IR 05000366/1978044
| ML19312A126 | |
| Person / Time | |
|---|---|
| Site: | Hatch  |
| Issue date: | 12/01/1978 |
| From: | Ashenden M, Jenkins H, Kellogg P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19289D017 | List: |
| References | |
| 50-366-78-44, NUDOCS 7901290131 | |
| Download: ML19312A126 (27) | |
Text
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Report No.: 50-366/78-44 Docket No.: 50-366 License No.: h7F-5
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Licensee: Georgia Power Company Plant E. I. Hatch P. O. Box 442 Baxley, Georgia 31513 Facility Name: Hatch Nuclear Plant Inspection at:
B.aley, L orgia and Corporate Of fices, Atlanta, Georgia Inspection conducted: October 23-27, 1978 Inspectors:
H. D. Jenkins M. C. Ashenden W. A. Ruhlman J. A. Mcdonald I
R. S. Markowski Accompanying Personnel:
M. J. Graham P. J. Kellogg ell
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Approved by:
P. 7 @ 1 L V Chief Ifatb Nucledr!bhrtSectIn/
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No. 2 Reactor Operations and Nuclear Support Branch Inspection Sunnary Inspectica on October 23-27, 1978 (Report No. 50-366/78-44)
Areas Inspected: Routine, announced inspection of the procedures and activities implementing the Georgia Power Company Quality Assurance Program in the areas of: QA/QC Administration; audits; document control; varehouse tour; maintenance; design changes / modifications; surveillance testing and calibration; procurement; receipt; storage and handling; quality assurance records; test and experiments; test and men.urement equipment; and a plant tour. The inspection included an in-office manual review involvin;; 84 inspector-hours, an on-site inspection of 122 inspector-hours, and a corpo-rate offices' audit of 26 inspector-hours. This inspection was conducted by five NRC inspectors.
7901290(31
Inspection Summary-2-Results: Of the thirteen areas inspected, no items of noncompliance were identified in six areas, and seven items of noncompliance were identified in seven areas.
(infraction - failure to control special processes - Detail 5.c; infraction - failure to ensure proper calibration - Details 7.c and 13.b; infraction - failure to establish the accepted QA Program - Details 3.e, 5.d and 6.e; infraction - failure to take timely corrective action -
Detail 3.c; infraction - failure to clearly delineste organizational duties
- Detailu 6.d and 8.d; infraction - failure to maintain sufficient records -
Details 3.f and 5.e; deficiency - failure to document audit findings - Detail:
3.d.)
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RII Report No. 50-366/78-44 I-1 DETAILS I Prepared by:
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H. IfG as, iffactyrj" Inspector Da t'e /
Nuclea upport Sectyn No. 2 Reactor Operations and Nuclear Support Branch k-A L alifn W. A. Ruhlman, Reactor Insp,ector Date Nuclear Support Section No. 2 Reactor Operations and Nuclear Support Branch
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/2 bf p.A. Mcdonald,ReactorInspector Date Nuclear Support Section No. 2 Reactor Operations and Nuclear Support Branch T//h/$:AuAw l2//l78 M. C. Ashenden, Reactor Inspector Date
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Nucl-ar Support Section No. 2 Reactor Operations and Nuclear Support Branch Dates of Inspectio.
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'27, 1978
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Reviewed by:
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Nucle. Me %ar IS h rt Seltion No. 2 P.
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Reactor Operations and Nuclear Support Branch 1.
Persons Contacted E. F. Aldridge, Supervisor of Materials R. D. Baker, Senior Design Nuclear Engineering S. X. Baxley, Operations Superintendent C. E. Belflower, QA Site Supervisor J. H. Boykin, GPC Chief Engineer C. L. Coggin, Engineering Supervisor R. A. Day, Administrative Assistant H. W. Dyer, Operations Supervisor G. B. Ellis, I&C Supervisor T. L. Elton, Junior Plant Engineer H. H. Gregory, III, Construction Project Manager M. A. Griffis, I&C Supervisor L. T. Gueva, GPC Nuclear Engineer
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RII Report No. 50-366/78-44 I-2 J. R. Jordan, Project Manager, Engineering Services M. Manry, Plant Manager T. F. McCarley, I&C Supervisor D. McCusker, QC Specialist C. R. Miles, Jr., GPC QA Field Supervisor C. T. Moore, GPC Production Engineer H. C. Nix, Assistant Plant Manager R. T. Nix, Maintenance Supervisor W. H. Rogers, Health Physicist Radiochemist
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D. R. Savage, QA Engineer G. E. Spell, Jr., Senior QA Field Representative R. W. Staffa, GPC Manager QA C. F. Whitmer, GPC Vice President of Power Support Engineering and Services W. A. Widner, GPC Manager Power Generation The inspectors also interviewed other licensee employees during the course of the inspection.
Included were personnel from engineering, technical support, maintenance, operations, document control, quality assurance and stores.
(Note:
All personnel contacted attended either the site or corporate offices exit interviews.)
2.
QA/QC Administration References:
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FSAR Chapter 17.2 Quality Assurance Manual
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QA-04-12, QA Department Procedure Manual Control, Revision 3,
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<sted November 1976
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a.
Program Review The referenced documents were reviewed to verify that the licensee's program clearly defined those structures, systems and components and other items and services to which the QA/QC controls are to be applied.
In addition, the Program documents were reviewed to ascertain that proc.dures and responsibilities had been established for making changes to such listings. A review of the controls for audits was also conducted to verify that methods were established to issue / revise / control QA/QC procedures, to periodically evaluate the effectiveness of the QA/QC program and provide emphasis where needed in problem areas, and to provide management with an evaluation of the overall effectiveness of the QA Program.
