IR 05000338/1981007
| ML20030B650 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 08/06/1981 |
| From: | Belisle G, Bemis P, Fredrickson P, Skinner P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20030B623 | List: |
| References | |
| RTR-NUREG-0737, RTR-NUREG-737, TASK-2.B.4, TASK-TM 50-338-81-07, 50-338-81-7, 50-339-81-08, 50-339-81-8, NUDOCS 8108180398 | |
| Download: ML20030B650 (20) | |
Text
-
_.
-_--
-
-
-
_ - _
.
- '
'o UNITED STATES
- g
!*
NUCLEAR REGULATORY COMMISSION n
$.
O [E REGION 11 0,
101 MARIETTA ST., N.W.. sulTE 3100 g
j'
ATLANTA, GEORGI A 30303
'
+....
Report Nos. 50-338/81-07 and 50-339/81-03 Licensee:
Virginia Electric and Power Company
Richmond, VA 23261 Facility Name:
North Anna Docket Nos. 50-338 and 50-339 License Nos. NPF-4 and NPF-7 Inspection at North Anna Site near Mineral, Virginia and Company Offices in Richmond, Virginia
,
Inspectors:
7<
.I 6 -f - 8/
Date Signec G. A. Beli sleM ha-
-
,
(, - f - b' l
'
P.,
emby Date Signed
>
Y~t g2.-W b l!, $ /
_
._
P. E. Fredri Kson Date S'igned
/
.
.
P. H. Skinner Date Signed
_
Accompanying Personnel:
M. B. Shymlock (py 1,1981 only)
Approved by:
.
Nx._/l'
d'
N/
C. M. Upright,. SLFctiojr; Chief Ofte S(gned EngineeringIfnectitu( Bnanch Engineering and Technical' Inspection Division SUMMARY Inspection on April 27 - May 1,1981 Areas Inspected This routine, announced inspection involved 152 inspector-hours on site and at the Company Offices.
Tr.a insps; tion was conducted in the areas of licensee action on previous inspection findings; QA annual review; design change program;
procurement; surveillance testing ai.d calibration program; QA audits; maintenance
]
program; housekeeping; licens.ed training; noa-licensed training; procedures;
'
QA/QC administration and Three Mile Island (TMI) action plan implementation.
8108100398 B10905 PDR ADOCK 05000378 G
PDA
,. _, _ _ _ _ _ -~-___._,
_. _. _,. _.
.
.
.., _ _ _.
_. _ _
._. _ _
.
_
.
.
Results Of the 13 areas inspected, no violations or viations were identified 5 sevea areas; six violations ware found in five..eas (Failure to follow procedures, paragrcphs 7.b and 12.b; Failure to maintain records, paragraphs 9.a and 15.a; Failure to perform periodic QA procedure reviews, paragraph 5.a; Failure to perform required retraining, paragraph 12.a; Failure to document specific calibration frequency, paragraph 8; Failure to include consumables/expendables in the QA program, paragraph 7..).
Two deviations were found in one area (Failure to adequately train operating personnel, paragraph 15.b; Failure to perform required training, paragraph 15.c).
J
!
- -
.
_ - -
-
.-
.-
_
-
-
-
-
.-
- --
.',
-
.
,
.
l
,
REPORT DETAILS
!
1.
Per ons Contacted
Licensee Employees
"F. Cu', ling, Supervisor, Nuclear Training (Corp.)
J. Grandstaff, Stores Supervisor
- W. Harrell, Assistant Station Manager
'
- M. Harrison, Resident QC Engineer
- J. Harper, Superintendent-Maintenance
- /.. Hogg, Nuclear Training Supervisor
!
- K. Huffman, Clerk
- J. Martin, Manager, QA Operations
!
- F. Rentz, Resident QC Engineer (Surry)
l
- C. Swepe, Senior QC Inspector l
- B. Sylvia Manager, Nuclear Operations
- M. Tower, Staff Engineer i
)
Other licensee employees contacted included technicians, operators, mechanics, sect;'ity force members, and office personnel.
NRC Resident Inspector
'
- E. Webster
- Attended exit interview 2.
Exit Interview The inspection scope and findings were summarized on May 1,1981 with those persons indicated in paragraph I above.
The 1icensae was informed of the inspection findings as indicated in paragraph 17. The licensee acknowledged the inspection findings.
3.
Licensee Action on Previous Inspection Findings (92701)
The following abbreviations are defined and used throughot.t this report.
Accepted QA Program VEPC0 Topical Report Quality Assurance Program Operations Phase, VEP-1-3A, Amendment 3 dated 3/77 APM Administrative and Procedures Manual NPSQAM Nuclear Power Station Quality Assurance Manual PC/M Plant Change / Modification P0 Purchase Order PT Pariodic Test
'
_ _ _ _ _ _ _
_ _
...,, _ _ _. _.. _ _ _ -,.., _, _ ~ -,
-. _ -
_ _ _. _ _.
