is designated (338/79-08-05).
Formulation of an Escalation Procedure g.
QA program, through the NPSQAM, Section 2.4.2(d)
The accepted provides for differences of opinion between QA personnel and other resolved either at the station level with the departments to be station manager and senior member-station quality assurance staff or to be referred through the nomal administrative chain for resolution at the corporate level. The inspector identified audit reports N-77-24, N-76-27, N-78-60, N-77-68 and N-78-ll as generating between QA/QC and various departments.
However, disagreements there appeared to be no formal method '.o carry out the escalation Until a formal process for the disputed audit item documented above.
escalation method is written, approved and implemented, this unre-solved item is designated (338/79-08-06).
h.
Submittal of Follow-Up Reports by Audited Organizations The inspector identified ten (10) items within the reviewed audits documented in paragrap 6.b that had exceeded estimated implemen-tation dates without any means of effecting a follow-up program.
ANSI-N45.2.12 (Draf t 3, Revision 4-1974), as comitted to by the accepted QA program, requires the audited organization to provide a follw-up repe-t stating the corrective action taken and the completion date of correttive action.
This is required in addition to the response to the original audit report which shall be accomplished within thirty (30) working days of receipt of the report.
Until the licensee approves and implements a method to require follow-up reports f rom audited organizations, this unresolved item is designated (338/79-08-07)
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Authority and Organizational Freedom A number of items identified during the inspection deal with the usage of authority and organizat.onal freedom. Accepting inadequate responses, closing items without review of objective evidence, no escalation to higher authority when such items were found, and similar inadequacies documented in Paragraphs 6.b through 6.h above, lead to the question of whether sufficient authority and organization freedom existed within the QA organization.
Statements made by responsible managers and documented within the accepted Quality Assurance Program conclude that the required However, in order to determine if the requirements elements exist.
of 10 CFR 50, #ppendix B, Criterion I and the requirements of the additional infor-accepted Quality Asc rance Program are being met, eation is required. In order to obtain this additional information, che NRC will more closely monitor the activities of the Quality Assurance organization and the interface between that organization and the operating units at the North Anna site.
Based on this determination and take additional review, the NRC will make a appropriate action.
No additional action is required of the licensee with respect tc this area since all of the r? view and evaluation necessary to determine if the item is accepable, a deviation, or an item of noncompliance will Le performed by the NRC.
However, until this additional evaluation has been completed, this is an unresolved item (338/79-08-08).
7.
Procurement References:
a)
VEPC0 Nuclear Power Station Quality Assurance Manual, Section 4, " Procurement Document Control" b)
'EPC0 Nuclear Power Station Qulity Assurance Manual, Section 7, " Control of Purchased Material, Equipment and Services", Revision 2, February 21, 1978 c)
VEPC0 Nuclear Power Station Quality Assurance Manual, Section 8, " Identification and Control of Materials, Parts end Components", Revision 2 January 24, 1978 d)
VEPC0 Nuclear Power Station Quality Assurance Manual, Section 13, " Handling, Storage and Shipping", Levision 2, May ll,1978
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-10-Inspection Items a.
reviewed the procurement area to verify that the Tbe inspectorspecifications used in the purchase of components and procurement naterial from selected systems included proper approval, quality control inspection requirements and quality record requirements.
Components were selected from the Emergency Cooling System, Instrumentation and Plant Electrical power systems. The specific items selected were:
(1) Bearing Thrust Sleeve, stock number 3067178, purchase order number 35564 (October 6,1977)
(2) Trausformer (Inventer), stock number 0750824, purchase order number 97201 (March 2,1979)
(3) Process Level Control Transmitter, stock number 1489215, purchase order number 55530 (May 1,1978)
For the items selected, the inspector verified that documentary e,-idence was available on-site to support their conformance to procurement requirements.
In reviewing activities to assure that these items were inspected upon delivery and that they were handled in accordance with established controls in addition to being supplied by an approved vendor, the inspector reviewed the warehouse and related activities.
The inspector identified three items of noncompliance with respect to procurement, storage and maintenance.
These are documented in paragraphs 7.b, 7.c and 7.d below. Additionally, two unresolved identified with respect to control of local purchase items were items and the review an placing of certain consumables/expendables under the QA program controls. These are documented in paragraphs 7.e and 7.f below.
b.
