IR 05000338/1982001
| ML20052G234 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 02/23/1982 |
| From: | Belise G, Belisle G, Fredrickson P, Skinner P, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20052G223 | List: |
| References | |
| 50-338-82-01, 50-338-82-1, 50-339-82-01, 50-339-82-1, NUDOCS 8205140433 | |
| Download: ML20052G234 (25) | |
Text
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'o UNITED STATES
- 8" NUCLEAR REGULATORY COMMISSION g
$
r REGION 11
o 101 MARIETTA Si., N.W., SUITE 3100 ATLANTA, GEORGIA 30303
Report Nos. 50-338/82-01 and 50-339/82-01 Licensee: Virginia Electric and Power Company Richmond, VA 23261 Facility Name:
North Anna 1 and 2 Docket Nos. 50-338 and 50-339 License Nos. NPF-4 and NPF-7 Inspection at North n site near Mineral, VA 23 82 Inspectors:
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/Date Signed r
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P. E. Fredrickson IDate' Signed I
l 3v Z382-A P. H. Skini1er date Signed Accompanying Personnel:
K. E. Davenpo t, Region II Approved by: /
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C(M~. Opri pt, ectio Chief
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Engineering In pectf n Branch
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Engineering A d Tec nical Inspection Division t
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SUMMARY
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l Inspection on January 18-28, 1982 Areas Inspected This routine, unannounced inspection involved 207 inspector-hours on site in
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the areas of licensee action on previocs enforcement matters; organization and administration; design changes and modifications; onsite review committee; procedures; surveillance; maintenance; QA program annual review; audits and
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8205140433 020503 DRADOCK00000g
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audit implementation; training; requalification training program; test and exper-iments; receipt, storage, and handling; records; document control; and review of previously identified inspection findings.
Results Of the 16 areas inspected, no violations or deviations were identified in 15 areas; three violations were found in one area (Failure to provide general employee training and retraining, paragraph 13.a; failure to provide required indoctrination and training for QA personnel, paragraph 13.b; failure to maintain controlled documents, paragraph 13.c ).
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REPORT DETAILS-1.
Persons Contacted Licensee Employees
- C. Arritt, Staff Assistant (Records)
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- M. Beauchamp, Staff Assistant L. Byron, Clerk
- W. Cartwright, Station Manager D. Craig, Training Instructor
- F. Curling, Director Training Services
' *R. Driscoll, Manager, QA (Surry)
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- M.
Fellows, Staff Assistant
- R. Garner, Senior Nuclear Training Coordinator
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- J. Goode, Superintendent Projects J. Grandstaff, Stores Supervisor
- J. Hanson, Jr., Superintendent Technical Services
- J. Harper, Superintendent Maintenance
- S. Harvey, Superintendent Operations
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- P. Knutsen, Supervisor Design Control
- R. Leasburg, Vice President Nuclear Operations Department
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- F. Miller, Supervisor QC
S. Montgomery, Training Instructor M. Pinion, Design Control Engineer
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- F. Rentz, Supervisor QC (Surry)
- H. Salken, Project Analyst L. Silman, QC Coordinator l
- D. Smith, QC Coordinator
- J. Smith, Supervisor QC MPP
J. Smith, Engineering Supervisor, Performance and Tests l
- A. Stafford, Supervisor Health Physics i
D. Thomas, I&C Supervisor l
F. Timpano, Performance Engineer E. Tracy, Security Operations Supervisor i
Other licensee employees contacted included technicians, operators, and office personnel.
I NRC Resident Inspector
- D. Johnson, Senior Resident Inspector
- Attended exit interview i
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Exit Interview The inspection scope and findings were summarized on January 28, 1982, with those persons indicated in paragraph 1 above. The licensee acknowledged the inspection findings.
3.
Licensee Action on Previous Enforcement Matters The following terms are defined and used throughout this report.
Accepted QA Program VEPC0 Topical Report, Quality Assurance Program, Operations Phase, VEP-1-3A, Amendment 3 AE Architect Engineer
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CAR Corrective Action Request I&C Instrument and Control ISI Inservice Inspection Program (Pumps and Valves)
NPSQAM Nuclear Power Station Quality Assurance Manual QA Quality Assurance QC Quality Control SNSOC Station Nuclear Safety and Operating Committee T/S Technical Specifications a.
(Closed) Unresolved Item (338/78-24-01): Improper Storage Of "Q"-Type Measuring And Test Tools.
The inspector performed a review of the storage locations of measuring and test tools and confirmed adequate separation between "Q" and non "Q" measuring and test tools, b.
(Closed) Unresolved Item (338/78-24-02):
RCS Flow Measurement In Accordance With 1-PT-27. The inspector reviewed the historical infor-mation relative to 1-PT-27, RCS Flow Measurement, and confirmed that the correction made in loop A thermal power calculation was carried through to calculation of flow during. subsequent performances of 1-PT-27.
c.
(Closed) Unresolved Item (338/78-24-03):
Verify Calibration Of Installed Instruments In 1-PT-57.1A.
The inspector reviewed the historical information available for 1-PT-57.1A, ECCS Subsystems Low Head Safety Injection Pump (1-SI-P-1A), and confirmed that requirements
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had been added to this test to verify calibration of installed instru-ments where used in the performance of the test.
d.
(Closed) Unresolved Item (338/79-08-08): Authority And Organization Freedom.
Since. the time of this item (January 1979), additional inspections have identified that the authority and organization freedom of the VEPC0 QA organization has not been effective. Specific enforce-ment acticns relative to the inadequacy of the QA organizatfor were one subject of an enforcement conference conducted in August 1981, and is documented in IE Reports 50-280/81-23, 50-281/81-23, 50-338/81-24 and 50-339/81-21. The reorganization of QA personnel and review of the
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accepted QA. Programs are the licensee's corrective actions to strengthen the authority and organizational freedom of the QA department.
