IR 05000369/1978039
| ML19269C388 | |
| Person / Time | |
|---|---|
| Site: | McGuire  |
| Issue date: | 12/22/1978 |
| From: | Ashenden M, Jenkins H, Kellogg P NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19269C377 | List: |
| References | |
| 50-369-78-39, NUDOCS 7902020046 | |
| Download: ML19269C388 (24) | |
Text
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Report No.: 50-369/78-39 Docket No.: 50-369 License No.:
CPPR-83 Licensee: Duke Power Company Post Office Box 33189 442 South Church Street Charlotte, North Carolina 28242 Facility Name: McGuire Nuclear Station Unit 1 Inspection at:
Corneluis, North Carolina and Company Offices, Charlotte, North Carolina Inspection conducted: November 7-9 and 13-15, 1978 Inspectors:
M. C. Ashenden H. D. Jenkins J. A. Mcdonald W. A.
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Approved by:
Nuc ear upport Section No. 2 Reactor Operations and Nuclear Support Branch Inspection Summary Inspection on November 7-9 and 13-15, 1978 (Report No. 50-369/78-39)
Areas Inspected: Routine, unannounced inspection of procedures and activities necessary to implement an Operational Quality Assurance Program. This inspection was conducted to see if an Operational QA Program was in place or described in the areas of: QA/QC Administration / QA Audit Program; Document Control; Maintenance; Design Changes / Modifications; Surveillance Testing and Calibration Control; Procurement Control; Receipt, Storage and Handling of Equipment and Materials; Records; Tests and Experiments; Test and Measurement Equipment; and, Housekeeping. The inspection included an in-office manual review involving 42 inspector-hours, an on-site inspection of 76 inspector-hours and a Company offices inspection of 66 inspector-hours. This inspection was conducted by four (4) NRC inspectors.
Results: No items of noncompliance or deviations were identified.
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RII Rpt. No. 50-369/78-39 I-1 DETAILS I Prepared by:
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Dates of Inspectior}r? 09-9 and 13-15, 1978 Reviewed by:
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r, Ciirpi Date Nu 1 a Gupport Section No. 2 Reactor Operations and Nuclear Support Branch 1.
Persons Contacted Duke Power Company - McGuire Unit
- J. Barbour, Quality Assurance Manager, Operations
- W. Bradley, Quality Assurance Manager, Engineering
- R. Calhoun, Senior Quality Assurance Engineer, Construction
- G. Copp, Associate Engineer, Licensing
- J. Cox, Quality Assurance Engineer
- G. Figueroa, Planning Engineer
- D. Franks, Quality Assurance Specialist
- J. Frye, Senior Quality Assurance Supervisor, Audit Division
- G. Granby, Technical Specialist, Nuclear Safety Review Board
- D. Harrington, Training and Safety Coordinator
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RII Rpt.
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- D. Holt, Engineer, Licensing
- J. Jones, Jr., Engineer, Steam Production
- M. McIntosh, McGuire, Manager R. Micheal, Chemistry, Supervisor G. Mode, Health Physics, Supervisor
- D. Rains, Superintendent of Maintenance
- C. Robinson, Senior Quality Assurance Supervisor, Vendors Division
- C. Rogers, Engineer
- N. Rutherford, Jr., Director, Nuclear Safety Review Board
- W. Sample, Technical Services Engineer D. Simmons, Assistant Engineer
- L. Weaver, Performance Engineer
- J. Wells, Corporate Quality Assurance Manager
- R. Wilkinson, Superintendent of Administrative Services
- Denotes those present at the Corporate of fice or McGuire Station Exit Interview.
2.
QA/QC Administration References:
(a) McGuire Nuclear Station Nuclear Safety-Related Structures, Systems and Components, dated September 1976, with revisions through November 1978 (b) Duke Power Company Steam Production Department Administrative Policy Manual for Nuclear Stations (c) Duke Poser Company - Quality Assurance Department Quality Assurance Program (d) Duke Power Company Quality Control Procedure Manual a.
Program Review The referenced documents were reviewed to verify that the licensee's Program clearly defined those structures, systems and components and otner items and services to which the QA/QC controls are applied.
In addition, the Program documents were reviewed to ascertain that procedures and responsibilities had been established for making changes to such listings.
A review of the documents was also conducted to determine if methods were established to issue / revise /
control QA/QC procedures, to periodically evaluate the ef fectiveness of the QA/QC program and provide additional emphasis where needed in pro'slem areas, and to provide an evaluation of the overall effectiveness of the QA Progra.
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RII Rpt. No. 50-36c/78-39 I-3 The inspector identified five open items within the scope of the inspection criteria described above.
These are documented in paragraphs 2.c, 2.d, 2.e, 2.f and 2.g below.
b.
Implementation Implementation of Program controls was verified during the conduct of all the remaining inspection activities documented in this report.
c.
Defining Organizations Criterion II of 10 CFR 50, Appendix B requires regular review of the status and adequacy of the quality assurance program.