Protection of Materials During the inspection of warehousing and storage, the inspector identified that capping of pipe ends was not being performed as and NPSQAM required by the controlling standard (ANSI N45.2.2-1972)
Additionally, the inspector deter-Section 13, Paragraph 5.5.2(3).
mined that inspections in this area had not been performed as This matter was required by NPSQAM Section 13, Paragraph 5.2.5.
discussed with warehouse, station QC and management personnel.
VEPC0 concurred with the findings sad coenitted to corrective action. Since the licensee took ica.diate corrective action to cap
.the subject pipe prior to completion of the inspection, no response to this portion of the noncompliance is required.
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-11-This failure to cap pipes and perform the required inspections is an item of noncompliance (338/79-08-09) with respect to 10 CFR 50 Appendix B, Criterion X.
c.
Material Control Failure During the inspection of procurement activities, the inspector identified that contrary to the controlling procedure (NPSQAM, Section 7), VEPC0 maintenance personnel were transferring Category I valves and flanges from the Etone and Webster construction warehouse (Unit 2) to be utilized in Unit I without receipt inspection by the store's personnel as required by Paragraph 4.3, Section 7.
Further-more, the pipe flanges were being transferred without a purchase requisition being prepared. This matter was discussed with VEPCO warehouse, QC, maintenance and management personnel. VEPC0 concurred with the findings and committed to corrective actions.
This failure to issue purchase requisitions and perform receipt inspections as required by the controlling procedures, collectively constitute with paragraphs 8.e, 8.f, and 10.c, an item of noncompliance (338/79-08-10) with re;pect to 10 CFR 50 Appendix B, Criterion V.
d.
Failure to Establish Equipment Inspection Program During the inspection, the inspector identified that VEPC0 had failed to develop and implement a program that would identify hoisting equipment certification and an inspection program for equipment and rigging as required by the comitted standard ANSI N45.2.2-1972. This matter was discussed with VEPC0 maintenance, QA and management personnel. VEPCO concurred with the findings and comitted to corrective actions.
This failure to implement the requirements of the standard regarding hoisting equipment certification and the inspection program for equipment and rigging is an item of noncompliance (338/79-08-11)
with respect to 10 CFR 50 Appendix B, Criterion XIII.
Consumables/ Expendable Control e.
During review of QA controls applied to cot.sumables/ expendable items (e.g., lubricants, chemicals, resins, welding rods, gaskets,
"0" rings, packing, nuclear fuel, and gases), the inspector discovered they were not under the licensee's current QA program. The inspector conducted a random review of the licensee's control and usage of these items.
Boric acid, RTV Foam, lubricants and valve operator diaphrams were selected and reviewed during a plant tour on-site.
The inspector found no safety degrading problems or practices.
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-12-The licensee stated that consumable / expendable items would be reviewed to determine which items could effect safety-relatedHe functions of safety-related systems, structures and components.
further stated that the items determined by this review would be placed under the QA program controls to the degree required to ensure that safety was not degraded.
Until the review has been completed and controls have been implemented, this item is unresolved (338/79-08-12).
f.
Procurement Control During review of activities relative to the control of local purchase items, the inspector o:scovered that there existed no administrative controls to ensure that no Category I items could be locally purchased without proper technical and QA review.
The licensee stated that he would review this area and implement the necessary corrective actions required to assure that all through the local purchase as'.od would provide materials bought the necessary controls for technical and QA review when required.
Until this review has been completed and controls have been imple-mented, this unresolved item is designated (338/79-08-13).
8.
Design Changes / Modification References:
a)
NPSQAM, Section 3, Design Control, Revision 8, dated 8/78 b)
NPSQAM, Section 14, Paragraph 5.2, Use of Jumpers,
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Revision 3, dated 7/77 a.
Inspection Items to The inspector reviewed the design change / modification areas verify that they were made and documented in accordance with 10 CFR 50.59, reviewed and approved in accordance with Technical Specifications and QA/QC controls, and conducted using formal, approved procedures.