The functioning of the QA department will be reinspected during future inspections.
e.
The following item of noncompliance from inspection report 50-338/79-08 was reviewed with respect to the licensee's letter dated June 19, 1979:
(Closed) Infraction (338/79-08-14):
Failure To Perform / Evaluate Testing. This item was a two part noncompliance.
Part 1: The inspector requested the test. results that were to. be performed on the four boric acid transfer pumps as committed to by the licensee's reply. Only the A, B and C pump test results were avail-
able. The D pump had been tested but the results were inconclusive due to a lack of proper temperature probes. The proper equipment has beeri received onsite and the temperature checks will be performed when the D pump is in operation. Due to the heat tracing system with thermocouple alarms being in use at North Anna which would identify inadequate temperatures caused by improper insulation installation, no deviation from the licensee's commitment is identified.
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Part 2: The inspector reviewed the test results from DC-78-06 with the
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written evaluations, and determined that the results were satisfactory.
f.
(Closed) Unresolved Item (338/79-08-19):. Test Control Of Design Change DC-78-01. The inspector reviewed the data supporting the minimum flow requirements for the Recirculation Spray Pumps and the Low Head Safety Injection Pumps as addressed in North Anna Engineering Work Request No.79-230.
This review determined that the flow design inputs had been adequately verified.
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(Closed) Unresolved Item (338/79-27-02):
Licensed Operator Required
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Review Of Emergency And Abnormal Procedures.
A review of various licensed operator training records indicate emergency and abnormal procedures are being reviewed on an annual basis.
h.
The following deficiency was reviewed with respect to licensee's correspondence dated December 27, 1979, Serial Number 1121/12079 P0/RMT:baw:
(Closed) Deficiency (338/79-45-02):
Mechanical Development Program Training Records Not Being Maintained At The Station. A review of various training recorJs indicates that copies of the Development Program Training is being provided to the station for inclusion in training records.
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The following item of noncompliance vias reviewed with respect to licensee's correspondence dated July 2,1980.
(Closed) Infraction (338/80-22-01): Failure To Implement Surveillance Test.
The inspector verified that station management distributed a letter reemphasizing the requirements of periodic test scheduling to station supervisors. Station management also reviewed the requirements of Technical Specification 4.0.2, the allowable extention period for surveillance requirements, with station personnel.
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The following violations were reviewed with respect to licensee's correspondence dated July 10, 1981:
(Closed) Violation (338/81-07-01, 339/81-08-01): Failure To Maintain Records.
(1) The inspector reviewed audits N-79-52 and N-80-02 and followup l
audits conducted August 1 and May 1, 1980, respectively, and verified that closeout actions for items identified had been completed.
The inspector also verified that documentation indi-cating that replies to audits N-79-52 and N-80-02 were lost, had been filed with the respective audits.
(2) A review of STA records indicates that the training attendance records and results of exams and quizzes have been obtained from Virginia Polytechnic Institute and State University and entered into the records of the training department.
(Closed) Violation (338/81-07-02, 339/81-08-02):
Failure To Perform Periodic Reviews Of NPSQAM Procedures. The inspector reviewed NPSQAM, Section SA, Nuclear Power Station Quality Assurance Manual, Revision 4, and confirmed that administrative controls have been established for the review of the NPSQAM procedures as required by regulatory require-ments.
The inspector reviewed NPSQAM Sections 1, 8, 9 and 10 and verified reviews were being performed at the required frequencies.,
(Closed) Violation (338/81-07-03, 339/81-08-03):
Failure To Provide Retraining For Offsite Personnel. A computerized record keeping system has been initiated as discussed in VEPC0 correspondence to the NRC dated July 10, 1981.
However, this system has not corrected this problem. This item is closed based on a similar violation identified in paragraph 13.a.
(Closed) Violation (338/81-07-04, 339/81-08-04): Failure To Document Specific Calibration Frequency. A review has been conducted and those instruments originally listed in Periodic Test 1-PT-32.7.1 have been separated into those to be managed under the requirements of Regulatory Guide 1.33, Revision 2.
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(0 pen) Violation (338/81-07-05, 339/81-08-05):
Failure To Include Consumable /Expendables In QA Program. The licensee is in the process of developing this program. The implementation date of this program is June 30,1982.
(Closed) Violation (338/81-07-06, 339/81-08-06):
Failure To Follow Procedure - Purchase Requisitions.
The inspector reviewed several purchase requisitions at the site warehouse and noted that the QA category had been written on all selected documents.
4.
Unresolved Items Unresolved items were not identified during this inspection.
5.
Organization and Administration (36700)
References:
(a) Technical Specifications, Section 6, Administrative Controls (b) Accepted QA Program, Section 17.2.2.5, Qualification Requirements of QA Supervisor (c) ADM-1.0, Station Organization and Responsibility, dated 10/81 The inspector reviewed the qualifications of various personnel within the onsite organization to assure that they met requirements of references (a)-(c). The following positions and persons assigned to the positions were reviewed:
Assistant Station Manager
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E. W. Harrell Site QC Manager
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A. L. Hogg, Jr.
Supervisor QC-0&M F. P. Miller
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Inspector, MT&E R. E. Craddock
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Superintendent Maintenance
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J. R. Harper
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Superintendent Technical Services J. A. Hanson
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Superintendent Operations
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S. L. Harvey Engineering Supervisor
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F. Termine11a Engineer, Shift Technical Advisor
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C. Kelsey Shif t Supervisor
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J. R. Hayes Reactor Engineer
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J. Smith
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l Chemist Technician
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C. Henson Based on this review, no violations or deviations were identified.
6.