It further requires that management of other organizations partici-pating in the quality assurance program shall regularly review the status and adequacy of that part of the quality assurance program which they are exccuting.
During this inspection, the inspector was shown a documented procedure for a corporate audit by an outside organization which required the review of the status and adequacy of the antire QA Program. However, there were no documented programs or procedures for other managers within the Duke Power Company to review the status and adequacy of that portion of the QA Program which they were executing. Although ANSI N45.2-1977 discusses the interdisciplinary aspect of QA and various " organizational components" and the assigning of responsibility within an organization, it does not clearly define how organizations are to be considered from the review requirements aspect discussed in the last paragraph of Section 2 of the Standard. However, a breakdown by assignment of areas of functional responsibilities is discussed in the second paragraph of Section 2.
The Manager of Quality Assurance acknowl-edged the inspector's statements and then stated that an additional review of this area would be conducted to determine if any further controls were necessary or desirable to meet the requirements of Criterion II.
Until the licensee as completed and documented the results of this additional review and the results have been evaluated by Regicn II, this item (369/78-39-01) is open d.
Consumable / Expendable Items - Interior to Structures, Systems and Components In reference (a), the licensee had a listing of several consum-able/ expendable items. These items were all either part of or used in safety-related structures, systems and/or components. However, the inspector gave several additional examples such as nuclear fuel, lubricants, snubber fluid and battery acid which were not
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RII Rpt. No. 50-369/78-39 I,-4 currently on the list. While the procedures included criteria for determining when/if a structure, system or component is safety-related, no criteria were stated for consumable / expendable items except as they are included as part of a structure, system, or component.
Until the licensee completes an additional review of consumable /
expendable items that are part of, or contained within, and that affect the functioning of safety-related structures, systems and components and determines what portion (s) of his established QA Program will be applied, this item (369/78-39-02) is open.
e.
Consumable / Expendable Items - Exterior to Structures, Systems and Components As mentioned above, the licensee had previously considered and partially listed as safety-related consumable / expendable items which were part of safety-related structures, systems and components. However, such items as chemicals and reagents used to verify Limiting Conditions for Operations (LCO's) required by Technical Specifications on various safety-related structures, systems and conponents had not been previously considered.
The licensee listened without comment to the inspector's technical justification for inclusion of such items in a QA Program. The Manager of Quality Assurance stated that a review of this area would be conducted.
Until the licensee completes a review of consumable / expendable items used to verify the functioning of safety-related structures, systems and components and decides whether or not to include these items under all or a portion of his established QA Program, this item (369/78-39-03) is open.
f.
Guidance Versus Requirement in QCK-1 Reference (d) includes a procedure, QCK-1, " Control of Nonconforming Items".
Section 4.4 of that procedure states thct identified nonconformances involving possible vendor problems "should" be forwarded to the QA Manager, Vendors.
The licensee's internal policy defines "should" as a recommendation.
Section 5.6 of ANSI N45.2.13-1976 states that such identified problems "shall" be forwarded to the group evaluating suppliers.
Until the licensee revises QCK-1 or provides other assurances that nonconformances involving possible vendor problems shall be forwarded to the QA Manager, Vendors, this item (369/78-39-04) is ope.
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RII Rpt. No. 50-369/78-39 I-5 g.
Cross-Reference Index Section 5.1 of ANSI N18.7-1976 requires that a summary document shall be compiled by the licensee to identify the sources, to index such source documents to the requirements of the Standard and to provide a consolidated base for description of the program.
Section 2 of ANSI N45.2-1977 contains a similar requirement. The licensee has a cross-reference demonstrating Program elements that meet the 18 criteria of Appendix B, but did not have the more extensive index required by ANSI N18.7.
Until the licensee provides the index and cross-referencing required by Section 5.1 of ANSI N18.7-1976, this item (369/78-39-05) is open.
3.
QA Audit Program Referentes:
(a) QA-210, Departmental Audit Procedures, Revision 5, dated 3/78 (b) QA-230, Departmental Audit Scheduling and Follow-up, Revision 6, dated 10/78 (c) QA-130, Qualification and Training of Lead Auditors, Revision 3, dated 6/78 a.
Program Review The referenced documents were reviewed with respect to the Duke Topical QA Program and ANSI N45.2.12 (Draf t 3, Revision 4,1974) as committed to by that Nogram.
The licensee's audit program was reviewed to ensure overall responsibilities were designated in writint;; auditing personnel were adequately qualified; internal review was provided; administeative channels were defined to correct deficiencies; and, that procedures / checklists were required to be used in the audit.
The inspector identified no items of noncompliance er deviations during this review.
b.
Implementation The licensee's program of Quality Assurance Audits was reviewed, both at the Company of fices and at the McGuire Station, with respect to the licensee's imp:ementing procedures referenced above. All outstanding audits of McGuire Station were reviewed to ensure checklists / procedures were prepared properly, qualified auditors were employed; deficiencies found were tcsolved or carried as "open
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RII Rpt. No. 50-369/78-39 I-6 items", written reports were generated; written responses were obtained; and the audit program was evaluated by management.