Safety-related design change packages were reviewed for four (4) systems. The specific items reviewed were:
DC-78-01-Recirculation Spray to Low Head Safety Injection
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Cross Connect DC-78-06-Casing Cooling Subsystem of Recirculation Spray
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e-13-DC-78-09-Boric Acid Transfer Pump Insulation
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DC-78-27-Pressurizer Pressure Transmitter Replacement
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For the items selected, the inspector verified that documentary evidence was available on-site to support their conformance to d:: sign change requirements.
Design inputs, encompassing codes, standards, regulatory requirements and design bases were verified.
The test and acceptance criteria stipulated in the design change procedures were reviewed as to their status and adequacy and that the final modified equipment performance was reviewed and approved indicating their conformance to Technical Specifications. Additionally, operating procedures and as-built drawings rffected by the selected design changes were reviewed to verify their up-to-date revision Non-safety-related design change package DC-78-11 (bearing status.
cooling water modification) was reviewed only to verify compliance with 10 CFR 50.59 regulatory requirements.
The inspector re viewed the Jumper Log and selected three (3) entries.
Each was reviewed to determine that the log reflected the actual status of the item, the temporary modifications were documented in accordance with 10 CFR 50.59 and independent verification of instal-lation and removal had been performed.
The following Jumper Log entries were reviewed:
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Serial 151 Radiath Monitoring Channel RM-CH-129 Serial 183 Temporary brass to Boron Recovery System
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Gas Stril ping Pump 1-BR-P-10A Serial 191 Add Drip lag and Catch Bottle to High Side
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of LT1-106 As a result of the review, the inspector identified five (5) items of noncompliance and an example contributing to one (1) additional item of noncompliance are documented in Paragraphs 8.b through 8.g below and three unresolved items as set forth in Paragraphs 8.h through 8.j below.
b.
Failure to Perform / Evaluate Testing 10 CFR 50, Appendix B, Criterion XI requires that testing to demonstrate satisf actory performance be performed in accordance with written test procedures and furthermore that results be evaluated to assure test requirements are met. Section 17.2.11 of
' the accepted QA program reiterates those requirements.
Required b)
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-14-performed for design change DC-78-09 which was testing was not installed on the A, B and C boric acid transfer pumps and placed in service in August 1978.
The test procedure was still unapproved and the licensee stated it had not been performed at the time of this inspection. The inspector comented that the unapproved pacedure failed to test the design Test input requirement for maximum insulation surface temperature.
properly evaluated for design change DC-78-06.
results were not Section 5.1 of the Final Design Controlling procedure gave acceptance criteria for the performance of the casing cooling pumps as at 1000 gpm against at least 113 feet TDH. The performance was least recorded for pump 1-RS-P-3A as 1006.-tm against 112.42 feet TDH and Both the for pump 1-RS-P-3B as 1000 gpm agair.sc 112.87 feet TDH.
data page and the acceptance criteria signature of the Final Design signed without coment.
The licensee Controlling procedure were could provide no written evaluation of the acceptability of this data and did not state that one was performed.
These two examples of failure to control testing collectively constitute an item of noncompliance (338/79-08-14).
Failure to Maintain Sufficient Records c.
10 CFR 50, Av endix B, Criterion XVII requires the maintenance of records inc.aing results of reviews and the monitoring of work Section 17.2.17 of the accepted QA program reiterates performance.
In the following two specific examples records these requirements.
were not maintained as required. Records were not maintained as required in that NPSQAM Section 3, Paragraph 5.8 requires reviews of the performance of design changes yet no records of these reviews These were maintained for any of the four design changes reviewed.
design changes had been implemented as follows:
DC-78-01, implemented 4/13/78
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DC-78-06, implemented 5/28/78
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DC-78-09, implemented 7/31/78
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DC-78-27, implemented 5/18/78
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These two examples of failure to maintain required records combined with a similar failure documented in Paragraph 6.d collectively constitute an item of noncompliance (338/79-08-03).
d.
Failure to Perform 10 CFR 50.59 Safety Analysis ne maintenance of records, including a 10 CFR 50.59(b) regt.
written safety evalur
, of changes to the facility as described in the safety analysis report. Two examples of modifications which 488 y~;
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-15-did r#L fulfill tnis requirement were noted. One safety-related temporary modification to the chemical and volume control system (Jumper Log, serial 191) had no documented safety analysis. One design change to the bearing cooling water system (DC-78-11) consti-tuted a change to the facility as described in the safety analysis This change also had no documented safety analysis.
report.