Design, Design Changes, and Modifications (37700, 37702)
t References:
(a) NPSQAM, Section 3, Design Control, Revision 13 (b) NPSQAM, Section 14, Inspection Test and Operating Status, Revision 6 f
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(c) PPM-4, Design Change Implementation and Turnover, Revision 7 (d). POP 2.0.4, Drawing Management Multiple Power Projects, Revision 0 (e) POP 2.0.5, Handling of Design Change Packages - Multiple
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Power Projects, Revision 0 (f) POP 2.0.6, Validation and Close-out of Design Change
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Packages - Multiple Power Projects, Revision 0 The inspector reviewed the references listed to verify that they met requirements of the accepted QA Program and ANSI N45.2.11 as endorsed by that program. The inspector verified the following aspects of the design change program:
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Procedures have been established for control of design and modification change requests Procedures and responsibilities for design control have been estab-
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lished Administrative controls for design document control have been
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established
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Administrative controls assure that design changes are incorporated into plant procedures, operator training, and the updating of drawings
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Controls have been developed that define channels of communication between design and responsible organizations Administrative controls require that design documentation and records
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be collected and stored
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Controls require that implementation of approved design changes be in accordance with approved procedures
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Controls require that post-modification testing be performed ~per approved test procedures and that the results evaluated
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Responsibility has been assigned for identifying post-modification testing requirements
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Responsibility and method for reporting design changes to the NRC in accordance with 10 CFR 50.59 has been identified.
Similar methods and controls were also verified for use of temporary modi-fications (jumpers and disconnected leads).
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Based on this review,'two inspector followup items were identified. ~
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Odscription of Design' Interfaces
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- The NPSQAM, Sectio 3, [a'ragraph 3.1 states'that it is not practical to C.
provide concise details of design interfaces betweensparticipating desig,n. organizations outside the, company for each contractor,%A review of design documents identified that interfaces bttween oiganizations appear to be' adequate'; howiver, the statement in the NPSQAM contradicts requirements of ANSI N45.2.11.
Until the licensee clarifies / deletes
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this apparent. conflict betwaen the NPSQAM and ANSI N45.2.11,. this is e
identified as an inspector followup sitem (338,339/82-01-06).
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b.
Drawirig Control Prob 1' ems'
Audit N-79-02 conducted ' January 8, 1979,. identified that a problem eyhted in obtaining timely verificationifrom the AE on updating
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coa. rolled drawings affected by de' sign changes.
A memo from E. R. Smith, Jr., (Superintendent 7 Technical Services).to D. L. Smith
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dated March 5,1979, outlings a c'onversation with representatives of the AE stating' that revisions'to documents would be handled in a.more
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timely manner. TFe.correcti@ actjon date for this~ item was October 1,N
1979, but.was changed to Novembe~r 15, 1979, in'a memo from GL A. Kann, dated September 14, 1979 The corYective action date was again changed ~
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to January 1,1980; in a' memo from G.lA. Kann dated NovembeAl bl9'.C
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On March 19 1980r the - corrective. ac' tion f or this item states that v
methods have been ^ implemented?tofinsure timely notification of con-
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trolled drawing updates (niemo from G. A. Kann dated March 19,:1980).
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During audit N-79-02A conducted Ma'y 30, 1980, this same item was
reidentified with a recommendation:to escalate the finding. In a memo dated May 30, 1980, from D. Smith to W. Cartwri,qht, a schedule was set-
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to escalate this finding with a request for a ' conference by June 6,
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1980. 'The c[onference was held on June 4,1980.
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A memo dated June 10, 1980, from J.
W.. Martin, Jr., to W. L. Stewart:.
requested a resolution' and completion pate for this finding by June 24';,
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l 1380. A memo from R. M. Berryman to J. W. Martin, Jr., dated June 24,
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l 1980, requested additional specific information relative to' ~ audit
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N-79-02A co.nducted May 30, 1980.
Additional information ' to. the '
March 19, 1980, memo was provided in a memo from J. W. Martin _, Jr., to W. L. Stewart dated June 9,1980. On September 19, 1980, audit N-80-14 was conducted and ident,1fied, for specific de, sign changes, multiple examples of failure.to update drawings (finding 1). A similar history can be documented on audit N-80-14 as was donef for audit N-79-02.
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On November 11, 1980, an escalation conference was held between QA and plant management representatives discussing previously identified audit findings. Audit findings from audit N-79-02 and N-80-14 (finding 1)
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r were to be again escalated on November 17, 1980, in a memo from M. A. Harrison to 0. L. Smith and W. L. Stewart.
The lack of satis-
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factory results after escalation to offsite personnel was the subject of anott
, escalation conference conducted June 12, 1981 (discussed
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in memo f rom J. D. Kellems and J. L. Smith to W. R. Cartwright and
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M. A. Harrison dated June 24,1981). The corrective action was that a program was to be; developed and implemented by August 31,.1981, and a reaudit was scheduled for September 1,1981.
An enforcement conference was conducted -in the Region II office with-VEPC0 management representatives on August 25, 1981, to discuss weak-nesses in which the QA Program had not achieved meaningful corrective action.
The results of this meeting are detailed in IE Reports 50-280/81-23, 50-281/81-23, 50-338/81-24 and 50-339/81-21.
Another escalation conference was conducted September 8, 1981, and the correc-tive action for audits N-79-02 and N-80-14 was rescheduled for October 1,1981.
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On Octcber 29,1981,iaudit N-79-02B was conducted to close out findings from audits N-79-02 and N-79-02A. The corrective action for this item on timely verification still had not been corrected so the item was left open. On October 30, 1981,- corrective action reports were issued (CAR 81-13 and 81-15) against the findings in N-79-02 and N-80-14. The item was resolved. The results of the conference stated that a program is now working and that the program will be reviewed to insure it is properly proceduralized by January 15, 1982.
