IR 05000348/1983013
| ML20024F557 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 06/01/1983 |
| From: | Belisle G, Debbage A, Skinner P, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20024F518 | List: |
| References | |
| 50-348-83-13, 50-364-83-11, NUDOCS 8309090473 | |
| Download: ML20024F557 (33) | |
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NUCLEAR REGULATORY COMMISSION I' ~8 REGION 11 I N $ 101 MARIETTA ST., N.W., SUITE 3100
" ~f ATLANTA, GEORGIA 30303 l \\...../ l ! l Report Nos: 50-348/83-13 and 50-364/83-11 Licensee:. Alabama Power Company 600 North 18th Street Birmingham, AL 35291 , Docket Nos: 50-348 and 50-364 License Nos: NPF-2 and NPF-8 Facility Name: Farley ~ Inspection at Farley site near Dothan, Alabama and Corporate Offices in Birmingham, Alabama Inspectors: %N
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Approved by: [ 8/ WA.
87 C. M. Upright, Sec on Ch)ff Date S'igned Engineering Prog s BrarMh Division of Engineering and Operational Programs SUMMARY Inspection on April 25 - 29 and May 2 - 6, 1983 Areas Inspected This routine, unannounced inspection involved 142 inspector-hours on site and the corporate office in the areas of QA Program; audits; training; requalifica-tion training; QA/QC administration; housekeeping / cleanliness program; nonroutine reporting program; test and experiments program; records program; document control program; procurement program; receipt, storage, and handling program; design change program; measuring and test equipment program; surveillance testing and calibration control program; maintenance program; and offsite staff.
8309090473 830901 PDR ADOCK 05000348 G PDR
. . Alabama Power Company
Docket Nos. 50-348 and 50-364 Farley License Nos. NPF-2 and NPF-8 4.
10 CFR 55.31(e) requires that if a licensed individual has not been actively performing the functions of an operator or senior operator for a period of four months or longer, he shall demonstrate to the Commission that his knowledge and understanding of facility operation and administration are satisfactory prior to resuming licensed duties. Although no licensee was identified that had performed the functions of a licensed operator in violation of this requirement, measures have not been established to formally document the removal and reinstatement of personnel who are subject to this requirement.
This list is not intended to be all inclusive.
This is a Severity Level IV Violation (Supplement I).
B.
Technical Specification 6.4.1 requires a retraining and replacement training program for the facility staff to be maintained under the direction of the Training Superintendent and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and Appendix "A" of 10 CFR Part 55 and the supplemental requirements specified in Section A and C of Enclosure 1 of the March 28, 1980, NRC letter to all licensees, and shall include familiarization with the relevent operational experience.
1.
Section C.2 of Enclosure 1 requires a licensed individual to participate in accelerated requalification if he scores less than 80% overall or 70% in a category on the annual requalification examination.
Contrary to the above, due to a mathematical error during the grading process of an examination one individual was given 70% in a category when his actual score was 66.7%. Upon notification of this error by the inspector, the licensee immediately removed the individual from licensed duties and placed him in an accelerated training status.
2.
Section C.3 of Enclosure 1 requires that control manipulations identified in Enclosure 4 of the March 28, 1980, letter be performed as detailed in the enclosure. These manipulations are required to be performed over a two year period.
Contrary to the above, all required reactivity manipulations were not accomplished over a two-year period. One required manipulation involving loss of instrument air had not been performed by any of the individuals selected for review. Two other personnel had not-performed one other required manipulation involving loss of service water.
This is a Severity Level IV Violation (Supplement I).
' - Alabama Power Company
Docket Nos. 50-348 and 50-364 Farley License Nos. NPF-2 and NPF-8
C.- Technical Specification 6.5.2.10.c requires that audit reports shall be forwarded to the Senior Vice President and to management positions responsible for the areas audited within 30 days after completion of the audit.
Contrary to the above, the following audits were not forwarded to these positions.within 30 days after completion of the audit: Areas Audited Dates of Audit Date Forwarded I&C STP 2/7 - 2/21/83 3/28/83 Procurement 1/31 - 2/15/83 3/28/83 Plant Operations 1/1 - 1/25/83 3/7/83 FNP Emergency Program 1/3 - 2/1/83 3/7/83 Quality Control 11/22 - 12/2/82 1/5/83 Unit 2 Refueling 10/25 - 12/2/82 1/5/83 Safety Program 10/25 - 12/3/83 1/5/83 Material Control Activities 2/21 - 3/7/83 4/12/83 Environmental Monitoring 2/15 - 3/4/83 4/12/80 These examples are not intended to be all inclusive.
This is a Severity Level V Violation (Supplement I).
Pursuant to the provisions of 10 CFR 2.201, you are hereby required to submit to this office within thirty days of the date of this Notice, a written statement or explanation in reply, including: (1) admission or denial of the alleged viola-tions; (2) the reasons for the violations if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further violations; and (5) the date when full compliance will be achieved. Consideration may be given to extending your response time for good cause-shown.
.JUN 7 1983 Date:
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. REPORT DETAILS 1.
Persons Contacted Licensee Employees R. Badham, Safety Audit and Engineering Review (SAER) Engineer B. Bell, Electrical Maintenance Engineer
- R. Berryhill, System Performance and Planning Superintendent M. Carnley, I&C Sector Supervisor
- D. Culver, SAER Engineer D. Dozier, Control Technician
- L. Enfinger, Administration Superintendent
- H. Garland, Maintenance Supervisor
- G. Hairston, III, Plant Manager J. Hudspeth, Document Control Supervisor L. Jones, IV, Materials Supervisor
- J. McGowan, Manager SAER
- D. Morey, Operations Superintendent
- C. Nesbitt, Techniccl Support
- L. Stinson, Plant Modifications Supervisor L. Ward, I&C Supervisor
- W. Ware, Supervisor SAER F. Watford, Fire Marshall
- R. Wiggins, Sector Supervisor Training
- L. Williams, Training Director
- J. Woodard, Assistant Plant Manager Other licensee employees contacted included operators and office personnel.
NRC Resident Inspectors
- W. Bradford, Senior Resident Inspector
- W. Ruhland, Resident Inspector
- Attended exit interview April 29, 1983
- Attended exit interview May 6, 1983 2.
Exit Interview The inspection scope and findings were summarized on April 29 and May 6, 1983, with those persons indicated in Paragraph 1 above. Additionally, a telephone conversation was conducted May 13, 1983, with licensee personnel.
All items identified during the inspection were reviewed with the licensee.
This was conducted to provide clarification of the following inspection findings: Violation 348/83-13-01,364/83-11-01: Failure to Provide Quantitative or Qualitative Acceptance Criteria for Licensed Operator Requalifica-tion, Paragraph _ - _ _ _
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~ Violation 348/83-13-02,364/83-11-02: Failure to Receive All Reactivity Manipulation Training and Failure to Properly Grade Licensed Operators Requalification Examinations, Paragraphs 8.b. and 8.c.