These two examples of failure to maintain records of written safety an item of evaluations per 10 CFR 50.59 collectively constitute noncer.ipliance (388/79-08-15).
Failure to Use Approved Design Change Document e.
10 CFR 50, Appendix B, Criterion VI requires approval of documents and their distribution to and use at the location of the prescribed Section 17.2.16 of the accepted QA program also requires activity.
approval of documents prior to release sod that a copy of the procedure be available at the activity location prior to the start of that activity. Design change DC-78-09 (boric acid transfer pump insulation) was noted by the licensee on July 31, 1978 to have already been accomplished, yet the Final Design Controlling procedure had not beca approved.
This example of failure to use an approved procedure in an activity affecting quality collectively constitutes with paragraphs 7.c, 8.f, and 10.c an item of noncompliance (388/79-08-10) with respect to 10 CFR 50 Appendix B, Criterion V.
The licensee's inanediate corrective action was completed prior to this inspection.
The licensee need only address steps taken to prevent recurrence in response to this item.
f.
Failure to Select Design Change Materials 10 CFR 50, Appendix B, Criterion III requires toe selection and review for suitability of materials that are essential to safety-related functions.
Section 17.2.3 of the accepted QA program reiterates these requirements. NPSQAM, Section 3, Paragraph 5.7.5 requires materials used to complete design changes to be listed on the materials list form and the instructions in Section 6 for the saterials list (number 889.17) require the design control engineer The materials and quality assurance engineer to review this input.
list for design change DC-78-09 (boric acid transfer pump insulation)
did not include a thermometer even though a calibrated thermometer was required by the final design.
I was noted that a metallic strip thermometer was installed.
/
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-16-select / review materials necessary for a safety-This failure to related design change collectively constitutes with paragraphs 7.c, 8.e, and 10.c an item of noncompliance (388/79-08-10) with respect to 10 CFR 50 Appendix B, Criterion V.
Failure to Include Appropriate Quantitative Acceptance Criteria g.
10 CFR 50, Appendix B, Criterion V requires:
"... Instructions, procedures, or drawings shall include appropriate quantitative or acceptance criteria for determining that important qualitative activities have been satisfactorily accomplished." The accepted QA
"... Measures are established Program Section 17.2.3 states in part:
to assure that applicable regulatory requirements... are correctly translated into VEPC0... procedures and instructions applicable to design changes and/or modifications for the operating nuclear power station...."
Nuclear Power Station Quality Assurance Manual Section 14, Paragraph 5.2.
addresses the applicable 10 CFR 50.59 regulatory requirements.
However, it does not include the appropriate qualitative acceptance criteria for determining the need to perform a written safety This paragraph does not require a safety evaluation evaluation.
for a safety-related temporary modification if it can be shown that the specific change is not described in the safety analysis report.
No examples of failure to perform a safety analysis for a safety-related temporary modification were ;ttributable to this inadequate procedure.
Until the licensee revises his procedures to require written safety evaluations for all changes that are necessary to satisfy 10 CFR 50.59 this item (388-79-08-16) is unresolved.
h.
Field Change Design Control Measures Section 3, Paragraph 5.7.6 does not clearly specify the NPSQAM, requirements of Section 17.2.3 of the accepted QA program for field changes to be justified and subjected to design control measures No field comensurate with those applied to the original design.
changes which were inpsected had received less review than that required by the accepted Q/1 program. However, the level of review to detemine whether or not a field change meets all appropriate design inputs is not clearly required by the NPSQAM, Section 3.
Until the licensee revises his field change procedures to fulfill a?1 the requirements of his comitments, this unresolved item is designated (338/79-08-17).
488 264 Nbud bhuddd
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Procedures for Implementing Temporary Modifications i.
Paragraph 5.2.1 does not require the implemen-NPSQAM, Section it.,
tation of temporary modifications which were beyond the nkill of the craftsman to be performed in accordance with an approved No safety-related proce are z> reouired by Regulatory Guide 1.33.
reviewed were beyond the skill temporary modifications which were of the craftsman to implement.