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RII Report No. 50-366/78-44 I-3 The inspector identified two unresolved items with respect to the designation of structures, systems, components, items and services to which the Program controls are to apply. These are documented in Paragraphs 2.c and 2.d below.
b.
Implementation Implementation of Program ccatrols was verified during the conduct of all the remaining inspection activities documented in this Report.
c.
Maintaining the "Q" List In an audit conducted on September 5-7, 1978, the licensee had determined that no procedure existed for maintaining the "Q" list. This inadequacy was documented as finding AFR 78-1 in the Report dated September 14, 1978. The audited organization's response stated:
"For ENP-1, we will take the "Q" list by systems and list it on the computer. We will write a procedure complete with forms for adding components to this listing as replacement parts are ordered or systems are added or modified. These procedures will be used by the site, NED, PSE&S, SCSI and Bechtel as required.
For HNP-2, we will acquire Bechtel's Equipment Location Index on tape and enter it on the Southern Company computer.
We will write a procedure covering additions and corrections to this listing for use by the site, NED, PSE&S, SCSI and Bechtel. We will have this work completed by January 1, 1979, except for the computer programming effort."
Until the licensee completes the action necessary to close his internal audit finding AFR 78-1, this item (366/78-44-01) is unresolved.
d.
Consumables/Expendables The licensee's current "Q" list does not address consumables/
expendables such as boric acid, snubber fluid, resins, "0" rings, gaskets, packing, lubricants, filters and other items. However, during the review of the licensee's current practices in this area, no breakdown in quality was observed. One ites of noncom-pliance with respect to documentation of usage was found as documented in Paragraph.
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RII Report No. 50-366/78-44 I-4 Until the licensee conducts a review of all consumables/expendables used to determine those which require controls because they affect the safety-related function of safety-related structures, systems or components and until he specifies what portion (s) of the QA Program controls are necessary to be applied to these items, this item (366/78-44-02) is unresolved. The Manager of Quality Assurance gave a date of July 26, 1979, for completion of this item.
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3.
Quality Assurance Audits References:
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QA-01-01, Organization and Responsibilities of the QA Department, Revision 4, dated April 1978
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QA-05-01, Design Audit, Revision 3, dated May 1978
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QA-05-03,SupplierAudit/Ir.spection, Revision 2,datedAprii1978 QA-05-06, Preoperational, Startup and Operational Audits, Revision 3,
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undated QA-05-07, Audit Report Writing (QAFR), Revision 2, dated June
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1978 QA-05-13, Open Items Control (QA Field Office), Revision 2, dated
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June 1978 Abbreviations:
QASS, Quality Assurance Site Supervisor
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QAFR, Quality Assurance Field Representative
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a.
Program Review The referenced documents were reviewed with respect to the licensee's accepted Quality Assurance Program as delineated in Chapter 17 of the FSAR and with respect to selected requirements of ANSI N45.2.12 (Draft 3, Revision 4, dated February 1974) as committed to by that program. The in-office review indicated several areas where the referenced documents did not include specific requirements of either the accepted Program or the ANSI standard.
Each of these areas was reviewed during the implementation inspection.
If the licensee was implementing these requirements and only procedural documentation was lacking, the items were left unresolved pending completion of the required documentation (see Paragraph.
RII Report No. 50-366/78-44 I-5 through 3.i below). Where both procedural definition and imple-mented practices were inadequate, appropriate citations were written (see Paragraphs 3.c and 3.d below).
b.
Implementation The licensee's program of quality assurance audits was reviewed both at the company offices and at the Hatch. plant site with respect to the licensee's implementing procedures referenced above. Where these procedures had been determined to be inade-quate during the Program Review, they were reviewed with respect to the applicable requirements of the licensee's accepted Quality Assurance Program and the ANSI standards committed to by that program. Two items of noncompliance and examples contributing to two additional items of noncompliance are documented in Paragraphs 3.c through 3.f below. Three unresolved items were also found as set forth in Paragraphs 3.g through 3.i below.
c.
Failure to Take Timely Corrective Action In reviewing the implemented audit program, sixteen (16) audit reports issued after June 12, 1978, (date that the Operating License was issued for Hatch Unit 2) were inspected.
In addition, corrective action for audits conducted prior to June 12, 1978, was reviewed since this activity was also under the control of the accepted Program for all items not corrected prior to issuance of the Operating License.
The draft of the ANSI standard for audits, ANSI N45.2.12, to which the accepted QA Program provides a conunitment, requires that the audited organization provide a response in writing within thirty (30) days after receipt of the report by the auditing organization. This response is required to clearly state the corrective action taken and, in the event that corrective action can not be completed within thirty (30) days, the scheduled date for the corrective action. Of the reports reviewed, the inspector found several that did not meet the specific requirements of the standard which implement the requirements of 10 CFR 50, Appendix B, Criterion XVI to provide prompt corrective action.
Specific examples include:
(1) Two findings associated with Audit 78-Maint.-1, issued in a report dated February 22, 1978, which had neither been corrected nor responded to as of October 26, 1978.
(2) Two findings associated with Audit 78-Adm.-1, issued in a report dated July 28, 1978, which had neither been corrected nor responded to as of October 26, 197.
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RII Report No. 50-366/78-44 7-6 (3) Three findings associated with Audit 78-Surv.-3, issued in a report dated September 8, 1978, which had neither been corrected nor responded to as of October 26, 1978, and, (4) Two of six findings associated with Audit 78-EP-1 w.th corrective action completion scheduled dates of September 1, and September 15, 1978, which had not been corrected as of October 26, 1978.
These four examples of failure to provide prompt corrective action, collectively, constitute an item of noncompliance (366/78-44-03).
d.