_.,. _,,
-
-.
__
_____
-
-
.
,
.
.
QA0MI Quality Assurance Operations and Maintenance Instruction RQCE Resident Quality Control Engineer SNSOC Station Nuclear Safety and Operating Committee STA Shift Tech'ical Advisor SyNSOC System Nuct'ar Safety and Operating Committee VQAM VEPCO Qualit Assurance Manual
(Closed) Unretnived Item (338/79-08-12):
Cc summable expendable control.
This item was unresolved pending a licensee review of the consummable/
expencable items which corld effect safety-related functions and the i
inclusion of those identified items into the QA program.
Although a shelf-life program has been initiated for items that could suffer storage l
deterioration, no consumable / expendable program has been initiated.
This item is closed for record purposes and has been esca?ated to a violation as discussed in paragraph 7.a.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
QA program Annual Review (35701)
References:
(a) VEP-1-3A, Amendment 3 dated 3/77 (b) NPSQAM (c) Technical Specifications The references listed, as well as the references listed throughout this report, were reviewed to verify they met the requirements of the accepted QA Program. The licensee has not made any changes to the accepted QA Program since tF: last date of irspection in this area (January 1979). The licensee is currently developing proposed Amendment 4 to the accepted QA Program.
The inspector interviewed licensee personnel who will have responsibility for implementing procedures when Amendment 4 is issued.
Based on this review, one violation and two f ospector followup items were identified and are discussed in parsgraphs 5.a. - 5.c.
a.
Failure to Review NPSQAM Procedures 10 CFR 50, Appendix B Criterion V and the accepted QA Program Section 17.2.5 collectively require that activities affecting quality shall be prescribed by instructions, procedures and drawings. The accepted QA Program, Table 17.2.0, endorses ANSI N18.7-1972. Section 5.4 of this Standard requires periodic review of procedures and that the frequency of these reviews shall ba specified.
l
._ -.
. -_. _.
_
.
-
,
,
.
.
,
L
3 l
NPSQAM Procedures 1, 8, 9 and 10 were last reviewed 11/76, 11/76, 9/77 and 3/78, respective 13 They have not been reviewed since nor has the
.
frequency of review for these procedures been specified.
1.*.fs failure to periodically review NPSQAM procedures and to specify the frequency of reviews is a violation (338/81-07-02, 339/81-08-02).
b.
Organizational Inconsistencies
l Heferences (a), (b) and (c) give organizational charts for plant and
.
corporate personnel. Due to organizational changes these charts vary
'
in personnel and position titles.
Work is currently in progress for issuing amendment 4 to reference (a) and a review and updating o/
reference (b) is in progress.
Until the organi:ational charts for references (a), (b) snd (c) are compatible, these inconsistencies are identified as an inspector followup item (338/81-07-15, 339/81-08-15).
j c.
Inconsistent Regulatory Guide Commitments Technical Specification 6.8.1 and 6.8.1.a require that written proce-dures shall be establi;ied.
These applicable procedures are recom-
!
mended in Appendix A of Regulatory Guide 1.33, Revision 2 February 1978. The accepted QA Program, Table 17.2.0 endorses Regulatory Guide 1.33-1972.
Until this inconsistency is resolved, this item is identified as an inspector followup item (338/81-07-16, 339/81-08-16).
6.
Design Changes and Modification P ogram (37702)
!
References:
(a) VEP-1-3A, Section 17.2.3, Design Control (b) NPSQAM, Section 3, Des'gn Control, Revision 12 dated 9/80 (c) APM, Section 3.16, Design Change Package, Revision 0 dated 2/81
'
(d) APM, ;;ction 3.17, Calculations, Revision a dated 2/81 The references listed were reviewed to verify they met the requirements of the accepted QA Program and ANSI N45.2.11-1974 as committed to by that
,
Program. The inspector verified the following aspects of the design control
'
program:
Procedures have been Established for control of PC/M requests
'
-
Procedures and responsibilities for PC/Ms have been established
-
Administrative controls for design document control have been
-
established Administrative controls assure that PC/Ms are incorporated into plant
-
procedures, operator training and the updating of drawings i
>
.-
m m
.
.
.
m-m-m
.
..
-
...
m
.
.
-
.
-
..
.
m.
-
_ _ _ _ _ _ _ _ _ _ _ _
.
-
.
,
.
Controls have been developed that define channels of communication
-
between design and responsible organizations Administrative controls require PC/M documentation and records Le
-
collected and stored Controls require implementation of PC/Ms be in accordance wi'.h approved
-
procedures
-
Controls require post modification testing be performed per approved test procedures and the results evaluated Responsibility has been assigned fcr identifying post modification
-
. testing requirements Responsibility and method for reporting design changes to the NRC in
-
accordance with 10 CFR 50.59 has been identi,fied Based on this review, no violations or deviations were identified.
7.