The inspector identified numerous design changes that were installed but not fully completed in that controlled drawings had not Deen updated; however, due to the licensee's corrective action to audits N-79-02 and 80-14, no violation was issued. Our concern regarding the time needed to achieve meaningful corrective action resulted in several telephone conversations between Region II and VEPC0 management per-sonnel. As confirmed in.the cover letter of this inspection report, VEPC0 will update all drawings impacted by installed design changes by March 12, 1982. Pending completion of this action, this is idenitfied as an inspector followup item (338,339/82-01-07).
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Onsite Review Committee (40700)
References:
(a) Technical Specifications (b) NPSQAM, Section 1, Organization, Revision 4 (c) ADM-2.0, Station Nuclear Safety and Operating Committee, dated 9/81
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The inspector reviewed - references -(b) and (c) to verify that they met-requirements of reference (a), the accepted QA Program, and ANSI N18.7 as endorsed by that program.
The inspector reviewed selected SNSOC meeting results during 1981 (meeting minutes #1-290) and verified T/S requirements relative to membership, review process, frequency of meetings and quorum requirements. Discussions with the resident inspector identified that he frequently attends these meetings. The inspector attended a SNSOC meeting on January 21, 1981.
Based on this review, one concern was identified. Reference (a), Section 6.5.1.3 requires that alternates to the SNSOC be appointed in writing. The licensee's method of appointment of these members is to list the alternates-attending the meeting and then have the chairman, by signing the meeting minutes, concur in the appointment of the. alternates attending the meeting.
This method of appointment of alternates does not meet the intent of the T/S.
In reviewing SNSOC meeting minutes the inspector did not identify a lack of membership expertise during SNSOC meetings for agenda items. The SNSOC chairman agreed to a more formal method of appointing alternate members of the SNSOC and gave a tentative date of February 1, 1982 for implementation.
8.
Procedures (42700)
References:
(a) ANSI N18.7-1976, Administrative Controls for Nuclear Power Plants (b) Technical Specifications (c) Regulatory Guide 1.33, Rev. 2, Quality Assurance Program Requirements (Operation)
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Final Safety Analysis Report (e) NPSQAM, Section 5,
Instructions, Procedures and Drawings, Revision 19 The inspector reviewed selected plant procedures in accordance with guidance and requirements provided in references (a) through (e). From these refer-ences the following criteria were used for procedure review:
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Required review, approval and temporary changes of procedures are being performed
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Procedure changes were made to reflect Technical Specification revi-sions
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Changes to procedures were in conformance with 10 CFR 50.59(a) or 10 CFR 50.59(b) requirements
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Overall procedure content is consistent with references (b) through (d)
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Procedures include ; provisions to assure safety-related systems /
components which are exposed to 'a freezing environment remain func-tional following such exposure Records of procedure revisions 'are being maintained.'
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The following procedures were reviewed:
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Operating Procedures-(OP)
Unit 1
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Quench Spray System, Revision 8 OP-31.0 & 1
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Main Feedwater System, Revision 5 OP-31.2
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Steam Generator Auxiliary Feedwater System, Revision 9 OP-5.2 Reactor Coolant Pump Operations, dated 6/80
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DP-1.3 Unit Startup from Cold Shutdown Condition
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(Mode 5) to Hot Shutdown Condition (Mode 4)
s350 F, Revision 11.
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Unit Startup from Hot Shutdown Condition (Mode 4) to Hot Standby Condition (Mode 3) at 547 F, Revision 8 OP-1.5
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Unit Startup from Hot Standby Condition (Mode 3) to Startup Condition (Mode 2) with Reactor Critical at s5% Power, Revision 7
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Abnormal Procedures (AP)
Unit 1
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AP-21
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Loss of Feedwater Flow, Revision 7-AP-12 Loss of Service Water System, Revision 1
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AP-9
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AP-22
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Alternate Lineups, dated 11/79 Unit 2
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Loss of Instrument Air, Revision 0 AP-1.7
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Malfunction of Individual Rod Position Indi-cation, Revision 0
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AP-15
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Loss of Component Cooling, dated 10/78 l
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Malfunction of Nuclear Instrumentation, dated l
11/78
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Emergency Procedures (EP)
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Unit 1
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Reactor -Trip, Revision 14 EP-2
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Loss of Reactor Coolant Accident, Revision 22 EP-3
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Loss of Secondary Coolant, Revision 20 EP-4
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Steam Generator Tube Rupture, Revision 19 Mechanical, Instrumentation, & Electrical Maintenance Procedures (MMP,
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IMP, & EMP)
Units 1 & 2
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IMP-C-NI-01
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Repair of Nuclear Instrumentation ~ System, Revision 4 MMP-C-RC-1 Disassembly, Inspection, and/or Repair and
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Reassembly of A Reactor Coolant Pump, Revi-sion 3 MMP-P-EG-1
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Inspection and Repair of the Emergency Diesel Generator Engines, Revision 9 MMP-C-GV-1
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Valves in General, Revision 7 MMP-C-GP-1 Pumps in General, Revision 4
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.MMP-P-FW-2
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Auxiliary Feed Pumps, Revision 6 MMP-C-QS-1
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Containment Quench Spray Pump, Revision 2 Unit 2
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EMP-P-RT-118
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Protective Relay Maintenance for Breaker No. 25A3 Reactor Coolant Pump 2-RC-P-1A, Revision 0
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Administrative Procedures (ADM)
ADM-5.0'
Containment Ingress and Egress, Revision 0
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ADM-6.0
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Control Room Access, Revision 0 ADM-48.0
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Commitment Tracking Drogram,' dated 9/81 ADM-29.14
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Conduct of Operations, Revision 5/30
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ADM-29.9
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Conduct of Operations, Revision 5/80 ADM-13.0
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Review of Procedures, dated 12/81 ADM-13.1
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Procedure. for Processing New and Revised
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Procedures, dated 7/81
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Based on this review, no violations or deviations were identified. The j
inspector noted a lack of documented two year procedure reviews which was
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discussed with the licensee. This item was identified in a QA Audit by the licensee ar.d is in the process of being corrected.