Failure to Document Audit Findings as Required 10 CFR 50, Appendix B, Criterion XVIII, requires that audit reports shall be documented. The audit report required by the licensee's accepted QA Program is specified in Draft 3, Revision 4 of ANSI N45.2.12, Sections 4.3.3, 4.4.3 and 4.4.4.
These specifically require, respectively, that a post-audit conference be held, that persons contacted during the pre-audit, audit and post-audit activities be documented in the report, and that the report include an evaluation statement regarding the effectiveness of the quality assurance program elements which were audited.
None of the licensee's audits, either those conducted on-site or off-site, contained the required evaluation statement. None of the site-conducted audits reviewed contained a list of pre-audit contacts. Five of the sixteen (16) site audit reports reviewed stated that, although managers had been informed of audit results, no post-audit conference had been held.
An additional audit report failed to document a post-audit conference if one was held.
These three types of
. lures to document audit findings as required, collectively, cot titute an item of noncompliance (366/78-44-04).
e.
Failure to Establish the Accepted QA Program In order to meet the requirements of 10 CFR 50, Appendix B, the licensee submitted a Quality Assurance Program description in Chapter 17 of the FSAR.
10 CFR 50, Appendix B, Criterion II, requires that the licensee establish a program consistent with the schedule for accomplishing the activities by written policies and procedures. The Program commits the licensee to following ANSI N45.2.12 (Draf t 3, Revision 4, dated February 1974). Section 3.1 of the standard requires that the audit system be described in approved, written policies, plans, procedures, instructions,
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RII Report No. 50-366/78-44 I-7 or other such documents. Specific report writing / documenting inadequacies in procedures resulted in the citation documented in Paragraph 3.d above. However, additional requirements of the standard could not be determined, by the review of objective evidence, to be implemented, such as those in Sections 3.3, 3.4.2, 4.2, 4.3, 4.5, 5.1 and 5.3 as examples. The inadequacies of Section 4.4 and 4.3.3 were included in the citation under Criterion XVIII.
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These examples of failure to establish the accepted Program in written procedures have oeen combined with similar failures documented in Paragraphs 5.d, 6.d and 8.c to collectively consti-tute an item of noncompliance (366/78-44-05).
f.
Failure to Maintain Required Records 10 CFR 50, Appendix B, Criterion XVII requires that sufficient records be maintained to furnish evidence of activities affecting quality. The licensee's accepted QA Program implementing procedures (QA-05-06 and QA-05-13) specify that the results of two specific reviews be documented. The licensee was unable to furnish any objective evidence that the required documentation of the review of deficient items (to be conducted every 90 days by the QASS) or the review of the QAFR's file folders (to be conducted every 30 days by either the QASS or Senior QAFR) had been conducted.
These two examples of failure to maintain a required record has been combined with a similar failure documented in Paragraph 5.e to collectively constitute an item of noncompliance (366/78-44-06).
g.
Frequency of Conducting Audits Since the Operating License was issued on June 12, 1978, the requirement to conduct audits of applicable elements of the Quality Assurance Program at least annually (Section 3.4.2 of ANSI N45.2.12) could not be verified. The licensee's audit schedule indicated that all operational activities were covered /to be covered within the required timeframe. However, both Section 17.2 of the FSAR and other program documents allow up to two
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years to accomplish the audits. This conflict between commitments and implementing documents requires resolution.
Until the licensee btings his program documents and his commit-ments into alignment in this area, this item (366/78-44-07) is unresolved. The Manager of Quality Assurance gave a date of April 26, 1979, for completion of this ite RII Report No. 50-366/78-44 I-8 h.
Actual Procedures Versus Committed Procedures Table 17.2-1 of the licensee's FSAR states that certain proce-dures will be written to implement the Program; many of these procedures have not been written. The licensee stated that some of these procedures, originally believed to be needed, are no longer necessary. However, this same table is used to satisfy the requirement of Section 5.1 of ANSI N18.7-1976 with respect to an index of source documents to the requirements of the Standard.
Until the required procedures have been written or the subject table has been revised and accepted by NRR, this item (366/78-44-08) is unresolved. The Manager of Quality Assurance gave a date of April 26, 1979, for the completion of this item.
i.
Acceptability of Corrective Actions / Escalation During oral discussions, the Manager of Quality Assurance stated what methods could be employed to handle cases where the auditing organization disagreed with the response of the audited organiza-tion with respect to either proposed action or pr > posed schedule.
He further described what escalation options were available if this hypothetical conflict could not be resolved between the cognizant managers.
In the only case reviewed by the inspector, these described methods were not employed. However, in this single case observed, the matter did not i volve a safety or quality issue under the purview of NRC. AhoI N18.7-1976 includes requirements (Sections 4.2(2) and 4.2(10)) to evaluate and approve /
disapprove contemplated actions and to establish an effective audit program.
Until the licensee documents his methods for:
(1) evaluation of proposed corrective action and schedules; (2) taking action when either proposed schedule or action is considered inappropriate to effect correction of the noted problem; and (3) escalation of any conflicts between auditing and audited organization with respect to the above action to a level of management capable of imposing a solution on both parties, this item (366/78-44-09) is unresolved.
The Manager of Quality Assurance gave a date of April 26, 1979, for completion of this item.
4.
Document Control References:
ERP-10, Document Distribution and Control, Revision 5, dated
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August 1978
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RII Report No. 50-366/78-44 I-9 HNP-813, Drawing Control, Revision 9, dated June 1978
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HNP-820, Plant Records Management, Revision 8, dated October 1978
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a.
Program Review The referenced documents were reviewed with respect to the licensee's accepted Quality Assurance Program as delineated in Chapter 17 of the FSAR and with respect to the requirements of ANSI N45.2.9-1974 as committed to by that Program.