During discussions with the McGuire Station Senior QA Engineer and his people, the inspector addressed the on-site surveillance program with regard to its functional capacity within the QA organization.
Since the licensee's implementing station procedures for surveillance do not specify a schedule or frequency for reaudit, corrective action or audited organization response times, the potential exists for deficiencies at the site level to be found but not corrected in a prompt manner. The surveillance system in effect at the present time provides no NRC-related official audit function and appears to lack the necessary controls to ensure that prompt corrections are initiated. The inspector commented upon the subject at the exit interview and received acknowledgement by the Corporate QA Manager that these were points to be considered.
The inspector identified no items of noncompliance or deviations during this review.
4.
Document Control References:
(a) Station Directive 2.1.1, Control of Master File Documents, Revision 3, dated 6/78 (b) Station Directive 2.1.2, Drawing Distribution and Control, Revision 2, dated 7/77 a.
Program Review The referenced documents were reviewed with respect to the Duke Topical QA Program, ANSI N18.7-1976, and ANSI N45.2-1971 as committed to by that Program.
The inspection was to verify that administrative control had been established for the indexing, issuance and revision of drawings.
The inspector identified no items of noncompliar.ce or deviations during this review.
b.
Implementation The licensee's document control program was reviewed at the Company offices and at the McGuire Station with respect to the licensee's implementing procedures referenced above. The inspector selected ten (10) drawings and five (5) documents to assure that master file and issued copies were censistent with the master inde.
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RII Rpt. No. 50-369/78-39 I-7 The inspector identified two open items within the scope of the inspection criteria described above.
These are documented in paragraphs 4.c and 4.d.
c.
Drawing Control The licensee's drawing control program is not implemented in that nine (9) of seventy-four (74) copies of drawings inspected were either not updated to reflect current revision status or were missing from the assigned location.
The licensee is p:anning to conduct an audit of this area and to accomplish the required corrective action.
Until the licensee implements the drawing control progra'n and the effectiveness of this corrective action is reviewed, this iteo (369/78-39-06) is open.
d.
Vendor Instruction Manual Control Document control measures do not provide for ascertaining that proper documents are being used in that the current revision status of vendor instruction manuals is not indicated as required by Section 7 of ANSI 45.2-1971.
Until the licensee establishes and implements document control measures to assure that the current revision status of vendor instruction manuals is indicated, tnis item (369/78-39-07) is open.
5.
Maintenance References:
(a) McGuire Nuclear Station, Maintenance Manual, Revision 0, dated 1/78 (b) Station Directive 2.7.1, Control of Interfacing Individuals and Organizations, Revision 1,
dated 10/78 (c) Station Directive 3.1.25, Shutdown Request Procedures, Revision 4, dated 5/78 (d) Station Directive 4.7, Control of Maintenance Prcgram, Revision 1, dated 6/78 a.
Program Review The referenced documents were reviewed with respect to the requi.e-ments of the Duke Topical QA Program and ANSI 18.7-1976, as committed to in that program.
The inspection was conducted to verify that
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RII Rpt. No. 50-369/78-39 I-8 responsibilities had been established for the initiation, approval, inspection and review of preventive and corrective maintenance of safety-related systems, components and structures.
The inspector identified no items of noncompliance during the review.
b.
Implementation
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The licensee's maintenance program was reviewed both at the Company offices and at the McGuire Station with respect to the licensee's implementing procedures referenced above. The inspector selected ten (10) documents of completed maintenance activities, to verify maintenance requests were properly initiated, approved, inspected and reviewed to ensure the required controls were being implemented.
Two open items were identified within the scope of the inspection criteria described. These are documented in paragraphs above and in paragraphs 5.c and 5.d.
c.
Maintenance Scheduling The inspector noted that the McGuire Station had not yet imple-mented a complete preventive maintenance schedule as required by Section 5.2.7.1 of ANSI N18.7-1976 which requires an approprirte senedule for safety-related structures, systems and components and prescribes the frequency and type of maintenance to be performed.
Until a complete preventive maintenance schedule is fully developed, this item (369/78-39-08) is open.
d.
Preventive Maintenance The inspector noted at McGuire Station that a post-maintenance retesting program had not yet been established.
The inspector discussed this problem with the licensee and it was determined that the problem had been identified by the Station QA group, and that a procedure was forthcoming to ensure replacement components receive adequate retesting to indicate a high probability of satisfactory performance of a safety-related system, structure or component as required by Section 5.2.7.1 of ANSI N18.7-1976.
Until such time that the procedum is approved and implemented, this item (369/78-39-09) is ope.
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RII Rpt. No. 50-369/78-39 I-9 6.
Design Changes / Modifications Reference:
Administrative Instructions for Modifications, Section 4.4 of the Steam Production Department APM a.