Violation 348/83-13-03,364/83-11-03: Failure to issue audits within Technical Specification Time Limits, Paragraph 6.a Inspector. Followup Item 348/83-13-04,364/83-11-04: Appointment of Provisionally Qualified Lead Auditors, Paragraph 6.b.
Inspector Followup Item 348/83-13-05,364/83-11-05: Followup to Proce-dure Changes, Paragraph 17.a.
Inspector Followup Item 348/83-13-06,364/83-11-06: Drawing Discrepan-cies, Paragraph.17.b.
3.
, Licensee Action on Previous Enforcement Matters Not inspected.
-4.
Unresolved Items Unresolved items were not identified during this inspection.
-5.
QA Program Review (35701) References and documents used throughout this report provided the basis for verifying the. adequacy of the licensee's QA program. The inspector inter-viewed licensee supervisory personnel and verified that they are cognizant ofl changes to the QA program. The inspector also verified that existin procedures are-in conformance with the licensee's accepted QA Program (g QA FSAR Section 17.2).
6.
Audits.(40702,40704) References: '(a) 10 CFR 50 Appendix B, Criterion XVIII, Audits (b) 10 CFR 50 Appendix B, Criterion XVI, Corrective Action (c) -FSAR Section.17.2 (Accepted QA Program) (d) ANSI N45.2.12, Draft 3, Revision 4-1974, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants (e) Regulatory Guide 1.146, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants (f) ANSI N45.2.23 - 1978, Qualification of Quality Assurance Program Audit Personnel for Nuclear Power Plants i
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, (g) Regulatory Guide 1.28, Quality Assurance Program Requirements (Design and Construction) (h) ANSI N45.2 - 1971, Quality Assurance Program Require-i.
ments for Nuclear Power Plants (1) Regulatory Guide 1.33, Quality Assurance Program Requirements (0peration) (j) ANSI N18.7 - 1972, Administrative Controls for Nuclear Power Plants (k) Technical Specifications Section 6, Administrative Controls The inspector reviewed the licensee's audit program required by References (a) - (k) and verified that auditing activities were conducted in accordance with regulatory requirements, industry guides or standards, and Technical Specifications. The following criteria were used during this review: The scope of the audit program has been defined and is consistent with - Technical Specification and QA program requirements.
Responsibilities have been assigned in writing for overall management - of the audit program.
- Methods have been defined for taking corrective action when deficiencies are identified during audits.
- The audited organization is required to respond in writing to audit findings.
Distribution requirements for audit reports and corrective action - responses have been defined.
Checklists are required to be used in the performance of audits.
- The documents listed below were reviewed to verify that these criteria had been incorporated into auditing activities: FSAR Chapter 13.4, Review and Audit .0QAPM Chapter 16, Corrective Action, 2evision 20 0QAPM Chapter 18, Audits, Revision 20 OQAPM Chapter 1, Operations Quality Assurance Program, Revision 20 0QAMP Chapter 19, Training, Revision 20 0QAPM Chapter 2, Organization, Revision 20 SAER-AP-01, SAER Organization, Revision 5 SAER-AP-02, Development and Implementation of Procedural Guidance, Revision 0 SAER-AP-03, Control of Guidance Documents, Revision 0
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, SAER-AP-04, 0QA Quality Assurance Records and Quality Assurance l Administrative Records, Revision 0 SAER-AP-05, Audit Coverage Planning, Revision 6 SAER-AP-06, Audit Implementation, Revision 6 SAER-AP-07, Qualification and Training, Revision 2 SAER-AP-08, Employee Orientation, Revision 0 SAER-AP-09, Corrective Action, Revision 0 SAER-AP-10, Reviews and Evaluations, Revision 0 SAER-AP-11, Summaries and Analysis of Audit Results, Revision 0 The inspector reviewed the following audit checklists: l SAER-WP-16 Emergency Plan SAER-WP-17 Quality Control SAER-WP-18-Test Control SAER-WP-19 Corrective Action SAER-WP-21 Spot Auditing SAER-WP-26 Off-Site Monitoring Audits SAER-WP-27 Fuel Reloading The inspector reviewed ten audits conducted during 1982 and 1983. The following are the specific audits selected for review: AREA AUDITED DATES CONDUCTED Procurement 01/31 - 02/15/83 Plant Operations 01/01 - 01/25/83 FNP Emergency Program 01/03 - 02/01/83 Four Month Interval 03/21 - 03/25/83 Environmental Monitoring 02/15 - 03/04/83 Material Control Activities 02/21 - 03/07/83 I&C STP 02/07 - 02/21/83 Quality Control 11/22 - 12/02/82 Unit 2 Refueling 10/25 - 12/02/82 Safety Program 10/25 - 12/03/82 The inspector reviewed three spot audits conducted during 1982 - 1983. The following are the specific spot audits selected for review: AUDIT DATES CONDUCTED Unit 1 Turbine Generator Inspection / Maintenance 02/25 - 03/17/83 Unit 1 Turbine Generator Inspection / Maintenance 01/21 - 01/27/83 System Lineups 11/23 - 12/02/82 The inspector reviewed the licensee's tracking and closure of audit findings. Those items identified during audits to be non-conformances are identified by corrective-action reports (CARS). All CARS are formally answered by the audited organization and reviewed by the Plant Manager. The SAER group. receives copies of the corrective action and comments on the . .. . . .. _ - _ _ _ _ _ _ _ _ _ _ _ _ _ _
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\\ . adequacy of the corrective action if required. The Vice President-Nuclear ! Generation (VP-NG) judges the adequacy of all CARS. The inspector reviewed the following CARS: 617, 633, 641, 653, 756, 650, 755, 671, 644, 744, 745 and 749.
The inspector identified that corrective actions for CARS reviewed in some - instances were not being accomplished in a timely manner as required by Reference (b).
In November 1982, a reorganization of corporate licensee personnel was conducted. Prior to this reorganization,-the General Manager - Power Generation reviewed CAR corrective actions prior to submitting them to the VP-NG for final disposition. Since the - reorganization, all CAR corrective actions are submitted directly to the VP-NG and corrective action timeliness has improved.
No violation is issued for failure to meet the requirements of Reference (b) since the reorganization of licensee personnel has appeared to eliminate the lack of timely corrective action. The corrective action for those items identified prior to this reorganization have been addressed and is ongoing. CARS 617, 633, and 744 have been closed during auditing activities conducted in April 1983.
The inspector-reviewed the timeliness of audited organization responses to audit findings. Of 123 audit findings, 4 findings were not responded to within the time limits of Reference (d). The responses to these four findings are considered anomalies; consequently, no violation is issued for failure to meet requirements of Reference (d).
Within this area, one violation and one inspector followup item were identified and are discussed in the following paragraphs.
a.