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9.
Surveillance (61700)
References:
(a) ADM-11.4, IWP/IWV Evaluation, dated 1/81 (b) NPSQAM, Section 5,
Instructions, Procedures and Drawings, Revision 20
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(c) DCM-6, Procedure for. Periodic. Test Procedures, dated 12/81 (d) DCM-38, Procedure for Completed Procedures, dated 12/81 (e) ENGR. ADMIN. 13, Controlling Procedure for Completed-Periodic Tests, dated 6/81 (f) ENGR. ADMIN. 14, Controlling Procedure for Inservice Inspection (ISI) Documentation (Valves), dated 7/01 (g) ENGR. ADMIN. 15, Controlling Procedure for Inservice Inspection (ISI) Documentation (Pumps), dated 6/81 (h) ENGR. ADMIN. 16, Controlling Procedure for Periodic Test Performance Logbook, dated 6/81 (i) ENGR. ADMIN. 17, Controlling Procedure for Periodic Test Schedule System, dated 6/81 (j) ENGR. ADMIN. 18, Controlling Procedure for Surveillance Cross Reference File, dated 6/81 (k) ' ENGR. ADMIN.19, Controlling Procedure for Surveillance Requirement Change Reviews, dated 6/81 The inspector reviewed the listed references to assure that they met the requirements of T/S and ANSI N18.7-1976.
The inspector verified that periodic testing for systems identified in T/S and ISI Program for pumps and valves are covered by approved procedures (pts).
The inspector reviewed 15 procedures and verified that testing of related systems / components assures compliance with requirements specified in T/S and the ISI Program.
Other aspects of surveillance program activities are routinely performed by the resident inspectors and are discussed in their monthly reports.
Based on this review, no violations or deviations were identified.
10. Maintenance (62700)
References:
(a) Technical Specifications (b)Section XI, ASME Boiler and Pressure Vessel Code
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The inspector reviewed maintenance activities on safety-related systems and
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components to ascertain whether the activities were conducted in accordance with approved procedures, regulatory guides, and industry codes and in conformance with Technical Specification requirenents.
The following aspects were used during this review;
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Required administrative approvals were obtained prior to initiating the work
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Limiting conditions for operation were met while the components-were removed from service Approved procedures were used where the. activity appeared to be beyond
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the normal skills of the craft
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Activity was accomplished by qualified personnel
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The licensee had evaluated system failures and reported them in accord-ance with the Technical Specifications
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Written procedures ware established for initiating requests for routine
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and emergency maintenance
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Criteria and responsibilities for review and approval of maintenance requests were established
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Criteria and responsibilities that form the basis' for designating the activity as safety or non-safety-related were established
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Criteria and responsibilities were designated for performing work inspection of maintenance activities i
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Provisions and responsibilities were established for the identification of appropriate inspection hold points related to maintenance activities
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Methods and responsibilities were designated for performing functional
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I testing of structures, systems, or components following maintenance
work and/or prior to their being returned to service.
Discussions with NRC Resident Inspectors identified that their inspection activities routinely include monitoring selected plant maintenance activi-
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ties for the previously mentioned aspects. The resident inspectors document
their inspection activities and findings in this area in their monthly inspection reports.
In addition, the inspector reviewed approximately ten-
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completed maintenance activi^ies.
Based on this review, no violations or deviations were identified.
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11. QA Program Annual Review (35701)
References:
(a) Accepted QA Program (b) NPSQAM 1 -
Organization, Revision 4
(c) NPSQAM 2 -
Quality Assurance Program, Revision 7
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(d) NPSQAM 3 -
Design Control, Revision 13
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(e) NPSQAM 5
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Instructions, Procedures.and Drawings, Revision 19 (f) NPSQAM 10 -
Inspection, Revision 4 (g) NPSQAM 16 -
Corrective Action, Revision 12 (h) NPSQAM 18 -
Audits, Revision 6 (i) NPSQAM 5A -
Nuclear Power Station Quality-Assurance Manual, Revision 4 The inspector reviewed references (b)-(i) as well as other NPSQAM procedures mentioned throughout this report to assure they met the requirements of reference (a).
The licensee has not made any changes to reference (a) since the last inspection in this area (IE Reports 50-338/81-07 and 50-339/81-08, April 1981). The licensee has recently reorganized the QA Department in an effort to increase the effectiveness of this group. Due to this reorgani-zation there were significant personnel as well as position title changes.
During the review of the references listed, personnel titles do not coincide with the new positions identified since the reorganization.
For consis-tency, at the earliest convenience after stabilization of the new organi-zation, a review must be made by the licensee to upgrade position titles in the NPSQAM and the T/S to reflect the current organization.
The Manager of Quality Assurance has been recently appointed. Although this person has extensive nuclear plant experience, his experience with QA is limited.
Since significant problems have been identified with the QA organization at VEPCO as discussed in IE Reports 50-280/81-23,50-281/81-23, 50-338/81-24 and 50-339/81-21,- tim overall effectiveness of the QA organi-zation will be closely monitored during subsequent inspections.
Based on this review, no violations or deviations were identified.
12. Audits and Audit Implementation (40702, 40704)
References:
(a) Technical Specifications, Section 6 (b) NPSQAM 18, Audits, Revision 6 (c) NPSQAM 16, Corrective Actions, Revision 12 The inspector reviewed references (b) and (c) to assure that they met requirements of reference (a), the accepted QA Program, and ANSI N45.2.12 as endorsed by that program. The inspector verified the following aspects of the audit and audit implementation program:
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The scope of the audit program has been defined and is consistent with the Technical Specifications
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Responsibilities have been assigned in writing for the overall manage-ment of the audit program
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Methods have been defined for.taking' corrective action when deficien-cies are identified during audits
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The audited organization is required to respond in writing to audit findings Distribution requirements for audit reports and corrective action
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responses have been defined
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Checklists are required to be used in the performance of audits
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Audits are conducted by trained personnel not having direct responsi-bility in the area being audited
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The frequency of audits is in conformance with Technical Specification requirements.