Procurement (38701)
References (a) NPSQAM, Section 4,
Procurement Document Control, Revision 4 dated 3/80 (b) NPSQAM, Section 7, Control of Purchased Mat-1, Equipment and Services, Revision 5 dated 6/80 (c) NPSQAM, Section 2, Quality Assurance Program, Revision 5 dated 11/78 (d) VQAM 7.2, Vendor Surveillance Program, Revision 1 dated 3/73 (e) VQAM 7.10, Selection of Procurement Sources, Revision 1
,
dated 8/79 (f) ADM 46.0, Material and Stock Raquisition Processing, dated 3/81 (g) Vendor List Assignment, Revisian 0 dated 3/81 The inspector reviewed the referenced administrative controls to assure that they provided the following for the purchase of quality identified items:
specific identification of the item and required tests or special instruc-tions; required technical information; access to the supplier's plant or records; QA program and documentation requirements; and applicable provi-sions to comply with 10 CFR 21. Control of vendors was reviewed to assure that required audits and other qualification practices were documented and completed The inspector also verified that responsibilities had been assigned for procurement document initistion, review and approval, changes to these documents, and verification of quality requirements relative to procurement docusants.
The inspector selected items which had been purchased and received on site.
For each item the inspector reviewed the purchase order to insure that the procurement documents had been prepared as
.
.-.
-
... - -
-- -
_-
. -.. --
.
-
,
.
- i
requ aed, that the purchases were from qualified vendors, and that required documentation and QA requirements had beer. included.
The items selected were:
l P. O. Number Iterr.
-
38718 Valves
'
26368 0' Rings 41368 Expansion Joints 53694 Motors 80880 Breakers 42437 Check Valves 37485 Instruments i
41159 Pumps and Motors
!
Based on this review, one violation, one item contributing to a violation J
and two inspector followup items were ichntified and are discussed in paragraphs 7.a - 7.d.
a.
Failure to Include Consummables/Expendables in the QA Program i
The inspector determined that the item discussed in paragraph 3 had i
been inadequately resolved by the licensee.
This item specifically
'
addressed the need for a review of those consummable/ expendable items
'
to be considered as components of safety-related systems. and the inclusion of these items into the QA Program.
No documented program for the identification, purchasing, receipt, handling and storage of
)
consummable/ expendable items has been established.
10 CFR 50, Appen-dix B Criterion II and Secti.on 17.2.2 of the accepted QA Program i
requires the identification of the structures, systems, and components to be covered by the quality assurance program. This failure to review and include those identified consummable/ expendable items into the QA
>
i Program is' a violation (338/81-07-05, 339/81-08-05).
b.
Failure to Follow Procedure - Purchase Requisitians During the review of purchase orders at the site warehouse, the inspector noted that two P0s, 42437 and 41159, did not contain the i
procurement. QA category. Reference (a) requires that the requisitioner record the QA category on the purchase requisition. As these P0s were written against a design change (80-S48), the inspectur completed the
,
review cf this item at the company office, to determine whether the l
purchase requisition contained the QA category. This review verified that the origins. purchase reouisitions were missing the QA category.
l This failure ;o follow procedure is combined with an its discussed in i
paragraph 12.b. to collectively constitute a violation (338/81-07-06,
339/81-08-06).
-,, __ _ _.,. _ -... - _ _. _..
.. _ _, _ _. _ _ _ _ _ _ -.., _ _ _.
,__ _,
._ _
..
_
_. _.
~
.
.
,
.
c.
Changes to Purchate Orders ANSI N45.2, committed to by the licensee, requires that changes to P0s i
be reviewed to the equivalant level as the original P0. Reference (a),
paragraph 5.3, requires a QA review of changes to Category I P0s. The inspector noted that two changes to P0 37485 (Category I) were reviewed oy the technical staff and fcrurded directly to the Purchasing Depart-ment.
This problem was also identified in the annual Purchasing Department Audit, Memo dated January 6,1981.
The corrective action of this audit relative to tne lack of PO change review will be rein-spected during a subsequent inspection and is identified as an inspector followup item (338/81-07-11, 339/81-08-11).
d.
QA/QC Review of Purchase Requisitions l
The review of reference (a) identified a discrepancy in that paragraph 5.2.2 does not require routing of Category II or III purchase requisi-tions through QA/QC, yet paragraph 5.5.2.e. requires QA/QC to review all QA category renuisitions.
This item was also identified in the annual Purchasing Audit, r.mo dated January 6,1981.
A revision of reference (a) is in progress, which'will include the resolution of this discrepancy. At present all QA category purchase requisitions are reviewed by QA/QC. The resolution of this inconsistency will be rein-spected during a.3ubsequent inspection and is identified as an inspector followuo item (338/81-07-12, 339/81-08-12).
8.