The inspector identified no items of noncompliance during this review.
b.
Implementation The licensee's program of document control was reviewed at the company offices and at the Hatch plant site with respect to the licensee's implementing procedures referenced above.
One unresolved item was found as set forth in paragraph 4.c below.
c.
Failure to Control Drawing Distribution The inspector selected five (5) controlled vendor instruction manuals and ten (10) controlled drawings and reviewed their control and accountability to verify implementation of reference (b). These manuals and drawings were inspected in the Plant Records Storage Room, and as appropriate in the Instrument Shop Drawing File and the Control Room Drawing File.
One (1) of five (5) manuals inspected in the Instrument Shop Drawing File was not listed in the Master Index, Drawing Check-out File or Instrument Shop Drawing File Index. Two (2) different copies of this manual were in the file. Five (5) of five (5)
manuals inspected in the Instrument Shop Drawing File were not signed out from the Drawing Check-out File. Four (4) of five (5)
manuals inspected in the Instrument Shop Drawing File Index were not listed in the Instrument Shop Drawing File. Six (6) of the seven (7) copies of the five (5) types of manuals inspected were not annotated to reflect the appropriate control number.
Six (6)
of nineteen (19) drawings inspected did not reflect current revision status. One (1) of twenty (20) drawings was not retriev-able from its assigned locatio RII Report No. 50-366/78-44 I-10 The storage location of vendor instruction manuals and engineering drawings is not specified in that there is no record of the total number of manuals or drawings assigned to the Drawing Check-Out File.
This item was identified during a licensee conducted audit.
Pending review of the licensee's response to this audit finding and the corrective action taken to assure control of vendor instruction manuals and engineering drawings, this item (366/78-44-10) is unresolved.
5.
Maintenance References:
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HNP-501, Equipment Clearance, Revision 2, dated July 21, 1978
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HNP-555, Welding and Cutting Safety, Revision 1, dated June 21, 1978
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ENP-8, Maintenance Request, Revision 11, dated August 7, 1978 HNP-821, Quality Control Work Inspection, Revision 4, dated
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July 14, 1978
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HNP-556, Plant Housekeeping, Revision 1, dated September 5, 1978
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ENP-425, Deviation Report, Revision 3, dated September 13, 1978 ENP-823, Qualification of Inspection Personnel, Revision 4, dated
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February 6,1978 ENP-824, Control of Special Processes, Revision 3, dated March 25,
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1978
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HNP-833, Near Distance Acuity Examination, Revision 1, dated June 10, 1978 a.
Program Review The inspector reviewed the references listed above with respect to the licensee's accepted Quality Assurance Program as delineated in Chapter 17 of the FSAR and the requirements of ANSI 18.7-1976 and ANSI N45.2.3-1973 as committed to by that program.
The inspector did not find sufficient information to ascertain whether the procedural requirements of the standards were met.
Questions generated during the review concentrated on:
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RII Rcrort No. 50-366/78-44 I-11 pendent verification; housekeeping procedures; and cleanliness procedures.
Independent verification and oa-site inspection were employed to ascertain the answers to those items mentioned above.
b.
Implementation The licensee's maintenance program was reviewed at the Hatch plant site with respect to the licensee's implementing procedures referenced above. Where these procedures had been determined to be inadequate during the Program Review, they were reviewed with respect to the applicable requirements of the licensee's accepted Quality Assurance Program and the ANSI Standards committed to by that Program. One item of noncompliance and two examples contri-buting to two additional items of noncompliance are documented in paragraphs 5.c through 5.e below. Two unresolved items were also found as set forth in paragraphs 5.f and 5.g below.
The inspector reviewed 70 individual Maintenance Requests (MR)
during this inspection for status and adequacy. The MR's reviewed covered the period July 1977 to October 1978.
c.
Failure to Control Welding 10 CFR 50, Appendix B, Criterion IX, requires measures be esta-blished to assure special processes, including welding, are controlled.
The licensee's accepted Quality Assurance Program (FSAR Chapter 17.2), Section 17.2.9, requires the Superintendent of Maintenance be responsible to assure special processes, including welding, be controlled.
Procedure HNP-824 additionally requires welding be performed in accordance with qualified welding procedures, initiated by a maintenance request, and inspection and monitoring of the welding be performed.
The licensee was unable to furnish objective evidence that any of the above requirements were met, in performing cutting and welding operations on seismic class I hanger 2b21 on September 15, 1978. The inspector, in discussion with the licensee, expressed the need for immediate evaluation and review of the subject weld to determine the adequacy of the structure. The licensee agreed to review the welding procedure used and evaluate the seismic requirements of the structure. The Plant Review Board met on October 25, 1978, and determined that continued operation of Unit 2 posed no safety problem in that it posed no threat to the safe shutdown of the reactor. This was documented in Plant Review Board meeting number 78-240. The Plant Review Board convened again on October 27, 1978, to review the findings of the Quality Control Department concerning the subject structure and recommended the structure be rewelded using an approved welding procedure during the next cold shutdown.
This decision is documented on Deviation Report 2-78-9,
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RII Report No. 50-366/78-44 I-12 This lack of control concerning special processes const' otes an item of noncompliance (366/78-44-11).
d.
Failure to Establish the Accepted QA Program In order to meet the requirements of 10 CFR 50, Appendix B, the licensee submitted a Quality Assurance Program description in Chapter 17 of the FSAR.
10 CFR 50, Appendim B, Criterion II requires that the licensee establish a program consistent with the schedule for accomplishing the activities by written policies and procedures. The Program commits the licensee to the following ANSI N45.2.3-1973.Section 2.1 of the Standard requires that necessary procedures and work instructions that are needed to assure compliance with the specified requirements shall be identi-fled and provisions made for their preparation, approval and control.