To verify the implementation of these aspects, the inspector reviewed the results of nine audits conducted in 1981 (N-81-3, 6,12,13,14,15,16,19 and 20).
The inspector also reviewed the qualifications of four lead auditors.
The inspector reviewed the results of several escalation con-ferences held by onsite personnel to determine the adequacy of resolution of previous audit findings.
Based on this review, no violations or deviations were identified.
13.
Non-Licensed Personnel Training (41700)
References:
(a) ANSI N18.1, Selection and Training of Nuclear Power Plant Personnel - 1971 (b) NPSQAM, Section 2, Quality Assurance Program, Revision 7 (c) Accepted QA Program, Sections 17.2.2.6, Training of j
QA/QC Employees (d) Accepted QA Programs, Section 17.2.2.7, Training of Other VEPCO Employees (e) ADM-12.0, Station Training, dated 12/81 (f) ADM-12.1, General Employee Training, dated 12/81 (g) VEPC0 General Employee Training and Retraining Manual (h) QA Operations and Maintenance Instruction Manual, Local Instruction 10.12, Certification Program for Inspectors and Auditors, dated 4/81 (i) QA Operations and Maintenance Instruction Manual, Local r
Instruction 10.13, Training Program for Inspectors and Auditors, dated 7/81 The inspector reviewed the general employee and QA/QC personnel training programs to assure compliance with requirements and commitments identified in references (a)-(d). References (e)-(g) implement recuirements for
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general employee training (GET) and references (h) and (1) implement
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requirements for QA/QC personnel training. These programs were reviewed to verify the following:
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The GET program covers training and retraining in the areas of admin-istrative controls and procedures, radiological health and safety, industrial safety, security procedures, emergency plan, quality assurance, fire fighting, and prenatal radiation exposure.
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The QA/QC personnel training program includes indoctrination in company i
policies, VEPC0 Quality Assurance Manuals, Technical Specifications, Health Physics Manual, Emergency Plan, selected portions of the FSAR, and appropriate codes and standards.
Implementation of the program was verified by reviewing 26 GET training
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records and 5 training records for QA/QC personnel.
Based on this review, three violations were identified as discussed below.
a.
Failure to Provide GET Retraining for Personnel Technical Specification 6.4.1 requires that a training and retraining program be implemented for facility staff. Reference (f) specifies the requirements for GET training and retraining. Paragraph 5.0 of refer-ence (f) requires personnel to be retrained and recertified annually and also provides a period of 90 additional days, if training within the specified 12 months can not be accomplished.
The inspector reviewed 26 training records of onsite and offsite personnel.
Of those reviewed, five persons had - not received the required retraining.
In addition, they were still badged with TLD's issued and measures had not been established to preclude access to controlled areas. This failure to provide GET retraining for personnel is a violation (338,339/82-01-01).
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Failure of QA Program to Provide All Required Training
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10 CFR 50, Appendix 0, Criterion II requires the QA Progrcm to provide indoctrination and training of personnel performing activities affec-ting quality to assure that suitable proficiency is achieved and maintained.
Reference (c) identifies the training to be provided for QA/QC personnel. References (h) and (i) implement the training program for QA/QC personnel.
References (h) and (i)- do not include all requirements specified in reference (c) in that training in the VEPC0 QAM and company policies is not provided in these procedures.
In addition, these procedures have not been updated to reflect recent QA department changes. This failure to provide all training required by the QA program is a violation (338,339/82-01-03).
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c.
Failure to Maintain Controlled Documents 10 CFR 50 Appendix B and tiie accepted QA Program, Section 17.2.6 require strict administrative control for documents affecting safety and measures must be establishe to assure their distribution and at the location where the activity is performed. A review of copy #06 of the Quality Assurance Operations and Maintenance Instructions indicated that LI 10.13, Training Program for Inspectors and Auditors, was not included in this manual. LI 10.13 describes the training program for-QA/QC inspectors and the individual responsible for implementation of this program was not aware of its existence.
A review of five inspector personnel records indicated sufficient evidence to conclude they had met required training but the training records did not meet the requirements described in LI 10.13. During the review of other manuals, copy #174 of the NPSQAM contained Section 16, revision 2, in lieu of revision 3 which had been approved and issued. This failure to maintain the latest revision of controlled documents is a violation (50-338,339/82-01-02).
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Licansed Operator Requalification Training (41701)
References:
(a)
10 CFR 55, Appendix A, Requalification Programs for Licensed Operators of' Production and Utilization Facilities (b) VEPC0 Licensed Operator Requalification Program --
Revised July 1980 (c) NUREG 0737, Clarification of TMI Action Plan Require-ments (d) ADM-12.12, Shift Technical Advisor Training, dated 12/81 (e) ADM-12.13, Licensed Operator Requalification Program, dated 12/81 The inspector reviewed the requalification program to determine conformance to references (a) through (e).
The training records of five licensed reactor operators were reviewed.
Based on this review, one inspector followup item was identified. Reference (e) which describes the licensed operator requalification program does not contain all the required lectures specified in reference (a).
Licensee representatives stated that the lectures required by reference (a) were conducted at the simulator.
This is identified as an inspector followup item (338,339/82-01-04) pending clarification of reference requirements (a)
in reference (e) and inspection of training activities at the VEPC0 simu-lator.