Program Review The referenced document was reviewed with respect to the Duke Topical CA Program, and ANSI 45.2.11-1974, as committed to by that Program. The review consisted of verifying that procedures existed for initiating derign change requests, proper reviews and evaluations were required, questions involving an unreviewed safety question per 10 CFR 50.59 were answered, design analysis and inputs were required, communications via internal and external interface links existed, and specific design organization responsibilities were delineated in writing.
The inspector identified three (3) open items as discussed in paragraphs 6.c, 6.d and 6.e.
b.
Implementation The licensee's program of Design Changes / Modifications was reviewed both at the Company offices and at the McGuire Station with respect to the licensee's f2plementing procedure referenced above.
Where th5s procedure had been determin =d to be inadequate during the Program Review, the program was f aspected to the applicable require-ments of the Duke Topical QA Program and the ANSI standard committed to by that Program.
During his review, the inspector audited ten (10) design change packages which covered the period January through October 1978.
The inspector identified no items of noncompliance or deviations during this review.
c.
Approval of Revisions to Design Changes During the manual review, the inspector noted that item 4.4.4.15 of the referenced document allowed revisions to the design change be made provided no significant alteration is made to the initial design change request. Additionally, if the revision was deemed insignificant, there was no requirement to review the original safety evaluation as a resalt of the revision. Until such time as the referenced document is amended and implemented to follow the requirements of ANSI 45.2.11, Section 7.2 in stipulating the necessary review and approval of revisions to design changes /
modifications, this item (366/78-39-10) is open.
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RII Rpt. No. 50-369/78-39 I-10 d.
Establishment of External Interface and Communications Documentation Based upon discussion with System Engineering-Licensing personnel and review of the above referenced procedure, the inspector found no procedural. provisions which identified in writing the external interface of design activities as required by Section 5.1 of ANSI N45.2.11-1974. Additionally, there existed no requirement to document design information as it was relayed between design acti-vities as stipulated in Section 5.1.4 of ANSI N45.2.11.
Until such time as the external interface between design activities is identified in writing and transmission of design information between organizations is documented, this item (369/78-39-11) is open.
e.
Design Input Informatior The referenced procedure does not require that the design change specify design inputs as required by ANSI N45.2.11-1974, Section 3.1.
Until a method is generated and approved to require design inputs to be identified within the design change, this item (369/78-39-12)
is open.
7.
Surveillance Testing and Calibration Control References:
(a) Station Directive 3.2.1, Identifying, Scheduling and Performance of Periodic Tests, Revision 1,
dated 5/78 (b) Steam Production Department Administrative Policy Manual, Revision 16, Section 3.2, Testing a.
Program Review The referenced documents were reviewed with respect to the Duke Topical QA Program and ANSI N18.7-1976 as committed to by that Program.
The inspection was conducted to verify that admini-strative control had been established for maintenance of a master schedule for conducting surveillance tests, calibration of safety-related instruments, for use of approved procedures in the conduct of these tests and calibrations, and review of procedure results.
The inspector identified no items of noncompliance or deviations during this revie.
RII Rpt. No. 50-369/78-39 I-11 b.
Implementation The licensee's program of surveillance testing and calibration control was reviewed at the McGuire Station with respect to the licensee's implementing procedures referenced above. The inspector selected one-hundred and twenty (120j surveillance tests from the requirements of the Technical Specifications and twelve (12)
safety-related plant instruments utilized to verify Technical Specification requirements to assure that each test requirement and instrument calibration had been included in master schedule and that approved procedures were available for their conduct.
Tw'; open items were identified during the inspection and are documented in paragraphs 7.c and 7.d.
c.
Surveillance Testing Procedures for the enduct of surveillance testing requ aed by the Ter' 3ical Specifications have not been written and approved for
.orty-two (42) of one-hundred and twenty (120) surveillance requirements inspected.
Until a subsequent NRC inspection of surveillance tests indicates that the required procedures have been written and approved prior to the accomplishment of the surveillance, this item (369/78-39-13)
is open.
d.
Calibration Control The program for calibration of instruments required to verify Technical Specification requirements has not been established. The equipment has not been identified nor included in a master schedule.
Until the licensee identifies the instruments required to verify Technical Specification requirements and prepares a master surveil-lance schedule for this equipment, this item (369/78-39-14) is open.
8.
Procurement Control References:
(a) Steam Production Department Administrative Policy Manual, Section 4.5, Purchase Specifications, Revision 16, dated 7/78 (b) Design Engineering Department Quality Assurance Manual, Section PR-302, Procurement, Revision 5, dated 6/77
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RII Rpt. No. 50-369/78-39 I-12 a.
Program Review The referenced documents were reviewed with respect to the require-ments of the Duke Topical QA Program and ANSI N45.2.13-1976 as committed to by that Program.
The inspection was conducted to verify that administrative controls had been established for the generation and approval of procurement documents and for the qualification and m..litoring of bidders / suppliers.
The inspector identified no items of noncompliance or deviations during this review.
b.