Surveillance Testing and Calibration Control Program (61725)
References:
(a) NPSQAM, Section 11, Test Control, Revision 11 dated 8/79 (b) NPSQAM, Section 12, Control of Measuring and Test Equipment, Revision 8 dated 9/80 (c) ADM 10.0, Administrative Control of Protection Instru-ment Channels, dated 1/81 (d) ADM 11.4, IWP/IWV Evaluation, dated 1/81 The referenced documents were reviewed with respect to the licensee's accepted Quality Assurance Program. The review was concerned with surveil-lance testing and calibration of in plant safety-related instruments not specifically controlled by Technical Scecifications.
The licensee's practices were reviewed to verify the following:
A master schedule for surveillarce testing / calibrations / inservice
-
inspections was developed which included frequency, responsibility and status for each test / calibration / inspection Responsibilities are assigned for maintaining the master surveillance
-
schedule and for assuring that all scheduled tests /calib>ations/
inspections are performed
-
_ - _ _ _ - _
_ _ _ _ _ _ _ _
.
-
Formal requirements, methods and responsibilities are established and defined for conduct, review and evaluation of tests / calibrations /
inspections
-
A master schedule for component calibrations had been established that included frequency, responsibility and status of safety-related con. pone n ts
-
Responsibilities are assigned to assure that the schedule is maintained and schedules are satisfied
-
Formal requirements have been established for performing calibrations in accordance with approved procedures Based on this review, one violation was identified. Reference (c) identi-fies the plant safety-related instruments, all of which have periodic tests which delineate the calibration frequency and method of calibration. One of the periodic tests that the insptetor reviewed was PT 1-PT-32.7.1 which provides the controls of the calibration schedule for safety-related instruments which are not calibrated pursuant to the Technical Specifica-tions.
This test prescribes a calibration frequency of two years, but allows the Instrument Supervisor to determine the actual calibration frequency, even to the point of not peforming the calibration at all.
Several instrument calibrations listed in this periodic test had not been performed since 1975; specifically, thermostats TS-HV-600B, 60CC, 601A, 6018, 602C, 603A, 603B and 603C.
Technical Specification 6.8.1 requires that applicable procedures identified in Appendix A of Regulatory Guide 1.33, Revision 2 dated February 1978, be implemented.
Section 8 cf this Guide requires that procedures be pravided to ensure that tools, gauges, instruments, controls and other measuring and testing devices are properly calibrated at specified periods to maintain accuracy.
The failure to maintain a specified calibration period for instrument calibrations is a violation (338/81-07-04, 339/81-08-04).
9.
Audits and Audit Implementation (40702, 40704)
References:
(a) Technical Specifications, Section 6 (b) VEP-1-3A, Section 17.2.18, Audits (c) VEP-1-3A, Section 17.2.16, Corrective Action (d) NPSQAM, Section 18, Audits, Revision 5 dated 3/81 (e) NPSQAM, Section 16, Corrective Action, Revision 6 dated 11/77 (f) QAOMI 3.1, Audits, Revision 2 dated 11/78 (g)
SyNSOC Procedure, SYP-3, Audf ts, Revision 3 dated 4/80 (h)
SyNSOC, By-Laws The references were reviewed to verify that they met the requirements of the accepted QA Program and ANSI N45.2.12 (Draft 3, Revision 4 - 1974) as committed to by that Program. The inspector verified the following aspects of the audit and audit implementation program:
_ _ _..
_ -.
_-
-
-..
.. _ _ - - - -
_ - _ -
.
.
-
.
i
,
-
The scope of the audit program has been defined and is consistent with
,
the Technical Specifications J
-
Responsibilities have been assigned in writing for the overall manage-ment of the audit program
,
Methods have been defined for taking corrective action when deficien-
-
cies are identified during audits
!
The audited organization is required to respond in writing to audit
-
I findings
>
,
Distribution requirements for audit reports and corrective action
!
-
'
cesponses have been defined Checklists are required to be used in the performance of audits
-
-
Audits are conducted by trained personnel not having direct responsi-
'
bility in the area being audited
'
-
The frequancy of audits is in conformance with Technical Specification requirements.
To verify the implementation of these aspects, the inspector reviewed the results of the following 16 audits.
Audit Audit Date
'
N-80-14 09/23/80 i
N-80-11
.
09/09/80
,
N-79-59 02/12/80
?
N-78-75A 11/20/78
N-79-12 04/19/79 N-79-45 10/08/79 N-79-47 08/02/79
'
i N-80-03 04/23/80 N-80-08 06/21/80
i N-79-47 08/02/79 N-79-49 09/10/79 N-79-52 10/29/79 N-80-13 10/16/80
.
N-80-02 03/25/80 N-80-15 10/28/80
'
N-80-11 09/12/80 Eased on this review, one item contributing to a violation and two inspector
-
followup items were identified and are discussed in paragraph 9.a. - 9.c.
-
-
- -
- -
-
-
- -
.
- - -
-
.
-
.
.
.
a.