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15. Tests and Experiments (37703)
References:
(a) Technical Specifications, Section 6, Administrative
' Controls-(b) NPSQAM Section 5, Paragraph 5.8.17, Special Test Proce-dure Revision 18 (c) NPSQAM Section 'll, paragraph 5.5, Special Tests, Revision 5 (d) ADM-13.1, Procedure for Processing New and Revised Procedures, dated 7/81 (e) ADM-40.0, Special Tests, dated 2/81 (f) ADM-49.0, NRC Routine Monthly, Semi-Annual and Annual Reports, dated 1/81 The inspector reviewed references (a)-(f) to verify the ~ following aspects of the test and experiments program:
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A formal method has been established to handle all requests or propo-sals for conducting special tests involving safety-related components
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Special tests will be performed in accordance with approved procedures
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Responsibilities have been assigned for reviewing and approving special test procedures
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A system, including assignment of responsibility, has been established to assure that special tests will be reviewed
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Responsibilities have been assigned to assure a written safety evalu-ation required by 10 CFR 50.59 will be developed for any special test to assure that it does not involve an unreviewed safety question or i
change in Technical Specifications.
The following special tests were reviewed:
1-ST-26, DG "1H" Start Demonstration Test, dated 5/80
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1-ST-32, Safety Injection and CDA Retest, dated 11/80
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1-ST-57, Safety Injection and CDA Retest, dated 1/81 1-ST-33, Class IE Electrical Equipment Environmental Qualification Veri-fication Inspection Program, dated 11/80 1-ST-41, High Head Safety Injection Flow Balance and Pump Head Curve, dated 3/81 Based on this review, no violations or deviations were identified.
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16.
Receipt, Storage, and Handling (38702)
References:
(a) Accepted QA Program, Section 17.2.7, Control of Purchased Material, Equipment and Services (b) Accepted QA Program, Section 17.2.13, Handling, Storage and Shipping (c) NPSQAM, Section 7, Control of Purchased Material, Equipment and Services, Revision 6 (d) NPSQAM, Section 13, Handling, Storage and Shipping, Revision 4 The inspector reviewed the licensee's program for the receipt, storage, and handling of equipment and material with respect to selected elements of the licensee's accepted QA Program.
The inspection was to verify that admin-
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istrative controls had been established concerning receipt inspection of safety-related materials; preparation and retention of required documenta-tion; control of acceptable, nonconforming, and conditional release items; and control of items in storage. Implementation of the program was reviewed by selectir.g several safety-related items in storage and verifying document and item control to be in accordance with the program. The specific items selected were the following:
Part Number.
Item 227347.
O' Ring 2070985 Yoke Subassembly 2941005 Flex Coupling 2946746 Gasket Based on this review, one concern was identified. During the inspection of the rtorage warehouse facility, the inspector noted a conventional file cabinent which contained purchase orders that pertained to the design changes which had been performed and also those in progress. Many of these purchases had been completed, in that all the material had been received and
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a receipt inspection report had been completed. The inspector identified
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several completed QA Category I purchase orders with their respective
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receipt inspection reports in this file: Purchase Orders 88130, 93397, and 72601. The inspector also identified that copies of repeating purchase requisitions are not being maintained in Station Records. The accepted QA Program, Section 17.2.7, requires that a copy of the purchase requisition, the receipt inspection report form, and a copy of the purchase order become a part of station records. The failure to maintain copies of this purchase documentation was also identified in North Anna Power Station Procurement Audit N-81-12. Although conversations with QA personnel and senior plant staff revealed the extent of this audit, first line supervisors appeared unaware that the problem had been previously identified by the QA organi-zation.
It appears that the licensee's corrective action to resolve audit N-81-12 will address and correct the inspector's concerns in this are __
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Records (39701)
References:
(a) Accepted QA Program, Section 17.2.17, Records (b) NPSQAM, Section 1/, Records, Revision 5 (c) DCM-2, General Document Control Procedure, dated 12/81 (d) ADM 43.0,' Records Management, dated 12/81 The inspector reviewed the references to verify that provisions _had been made to naintain various types of quality records and that responsibilities had been assigned to carry out the records storage requirements. -Records storage procedures were also reviewed to ensure that they described the storage facilities, the filing systems used, and methods of receipt, hand-ling and disposal of the records.
In order to verify implementation of these procedures, the inspector selected the following records to be retrieved:
Purchase Order 38718 DC 78-27 Purchase Order 42437 DC 80-S49 Audit N-80-11 1-PT 33.2, 4/5/78 Audit N-79-45 MR N1-80-0524-1130 1-5U.33, Oct. 80 Based on this review, one inspector followup item was identified. Section 17.2.17 of the accepted QA Program requires that records of modifications be controlled in accordance with Regulatory Guide 1.88, August 1974. Design change modification packages have been maintained in the staff engineering offices rather than the records vault during the period between the design change being declared installed and the final staff and QA reviews.
The timeframe between these two events has been as much as three years.
Although waiting for these reviews appears to keep the design change package as a " document" and thus not requiring QA record storage, declaring the design change installed actually completes the design change from a records control position. The licensee identified this problem in Audit N-81-14 and placed a concentrated effort on completing the final reviews. The licensee committed to a March 1, 1982 date for relocating all operable design change
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packages to the records vault and a date of March 15, 1982, for developing I
controls whereby future operabic design changes will be expeditiously relocated to the records vault. This area is identified as an inspector followup item (338,339/82-01-05).