Specific requirements of the Standard which could not be determined by the review of objective evidence to be impleinented include those in Sections ?. 1, 3.5 and 4.0, as examples.
These examples of failure to establish the accepted Program in written procedures have been combined with similar failures documented in Paragraphs 3.e, 6.d and 8.c to collectively consti-tute an item of noncompliance (366/78-44-05).
e.
Failure to Maintain Reuuired Records 10 CFR 50, Appendix B, Criterion XVII, requires that sufficient records be maintained to furnish evidence of activities affecting quality. The licensee's approved Quality Assurance Program FSAR Section 17.2-8, further requires traceability of an off-the-shelf item to a manufacturer's item number.
The inspector found that when lubricants were added to a component, they were not documented.
This example of failure to maintain required records has been combined with additional examples of similar failures documented in paragraph 3.f, and collectively constitute an item of noncom-pliance (366/78-44-06).
f.
Conflict Between Procedure and Practice Section C.9 of the licensee's procedure HNP-8 specifically requires that all parts used during performance of maintenance will be listed on the back of number three (3) copy of the Maintenance Request (MR).
In reviewing several MR's, the inspector found that the Test Group usually listed the parts used on the front of the MR in the " Comments" sectio.
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RII Report No. 50-366/78-44 I-13 Until the licensee brings his procedure and current practices into alignment, this item (366/78-44-12) is unresolved. At the exit interview, the Plant Manager stated that no change to the procedure was contemplated and that all personnel would be required to comply with the currently documented requirements. He further stated that completion of that action would be as of the close of the inspection, October 27, 1978.
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g.
ANSI N45.2.6 Certificat.:.on and Physical Requirements The inspector reviewed tte certification requirements of ANSI N45.2.6 with respect to individuris in the site QC Group and a sample of individuals desig 'ted as alternate inspectors. The inspector found that certifica-.on statements for two individuals indicated that the minimum experience requirements were not met.
Other records reviewed indicated that the certificates did not reflect the actual experience history, since both individuals did, in fact, meet the requirements.
In addition, several persons were designated as inspectors, although most were alternate inspectors, without having completed the visual acuity and/or color vision requirements. All of the examples noted were already identified by the acting Senior Quality Control Specialist (SQCS).
The SQCS had already initiated requests for the required tests and a complete review of all certification records to assure that education /past performance history was correct.
Until the licensee completes the required review and all inspectors have completed the required visual acuity and/or color vision tests, this item (366/78-44-13) is unresolved. The Plant Manager gave a date of November 30, 1978, for completion of this item.
6.
Design Changes / Modifications References HNP-809, Design Change Request, Revision 5, dated May 13, 1978
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HNP-821, Quality Control Work Inspection, Revision 5, dated September 19, 1978
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HNP-808, Document Change Request, Revision 3, dated June 10, 1978 HNP-812, As-Built Notice, Revision 2, dated March 14, 1978
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a.
Program Review The inspector reviewed the references listed above with respect to the licensee's accepted Quality Assurance Program as deline-
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RII Report No. 50-366/78-44 I-14 ated in Chapter 17 of the FSAR and to the requirements of ANSI N45.2.11-1974, as endorsed by Regulatory Guide 1.64.
The inspector found the program to be deficient in several areas in that the procedural requirements of the Standard were not met.
Examples contributing to two items of noncompliance are docu-mented in paragraphs 6.d and 6.e below. Two unresolved items were also found as set forth in paragraphs 6.f and 6.g below.
b.
Implementation The licensee's program of design changes / modifications was reviewed both at the corporate offices and at the Hatch plant site, with respect to the licensee's implementing procedures referenced above, and where these procedures had been determined to be inadequate during the program review, with respect to the appli-cable requirements of the licensee's accepted Quality Assurance Program and the ANSI Standards committed to by that program. One unresolved item was identified as set forth in paragreph 6.c below.
c.
Annotation of Controlled Drawings The inspector reviewed the process of annotating controlled drawings to reflect implementation status of design changes.
In order to preclude operating a system with an outdated drawing, provisions are necessary to ensure that the DCR process updates the drawing prior to system restoration. This process, or lack thereof, was addressed as a deficiency in an audit conducted in-house on September 26, 1978, by the QA Group.
Until such time that the re-audit establishes a method by which controlled drawings will be properly annotated to reflect design change implementation, this item is unresolved (366/78-44-14).
d.
Failure to Clearly Delineate Organizational Duties In order to meet the requirements of 10 CFR 50, Appendix B, the licensee submitted a Quality Assurance Program description in Chapter 17 of the FSAR.
10 CFR 50, Appendix B, Criterion I requires that the licensee clearly establish and delineate in writing the authority and duties of persons and organizations performing quality assurance functions. The program commits the licensee to following ANSI N45.2.11-1974. Section 2.1 of the Standard requires that program documents shall define organiza-tional structure and delineate the authority and responsibility of the persons and organizations involved performing design
. activities affecting the quality of design.
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RII Report No. 50-366/78-44 I-15 Specific requirements of the Standard which could not be deter-mined by the review of objective evidence to be clearly defined include those in Sections 2.1 and 3.2 as examples.
These examples of failure to clearly delineate organizational duties in writing have been combined with similar failures docu-mented in paragraph 8.d to collectively constitute an item ot noncompliance (366/78-44-15).
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e.
Failure to Establish the Accepted QA Program In order to meet the requirements of 10 CFR 50, Apper. dix B, the licensee submitted a Quality Assurance Program description in Chapter 17 of the FSAR.