Implementation The licensee's program of procurement was reviewed both at the Company offices and at the McGuire Station with respect to the licensee's implementing procedures referenced above. The inspector selected six (6) recently purchased safety-related items repre-sentative of the various disciplines (mechanical, electrical, I&C and operational) to assure that procurement documents were prepared, including documentation of quality and purchases were made from qualified vendors. Additionally, the inspector selected three (3)
suppliers to assure they had been evaluated and audited as required, and that the results of these audits had been applied to the approved bidder's list.
The inspector identified no items of noncompliance or deviations during this review.
9.
Receipt, Storage and Handling of Equipment and Materials References:
(a) MHP 1.2, Requisition for Materials, Revision 4 (b) MHP 2.1, Receipt, Inspection, and Control of Stores /
Stock, Capital Stock and Non-Stock Items, Revision 3 (c) MHP 3.1, Storage Methods and Areas, Revision 2 (d) MHP 7.1, Warehouse Temperature and Humidity Measurements, Revision 3 (e)
OCG-1, Receipt, Inspection and Control of Materials, Parts, and Components Important to Nuclear Safety Except Nuclear Fuel, Revision 10 (f) OCG-2, New Fuel and Rod Assemblies Receipt Inspection, Revision 5
RII Rpt. No. 50-369/78-39 I-13 (g) OP/0/A/6550/01, Receipt, Inspection and Storage of New Fuel, dated 7/78 (h) MP/0/B/7650/06, Slings - Safety Inspection, dated 6/76 (i) MP/0/B/7650/07, Chain Hoists - Safety Inspection, dated 6/76 (j ) MP/0/B/7650/08, Hooks - Safety Inspecticn, dated 6/76 a.
Progran. Review The referenced documents were reviewed with respect to the require-ments of the Duke Topical QA Program and ANSI N45.2.2-1972 as committed to in that Program.
The inspection was conducted to verify that administrative control had been established for receipt of safety-related items, for disposition of items received on-site, and for the storage and handling of items following their receipt.
Three potential areas of concern were identified during the in-of fice review. These areas were inspected during the implementation phase and each generated an open item as documented in paragraphs 9.c, 9.d and 9.e below.
b.
Implementation In addition to verifying the items detected during the Program Review phase, the inspector also selected six (6) recently purchased safety-related items representative of the various disciplines (mechanical, electrical, I&C and operational) to assure that they had been receipt inspected, dispcnitioned and stored as required; selected four (4) safety-related items currently in storage to verify that each was traceable back to receipt in-spection and procurements documents; and, conducted a tour of the warehouse to verify that required conditions were in force and that an additional sample of items listed on warehouse inventory files (three (3) safety-related pieces) were stored in the stated locations with the required storage controls.
As a result of the above inspection activities, five (5) addicional open items were disclosed as set forth in paragraphs 9.f through 9.j belo.
RII Rpt. No. 50-369/78-39 I-14 c.
Inconsistency between Procedures and Commitments in Topical QA Program During the review of the licensee'.c implementing procedures, the inspector noted a number of casen where the requirements of ANSI N45.2.2-1974 as committed to in the Duke Topical QA Program were either downgraded, incompletely described or missing. Some specific examples include, but are not limite.d to:
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Downgrading the requirements (shall) of Sections 6.2.2, 6.2.4 and 6.2.5 of the Standard into recommendations (should) when listing them in reference (c);
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Incompletely describing the shipping damage inspection required and stipulated as to content in Section 5.2.1 of the Standard when mentioning this activity in reference (b) and,
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Leaving out the very specific and detailed requirements for the marking of items given in Appendix A, Section 3.9 of the Standard.
Until the licensee takes action to bring his implementing procedures and his commitments in the Duke Topical QA Program into alignment, this item (369/78-39-15) is open.
d.
Control of Limited Shelf-Life Items During the review of the licensee's procedures, the inspector noted that control of limited shelf-life items was mentioned but the method of control was not stipulated. The licensee informed the inspector that a computer-based system for control of these items was being developed but was not yet in service.
Until the licensee completes and implements the program currently under development or establishes equivalent methods for the control of limited shelf-life items, this item (369/78-39-16) is open.
e.
Shipping Damage Inspectors' Qualifications Although the description of the shipping damage inspection was not complete (see paragraph 9.c above) this required inspection was addressed in the licensee's procedures.
However, the qualifi-cation / certification of the persons performing this activity was not addressed. During the implementation phase, the inspector was informed that varehouse personnel normally performed this inspection and that they were not qualified / certified to ANSI N45.2.6-1973.
Section 2.4 of the Standard requires that personnel who perform
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RII Rpt. No. 50-369/78-39 I-15 inspection activities shall be qualified in accordance with ANSI N45.2.6.
The shipping damage inspection is listed in Section 5.2.1 of ANSI N45.2.2.
Until the licensee establishes provisions to assure that personnel performing the shipping damage inspection described in Section 5.2.1 of ANSI N45.2.2 meet the requirements specified in Section 2.4 of the Standard, this item (369/78-39-17) is open.
f.