Until the licensee revises bis procedures for temporary modifi-catious to incorporate appropriate criteria for requiring implementation in accordance with an approved procedure, this item is unresolved (388/79-08-18).
j.
Test Control of Design Change DC-78-01 test procedure for design change DC-78-01 (Recirculation Spray The to Low Head Safety Injection System Cross Connect) did not establish tests to confirm these design inputs:
Recirculation Spray Pmops are supposed to be capable of supplying a minimum flow simultaneously to the Recirculation Spray
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System and to the Low Head Safety Injection System via the Cress ConSect.
The Low Head Safety Injection Pugs are supposed to supply a to the Low Head Safety Injection System inot to
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flow minimum be degraded by leakage through the cross connect to the Recir-culation Spray System).
Until the U.S. Nuclear Regulstory Commission reviews the adequacy of this test procedure, this item is unresolved (338 /79-08-19).
9.
Records References:
a)
NPSQAM, 6 ion 6, Document Control, Revision 7,
..
dated 4/78 b)
NPSQAM, Section 17, Quality Assurance Records, Revision 3, dated 3/78 c)
ADM-39.0, Station Drawing Revision Distribution, dated 4/77 d)
ADM-43.0, Records Management, dated 9/77 e)
P0P-716, Quality Assurance Records Turnover, Revision 1, dated 4/78
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POP-717, Document Control, Revision 1, dated 4/78 g)
Memorandum, Turnover of Construction Records to Operations, dated 12/76 h)
Memorandum, Turnover of Construction Records to Operations, dated 1/77 i)
Memorandum, Documentation-Turnover of Construction Recorde to Operations, dated 3/77 a.
Inspection Items The inspector reviewed the license 2's program for control, storage, tr ' ~
'.o n and retrieval of records and documents pertaining to
,-related systems to ver.fy that it was in conformance with
_sunical Specifications and yA program requirements. By selecting a representative sample of documents and drawings (listed below)
the inspector reviewed the implementation of these controls at the locations given. Documents selected and the location (s) where each was reviewed are listed below.
Document Record Instrument Control Engineering Maintenance Description File Shop Room Libra ry Shop / Area Print FM-35A X
X X
X Prin: FE-3, Sh. 1 X
X X
X Print FE-4AT X
X X
X Print FE-9GR X
X X
X Print FA-10A X
X X
X Print FA-1E X
X X
X Print FS-508C X
X X
X Flant Manual X
X X
RCP Tech Manual X
X X
Rod Drive Tech Manual X X
X X
X Procedure 1-PT-11 X
X Procedure 1-PT-30.2.1 X X
Procedure 1-PT-59.3 X
X X
Cycles Log 1-1.0G-13 Personnel Training Records X
The.nspector also reviewed the licensee's operations and maintenance recordkeeping systems to ar.sure that the informatio2 documented was suf ficient to permit review by licensee personnel to detect long-term equipmer.t tegradation or adverse trends.
The transfer of this inf orsetten to other organizationc for evaluation was also reviewed.
488 266 h
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-19-The licensee had not performed any tests / experiments since this area was last reviewed by the NRC.
The records required by 10 CFR 50.59(b) for items it this area were not, therefore, reviewed.
As a result of the above reviews, the inspector identified three items of noncompliance (Paragraphs 9.b, 9.c and 9.d) and one unresolved item (Paragraph 9.f).
In conjunction with the inspection of the Quality Assurance Program for North Anna Unit 2 (Report 50-339/79-11), the inspector also reviewed the records being turned over to the licensee by the This review resulted in one item of nonecmpliance constructor.
(Paragraph 9.e) and one unresolved item (Paragraph 9.g).
b.
Failure to Review Required Procedures-SNSOC In reviewing reference d), the inspector noted that an Attachment B The attachment was referenced but not included with the procedure.
located in the Records File room. The inspector found that was this attachment listed the required records and the record retention times.
The inspector also was infomed that the SNSOC did not review this attachment when changes were made.
Technical specification 6.8.2 requires that the SNSOC review all applicable procedures listed in Appendix A to Regulatory Guide 1.33 of November 1972. Item A.8 of that Appendix lists Record Retention procedures as one of the required items.