10 CFR 50, Appendix B, Criterion II requires that the licensee establish a program consistent with the schedule for accomplishing the activities by written policies and procedures. The program commits the licensee to following ANSI N45.2.11-1974. Section 2.2 of the Standard requires procedures shall be employed to assure that design activities are carried out in a planned, controlled and correct manner. Specific require-ments of the Standard which could not be determined by the review of objectiva evidence to be implemented include thoaa in Sections 2.2.7, 4.3, 4.5 and 5.1, as examples.
These examples of failure to establish the accepted Program in written procedures have been combined with similar failures documented in paragraphs 3.e, 5.d and 8.c to collectively consti-tute an item of noncompliance (366/78-44-05).
f.
Corporate Procedural Revision In the course of reviewing design change request procedures at the corporate office, the inspector noted the latitude within General Procedure 12030 of allowing the Project Manager, Engineer-ing Services, to make minor corrections to previously approved DCR's.
The inspector discussed the item with the Project Manager to ascertain the degree of change that was acceptable. The Project Manager agreed to provide guidance as to what constituted a minor change.
Until such time that General Procedure 12030 is revised to reflect guidance as to the scope of a minor change, this item is unresolved (366/78-44-16). The Manager of Quality Assurance gave a date of April 26, 1979, for completion of this ite.
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RII Report No. 50-366/78-44 I-16 g.
10 CFR 50.59 Safety Evaluation In that a 10 CFR 50.59 Safety Evaluation is required for all DCR's affecting changes of the facility as described in the FSAR, it was found that no mechanism was incorporated within the DCR procedure to specifically address FSAR described facility changes.
Until a procedural revision is generated, and approved to speci-fically incorporate required safety evaluations on all changes of FSAR described facility changes, this item is unresolved (366/78-44-17). The Manager of Quality Assurance gave a date of April 26, 1978 for completion of this item.
7.
Surveillance Testing and Calibration Control References:
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HNP-831, Technical Specifications Surveillance Program, Revision 5, dated June 1978 HNP-832, Calibration Program for Instrumentation not Covered by
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Technical Specifications, Revision 8, dated July 1978 a.
Program Review The referenced documents sere reviewed with respect to the licensee's accepted Quality Assurance Program as delineated in Chapter 17 of the FSAR and with respect to the requirements of ANSI N18.7-1976 as committed to by that Program.
The inspector identified no items of noncompliance during this review.
b.
Implementation The licensee's program of surveillance testing and calibration control was reviewed at the Hatch plant site with respect to the licensee's implementing procedures referenced above.
One item of noncompliance is documented in paragraph 7.c below.
c.
Failure to Assure Calibration Accomplishment The inspector selected sixty-five (65) calibration requirements encompassing one-hundred and eighty-nine (189) individual instru-ments to verify scheduling, accomplishment and availability of approved procedure.
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RII Report No. 50-366/78-44 I-17 10 CFR 50, Appendix B, Criterion XII, requires the establishment of measures to assure that gauges and instruments affecting quality are calibrated at specified periods. The accepted Quality Assurance Program (FSAR Chapter 17), section 17.2.12, requires periodic calibration of test and measurement equipment.
Contrary to the above, as of October 26, 1978, measures had not been established to assure that instruments were calibrated at specified intervals in that of one-hundred a'nd eighty-nine (189)
instruments used to assure that parameters are within those specified by Technical Specifications, thirty (30) had not been calibrated within the specified intervals as follows:
6.9 percent were overdue from 1 to 3 months
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2.1 percent were overdue from 3 to 6 months
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4.8 percent were overdue from 6 to 9 months, and
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2.1 percent were overdue from 9 to 11 months This example of failure to establish measures to assure that instruments are calibrated at specified intervals has been combined with an additional example of similar failure, documented in paragraph 13.b,to collectively constitute an item of noncompliance (366/78-44-18).
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d.
Surveillance Testing The inspector selected twenty (20) surveillance tests from the requirements of the Technical Specifications and verified through the Surveillance Engineer the scheduling and the availability of approved procedures for the conduct of these tests.
The inspector identified no items of noncompliance in this area.
8.
Procurement References:
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GPND-05, Spare Parts Procurement, Revision 0, dated August 1978 QA-04-18, Requisition / Purchase Order Review / Approval (Operating
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Plants), Revision 0, dated July 1978
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HNP-802, Stock Material Control, Revision 6, dated July 1978
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RII Report No. 50-366/78-44 I-18
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HNP-803, Material and Services Procurement, Revision 10, dated July 1978
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HNP-828, Requisition Review for Quality Requirements, Revision 3, dated June 1978
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Interoffice Memo, Implementation of Plant Hatch Parts Procurement Program, dated July 11, 1978
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a.
Program Review The referenced documents were reviewed with respect to the licensee's accepted Quality Assurance Program as delineated in Chapter 17 of the FSAR and with respect to ANSI N45.2.13-1!76 as committed to by that Program.
The in-office review indicated several areas where the referenced documents did not include specific require-ments of either the accepted program or the ANSI standard. Each of these areas was reviewed during the implementation inspection.
If the licensee was implementing these requirements and only procedural documentation was lacking, the item was left unresolved pending completion of the required documentation (see paragraph 8.e below). Where both procedural definition and implementation practices were inadequate, appropriate citations were written (see paragraphs 8.c and 8.d below).
b.
Implementation The licensee's program of procurement was reviewed, both at the company offices and at the Hatch plant site, with respect to the licensee's implementing procedures referenced above, and where these procedures had been determined to be inadequate during the Program Review, with respect to the applicable requirements of the licensee's accepted Quality Assurance Program and the ANSI Standards comitted to by that program.
Additional examples contributing to two items of noncompliance are documented in paragraphs 8.c and 8.d below, c.
Failure to Establish the Accepted QA Program In order to meet the requirem2nts of 10 CFR 50, Appendix B, the licensee submitted a Quality Assurance Program description in Chapter 17 of the FSAR.