Adequacy of " Periodic" Inspection Plans of the Licensee Section 6.2 of ANSI N45.2.2-1972 states, " Periodic inspection shall be performed to assure that storage areas are being maintained in accot Nnce with these requirements. The housekeeping requirements shall be in accordance with N45.2.3".
Section 6.4.1 of ANSI N45.2.2 states, " Inspections and examinations shall be performed and docu-mented on a periodic basis to assure that the integrity of the item and its container as provided for under Section 3 of this standard is being maintained.
Deficiencies noted shall be corrected and documented." The Standard then goes on to enumerate six (6) charac-teristics to be verified. The licensee informed the inspector that for both of these requirements the periodic frequency for inspection would be annual.
The inspector pointed out the apparent on going characteristic of these requirements as indicated by the phrases
"are being maintained" and "is being maintained".
In a telephone conversation between the Operatins Quality Assurance Manager and Mr. Ashenden on November 20, 1978, the licensee acknowledged the inspector's statement and then stated that Duke Power Company would review their current procedures with respect to the "on going" characteristic mentioned.
Following that review, additional or more frequent inspections involving one or more groups within Duke Power Company would be documen'.ed if deemed necessary to comply with the stipulated requirements of the Standard.
Until the licensee completes his review of current inspection plans with respect to the requirements of Sections 6.2 and 6.4.1 of ANSI N45.2.2 and the results of that review are inspected for adequacy, this item (369/78-39-18) is open.
g.
Conflict between Procedures QCG-1 and MHP 5.3 As one of the items to verify (see paragraph 9.b above), the inspector selected a recent shipment of welding material.
The inspector found that the weld material was not stored in its documented location (see also paragraph 9.h below) but it was located in the QC Hold Area.
In reviewing the QC Receipt Inspection, the inspector found that the material had been correctly innpected and received.
Hozever, the QC procedure,
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RII Rpt. No. 50-369/78-39 I-16 QCG-1, was written to match a system in use at the licensee's other nuclear power site (Oconee) where a weld material issue station is used. At the McGuire Station, such a system is not currently in use.
The conflict that arises is based on the removal of the QC acceptance tag which then prohibits storage under the licensee's Material Hrndling Procedure (MHP) 5.3.
Until the licensee resolves the current conflict between OCG-1 and MHP 5.3 with respect to the handling of marking of acceptability for welding material, this item (369/78-39-19) is open.
h.
Incorrect Storage Locations During the review of the warehouse storage, the inspector selected items to verify that they were in their listed storage location.
Of ten (10) items reviewed, three (3) were not in the location indicated in the licensee's records.
One item (see paragraph 9.g above) had been moved because of a conflict in procedures. Two other items were stored on a shelf other than the ene listed. All items were eventually located. Section 6.6 of ANSI N45.2.2-1972 requires that records indicate storage location. The licensee's procedure requires an annual update of all storage locations.
Until the licensee completes the annual update of locations and the ability to meet the requirements of Section 6.6 of ANSI N45.2.2 is subsequently verified by NRC, this item (369/78-39-20) is open.
i.
Periodic Inspection of Handling Equipment References (h), (i) and (j) cover various types of handling equipment. The licensee also has procedures for the inspections of cranes and hoists, but these were not reviewed as part of this inspection. The inspection of hooks and chain hoists (references (i) and (jl) is documented; the inspection of slings (reference (b)) is not. The licensee stated that visual inspections (required by reference (h)) are performed whenever the slings are checked out for use. Section 7.4 of ANSI N45.2.2-1972 requires that an inspection program shall be established for equipment and rigging. The Section further requires that periodic inspection shall be supplemented with a special visual test prior to handling, and Section 7.4 states that the system used shall indicate acceptability cf all equipment and rigging af ter each inspection.
Section 2.3 of the Standard requires that inspection and test results be documented and lists three (3) specific items which these reports are to contain.
Until the licensee establishes provisions for periodic inspections and documentation of the results as required by Section 7.4 and 2.3 of ANSI N45.2.2, this item (369/78-39-21) is ope.
RII Rpt. No. 50-369/78-39 I-17 j.
Rodent /Small Animal / Insect Control During this inspection of records (see paragraph 10) and during the review of activities covered under this paragraph, inspectors found that no program existed for the control of rodents and small animals as required by Section 6.2.5 of ANSI N45.2.2-1972 nor for the control of rodents and insects as required by Section 5.6 of ANSI N45.2.9-1974.
However, this inadequacy had been detected by the licensee as documented in Finding 3 of audit 0-78-5.
To answer this audit finding, the licensee is to establish a rodent /small animal / insect control program for the entire McGuire Station.
Until the licensee implements a rodent /small animal / insect control program meeting the requirements of Section 6.2.5 of ANSI N45.2.2 and Section 5.6 of ANSI N45.2.9, this item (369/78-39-22) is open.
10.