Failure to Issue Audits Within Technical Specification (TS) Time Limits TS 6.5.2.10.c requires that audit reports shall be fonvarded to the Senior Vice President and to management positions responsible for the areas audited within 30 days after completion of the audit. The inspector selected nine audits to verify TS compliance.
Based on the information from audit reports, the inspector concluded that this requirement was not being met. The licensee allows up to two weeks (SEAR.-AP-06, Paragraph 5.4) after completion of the audit to conduct a post audit conference as required by Reference (d). Due to this additional tim (which in reality is part of the audit) the licensee did not comply with TS 6.5.2.10.C.
Documentation of post audit conferences dates was provided to the inspector for audits reviewed. This documentation was obtained from daily work note pads but was not included in the actual audit reports. This failure to meet requirements of TS 6.5.2.10.c constitutes a violation (348/83-13-03,364/83-11-03).
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b.
Appointment of provisionally Qualified Lead Auditors SAER-AP-07, Paragraph 7.0 allows' the Manager SAER to provisionally qualify lead auditors. This provisional qualification is contrary to Reference (f). No personnel have been provisionally qualified as lead auditors. Licensee QA staff lead auditors meet Reference (f) require-ments. Until SAER-AP-07 is revised to fully meet requirements of Reference (f), this is identified as an inspector followup item (348/83-13-04,364/83-11-04).
7.
Training (417000) References: (a) Technical Specifications Section 6.4, Training (b) ANSI N18.1-1971, Selection and Training of Nuclear Power Plant Personnel-(c) Regulatory Guide 1.8, Personnel Selection and Training, March, 1971 (d) Regulatory Guide 8.13, Instruction Concerning Prenatal Radiation Exposure (e) Regulatory Guide 8.27, Radiation Protection Training for Personnel at Light-Water Cooled Nuclear Power Plants (f) Operations Quality Assurance Manual, Chapter 19, Training (g) FSAR, Chapter 13.2, Training The inspector reviewed the licensee's training programs required by References (a) through (g) to verify that activities were conducted in " acccrdance with regulatory requirements, industry guides or standards, and Technical Specifications. The following criteria were used during this review: ' - The program complies with regulatory requirements and licensee commitments.
- The program covers training in the areas of administrative controls and - procedures, radiological health and safety, industrial safety, security procedures, the emergency plan, quality assurance,' fire fighting, and prenatal radiation exposure.
, , ' The QA/QC personnel training program includes indoctrination in company - policies,-Quality Assurance Manuals, Technical Specifications, the Emergency Plan, and appropriate codes and standards.
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The documents listed below were reviewed to verify that previously listed criteria had been incorporated into licensee training activities: FNP-0-AP-27, Conduct of Operations Training Group, Revision 3 FNP-0-AP-45, Farley Nuclear Plant Training Plan, Revision 3 Farley Nuclear Plant Master Training Plan Operations Curriculum Guide The inspector reviewed training records of approximately 30 licensee and contractor personnel and verified that they were given training as required.
Within this area, no violations or deviations were identified.
8.
RequalificationTraining(41701) References: (a) 10 CFR 55, Appendix A, Requalification Programs for Licensed Operators of Production and Utilization Facilities (b) NUREG 0737, Clarification of TMI Action Plan Require-ments (c) Technical Specifications Section 6, Administrative Controls (d) Regulatory Guide 1.8, Personnel Selection and Training, second proposed Revision 2 (e) ANSI N18.1-1971, Selection and Training of Nuclear Power Plant Personnel (f) Letter from H. R. Denton, Director NRR, to All Power Reactor Applicants and Licensees. Subject: Qualifica-tions of Reactor Operators, dated March 20, 1980 (g) FSAR Chapter 13.2.2, Retraining Program The inspector reviewed the licensee's requalification training program required by References (a) through (g) to verify that activities were conducted in accordance with regulatory requirements, industry guides or standards, and Technical Specifications. The following criteria were used during this review: Determination that changes to the requalification training program were - in conformance with NRC requirements.
- Documentation that required procedure reviews were performed.
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Lesson plans are prepared for subject matter presented during the - requalification program.
Determination that all aspects of the requalification program were - being adequately addressed.
The documents listed below were reviewed to verify that previously listed criteria had been incorporated into licensee training activities: FNP-0-AP-16, Conduct of Operations - Operations Group, Revision 11 FNP-0-AP-27, Conduct of Operations - Training Group, Revision 3 FNP-0-AP-45, FNP Training Plan, Revision 3 Farley Nuclear Plant Master Training Plan Operations Curriculum Guide The document listed above implement the requirements of References (a) through (g). The inspector reviewed these documents to determine adherence to requirements. The inspector reviewed the following areas: retraining conducted in 1981, 1982, and to date in 1983; annual written examinations and individual's responses; documentation of required control manipulation; schedule for conducting lectures and prepared lesson plans; and, participa-tion in an accelerated training program when applicable. The training records of nine licensed operators were reviewed.
During this review, various records were requested by the inspector. The retrievability of these records was very time consuming and difficult to retrieve from the system being used at Farley Nuclear Station. One such record, a licensed operator accelerated retraining examination, could not be retrieved. Since this appears to be an isolated example, no violation will be issued for this failure ~to maintain required training records.
Within this area, two violations were identified and are discussed in the following paragraphs.
a.
Failure to Provide Qualitative or Quantitative Acceptance Criteria for Licensed Operator Requalification 10 CFR 50 Appendix B, Criterion V, and the accepted Quality Assurance Program (FSAR Section 17.2.5) require that procedures include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Farley Nuclear Station has provided various documents (those listed above) to detail the requirements identified in References (a) through (g) above.
It appears that as a result of using various documents several areas are not addressed to adequately provide quantitative or qualitative acceptance criteria. Example of these areas are identified below: 1) Reference (f), Enclosure 1, Section C.2 specifies the criteria for requiring a licensed individual to participate in accelerated _ - - - - - - - - -
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requalification training. Although Farley Nuclear Station is conforming to these requirements, they are not qualitatively or quantitatively specified in their programmatic documents.
2) Reference (f), Enclosure 1, Section C.3 identifies reactivity control manipulations that are required to be incorporated into a licensee's requalification program. All reactivity manipulations specified by this enclosure have not been incorporated into requalification program (i.e. loss of instrument air).
3) Reference (a), Section 3.d, requires that each licensed operator review the contents of all abnormal and emergency procedures on a regularly scheduled basis. The licensee's requalification program has not established the measures to specify how to accomplish this requirement.
In addition, the time frame for this review has not been established.
4) 10 CFR 55.31(e) requires that if a licensed operator has not been actively performing the functions of an operator or senior operator for a period of four months or longer, he shall demonstrate to the Commission that his knowledge and understanding of facility operation and administration are satisfactory prior tc resuming licensed activities. Measures have not been established to formally document removal and reinstatement requirements for. personnel who are placed in this situation.