Failure to Maintain Written Replies to Audit Findings Reference (d), Section 3, refers to ANSI N45.2.12-1977. Reference (b),
Table 17.2.0, refers to WASH 1309 which incorporates ANSI N45.12 (Draf t 3, Revision 4-1974).
ection 5.2 of both of these Standards requires audit records to be gt..lerated and retained for all audits.
Records shall include, among other items, written repiies to audits.
During the review of audits N-79-52 and N su-02, the inspector identified that all written rep? 4es were not incloded in the audit records files maintained by the QA staf.f.
Since tnese records were incomplete, the permaner.t record storage facility (vault) was searched to verify if the written replies were available.
These records of written replies were not available in the vault.
This failure to maintain records of audit findings is combined with an item discussed in paragraph 15.a. to c61ectively constitute a violation (336/81-07-01,339/81-08-01).
b.
Accepted QA Program and NPSQAM Inconsistencies The accepted QA Program, Table 17.2.0 commits the licensee to WASH-1309, Guidance on Quality Assurance Requirements during the Construc-tion Phase of Nuclear Power Plants (Green Book), dated 5/74. This book contains ANSI N45.2.12 (Draf t 3 Revision 4-1974), Requirements for Auditing of Quality Assurance /rograms of Nuclear Power Plants.
Reference (d), Section 3.0, Ref erences,11sts ANSI N45.2.12-1977 as the basis for reference (d). Amendment 4 to reference (b) is cur,ently in draft form and Table 17.2.0 has been modified to include ANSI N45.2.12-1977 as the accepted standard. Until Amendment 4 of reference (d) is issued and inspected, the inconsistency between references (b) and (d)
is identified as an inspector followup item (338/81-07-14, 339/81-08-14).
c.
Correction of Weaknesses in Escalation Program 10 CFR 50, Appendix B Criterion I requires in part that persons and organizations performing quality functions shall have sufficient authority and organizational freedom to identify quality problems; to initiate, recommend or provide solutions; and to verify implementation of solutions.
Such persons and organizations performing quality assurance functions shall report to a management level such that this required authority and organizational freedom is provided.
10 CFR 50, Appendix B Criterion XVI requires that measures shall be established to assure that ccnditions adverse to quality are promptly identified and corrected.
Items identified in audits N-78-75, N-79-12 and N-79-45 were escalated to the company office by onsite personnel 12/19/80, 11/17/80 and 11/17/80, respectively. The audits were originally conducted 11/20/78, 4/19/79 and 10/3/79 respectively. Discussions with company personnel
-
-
-
_ _..
.. =
- _ _ _ _ = _ _ - -
_.-___.
-
.
--
..
_..
l.
'
-
,
t
'
.
l
!
!
i revealed that some preliminary progress had been made in seeking solutions to these findings but the final solutions were still pending.
<
This lack of active participation by management in providing solutions to quality problems and lack of prompt correction to items adverse to cuality is identified as an inspector followup item (338/81-07-17, 339/81-08-17). No violation is issued for failure to meet the require-ments of 10 CFR 50, Appendix B Criterion I and XVI since this prubleria had been previously identified in licensee audit. N-81-03. The NRC will l
closely monitor the ccrrective action taker with respect to the items
'
identified in audit N-81-03.
!
10.
Maintenance Program (62702)
,
References:
(a) NPSQAM, Section 16, Corrective Action, Revision 12 dated 4/80
(b) NPSQAM, Section 10, Inspections, Revision 3 dated 3/78
,
l (c) NPSQAM, Section 14, Inspection, Test and Operating
]
Status, Revision 6 dated 4/80 The referenced documents were reviewed with respect to _ the licensee's accepted Quality Assurance Program. The review was concerned with preven-tive and corrective maintenance programs, equipment control and cleanliness.
The licensee's practices were reviewed to assure thu a praventive mainte-nancc (PM) program had been established and that a PM schedule had been developed.
The licensee's corrective maintenance practices were reviewed to verify i
that:
Written procedures had been established for initiation of routine and
-
emergency maintenance
.
-
Criteria and responsibilities had been established for approval of maintenance requests, for designating activities as safety /non-safety-
'
related, for designating inspection hold pointa, for performing required inspections, and for determining required functional testing to be performed following completion of ths activities Administrative controls require approval of maintenance requests;
-
identification of personnel performing and inspecting the work; identification of the malfunction or failure which necessitated the
,
i work; identification of the maintenance performed including any post-
'
maintenance testing; that materials used are identified along with any measuring or test instrumentation; and that records verifying the above
'
are prepared, assembled and transferred to records storage Responsibilities had been assigned for the review of the records
-
'
including an assessment to identify repetitive failures or marginal
'
performance and for transfer of these records as required
t
--+. a
.
.. -.
.
.
-
-
.--mm
.A-m---.
m
-
-
.
.. - -. - - -
u
-.
-
-
.
.