During subsequent investigation, the inspector found that the SNSOC was not required to review several other procedures listed in The list of Administrative Appendix A to ReFalatory Guide 1.33.
Procedures states that only those with an asterisk require SNSOC In addition, when the inspector requested evidence that review.
the procedures (listed below) in question had been reviewed, the licensee did not produce any. The procedures and the reference to appropriate Appendix A areas of Regulatory Guide 1.33 are given below:
ADM-8.0, Fire Prevention (C.17 and/or F.23)
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ADM-19.0, Adherence to Health Physics Radiation Protection
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Manual (G.5)
ADM-25.0, Operation of the Station During Hazardous Conditions
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(Section F, Various)
ADM-29.0 through 29.15, Various Procedures Covering conduct of
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Operations (Sections A, B and C)
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ADM-34.0, Administrative Controls for Fuel Handling (B.10
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and/or A.2)
ADM-43.0, Records Management (A.8)
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As part of the inspection of activities documented in Paragraph 10.b of this report, it was also found that the procedures for implementing the Planned Maintenance System-Electrical (Section I) were not approved by the SNSOC.
failu ;s to review required procedures, collectively, These constitute an item of noncompliance (338/79-08-20).
Failure to Comple.e Required Retraining c.
The training records for two station employees were selected to verify that they were correctly filed.
While examining these records, the inspector noted that several areas of training had not been completed on the records.
The inspectr then reviewed training records for 63 operations employees and found that 28 had not received re-training on a calendar year basis as required by ADM-12.0.
10 CFR 50, Appendix B, Criterion II requires that personnel be trained to both achieve and maintain suitable proficiency.
Section 12.2.1 of ADM-12.0 requires that all regular employees re-training /re-certification at least once per calendar receiveThirteen (13) of the twenty-eight (28) employees not receiving such re-training were last trained / certified in 1976; the remaining year.
fif teen (15) had received training in 1977.
This item had been identified by Station QA (Audit N-77-68, dated the corrective action which the inspector found 9/77). However, was inappropriate as of February 1,1979, had been closed by Station The closing of audit items without review of objective QA on 1/79.
evidence is cited as an example contributing to &n item of noncom-pliance documented in Paragraph 6.b of this report.
The failure to perform the required training, twenty-eight examples in the sample of sixty-three persons selected, constitutes an item of ocncompliance (338/79-08-21).
Failure to Review Required Procedures-Station QC Engineer d.
In reviewing references c) and d) and ADM-12.0 referenced in these documents had Paragraph 9.c above, the ins ector noted thatging r or any design not been reviewed by t.he 488 263 d, ! Mgth
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The Station QC member Enginee. stated that he " believed that he might have reviewed" the procedures, but no objective evidence of such a review could be produced.
Reference c) implements aspects of Criterion V of the accepted QA reference d) implements aspects of Criterion VI; and, ADM-program; 12.0 implements aspects of Criterion II.
10 CFR 50, Appendix B, Criterion I requires that the quality assurance function of anuring that an appropriate quality assurance program is established and effectively executed be prformed by the quality assurance organization. This requirement could be satisfied by the Station Resident Quality Control Engineer since he is charged with " procedure reviews" as part of hi:. described duties in both the ac_apted QA program (Section 17.2.1.2.3) rad his NPSQAM (Section 1, Paragraph 4.3.4(d)).
This failure to review procedures to assure that the accepted QA p;ogram is effectively implemented and executed, four (4) examples, constitutes an itera of noncompliance (338/79-08-22).
The Star. ion Resident QC Engineer did perform a review of the listed (ADM-37.0, Control of Work and Special procedures and two others Processes, AEU-45.0, Housekeeping) which implemented aspects of the This action was documented in a memorandum accepted QA program.
frcm the Resident QC Engineer to the Station Manager dated February 1, 1979. This action was verified by the inspector and is suitable for completion of imediate corrective action for the identified item of noncompliance. Therefore, only the action taken or scheduled for preventing recurrence of this item needs to be addressed in response to this item.
Failure to Establish Rr:ceipt Controls-Construction Documents e.
10 CFR 50, Appendix B, Criterion VI requires that controls for issuance or documents be established.
The licensee's accepted Quality Assurance Program, Section 17.2.17, states that the controls of ANSI N45.2.9-1974 will be used to meet this require-ANSI N45.2.9-1974, Paragraph 4.3 requires that a records ment.
checklist be used to determine that required records are received /
issued.