10 CFR 50, Appendix B, Criterion II requires that the licensee establish a program consistent with the schedule for accomplishing the activities by written policies and procedures. The program commits the licensee to following ANSI N45.2.13-1976. Section 2 of the Standard requires that planning shall result in the documented identification of methods
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RII Report No. 50-365/78-44 I-19 to be used in procurement activities, sequence of action and milestones indicating the con.pletion of these activities, and the preparation of applicable proce.dures prior to initiation of each individual activity. Specific requirements of the Standard which could not be determined by the re riew of objective evidence to be implemented include those in Sections 2, 3.2, 8.2 and 9.2, as examples.
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These examples of failure to establish the accepted program in written procedures have been combined with similar failure?-
documented in paragraphs 3.e, 5.d and 6.d, to collectively consti-tute an item of noncompliance (366/78-44-05).
d.
Failure to Clearly Delineate Organizational Duties In order to meet the requirements of 10 CFR 50, Appendix B, the licensee submitted a Quality Assurance Program description in Chapter 17 of the FSAR.
10 CFR 50, Appradix B, Criterion I, requires that the licensee clearly establish and delineate in writing the authority and duties of persons and organizations performing quality assurance functions.
The Program commits the licensee to following ANSI N45.2.13-1976. Sectiet ' of the Standard requires that each organization involve' m the procure-ment process be identified and have their responsieilities delin-eated. Specific requirements of the Standard which could not be determined by the review of objective evidence to be clearly delineated include those in Sections 3, 4, 5, 6, 8, 9 and 10, as examples.
These examples of failure to clearly delineate organizational duties in writing have been combined with similar failures docu-mented in paragraph 6.c to collectively constitute an item of noncompliance (366/78-44-15).
e.
Determination as to When Procurement Documents are Approved Sections 3.1 and 6.4 of ANSI N45.2.13 specify controls which must be employed for changes in approved / completed procurement documents.
The licensee's current procedures did not clearly define when changes to documents or services require the change controls specified. The licensee stated that procedures would be revised /
issued to clearly define when the controls of Section 3.1 and 6.4 were to be applied.
Until the licensee has issued / revised his procedures to clearly establish when a purchase requisition becomes a purchase order for the purposes of implementing the controls of Sections 3.1 and
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RII Report No. 50-366/78-44 I-20 6.4 of ANSI N45.2.13, this item (366/78-44-19) is unresolved.
The Manager of Quality Assurance gave a date of April 26, 1979 for completion of this item.
9.
Receipt, Storage and Handling References:
HNP-800, Materials Receiving, Revision 8, dated June 10, 1978
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HNP-801, Nonconformances, Revision 9, dated June 27, 1978
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HNP-804, Equipment Storage, Revision 7, dated June 12, 1978
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HNP-805, Shipment of Material, Revision 3, dated June 12, 1978
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HNP-822, Material Inspection Request, Revision 0, dated August 12,
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1978 HNP-825, Use of Dessicants for Storage and Shipping, Revision 7,
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dated August 12, 1978 a.
Program Review The inspector reviewed the references listed above with respect to the licensee's accepted Quality Assurance Program as delin-eated in Chapter 17 of the FSAR, and the requirements of ANSI 18.7-1976 and ANSI N45.2.2-1972.
The inspector did not find sufficient information to ascertain whether the procedural requirements of the Standards were met.
Questions generated during the review concentrated on: control of shelf life dependent items; and, handling equipment inspection program.
Independent verification and on-site inspection were employed to ascertain the answers to those items mentioned above.
b.
Implementation The licensee's program of storage and handling was reviewed, both at the company offices and at the Hatch plant site, with respect to the licensee's implementing procedures referenced above and, where these procedures had been determined to be inadequate during the Program Review, with respect to the applicable require-ments of the licensee's accepted Quality Assurance Program and the ANSI standards committed to by that program.
The inspector identified no items of noncompliance.
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RII Report No. 50-366/78-44 I-21 10.
Warehouse Tour The inspectors performed a tour of the Power Generation Warehouse and verified by direct observation and/or review of documentation, that:
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items were identified as acceptable or unacceptable;
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items in a " hold" status were segregated;
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housekeeping was adequate;
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dessicant usage was controlled and motors were being routinely
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meggered and rotated; storage area inspections were being performed periodically; and,
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item marking / identification provided traceability to purchase order, receipt inspection and item certification documents (five items selected).
The inspectors identified no items of noncompliance during this review.
11.
Quality Assurance Records Reference:
HNP-820, Plant Records Management, Revision 8, dated October 1978
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a.
Program Review The referenced document was reviewed with respect to the licensee's accepted Quality Assurance Program as delineated in Chapter 17 of the FSAR and with respect to the requirements of ANSI N45.2.9-1974, as committed to by that Program.
The inspector identified no items of noncompliance during this review.
b.
Implementation The licensee's quality assurance record program was reviewed at the Hatch plant site with respect to the licensee's implementing procedure referenced above.
The inspector identified no items of noncomplianc.-
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RII Report No. 50-366/78-44 I-22 c.
Operating Records Review The inspector selected sets of records to verify the licensee's system to control, store, retain and retrieve operating records in accordance with the referenced procedure.