. -
..
.
.m m..
.
.-
.-
_,
.-.. ___ _
.
.
. -
.-_
__
.---
-
.
,
.
.
.
!
i i
Work control procedures adequately covered special controls necessary
-
for activities such as welding, cutting or use of ignition sources Work control procedures require a firewatch with the capability of
-
communication with the control room if welding, cutting, or use of ignition sources are to be performed in the proximity of flarmble
,
material, cable trays or process equipnient.
Based on this review. one inspector followup item was identified.
ANSI
N18.7-1972, committed to by the licensee, requires in paragraph 5.1.6.1 that
.
causes of equipment failures be evaluated and that reviews shall be
!
conducted to determine whether a replacement component of the samo type can be expected to perform it's functicn reliably; i.e., equipment malfunction trend analysis. The licensee has no such pre. gram, but has identified this
!
problem in QA Audit N-81-03, dated 4/81.
This lack of maintenant trend i
analysis will be reviewed during a subsequent inspection and is identified I
as an inspector followup item (338/81-07-13, 339/81-08-13).
i 11.
Housekeeping (54701)
l References:
(a) ANSI N18.7-1976, Administrative Controls and Quality i
Assurance for the Operational Phase of Nuclear Power Plants Section 5.2.10 (b) AN3I N45.2.3-1976, Housekeeping During the Construction Phase of Nuclear Power Plants s
(c) Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation)
'
(d) ADP 45.0, Housekeeping, dated 5/80
!
General plant nousekeeping and cleanliness was observed by the inspector on i
tours of the facilities and discussed with individual superintendents, supervisors, technicians and craftsmen. A detailed program evaluation will i
be conducted during a subsecuent inspection.
!
Based on these observations and discussions, no violat'.ons or deviations were identified.
-
12.
Training (41700)
'
References:
(a) ANSI N18.1, Selection and Training of Nuclear Power Plant Personnel-1971 (b) NPSQAM, Section 2, Quality Assurance Program, Revision 6
'
dated 6/79 (c) ADM-12.0, Station Training, dated 4/80
<
(d) QA Operations and Maintenance Instruction Manual,
'
Section 7.1, Training Instruction, Revisio, ' dated 4/81
(e) Operational Quality Control Loca Instruction 10.12, Certification Program for Inspectors and Auditors, dated 4/81 i
i
<
!
..
-.._
.
.
-
-
.
.
__
.
-
_ - _ _
-
-
.
,
.
.
(f) Operational Quality Control Local Instruction 10.13, Training Program for Inspectors and Auditors, dated 4/81 (g) VEPC0 General Employee Training and Retraining Manual, Chapter 5 (h) VEPC0 Development Policy Manual The inspector reviewed the general emp'oyee training program for facility staff personnel.
This program was reviewed to verify that:
the program complies with requirements and commitments contained in references (a) and (b); the program covers training in the areas of administrative controls and procedures, radiological health and safety, industrial safety, security j
procedures, emergency plan and quality assurance training, fire fighting l
training and pre-natal radiation exposure training; and audits conducted by the licensee in the areas of general employee training. This included the
review of approximately 35 training records.
Based on this review, ona violation, one item contributing to a violation and one inspector followup item were identified and are discussed in paragraphs 12.s. - 12.c.
a Failure ia Provide Retraining for Off-site Personnel The accepted QA Program states that VEPC0 conforms to the requirements
.
of reference (a).
Paragraph 5.4. of reference (a) identifies the I
General Employee Training to be provided to regularly employed, temporary and service personnel and paragraph 5.1 requires that a
'
continuing program shall be used after plant startup for retraining
necessary to ensure that personnel remain proficient.
Reference (c)
implements the training program for North Anna.
Paragraph 12.2.2 of reference (c) identifies the training and retraining requirements for off-site personnel and includes a requirement to retrain and recertify
off-site personnel every 12 months.
Off-site personnel who fail to i
cttend i etraining or fail to achieve a passing grade on the recerti-fication examination have an additional 90 days to successfully complete retraining. Section 3.2.1 of reference (g) requires a memo to
.
be sent from the Training Department to the Station Manager when i
out-of-date retraining occurs. No guidance is provided to specify the action the Station Manager takes but discussions with Training Department personnel indicates that the security badge of the indi-vidual involved is removed from the plant access listing. Contrary to the above, a review of records available and discussions with Training Department personnel indicated there is no method being used to
determine when retraining is required for off-site personnel. Of three of f-site personnel checked (two Stone and Webster, ene Westinghouse),
none had received the required retraining and no memorandum had been
sent to the Station Manager. This inspecticn finding initiated a memo from tne Training Department to the Station Manager identifying that out of date retraining for several personnel had occurred.
This failure to provide retraining to off-site personnel is a violation (338/81-07-03, 339/81-08-03).
-
..
.
.
.- -
.m.
.