The inspector observed the activitiet involving the receipt of records from the North Anna Unit ' and 2 construction contractor.
The inspector asked one of the '
noicians performing the receipt of records (over 260,000 had.iready been processed) whether any methods existed to verify that a comnlete record was received. The
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-22-technician stated, and subsequent review of the controlling procedures verified, that no methods currently existed to allow the licensee to detect records that were missing from a transmitted record package.
The individual packages are verified, but not their contents.
This failure to establish required verification controls for issuance / receipt of documents is an item of noncompliance (338/79-08-23).
item had been identified by Station QA (Audit N-78-13) on This February 3, 1978 and was subsequently closed on June 2, 1978.
1979 and had Since this item var unacceptable as of February 1, been closed while in this status by Station QA, this is a contributing example to an item of noncompliance listed in Paragraph 6.b of this report for closure of audit items without the correction of the identified problems and/or without reviev of objective evidence of satisfactory completion.
f.
Documentation cf Trend Review Practices As indicated in Paragraph 9.a, the inspector reviewed recordkeeping practices for operations and maintenance to assure that trends could be detected.
The current system provides for a computer When equipment printout of all completed maintenance activities.
fails, the responsible supervisor is requested to identify the cause of d-failure. These data are reviewed by the Resident QC the Supervisor of Quality Assurance-Engineer and lorwarded to Operations and Maintenance who then informs personnel involved in selection as needed.
As described, and based on the vendor objective evidence available for review, the above processes would appear to meet the requirements of the accepted QA program's comit-All of the elements from ments to follow ANSI N18.7 and N45.2.13.
N18.7 (Sections 4.1 and 5.1.6) and N45.2.13 (Section 7.6) were covered by the oral trend analysis activities. However, none of the reports or other actions is required by any written procedure or instruction.
Until the licensee documents trend analysis activities which will the accepted QA program's comitment to meet the comply with requirements of ANSI N18.7 and N45.2.13, this is an unresolved item (338/79-08-24).
pefinitionof"ProjectCompletion" g.
Sedton 17.2.17 of the licensee's accepted QA program states that the controls of ANSI N45.2.9 will be met. Section 4.2 of ANSI N45.2.9 requires that an agreement for the turnover of documents from 488
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-23-construction to o)eration be available. As reviewed, references e), f), g), b) and i) would, collectively, constitute the required agreement with one exception--no time for completion of the turnover is defined.
These documents and others related to the activity refer to completion of turnover based on " project completion" or some period following " project completion". Since this term is not defined and no concensus on the definition of this phrase was available from the licensee, the required turnover agreement has not been concluded.
However, since cl1 persons agreed that " project completion" had not been reached for many of the records related to Unit 1, additional
- mt:me was available before this lack of definition produced a concern wi'.h respect to ef fective regulation of the activity.
Until the licensee defines when records will be turned over from construction to ope rations, this is an unrcsolved item (338/79-08-25).
This item had been identified by Station QA (Audit N-78-13) on February 3, 1978 and was subsequently closed on June 2, 1978.
Since this item was unacceptable as of February 1, 1979, and had been closed while in this status by Station QA, this is a contri-boting example to an item of noncompliance listed in Paragraph 6.b of this report for closure of audit items without the correction of the identified problems and/or without review of objective evidence of satisf actory completion.
The closure of this item was done without the benefit of the two additional procedures (references e)
and f)) which allowed the inspector to say that the item was not, at this time and because of the additional material furnished by these two procedures, an item of noncompliance.
Although the procedures were issued April 1978 and the item was not closed until June 1978, the auditor stated, when questioned by the inspector, that he had not reviewed these two documents when he closed the item.
h.
Implementation c,f ANSI N45.2.9-1974 An open item with respect to the implementation of ANSI N45.2.9-1974 has previously been identified on Unit 1 (338/77-57-04). In response to this
'em, the licensee issued a letter (VEPC0 to J. P. O'Reilly, dated May 5, 1979, serial number 260) requesting an extension until July 1978 for implementation of all the required controls. This area was inspected and the comitment date was discussed with the Station Manager.