Records References:
(a) QA-111, Interdivisional Transfer of QA Records, Revision 1, dated 1/77 (b) QA-101, Quality Assurance Records Storage Vault (General Office), Revision 0, dated 5/77 (c) QA-102, Storage of Radiographs, Revision 0, dated 9/78 (d) QA-410, Processing of QA Records for Purchased Items, Revisica 4, dated 9/78 (e) QA-411, Filing of QA Records for Purchased Items, Revision 2, dated 5/77 (f) QA-504, Quality Assurance Records, Operations, Revision 6, dated 4/78 (g) PR-930, Supplier QA Record Review, Approval and Storage, Revision 3, dated 3/76 (b) PR-931, Design Quality Assurance Records Collection, Maintenance and Storage, Revision 0, dated 3/78 (i) Station Directive 2.1.1, Control of Master File Documents, Revision 3, dated 6/78
RII Rpt. No. 50-369/78-39 I-18 a.
F;ogram Review The referenced documents were reviewed with respect to the licensee's accepted Duke Topical QA Program and with respect to selected requirements of ANSI N45.2.9-1974 as committed to by that Program. The inspection was conducted to verify that administrative control had been established for the ma inter.anc e, storage and retention of required operating phase, preoperational test phase and construction phase QA records.
The inspector identified no items of noncompliance or deviations during this review.
b.
Implementation The licensee's program for the control, handling and storage of records was reviewed at the Company offices and at the McGuire Station with respect to the licensee's implementing procedures referenced above. The inspector selected ten (10) QA records to assure records are maintained, stored and retained as required.
Two open items were identified during this inspection and are documented in paragraphs 10.c and 10.d.
c.
Record Storage at Company Offices The inspector noted during the inspection at the Company offices that the records were not afforded the protection as required by Section 5.6 of ANSI N45.2.9-1974. The inspector further noted that procedure QA-504 referenced above permits the storage of documents in a hTPA class D file cabinet in a fire resistive building and also permited the storage in hTPA Class C file cabinet in a non-fire resistive building.
Until the written description of record keeping practices is made consistent with the commitments for recordkeeping in the Duke Topical QA Program, this item (369/78-39-23) is opea.
d.
Record Storage at McGuire Station In reviewing Station Directive 2.1.1 referenced above, the inspector noted that several satellite file storage locations were listed. During inspection of these files, the inspector noted they were not afforded the protection as described in Section 5.6 of ANSI N45.2.9-1974, which requires the storage of records to be located as to protect them from possible destruction by causes such as fire, flooding, tornadoes, insects, rodents and possible deteri-oratio RII Rpt. No. 50-369/78-39 I-19 In discussing the problem with the QA site personnel, it was found that this problem was identified in surveillance report MC-78-11, Document Control of Records. Until such time as the records are afforded the protection required by the Duke Topical QA Program, this item (369/78-39-24) is opent 11.
Tests and Experiments a.
Program Review The inspector reviewed the provisions generated by the licensee to ensure that proper safety evaluations per 10 CFR 50.59 were required if a test or experiment were proposed outside the scope of those operations described in the FSAR. There existed no formal programs for tests and experiments, but within the temporary testing procedure, the provision did exist to ensure that a safety evaluation was conducted.
The inspector identified no items of noncompliance or deviations during this review.
12.
Test and Measurement Equipment References:
h) Station Directive 2.3.0, Control of Measuring and Test Equipment, Revision 3, dated 8/78 (b) Steam Production Department Administrative Policy Manual, Revision 16, Section 2.3 (c) Standard and Testing Facility Reference Manual, Revision 5, dated 6/78 a.
Program Review The referenced documents were reviewed with respect to the Duke Topical QA Program and ANSI N18.7-1976 as committed to by that Program.
The inspection was conducted to verify that admini-strative controls had been established for the calibration, marking and utilization of test and measurement equipment.
The review indicated several areas where the referenced documents did not include specific requirements of either the accepted Program or the ANSI Standards. Each of these areas was reviewed during the implementation inspection.
Four un esolved items were identified during this inspection and are docunented in Paragraphs 12.d,12.e, 12. f and 1.
RII Rpt. No. 50-369/78-39 I-20 b.
Implementation The licensee's test and measurement equipment program was reviewed both at the Standards and Testing Facility and at the McGuire Station.
Ir. addition to verifying the items detected during the Program Review phase, the inspectors also selected five (5) Standards and Testing Facility and twelve (12) McGuire Station pieces of test and measurement equipment utilized by the various disciplines (mechanical, electrical, I&C, chemistry and health physics) to
~
assure that they had been properly stored, identified and calibrated by approved procedure with accuracy traceable to the National Bureau of Standards.
One open item was identified during the inspection and is documented in Paragraph 12.c below.
c.
Failure to Establish Master Calibration Schedule No master schedule has been established for the conduct of periodic calibration of test and measurement equipment used by the Health Physics Laboratory as required by Section 5.2.8 of ANSI N18.7-1976.