The examples cited above are not to be considered all inclusive. The examples identified above are collectively identified as a violation (348/83-13-01,364/83-11-01) of a failute to provide qualitative or quantitative acceptance criteria for determining that activities important to safety have been satisfactorily accomplished.
b.
Failure to Receive All Reactivity Manipulation Training Reference (c), Section 6.4.1, states that a retraining program shall be maintained to meet or exceed the requirements and recomendations specified in Section A and C of Enclosure 1 of Denton's March 28, 1980 letter. Denton's March 28, 1980, letter, Enclosure 1, Section C.3, requires that.the control manipulations identified in Enclosure 4 be performed as detailed in the enclosure. A review of training records of selected personnel identified that one of these manipulations (Loss of Instrument Air) had not been performed by any of the selected personnel. Discussions with the Training Director identified that this was not being covered in the requalification program.
Additionally, two other personnel had not received all the manipulations required, each had missed the same manipulation. These examples cited above are combined with the example discussed in Paragraph 8.c to collectively constitute a violation (348/83-13-02, 364/83-11-02) for failure to follow a Technical Specificatior. require-ment.
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c.
Failure to Properly Grade an Examination Reference (c), Section 6.4.1 states a retraining program shall be maintained to meet or exceed the requirements and recommendations specified in Sections A and C of Enclosure 1 of Denton's March 28, 1980 letter. Section C.2 requires a licensed individual to participate in accelerated requalification if he scores less than 80% overall or 70% in a category. The inspector reviewed ten examinations for grading problems, i.e., calculation errors.
In this area the inspection identified mathematical errors on three of the exams. One error identified that an individual had been given a grade of 70% for a category due to mathematical error. The individual's grade should have been 66.7%. The inspector identified this to plant supervision and the licensed operator was removed from licensed duties and placed in accelerated training. This failure to place an individual in an accelerated training program upon scoring less than 70% on an annual requalification examination is combined with the examples identified in Paragraph 8.b above to collectively constitute a violation (348/83-13-02,364/83-11-02) for failure to follow a Technical Specification requirement.
9.
QA/QC Administration (35751) References: (a) 10 CFR 50 Appendix B, Quality Assurance Crituia for Nuclear Power Plants and Fuel Reprocessing Plants (b) Regulatory Guide 1.28, Quality Assurance Program Requirements (Design and Construction) (c) ANSI N45.2-1971, Quality Assurance Program Requirements for Nuclear Power Plants (d) Technical Specifications Section 6, Administrative Controls The inspector reviewed the licensee's QA/QC administration program required by References (a) - (d) and verified that QA/QC administration requirements were conducted in accordance with regulatory requirements, industry guides or standards, and Technical Specifications. The following criteria were used for this review: - The licensee's QA program documents clearly identify those structures, systems, components, documents, and activities to which the QA program applies.
- Procedures and responsibilities have been established for making changes to QA program documents.
- The licensee has established administrative controls for QA/QC procedures which assure procedure review and approval prior to implementation, control of changes and revisions, and methods and control for distribution and recall.
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, , - Responsibilities have been established to assure overall review of the effectiveness of the QA program.
Methods exists to modify the QA program to provide increased emphasis - on identified problem areas.
The documents listed below were reviewed to verify that these criteria had been incorporated into QA/QC administration activities: FSAR Chapter 13.4, Review and Audit FSAR Chapter 17.3, Joseph M. Farley Nuclear Plant Quality Assurance Q-List CEAR-AP-02, Development and Implementation of Procedural Guidance, Revision 0 SAER-AP-09, Corrective Action, Revision 0 Within this area, no violations or deviations were identified.
10. Housekeeping / Cleanliness Program (54701) References: (a) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (b) Regulatory Guide 1.39, Housekeeping Requirements for Water-Cooled Nuclear Power Plants (c) ANSI N45.2.3-1973, Housekeeping During the Construction Phase of Nuclear Power Plants (d) Regulatory Guide 1.33, Quality Assurance Program Requirements (0peration) (e) ANSI N18.7-1972, Administrative Controls for Nuclear Power Plants (f) Regulatory Guide 1.37, Quality Assurance Requirements for Cleaning of Fluid Systems and Associated Components of Water Cooled Nuclear Power Plants (g) ANSI N45.2.1-1973, Cleaning of Fluid Systems and Associated Components During Construction Phase of Nuclear Power Plants i _. _ _ _
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The inspector reviewed the licensee's housekeeping program required by References (a) - (g) and verified that housekeeping / cleanliness activities were conducted in accordance with regulatory requirements and industry guides or standards. The following criteria were used during this review: - That administrative controls for general housekeeping have been established.
- That responsibilities for implementing housekeeping requirements have been delineated.
That administrative controls have been established for cleanliness - practices.
The documents listed below were reviewed to verify these criteria had been incorporated into housekeeping / cleanliness practices: FNP-0-AP-35, General Plant Housekeeping and Cleanliness control, Revision 8 FNP-0-AP-44, Cleanliness of Fluid Systems and Associated Components, Revision 4 FSAR Section 17.2.13, Handling, Storage, and Shipping FNP-0-AP-52, Equipment Status Control and Maintenance l Authorization, Revision 2 0QAPM Chapter 20, Cleanliness and Housekeeping, Revision 20 The inspector reviewed approximately 60 maintenance requests (MRs) and verified that cleanliness requirements were consistent with work activities.
The inspector interviewed maintenance planners to determine how cleanliness requirements were assigned to work activities. The inspector interviewed the Fire Marshall and verified housekeeping inspections were being performed.
The inspector reviewed tb results of five semi-annual housekeeping inspections performed by the Assistant Plant Manager and verified that identified deficiencies were corrected.
Within this area, no violations or deviations were identified.
11. Nonroutine Reporting Program (90714) References: (a) 10 CFR 21, Reporting of Defects and Honcompliance (b) Technical Specifications Section 6, Administrative Controls (c) Regulatory Guide 1.16, Reporting of Operating Informa-tion - Appendix A, Technical Specifications - _ _ _ - - _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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The inspector reviewed the licensee's nonroutine reporting program required by References (a) - (c) and verified that reporting requirements were conducted in accordance with regulatory requirements, industry guides or standards, and Technical Specifications. The following criteria were used during this review: - Administrative controls have been established for prompt review of off-normal events to assure identification of safety-related events.
Administrative controls have been established for prompt review of - planned and unplanned maintenance and surveillance testing activities to assure identification of prospective or actual violations of Technical Specifications requirements.
- Administrative controls have been established for completion of corrective actions relating to safety-related operating events.
- Administrative controls have been established for reporting safety-related events internally and to the NRC.
- Administrative controls have been established for recognition and reporting of events that are covered by 10 CFR 21.
- Administrative controls have been established for review and evaluation of vendor bulletins and circulars.