Although only the foundation of the record's storage facility had been completed, the July 1979 date for completion was reaf firmed. The implementation of the remaining controls of ANSI N43.2.9-1974 will be addressed in an additional letter if the July 1979 date can not be met according to the Station Manager.
rf f
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_ _. _
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-24-The inspector had no further questions at this time.
10.
Maintenance References:
a)
ADMIN 1.0, Station Orgenization and Responsibility, dated 4/78 b)
ADMIN 210, Station Nuclear Safety and Operating Comittee, dated 8/77 c)
ADMIN 10.0, Administrative Control of Protection Instrument Channels, dated 11/78 d)
NPSQAM, Section 1 through 18, dated 11/78 e)
North Anna Power Station Planned Maintenance System Electrical f)
Administration North Anna Power Station Mechanical Maintenance, Preventive Maintenance Program a.
Inspection Items The inspector reviewed the references listed above with respect to the licensee's accepted Quality Assurance Program as comitted to by that program.
The inspector reviewed 30 individual Maintenance Requests and 13 Periodic Tests that were completed during 1978. One item of non-compliance and one example contributing to an iter: of noncompliance are documented in Paragraphs 10.b and 10.c below. Two unresolved items were also found as set forth in Paragraphs 10.d through 10.e below.
b.
Maintenance Procedures The inspector noted that the Electricel Maintenance System contained procedures for maintenance on safety-related equipment which had not been reviewed by the SNSOC. Technical Specification 6.8.1.a recommended requires written procedures for applicable procedures in Appendix A of Regulatory Guide 1.33, November 1972.
6.8.2 requires that each procedure and changes thereto be reviewed by the SNSOC and approved by the Station Manager.
This example of failure to have approved procedures is combined with a similar failure documented in Paragraph 9.b above to collectively constitute an item of noncompliance (338/79-08-20).
t
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.25-c.
Drawing Control The inspettor noted that approximat.ely 25 percent of the Station Drawing in the Electrical Sbop had not been stamped to indicate they were controlled.
The inspect.or listed below which were not stamped-selected three drawings as 1175-ESK-IT, Revision 4
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1175-ESK-4JE, Revision 5
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1175-BSK-5J, Revision 10
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The listed drawings were checked at Station Records and found that two of the three drawings on file were of an earlier revision than the drawings in the Electric Shop. The accepted Quality Assurance Program requires the Station Records Department to maintain a record of drawings which list the current revision date.
Section 6,
" Document Control", of the NPSQAM list and defines Station Drawings as documents that require strict administrative control.
This failure to control drawings collectively constitutes with para-graphs 7.c, 8.e, and B.i, an item of noncompliance (338/79-08-10)
with respect to 10 CFR 50 Appendix B, criterion V.
d.
Calibration Records The inspector identified during the inspection of the calibration program that the instrument shop had in their shop file several quality records that should be under the control of the station records department.
These records were previously designated as non-safety-related and were maintained as such.
In view of the fact that these instruments are used to verify limiting conditions for operation and that the calibration data is considered a record.
Section 17 of the accepted QA program requires the identification and retrievability of these records and further be afforded the protection against destruction.
Until such time as a review of the shop files is conducted to ensure all records affecting quality are placed under the required control, this item is unresolved (338/79-08-26).
Test and Measurement Equipment e.
In reviewing Section 12 of NPSQAM, it was noted that Paragraph 2.2 is in conflict with 2.1 in that 2.2 states in part, "seasuring test equipment does not include permanently installed operating equipment...".
2.1 is applicable for systems, structures and components icvolved in limiting conditions for operation.
Neither the accepted QA program or the comitted ANSI 18.7-1972 standards exclude permanently installed operating equipment from test and measurement equipment.
epn
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-26-The inspector further noted that the hydrometer and thermometer used for the station battery maintenance is not included in the calibration program.
The above areas were discussed with two licensee and was explained in detail.
Until such time as Paragraph 2.2 is brought into alignment with the comitments and review is conducted to ensure that all instruments used to verify limiting conditions for operations and those examples mentioned in this paragraph and set forth in 5.3.6 of the comitted standard are in a calibration program, this item is unresolved (338/79-08-27).
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udigg;g 488 274
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