Those operating logs, surveillance records and changes to operating procedures selected were:
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(1) Reactor Pressure Vessel Flange Temperature Strip Chart (September 6, 1978)
(2) Reactor Pressure Vessel Temperature Recorder Calibration, generic Startup Manual procedure (February 16, 1977)
(3) Battery Individual Cell Surveillance, Diesel Generator 2A,
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procedure HNP-2-3752M (July 20, 1978)
(4) Reactor Water Level Instrument Calibration, procedure HNP-2-3003M (September 8, 1978)
(5) Reactor Water Monthly and Weekly Analysis, procedure HNP-2-7502 (July 1978, August 1978)
(6) Stack Vent Gas Activity, from shift foreman log (August 15, 1978 through October 8, 1978)
(7) Plant Records Management, procedure HNP-820, Revisions 0, 1, 2, 3, 4, 5, 6 and 7 (8) Technical Specifications Surveillance Program, procedure HNP-831, Revisions 0, 1, 2, 3 and 4 (9) Scram Report (October 7, 1978)
Collectively, the inspectors reviewed the records listed below at various times during the course of this inspection:
(1) Audit reports listed in paragraph 3 (2) Maintenance records listed in paragraph 5 (3) Design changes records listed in paragraph 6 (4) Surveillance testing and calibration control records listed in paragraph 7
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RII Report No. 50-366/78-44 I-23 (5) Procurement records listed in paragraph 8 (6) Receipt, Storage and Handling records, listed in paragraph 9 (7) Tests and Experiments records listed in naragraph 12 (8) Test and Measurement Equipment calibration records listed in paragraph 13.
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Examples contributing to one item of noncompliance are documented in paragraphs 3.f and 5.e above. One unresolved item was also found as set forth in paragraph 6.b.
12.
Tests a Experiments Reference:
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HNP-810, Test or Experiment Request, Revision 1, dated June 8, 1978 a.
Program Review The inspector reviewed the reference listed above with respect to the licensee's Technical Specifications and 10 CFR 50.59. The in-office review indicated one item where the referenced document did not include a specific requirement of either the accepted program or 10 CFR 50.59.
Provision was made to ensure preparation and approval of a written safety evaluation as it pertained to a test or experiment; however, no statement required said written evaluation be made if a conflict existed between an operation as stated in the FSAR and the proposed test or experiment.
Until the procedure is revised to require a written safety evalua-tion for each conflict a test or experiment has with regard to FSAR described facility operations, this item is unresolved (366/78-44-20). The Plant Manager gave a date of April 26, 1979, for completion of this item.
b.
Implementation The licensee's program for tests and experiments was reviewed at the Hatch plant site with respect to the licensee's implementing procedure referenced above and to the applicable requirements of 10 CFR 50.59. The inspector reviewed all tests or experiments which were generated for Unit 2 between July 1977 and October 197.
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RII Report No. 50-366/78-44 I-24 The inspector identified no items of noncompliance during this review.
13.
Test and Measurement Equipment References:
ENP-807, Control of Test Shop Instrumentatio,n, Revision 3, dated
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August 7, 1978
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HNP-826, Maintenance Shop Test Equipment Control, Revision 4, dated May 17, 1978
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Hatch FSAR, Section 17.2.12, Amendment 38 a.
Program Review The inspector reviewed the references listed above with respect to the licensee's accepted Quality Assurance Program as delineated in Chapter 17 of the FSAR and to the requirements of ANSI 18.7-1976, as modified in Appendix A to the FSAR (A.I.33-1).
The inspector identified no items of noncompliance during this review.
b.
Implementation The inspector reviewed the implementation of test and measurement equipment control to ensure that:
equipment lists were prepared to reflect use on safety-related structures, systems or components to include the calibration / adjustment frequency for each; formal requirements existed to identify the status of calibration; a prohibition existed to prevent the use of uncalibrated/out-of-calibration test and measuring equipments; responsibilities were assigned in writing to assure implementation of the program. A sample of several test and measurement equipment items included:
(1) Pressure gauges (2) Millivolt-Ammeters (3) Volt-Ohm Meters (4) Laboratory Instruments 10 CFR 50, Appendix B, Criterion XII states in part that "seasuring and testing devices used in activities affecting quality are properly calibrated...at specified periods...." Con *.ra ry to the above, the inspector found two spectrophotometers used for analysis of various substance concentrations in the primary plant lacking required calibration specificity. Calibration curves were esta-
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RII Report No. 50-366/78-44 I-25 blished for the instruments on July 14, 1976 (Bergmen-Duz) and May 13, 1978 (Perkin/Elmer Spectrophotometer), but no due date nor recalibration requirement existed to verify the curves upon a given frequency or when the light standard was replaced.
This example of failure to follow 10 CFR 50, Appendix B, Criterion XII has been combined with an additional example of a similar failure, documented in paragraph 7.c to collectively constitute an item of noncompliance (366/78-44-18).
14.
Plant Tour The inspector performed a tour of the Unit 2 plant and the diesel generator and warehouse buildings. Areas inspected included house-keeping and jumper controls. The inspector directly observed jumper placement in the Reactor Water Clean-Up Panel, and verified compliance in accordance with the procedure. Within the warehouse, the inspector noted leaning shelves. The diesel generator building lacked good housekeeping practices. The licensee stated that measures were already being taken to correct the leaning shelves and that the cleaning of the diesel generator would commence immediately.
The inspector identified no items of noncompliance during the tour.
15. Unresolved Items Unresolved items are items about which more information is required in order to ascertain whether they are acceptable items or items of noncompliance. Unresolved items identified during the conduct of this inspection are discussed in paragraphs 2.c, 2.d, 3.g through 3.1, 4.c, 5. f, 5.g, 6. c, 6. f, 6.g, 8. e and 12.a.
16. Exit Interview
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The inspectors met with licensee representatives (denoted in paragraph 1) \\~
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at the conclusion of the inspection on October 24, 1978, at the corporate offices, and on October 27, 1978 at the Hatch plant site. The inspectors summarized the purpose and scope of the inspection, and the findings as stated in this report. Target completion dates for the unresolve 3 items identified in paragraph 15 were confirmed as they are stated ' n the respective paragraphs.