Until the licensee establishes a master surveillance schedule for the test and measurement equipment controlled by the Health Physics 1.aboratory, this item (369/78-39-25) is open.
d.
Standards and Testing Facility-Recordkeeping During inspection of the Facility, the inspector was shown a dual recordkeeping system for some records.
The licensee's commitment to ANSI N45.2.9-1974 allows either a dual records arrangement or specifies a system for maintaining single records.
The Standards and Testing Facility Reference Manual describes only the controls applied to the records maintained in the Company offices and does not reference another set of records. Since the current description does not apply the controls required for single records systeos and does not specify that dual records will be maintained, the inspector could not verify that the procedural commitments necessary to implement the licensee's Topical QA Program were in place.
Until the licensee's written description in the Standards and Testing Facility Reference Manual implements the licensee's commit-ments in the Duke Tcpical QA Program in the recordkeeping area, this item (369/78-39-26) is ope RII Rpt. No. 50-369/78-39 I-21
,
e.
Standards and Testing Facility - Out of Calibration Controls Functionally, the Facility controls out of calibration equipment by removal of the calibration sticker when the instrument is printed out on the computer's list of equipment to be calibrated.
In addition, the computer generated Certificates of Calibration for instruments will not print out a certificate if an out of calibration or past due for calibration instrument is. listed as one of the calibrating units. However, these controls wcre not described in the documents presented for the inspector's review.
Until the licensee documents either his current practices or established equivalent controls to assure that out of calibration and/or past due for calibration instruments are not used for safety-related work, this item (369/78-39-27) is open.
f.
Standards and Testing Facility - Trend Analysis Equipment History Cards and other data available at the Facility would allow the review required by Section 4.1(4) of ANSI N18.7-1976.
Further, the persons interviewed indicated that, routinely, technicians performing calibrations are supposed to review these data to detect any chronic or repetitive failures. However, neither the data base nor the review requirements are described from this aspect in the licensee's documents.
Until the licensee establishes written requirements to use infor-mation currently available to detect chronic failures and other unsatisfactory trends on equipment under the control of the Standards and Testing Facility, this item (369/78-39-28) is open.
g.
McGuire Station Trend Analysis Equipment History Cards and other data available at the plant site would allow the review required by Section 4.1(4) of ANS: N18.7-1976.
Further, the persons interviewed indicated that, routinely, technicians performing calibrations are supposed to review these data to detect any chronic or repetitive failures. However, neither the data base nor the review requirements are described from this aspect in the licensee's documents.
Until the licensee establishes written requirements to use info rmation currently available to detect chronic failures and other unsatisfactory trends on equipment under the control of the McGuire Station, this item (369/78-39-29) is ope.
RII Rpt. No. 50-369/78-39 I-22 13.
Housekeeping References:
(a) Duke Power Company Steam Production Department Administrative Policy Manual for Nuclear Stations, Revision 16, dated 7/70 (b) Station Directive 3.11.0, Revision 2, dated 3/78 a.
Program Review The referenced documents were reviewed with respect to the accepted Duke Topical QA Program and ANSI N45.2.3-1973 as committed to in that Program.
Section 3.5 of the Standard requires periodic inspection and examination of work areas to be performed at scheduled intervals.
This same Section then lists specific items that shall be included in these inspections.
Reference (b) required that QC personnel perform these inspections on a random, not a scheduled basis. In addition, the procedure to be used for these QC inspections was in draft form and was currently under review.
Until the licensee makes the inspection requirement of Station Directive 3.11.0 consistent with the requirements of the Duke Topical QA Program and approves, issues and implements a procedure for performing the required inspections of housekeeping, this item (369/78-39-30) is open.
b.
Implementation Housekeeping activities were reviewed within the Administrative Building during this inspection. However, insufficient plant areas were under operational control to allow verification of controls in other areas at this time.
The inspector identified no items of noncompliance or deviations during this review.
14.
Open Items Open items, as utilized in this report, are items about which corrective action or further evaluation is required before a finding of acceptable implementation can be made. Open items identified during the conduct of this inspection are discussed in paragraphs 2.c through 2.g, 4.c, 4.d, 5.c, 5.d, 6.c, 6.d, 6.e, 7.c, 7.d, 9.c through 9.j, 10.c, 10.d, 12.c through 12.g and 1.
RII Rpt. No. 50-369/78-39 I-23 15.
Exit Interview The inspectors met with licensee representatives (denoted in paragraph 1) at the conclusion of the inspection on November 9, 1978, at the Company offices, and on November 15, 1978, at the McGuire Station.
The inspectors summarized the purpose and secpe of the inspection, and the findings as stated in this report. Since this inspection was conducted to verify the Operations QA Program prior to issuance of an Operating License, there were no items of noncompliance identified. All inspection findings requiring corrective action are identified in paragraph 14. At the Exit Interview on November 15, 1978, the Corporate Quality Assurance Manager stated that Duke Power Company would endeavor to resolve all items at least one month prior to issuance of the Operating License.