18. Document Control (39702)
References:
(a) Accepted QA Program, Section 17.2.6, Document Control
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(b) NPSQAM, Section 6, Document Cc.. trol, Revision 8 l
(c) ADM 13.1, Procedure for Processing New and Revised Procedures, dated 7/81 (d) ADM 39.0, Station Drawing Revision Distribution, dated l
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(e) DCM-26, Procedure for Revising E&DCR Numbers and Posting Design Change Numbers, dated 12/81 l
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The inspector reviewed the references to verify that they met requirements
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The following documents were reviewed for proper handling at various. controlled document locations throughout' the plant:
Vendor Manuals Procedures
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ITT Barton Model 752 DP Transmitter MMP-C-EG-1, 11/4/81 Ingersoll Rand RHR Pump MMP-C-FL-4, 4/13/81 Hayes Model 625 Dissolved 02 Analyzer FS-BD-1038, 1/15/79 EP-3, 5/8/81 Drawings
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11715-FK-1C, R6 11715-FB-102B, R1 11715-FC-12F, R7 1205-FM-18A, R14 11715-FE-7AF, R6 11715-FE-48K, R19 11715-FE-80E, R9-Based on this review, no violations or deviations were identified.
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Licensee Actions on Previously Identified Inspection Items (Closed) Inspector Followup Item (338/77-57-04): Startup Test Records.
a.
The record storage facility has been inspected and appears adequate.
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(Closed) Inspector Followup Item (338/79-07-01):
Document Control.
The licensee is taking corrective action in the area of document control by issuing administrative control procedures for these docu-ments.
c.
(Closed) Inspector Followup Item (338/79-07-03):
Systems Protected From Freezing Temperatures.
The inspector reviewed procedures MMP-P-EG-1 Rev. 9, MMP-C-GP-1 Rev. 4, and MMP-C-GV-1 Rev. 7, all of i
which had been revised to assure that the fluid systems when subjected to freezing temperatures are freeze protected during maintenance.
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d.
(Closed) Inspector Followup Item (338/79-07-04): Lists For Calibrated l
Equipment. The inspector reviewed electrical maintenance procedures ~to verify that equipment used for tests were on the list of calibrated
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equipment. For equipment used in EMP-P-RT-41, the inspector noted that the calibrated equipment list was maintained in Richmond, VA since the i
equipment originates from that office.
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(Closed) Inspector Followup Item (338/81-07-09, 339/81-08-09): Review Of Administrative Procedures.
The inspector reviewed the results of audits N-80-16 and N-80-16a through c.
The particular item relative to review of station administrative procedures was closed in audit N-80-16c on August 31, 1981.
A schedule of review of administrative procedures is currently being ' developed by station personnel for implementation during 1982.
f.
(Closed)
Inspector Followup Item (338/81-07-10, 339/81-08-10):
Performance Of Required Indoctrination And Training -For Quality Assurance Personnel.
This item is closed based on action by the licensee to clarify paragraph 5.2 of NPSQAM Section 2, Quality Assurance Program. Revision 7 to the NPSQAM deleted ambiguous training requirements.
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(Closed) Inspector Followup Item (338/81-07-11, 339/81-08-11): Changes To Purchase Orders. The inspector reviewed audit 80-22 Item JF-1 and confirmed that this audit finding was closed August 20, 1981'.
The closing of this item was accomplished by a review of 21 Category I Purchase Orders issued since February 10, 1981, with no adverse find-ings relative to changes to Category I Purchase Orders.
h.
(0 pen) Inspector Followup Item (338/81-07-12, 339/81-08-12): QA/QC Review Of Purchase Orders. The inspector reviewed NPSQAM, Section 4,
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Procurement Document Control, Revision 3.
This procedures is currently undergoing review for updating.
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(0 pen) Inspector Followup Item (338/81-07-13, 339/81-08-13):
Main-tenance Trend Analysis Program. The licensee is currently evaluating a method of maintenance trend analysis. The tentative date of formali-
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zation of this program is October 1,1982.
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j (0 pen) Inspector Followup Item (338/81-07-14, 339/81-08-14): Accepted
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QA Program And NPSQAM Inconsistencies.
The licensee is currently evaluating their QA Program. The licensee, as part of this evaluation, has hired a consultant to provide input to the accepted QA Program.
This is mentioned in licensee correspondence dated October 7,1981.
Discussions with cognizant personnel identified that the NPSQAM is also
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undergoing review.
Upon completion of this review and evaluation, a
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submittal will be made to the NRC updating the accepted QA Program.
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(0 pen) Inspector Followup Item (338/81-07-15, 339/81-08-15): Organi-zational Inconsistencies.
The licensee has recently revised their QA organization. The licensee is currently evaluating their accepted QA Program prior to a formal submittal to the NRC. This submittal to NRC and submittal of a T/S change should resolve these inconsistencies.
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(0 pen) Inspector Followup Item (338/81-07-16, 339/81-08-16):
Incon-sistent Regulatory Guide Commitments.
The licensee is currently.
performing an evaluation of the accepted QA Program prior to submitting changes to the NRC which should relolve these inconsistencies.
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(Closed)
Inspector Followup Item (338/81-07-17, 339/81-08-17):
Correction Of Weaknesses In Escalation Program.
The licensee has performed an extensive review and rewrite of NPSQAM, Section 18, Audits. This procedure contains specific ' guidance for. escalation of identified problem areas.
Previous audit items that have not been corrected have been escalated; corrective actions and completion dates have been addressed. Plant management is working closely with the QA organization to assure that problem areas are corrected.
20.
Index of Findings of Inspection Reports 50-338/82-01 and 50-339/82-01 REPORT ITEM NUMBERS ITEM DESCRIPTION PARAGRAPH 338,339/82-01-
Vi.olations
01 Failure to-Provide GET Retraining for Personnel 13.a
02 Failure to Maintain Controlled Documents 13.c
03 Failure Of QA Program to Provide All Training 13.b Requirements Inspector Followup Items
04 Update ADM 12.13 to Reflect Training Subjects
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Required by 10 CFR 55, Appendix A
05 Storage of Design Change Documentation
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Design Interface Controls in NPSQAM 6.a l
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Update Drawings Impacted by Design Changes 6.b Concerns
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Storage of Purchase Order Documentation
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Appointment of Alternate Members to SNSOC
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