The documents listed below were reviewed to verify that these criteria had been incorporated into reporting activities: FNP-0-AP-65, FNP Nuclear Nuclear Experience Evaluation Program, Revision 0 FNP-0-AP-63, Conduct of Operations, Systems Performance Group, Revision 1 Within this area, no violations or deviations were identified.
12. Test and Experiments Program (37703) References: (a) FSAR Section 13.4.2.1.2.1, Plant Operations Review Committee and Chapter 17.2.3, Design Control (b) Technical Specifications 6.5.1, Plant Operations Review Committee; 6.5.2, Nuclear Operations Review Board; 6.5.3, Technical Review and Control (c) FNP-0QAPM, Chapter 3.0, Design Change Control and Chapter 11.0, Test Control (d) FNP-0-AP-2, Plant Operations Review Committee, Revision 6 .. . .. . _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _
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(e) FNP-0-AP-4, Control of Plant Documents and Records, Revision 5 (f) FNP-0-AP-8, Design Modification Control, Revision 6 (g) FNP-0-AP-5?, Equipment Status Control and Maintenance Authorization, Revision 2 (h) SAER-AP-10, Administrative Procedure for Reviews and Evaluations, Revision 0 The references were reviewed to verify that: A formal method had been established to handle all requests or - proposals for conducting special tests involving safety-related components.
Special tests are performed in accordance with approved procedures.
- - Responsibilities have been assigned for reviewing and approving special test procedures.
A system, including assignment of responsibility, has bec.n established - .to assure that special tests are reviewed.
Responsibilities have been assigned to assure that a written safety - evaluation 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 change in Technical Specifications.
The test and experiments activity is incorporate in Reference (f). Changes to the plant design, which includes provisions for special tests, are initiated by production change requests (PCRs) and are activated with production change notices (PCNs). Upon receipt of an official review copy of a PCN, the plant modifications supervisor evaluates the design change and forwards the evaluation to the plant operations review committee (PORC).
If PORC decides that the design change involved an unreviewed safety question, the change is reviewed by the nuclear operations review board (NORB) prior to implementation. The responsibility for revising and issuing drawings is the document control supervisor and this is recorded in Section 10 of the Design Change Review Form.
The following PCNs were reviewed: PCN B - 82 - 1319 Duplication of Raceway Numbers PCN B - 82 - 1320 Emergency Power Board Handrails PCN S - 82 - 1325 Steam Generator Blowdown Drain Pump Pressure Gages . _ - -- , -- _ -. .
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- , PCN P'- 82 - 1327 Steam Chest Governor Valve Modification- _ PCN 5 - 83(- 1348 Program Changes for Steam Dump and Rod Speed Control , PCN P'- 83 - 1369 Removal of Circulating Water Tunnel Dewatering Examination of records showed that all signatures on the Design Change Review Forms were present with the exception of the Document Control Supervisor's signature. 'This indicates that there are a number of completed PCN's awaiting updating of drawings. An internal engineering review conducted by the SEAR staff on January 11, 1983, noted that there were many ' completed PCNs awaiting final drawings; this was identified as TS.4.
Criterion J. Discussion' with the Plant Modification Supervisor showed that he w6s aware of the' delay in updating drawings and that steps had been taken to expedite this activity. Howevar, all released controlled drawings are identified when specific PCNs need. to be incorporated so that the as-built condition can be readilf established.
' Audits of plant changes and modif.ications were_ examined'. Aud'it 82/3 was conducted November 5 - December-15, 1981, and audit 82/18 conducted l October 25 - November 30,1982. /0ne noncompliance remains open at this time but this does not impact safety ' issues, Within this area, no violations or deviations were identified.
~ 13. Records Program (39701) - -References: (a) FSAR 17.2.17, Quality Assurance Records (b) Technical Specification 6.10, Record Retention ' (c) 0QAPM Chapter 17, Quality Assurance Records, Revision 20 (d) FNP-0-AP-4, Control of Plant Documents and Records, Revision 5 r (e) FNP-0-AP-8, Design Modification and Control, Revision 6-(f) FNP-0-AP-16, Conduct of Operations ' Operations Group, . Revision 11 The references were reviewed to verify that provisions had been made to maintain various types of quality records and that responsibilities had been assigned to carry out records storage requirements.
Procedures were reviewed to ensure that they specifically require records to be retained in the station permanent records storage facility and that adequate storage controls were implemented to preserve and retrieve these records. To verify implementation of the program, records were retrieved, examined for completeness, and returned to storage.
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1 . The following reactor trip reports were reviewed: Trip # 117 8/28/82 Trip at 100% power, low-low steam generator level in C steam generator Trip # 118 9/27/82 Trip at 100% power, reactor coolant pump low flow trip (breaker open indication) Trip # 119 10/18/82 Trip at 100% power, low-low steam generator level in C steam generator Daniel's insulator backed into manual over-speed trip , , ' Trip # 124 12/02/82 Trip at 100% power, steam flow greater than - y . feed flow and steam generator level low.
~ Trip #'125 12/03/82 Trip at 6% power.. operator error in underfeed- _ > ' ing then overfeeding.
Trip # 126 01/14/83 Taking unit down for refueling outage, low-low level in B steam generator.
' Trip # 126 is the only trip recorded in 1983 , ? to date for either unit.
The following production change requests were reviewed: Hi PCR 82 - 1323'KS Penetration seals, controlled drawing requi:ed ' PCR 82 - 1324 KT Waste gas compressors drain line insulation
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.PCR 82 '1325 KU Steam generator blowdown drain pump pressure gages PCR'82 - 1326 LB RCCA change tool storage fixture ~
, PCR 82 '1327 LG Steam chest governor valve modification PCR 821-1328 LI Radiation monitors, R11 and R12 , ! <PCR 82 - 1329 LK.. Recycle holdup tank diaphragm ! 1.PCR 82 - 1332 Fuel assembly damage, upflow conversion l ) . ' ! a The following purchase order packages were reviewed to ensure that all . records from initial request through final receipt inspection acceptance reports,were available: P0.'83874, 84480, 84758, 85402, 85643, and 86196 x v The superviser stated that existing records and future records will be ~ s incorporated ~into the recently installed Honeywell Brown Multex Nuclear Records System. There are currently 12 APC0 staff and 5 contract support personnel hngaged in records management and document control activities.
The support / personnel are involved in construction change notice review and the keying-in of-record data. LThe document control center currently has a storage problem which is recognized by management.
Preparations are in hand for installing high rise cabinets,in the existing vault and for the storage of all radiographs in the construction vault.
' Within this area, no violations or deviations were identified.