_ _ - - - - -
- - - - - - -
-
. - -. _ - - - - - - - - _ - - - - - _ _ _
,
-
.
,
.
.
b.
Failure to Follow Procedure - Development Policy Manual Recuirements Paference (a) requires each of four people to sign the end of step and comprehensive examinations given to auxiliary operators. A review of 12 of the exams for various auxiliary operators indicated a "ack of all required signatures for two of these records. This failure to follow procedure is combined with the item detailed in paragraph 7.b. to cor.stitute a violation (338/81-07-06, 339/81-08-06).
c.
Performance of Required Indoctrination and Training for Quality Assurance Personnel Paragraph 5.2 of reference (b) identifies the indoctrination and training for quality assurance personnel. References (d) through (f)
implements these requirements for North Anna. The inspector reviewed references (d) through (f) and identified to the RQCE that the implemented program does not contain all items required by paragraph 5.2 of reference (b), such as the VEPCO QA Manual, Nuclear Power Station System Descriptions, Special Reports to NRC, SNSOC meeting minutes, ecc.
The inspector reviewed training records of five QA personnel. Three of these records indicated that the personnel had no
'
documentation that all training required by paragraph 5.2 of reference
(b) had been performed.
Discussions with the RQ;E indicates that paragraph 5.2 of reference (b) is in the process of being revised to
!
eliminate ambiguous training requirements.
Upon issuance of this j
revision the RQCE will insura all training required is conducted and documented. This item will be tracked as an inspector followup item (338/81-07-10, 339/81-08-10) until the revision is complete to reference (b), the training is conducted and a subsequent inspecticn reviews the training records.
13.
Requalification Training (41701)
References:
(a)
10 CFR 55, Appendix A, Requalification Programs for Licensed Operators of Production and Utilization Facilities (b) Technical Specifications (c)
Final Safcty Analysis Report, Section 13.2 (d) AP 12.0, Station Training, dated 4/80 (e) ANSI N18.1-1971, Selection and Training of Nuclear Power Plant Persoanel The inspector reviewed the requalification program to determine conformance to raferences (a) through (e) above. The training records of six licensed reactor operators and eight senior reactor operators were reviewed.
Based on this review, no violations or deviations were identifie. _ _
._
__
__
.
_
_
_
.
-
-
.
,
.
.
i
1 14.
Procedures (.42700)
References:
(a) Technical Specifications, Section 6.8 (b) NP3QAM Section 5, Instructions, Procedures and Crawings,
.
'
Revision 19 dated 9/80 (c) ADM-13.0, Review of Prccedures, dated 5/80 (d) ADM-13.1, Procedure for Proce:, sing i aw and Revised Preedures, datisd 3/81 (e) ADM-43.3, General' Document Control Procedure, dated 11/80 (f) Quality Asssance Audit N-80-16A, Statior ~rocedures, dated 1/19/81
.'
The inspector commenced a review of selected plant procedures in accordance
with the g tidance and requirements provided in references (a) through (e) to ascertain whether overall procedures are in accordance with regulatory
~
requirements. The following criteria were used during this review:
Required eview and approval of procedures and temporary changes had
-
been performed
'
-
Overall procedure content is consistent with reference (b)
-
Records of choges in procedures are being maintained Safety reviews pursuant to 10 CFR 50.59 were performej
-
The Training Department was appraised of changes to procedures
'
-
Administrative procedures were observed in the preparation and handling
-
of procedures
-
This procedure review was limited to a review of administrative require-ments.
Completion of this review will be performed on a subsequent i
inspection.
,
Based on this review, one insp ctor followup item was identified. Reference (c) requ1res that administrative procedures be reviewed by +he Station
.
Manager every two years.
The inspector reviewed the administrative pro:edures and found 50 of these procedures had not been reviewed as i
required. Discussions with the RQCE deter.nined that this area was identi-fied by ref=rence (f).
The response to this audit item will be inspected during a subsequent inspection and is identified as an inspector followup item (338/81-07-09, 339/81-08-09).
15. Three Hile Island Action Plan Implementation (92706)
References:
(a) NUREG 0737, Clarification of TMI Action Plan Rauire-ments, dated 11/80 (b) Letter, dated March 28, 1980, H. Denton to all q
licensees, Qu lification of Reactor Operators
-
-
-
--
- -
.
.
.
i The inspector reviewed the mitigating core damage program presented to VEPC0 personnel, and the prog.am designed and given to STAS.
Based on this review one item contributing to a violation and two deviations were identified and are discussed in paragraphs 15.a. - 15.c.
a.
Failure to Maintain Records - STA Personnel Qualifications Upon reviewing the training given to the STAS, the inspector found that there was little in the way of documentation of attendance, exains, or quizzes available at the site. After interviewing training ;9esonnel, STAS and the STA supervisor, it was apparent the training was given, but the documentation of the training given by tne VEPC0 site personnel in systems and transients was very sketchy in that only four attendance records could be found and only a few quizzes and exams could be located.