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y - ;Q r i-y /34. DocumentlContfulProgram(39702) I , e s- , - . " J'. C M ferences:.f(a) FSAR 13.5, Plant Procedurcs; 17.2, Operations Quality ' ' { _ ;-{f /.., Assurance Program; 17.2.6, Document Control '- . +f r' ~ / Wj - (b) Technical Specification 6.5.1.6,. Program Operating f M ReviewCommittee(PORC) Responsibilities;6.5.3.1, - v Technical Review and Control;.6.8, Procedures , . ,
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, , ' ,.. Q (c) 0QAPM Chapter 3, Design Control, Revision 20 (d) 0QAPM Chapter 5, Instructions, Procedures and Drawings, .,, 'v Revision 20 j ', / , "l
(e) 0QAFM Chapter 5, Docuinent Control, Revision 7.0 ' ,- ' t.. f , , "o<f (f) FNP-0-AP-1,Developmdnt, Review,andApprovalofPlant " Procedure, Revision 10 s' . . (g) FNP-0-AP-4, Control of Plant Documents and Recofds, / Revision 5 , ' ' . .~The, references were reviewed to verify that they met requirements of the QA Program. The_ inspector verified that controls appear to be adequate and ' that ttey are being implemented. Controls are maintained for drawings, specification ^s, procedures, manuals, records, and for revisions to controlling procedures and documents. Controls of all QA records on site are-regulated byfapproved procedures and these pr6cedures are properly issued and revised in accordance with requirements of Reference (f) and Reference (g).
During the preparation or revision.of safety related precedures, a safety evaluation is made in'accordance with 10 CFR 50.59 when' applicable.
Adequate reviews appear to be made to ensure technical correctness and provision for further review by PORC and by the Nuclear Cperations Review Board. A log of approved procedures and the master copy is maintained by ' the Document Control Supervisor's staff; distribution is in accordance with Reference (g). The control file controls the receipt, processing, storage, retrieval, and distribution of all controlled documents. Satellite files are located in selected locations in the plant including the training center. Plant drawings are maintained on 35mm aperture cards. All other ncn-drawing docur.ents are maintained on 16mm film.
Audit 82/7, Plant Administration, was conducted April 12 through May 5, 1982. The deficiencies identified were subsequently resolved. A recent audit on plant administration which incorporates the document control activity was conducted April 1 through 22, 1983. The report is not yet issued. No deficiencies were identified during this audit.
Within this area, no violations or deviations were identifie C
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l 15. Procurement Program (38701) References: (a) FSAR 17.2.4, Procurement Document Control 17.2.6, Document Control 17.2.7, Control of Purchased Material, Equipment and Services (b) 0QAPM Chapter 4, Procurement Document Control Chapter 7, Control of Purchased Material, Equipment and Services (c) FNP-0-AP-9, Procurement and Procurement Document Control, Revision 8.
(d) G0-NG-3, Procurement for Master Bid List Input, Revision 1 (e) G0-NG-9, Administrative Control of Plant Services Approved Suppliers List, Revision 1 (f) Nuclear-Generation Department Plant Services Approved Suppliers List, Revision 6 The references were reviewed to verify that administrative controls were established for preparation, review, approval, and revision of procurement documents.
Implementation of the program was verified by reviewing % procurement documents of several safety-related items and verifying that they were prepared in accordance with administrative controls, that items . were purchased from qualified vendors, and that documents required vendors " ( to supply the appropriate certification of quality, The program was also reviewed to verify that acceptable methods were being used to qualify vendors which provide quality goods or services, that these procedures reqrired maintenance of records of supplier qualifications and audits, and ,
that responsibilities have been assigned to perform the vendor qualification - program.
, Material requisitions are used to initiate the procurement of materials, equipment and services except for those procurement actions already covered by an ongoing blanket order or a letter of request. Material / Purchase requisitions are forwarded to APC0 HQ for conversion to purchase orders.
Minor purchase orders used for an emergency or one-time purchase are sent directly to the vendor from the plant site. The materials supervisor currently has five clerks aho are engaged in procurement activities.
The following in-process purchase requisitions were reviewed: PR 84996 Drum Tilter PR 84998 Personnel Airlock Seal Retaining Plate PR 84999 W2500 Computer Card Stack Repairs PR 8500 Crane Relief Valve
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The following purchase orders were reviewed to verify that administrative controls wer? effective: P0 84758 PRX51564 Copes Vulcan P0 84480 PRX48472 Fairbanks Morse Eng.
P0 83874 PRX48226 Namco Controls P0 86196 PRX51188 Namco Controls P0 85643 PRX48437 Burns Engineering P0 85402 PRX51545 Mack Electric Supply Audit 83/03, Procurement of materials and services, was conducted January 31 to February 15, 1983, by the site SAER. They identified that there are discrepancies between the Q-list and other documents as to which items are sa fety-related. However, the discrepancies appear to be on the conservative side.
Within this area, no violations or deviations were identified.
16. Receipt, Storage and Hedling of Equipment and Materials Program (38702) References: (a) FSAR 17.2.13, Handling, Storage, and Shipping 17.2.14, Inspection, Testing, and Operating Status 17.2.15. Nonconforming Materials, Parts, or Components 17.2.8, Identification and Control of Materials, Parts and Components (b) 0QAPM Chapter 7, Control of Purchased Material, Equipment and Services, Revision 20 Chapter 8, Identification and Control of Materials, Parts and Components, Revision 20 Chapter 13, Handling, Storage and Shipping, Revision 20 (c) FNP-0-AP-20, Receipt Inspections, Revision 4 (d) FNP-0-AP-21, Identification and Control of Materials, Parts and Components, Revision 5 (e) FNP-0-AP-22, Nonconformance Control / Deficiency Reporting, Revision 3 (f) FNP-0-AP-23, Handling, Storage, and Shipping of Materials, Components, and Equipment, Revision 3 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 verified that administrative controls had been established concerning receipt inspection of safety-
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related materials, prepara' tion and retention of required documentation, control of acceptable nonconforming and conditional release items, and control of items in storage.
Implementation of the program was reviewed by selecting several safety-related items in storage and verifying document and item control to be in accordance with the program.
Warehouses, including complex III formerly used for housing construction material and equipment, were inspected to verify that equipment remaining in storage was retained in the correct level of storage environment. Specific equipment examined included reactor coolant pump internals and double drain seals, flexitallic gaskets, spring anti-roll snubbers, double pole circuit breakers, reactor cavity hydrogen dilution fan and a large number of packaged spare parts. Dip seal coating of steel studs was observed being performed by Daniel Construction personnel in complex III during this inspection. The inspector observed that warehousing zones were kept clean and all nonconforming items segregated and identified. Stored items in the operations warehouse were clearly identified with a' prominent tag and a shelf life date. The QA Hold Areas within the warehouses were kept locked.
The warehouse organization was discussed with the supervisor. He stated that he had 5 clerks for procurement activities, 4 storekeepers, 21 warehousemen and 1 nuclear operator (janitorial services). The warehouse inventory had 27,000 line items and is in the process of converting manual inventory controls to electronic inventory controls. The terminal display system is active, in use, and should be completely converted by the end of 1983.
The following material receiving inspection reports (MRIR) were examined and compared with the initial material requisition, purchase requisition (PR), purchase order (PO) and any subsequent amendments to these documents.
P0 83874; PRX48226 Light Switch Namco Controls P0 84480; PRX48472 Motor Pump Assembly Fairbank Morse P0 84758; PRX51564 Cage Spacer Copes Vulcan-PO 85402; PRX51545 Wire Connector Mack Electric P0 85643; PRX48437 Panel Element Burns Engineering P0 86196; PRX51188 Limit Switch Namco Controls Within this area, no violations or deviations were identified.
17. DesignModifications(37702) References: (a) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (b) Regulatory Guide 1.64, Quality Assurance Requirements for The Design of Nuclear Power Plants (c) ANSI N45.2.11-1974, Quality Assurance Requirements for the Design of Nuclear Power Plants _ - _ _ _ _ _ _ _
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(d) Regulatory Guide 1.33, Quality Assurance Program Requirements (0peration) (e) ANSI N18.7-1972, Administrative Controls for Nuclear Pmver Plants (f) Regulatory Guide 1.28, Quality Assurance Program Requirements (DesignandConstruction) (g) ANSI N45.2-1971, Quality Assurance Program Requirements for Nuclear Power Plants (h) Technical Specifications Section 6, Administrative Controls The inspector reviewed the licensee's modification prcgram required by References (a) - (h) and verified that modification activities were conducted in accordance with regulatory requirements, industry guides or standards, and Technical Specifications. The following criteria were used during this review: Procedures have been established for control of plant change notices - (PCNs) Procedures and responsibilities for PCNs have been established.
- - Administrative controls for PCN document control have been established.
Administrative controls assure that PCNs are incorporated into plant - procedures, operator training, and the updating of drawings.
Controls have been developed that define channels of communication - between design and responsible organizations.
Administrative controls require PCN documentation and records be - collected and stored.
- Controls require implementation of PCNs be in accordance with approved procedures.
Controls require post-modification testing be performed per approved - , ' test procedures and the results evaluated.
- Responsibility has been assigned for identifying post-modification testing requirements.
- Responsibility and method for reporting PCNs to the NRC in accordance with 10 CFR 50.59 has been identified.
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Similar methods and controls were also verified for use of temporary modifications (jumpers and disconnected leads).
The documents listed below were reviewed to verify that these criteria had been incorporated into PCN activities.
FSAR, Chapter 17.2.1, Organization FSAR, Chapter 17.2.3, Design Control FSAR, Chapter 13.4, Review ano Audit 0QAPM Chapter 3, Design Control FNP-0-AP-8, Design Modification Control, Revision 6 FNP-0-AP-4, Control of Plant Documents and Records, Revision 5 FNP-0-AP-24, Test Control, Revision 2 FNP-0-AP-31, Quality Control Measures, Revision 6 FNP-0-AP-52, Equipment Status Control and Maintenance Authorization, Revision 2 FNP-0-AP-13, Control of Temporary Alterations, Revision 1 , G0-NG-11, Design Change and Design Control, Revision 1 The inspector selected three PCNs (78-295, 5-80-653.6 Revision 5, and , 80-876) and verified that the documentation had been completed in accordance l with FNP-0-AP-8. The inspector reviewed storage of completed PCNs in the ! Document Control Center. The licensee has several file cabinet drawers of PCNs that have been installed but are awaiting drawing changes before being documented as completed. The licensee also has several file cabinet drawers of PCNs that are awaiting procedure and drawing revisions prior to being l documented as completed.
Increased licensee attention has been focused to i fully document and thereby complete these PCNs. The modification group has ' records indicating what discipline groups need to update procedures to reflect PCN installation. The operations group is up-to-date with the exception of the very latest PCN installations. Other discipline groups are up to several months behind in updating procedures.
Within this area, two inspector followup items were identified and are discussed in the following paragraphs.
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Followup To Procedure Changes The modification group notifies various discipline groups of implementa-tion of PCNs.
It is the responsibility of these discipline groups to review the PCN and determine if their procedures need updating. The modification group tracks when the notice of PCN implementaticn is sent to the discipline groups; however, they do not request a date-to respond from the discipline groups when the procedures are updated.
Additionally, FNP-0-AP-8 does not include a time for procedure changes updating when PCN implementation is complete. Until FNP-0-AP-8 is upgraded to include a time limit for procedure updating upon PCN implementation, this is identified as an inspector followup item (348/83-13-05,364/83-11-05).
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Drawing Discrepancies A comparison of drawings was made between the Document Control Center and the Control Room. The following are the specific drawings selected for review: D175000 Sheet 1 Revision 5 D175000 Sheet 2 Revision 10 D175002 Sheet 1 Revision 10 D175002 Shcet 2 Revision 12 D175002 Sheet 3 Revision 3 The inspector identified that control room drawings D175000 Sheet 2 and D175002 Sheet 1 did not correctly identify all change notices (CNs) required by the document control center drawings. No violation is being issued for failure to control drawings since a similar observa-tion was identified by an INP0 inspection and corrective action is currently being planned to implement the INP0 recommendations. Until the INPO recommendations are fully implemented, this item is identified as an inspector followup item (348/83-13-06, 364/83-11-06).
18. Test and Measurement Equipment Program (61724) References: (a) Regulatory Guide 1.33, Quality Assurance Program Require-ments,(0perational) (b) ANSI N45.2.4-1972, Installation, Inspection and Testing of Electrical Equipment (c) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (d) Technical Specification Section 6, Administrative Controls The inspector reviewed the licensee's test and measurement equipment program required by References (a) - (d) and verified that test and measurement equipment activities were conducted in accordance with regulatory require-ments, industry guides or standards, and Technical Specifications. The following criteria were used during this review: Criteria and responsibility for assignment of calibration - frequency have been established.
An equipment inventory list has been established which - includes the equipment which will be used, the calibration frequency of each piece of equipment, the calibration standard for each piece of equipment, and the calibration procedure to be used for each piece of equipment.
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Requirements exist for uniquely identifying the calibration - date for each piece of equipment.
Requirements exists for prohibiting use of er.uipment which - have not been calibrated witnin the prescribed frequency.
Requirements exist for controlling and evaluating out-of- - calibration equipment.
Requirements exist for incorporating new equipment into - the existing program.
The documents listed below were reviewed to verify that these criteria had been incorporated into test and measurement equipment activities: FSAR Section 13.5, Plant Procedures FSAR Section 17.2.12, Control of Measuring and Test Equipment 0QAPM Chapter 12, Control of Measuring and Test Equipment, t Revision 20 FNP-0-AP-11, Control and Calibration of Test Equipment and Test Instrumentation, Revision 4 The inspector interviewed I&C and storeroom personnel to verify controls I had been established for controlling test and measurement equipment. An l inspection was conducted of the calibration laboratory and issuance ' locations of I&C, electrical and mechanical test and measurin Theinspectorselectedfourpiecesofcalibrationequipment(gequipment.