This tailure to maintain records it combined with another item discussed in paragraph 9.a. to collectively constitute a violatior.
(338/81-07-01,339/81-08-01). The training exams, and quizzes given by the Virginia Polytechnic Institute and State University professors were not documented on site. Until this documentation is brought or, site, this item will be carried by the resident inspector as a followup item in his reports 50-338/80-30 ano 50-339/80-36.
b.
Failure to Correctly Grade Examinations The inspector reviewed the mitigating core damage course given by a contractor to VEPC0 licensed personnel, the management of licensed pei sonnel and STAS as required by reference (a) and committed to by VEPC0 correspondence dated December 10, 1980. During this review the inspector determined that the training program met the requirements of reference (b) and that each individual who took the examination had a score above 80% as required by reference (b).
The inspector regraded five test papers and found that four made below 80%. VEPC0 training personnel regraded the same five exams and concluded that two people made below 80%; however, there were significant discrepancies in each paper graded, always in the lower grade direction.
This failure to adequately grade examinatiors and thus not meet the required grade level is a deviation (338/81-07-07, 339/81-08-07).
c.
Failure to Derform Required Training Reference (a), item II.B.4 requires the licensee to develop a training program in mitigating core damage by January 1,1981, and implement that program by April 1,1981 for managers and technicians in the health physics, chemistry, and instrumentation and control specialty groups, commensurate with their responsibilities.
The inspector determined that this program had neither been aeveloped nor imple-mcnted. Discussions with Training Deoartment personnel revealed that they were totally unaware of this recairement or VEPCO's commitment to this requirement. The failure to develop and implement this program is a deviation (338/81-07-0C, 339/81-08-08).
-.
--
.-.
..
-
--- -
-.
-
- - _ - -. - -
.
...
. ~.. -
. -_-.
. - -
. _.
-
.
- ,
-
>
.
,
.
!
!
'
a 16.
QA/0C Administration Program (35751)
,
References:
(a) VEP-1-3A, Amendment 3, dated 3/77
(b) NPSQAM, Section 2, Quality Control Program, Revision 0
-
dated 6/78
<
l (c) NPSQAM, Section 5,
Instructions, Procedures, and i
Drawings, Revision 19 dated 9/80 i
(d) NPSQAM, Section 16, Corrective Action, Revision 12 dated
4/80 The inspector reviewed the references listed to verify that the accepted QA f
Program documents clearly define those structures, systems, components and (
activities to which the QA Program applies.
The inspector. verified that i
procedur!s and responsibilities have been established for making changes to QA Progri.m documents; that administrative controls have been established for QA Program documents which assure review and approval prior to implementa-tion; that controls are provided for changes, revisions, distribution and
,
,
recall; that responsibilities have been established to assure overall review of the QA Program; and th'at methods exist to modify the QA Program to provide increased emphasis in identified problem areas.
,
Based on this review no violations or deviations were identified.
!
t i
,
i i
i
,_
- - -.
- -
. - - -
-
. -.
.. -
- -
- -
-
. - -
. - - -
.
-
-.
-. - - -
-..
- - - -
-..
.
-
. - - -
.
- - - -
- - -
'
.
,
.
.
17.
Index of Findings of Inspection Reports 50-338/81-07 and 50-339/81-08 Report Item Numbers Item Description Location 338/81-07, 33'J/81-08-VIOLATIONS C1
Failure to Maintain Records:
Audit Replies 9.a
-
- STA Personnel Qualificatiors 15.a
02 Failure to Perform Periodic Reviews 5.a of NPSQAM Procedures
03 Failure *, Perform Required Retraining 12.a for Offsite Personnel
04 Failure to Document Specific Calibra-8.
tion Frequency
-
05 Failure to !nclude Consumables/
7.a Expendables in QA Program
06 Failure to Follow Procedures:
- Purchase Requisitions 7.b
- Development Policy Manual Require-12.b ments DEVIATIONS
07 Failure to Correctly Grade Examina-15.b tions
08 Failure to Perform Required Training 15.c INSPECTOR FOLLOWUP ITEMS
09 Review of Station Administrative 14.
Procedures
10 Quality Assurance Personnel Training 12.c
11 Changes to Purchase Orders 7.c
12 QA/QC Review of Purchase Requisitions 7.d
13 Maintenance Trend Anal 3 sis Program 10.
_
_
.
_
_
__
'
-
.
,
.
.
Report Item Numbers Item Descriotion Location INSPECTOR FOLLOWUP ITEMS (Continued)
14 Accepted QA Program and NP50AM 9.b Inconsistencies
15 Organization Inconsistencies 5.b
16 Ir orlistent Regulatory Guide Commit-5.c a t. 9 t s
17 Correction of Weaknesses in the 9.c Escalation Program
,
l l
l
,
I i
{
!
l l
l l
l l
l
[
lL
,