FNP-FEC-0500, -HPEC-0600, -WTT-0002, and -MGK-0010) and verified they were calibrated by instruments whose calibration was traceable to the National Bureau of , r Standards.
Within this area, no violations or deviations were identified.
19. Surveillance Testing and Calibration Control Program (61725) References: (a) ASME Boiler and Pressure Vessel Code, Section XI (b) Technical Specifications a (c) Regulatory Guide 1.33, Quality Assurance Program Requirements,(0perational) (d) ANSI N18.7 - 1972 Administrative Controls for Nuclear Power Plants = - - _ - _ -
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The inspector reviewed the licensee's surveillance testing and calibration control program required by References (a) - (d) and verified that surveillance testing and calibration control activities were conducted in accordance with regulatory requirements, industry guides or standards, and Technical Specifications. The following criteria were used during this review: A schedule for surveillance testing, calibration, and inservice - inspection has been established which includes frequency, responsi-bilities for performance, and testing status.
Responsibilities have been assigned to maintain this schedule up-to- - date.
Requirements have been established for conducting testing in accordance - with approved procedures which include appropriate acceptance criteria.
- Responsibilities have been assigned for review and evaluation of test data.
Responsibilities have been assigned for assuring that required - schedules for surveillances are satisfied.
The inspector also verified that similar controls have been established for calibration of instrumentation not specifically identified in Technical Specifications. The documents listed below were reviewed to verify that these criteria had been incorporated into surveillance testing and calibra-tion control activities: FNP-0-AP-5 Surveillance Program Administrative Control, Revision 5 FNP-0-AP-31, Quality Control Measures, Revision 6 FNP-0-AP-63, Conduct of Operations - Systems Performance Group, Revision 1 FNP-0-AP-57, Preservice and Inservice Inspections, Revision 3 The inspector reviewed the licensee's master index and cross reference of surveillance activities required by Technical Specifications (TS) to verify that surveillance procedures clearly define activities required by TS. The inspector. randomly selected surveillance procedures and verified these procedures contained calibration requirements for gauges and acceptance criteria for surveillances performed.
Within this area, no violations or deviations were identified.
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20. Maintenance Program (62702) Reference: (a) Technical Specifications Section 6, Administrative Procedures (b) Regulatory Guide 1.33, Quality Assurance Program Requirements,(0perational) (c) ANSI N18.7-1972, Administrative Controls for Nuclear Power Plants (d) ANSI N45.2.1-1973, Cleaning of Fluid Systems and Associated Components (e) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (f) ANSI N45.2.3-1973, Housekeeping During Construction Phase of Nuclear Power Plants i The inspector reviewed the licensee's maintenance program required by References (a) - (f) and verified that maintenance activities were conducted in accordance with regulatory requirements, industry guides or standards, and Technical Specifications. The following criteria were used during this review: Written procedures were established for initiating requests for routine - and emergency maintenance.
- Criteria and responsibilities for review and approval of maintenance requests were established.
- Criteria and responsibilities that form the basis for designating the activity as safety or non-safety-related were established.
- Criteria and responsibilities were designated for performing work inspection of maintenance activities.
- Provisions and responsibilities were establshed for the identification of appropriate inspection hold points related to maintenance activities.
Methods and responsibilities were designated for performing functional - test of structures, systems, and components following maintenance work and/or prior to their being returned to service.
- Administrative controls for maintenance activities require maintenance records will be prepared, assembled, and reviewed prior to transfer to storage facilitie __ _ _ - -. - __ _ ____ _--___ _ _________ , . .
l Work control procedures require special authorization for activities - involving welding, open flame, or other ignition sources that take cognizance of nearby flammable material.
Responsibilities for equipment control have been clearly defined.
- A preventive maintenance program has been established.
- Administrative controls for special processes have been established.
- Administrative controls for housekeeping / cleanliness have been - established.
The documents listed below were reviewed to verify that these criteria had been incorporated into maintenance activities: FNP-0-AP-52, Equipment Status Control and Maintenance Authorization, Revision 2 FNP-0-AP-53, Preventive Maintenance Program, Revision 2 FNP-0-AP-44, Cleanliness of Fluid Systems and Associated Components, Revision 4 FNP-0-AP-14, Safety Clearance and Tagging, Revision 5 FNP-0-AP-15, Maintenance Conduct of Operations, Revision 7 FNP-0-AP-16, Conduct of Operation - Operations Group, Revision 11 FNP-0-AP-13, Control of Temporary Alteration, Revision 1 FNP-0-AP-38, Use of Open Flame, Revision 1 FNP-0-AP-35, General Plant Housekeeping and Cleanliness Control, Revision 8 FNP-0-AP-28, Plant Lubrication Program, Revision 6 FNP-0-RCP-2, Radiation Work Permit, Revision 9 FNP-0-GMP-1, Preventive Maintenance Procedure, Revision 4 FNP-0-IMP-0.3, Instrumentation and Control Preventive Maintenance, Revision 0 FNP-0-AP-31, Quality Control Measures, Revision 6 .... - _ _ _ _ _ _ _ _ - _ _ _ - _ _ _ _ _ _ _ _ _
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Specific documents relative to housekeeping / cleanliness are referenced in Paragraph 10.
Within this area, no violations or deviations were identified.
, 21. OffsiteSupportStaff(40703) References: (a) 10 CFR 50 Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (b) Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation) (c) ANSI N18.7-1972, Administrative Controls for Nuclear Power Plants (d) Regulatory Guide 1.28, Quality Assurance Program Requirements (Design and Construction) (e) ANSI N45.2.1 Quality Assurance Program Requirements for Nuclear Power Plants (f) Technical Specification Section 6, Administrative l Controls I ' The inspector reviewed the licensee's offsite support staff required by References (a) - (f). The inspector interviewed the following personnel: R. P. Mcdonald Vice President Nuclear Generation H. 0. Thrash Manager Nuclear Operations and Administration R. L. George Superintendent of Design and Licensing C. L. Buck Supervisor Design Support , J. P. McGowan Manager SAER C. M. Grove Senior QA Engineer L. L. Bailey, Jr.
Project Engineer II D. M. Varner Supervisor Procurement and Contracts The inspector verified that responsibilities, authority, and lines of communications are available for the personnel interviewed. The inspector verified that these personnel understand their authority and responsi-bilities. All personnel interviewed appear qualified for these positions.
The inspector reviewed audits conducted of offsite support functions. The following are the specific cudits reviewed: Audit Date Conducted SCS QA Department 12/22/82 SCS QA Department 10/19 - 10/21/82 Environmental Monitoring Activities 4/28/82 Non-Routine Environmental Monitoring 5/17 - 5/19/82 _ _ _ _
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Procurenent Activities 10/12 - 10/13/82 Operational Support Activities 1/12-26/83 Nuclear Generation Section, Operational Support 7/12 - 7/23/82 Within this area, no violations or deviations were identified.
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