IR 05000369/1981017

IE Insp Repts 50-369/81-17 & 50-370/81-05 on 810601-12. Noncompliance Noted:Failure to Review Plant Procedures Every 2 Yrs,Failure to Maintain Cleanliness & Failure to Control Temporary Jumper Installation

ML20032D092
Person / Time
Site:	McGuire, Mcguire
Issue date:	07/16/1981
From:	Belisle G, Bemis P, Fredrickson P, Skinner P, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20032D063	List: IR 05000369/1981017 ML20032D062 ML20032D067 ML20032D072 ML20032D077 ML20032D084 ML20032D087
References
50-369-81-17, 50-370-81-05, 50-370-81-5, NUDOCS 8111130379
Download: ML20032D092 (32)

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UNITED STATES 8%

NUCLEAR REGULATORY COMMISSION

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Report Nos. 50-369/81-17 and 50-370/81-05

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Licensee: _ Duke Power Company es

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Charlotte, NC 28242

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Facility Name: McGuire 1 and 2

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Docket Nos. 50-369 and 50-370

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License Nos. NPF-9 and CPPR-84

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Inspection at Cornelius, NC and Company offices in Charlotte, NC S

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Approved by:

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C. M. Uprightg ectM6 Chief

Engineering-spect'fon Branch

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Engineering and Technical Inspection Division

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SUMMARY

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Inspection on June 1-5 and 8-12,1981

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Areas Inspected

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This routine, announced inspection involved 324 inspector-hours on site ard at

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s the company offices in the areas of licensee action on previo.u_s inspection findings, QA Program annual review,.QA/QC administration program, personnel qualification program, design changes and modifications program, t~ests and -

experiments, procurement, receipt storage and handling records progra:n, document.

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control program, offsite review ' committee, audit and ' audit implementation program,.offsite support staff, training, requalification training, housekeeping /

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%1eanlines; program,, test and measurement. equipment program, surveillance pro-gram, procedurss program, licensee action on previously identified inspection l

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items, and independent \\inspectio3 ef fort.

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t Of the 21 ate'as inspect'vd, 'no violations or deviations were identified in 15 i

areas; five' v}olatior,s inre found in five areas (Failure to review plant proce-dures.every two years, paragraph 5; Failure to maintain cleanliness, paragraph 18;7Fdilu' re ~to control, temporary jumper installation, and removal, paragraphs 8.a and 3.b; Failure to use approved tape on quality stainless steel piping, para-grap111; and Failure to properly store training' records paragraph 16.a).

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r REPORT DETAILS

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Persons Contacted

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Licensee Employees

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1. J. Barbour, QA Manager, Operaticns j

• G. Figueroa, Planning Engineer

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• J. Foster, Health Physics Coordinator

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1. • D. Franks, QA Supervisor, Surveillance

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i J. Gaston, Instructor

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• G. Gilbert, Operating Engineer

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W. Griffin Instructor

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• A. Harringten, Training and Safety Coordinator

1. • R. Koehler, Manager Technical Training

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1. • D..Lampke, Jr., Assistant Engineer Licensing C. Majure, Instructor

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1. • M. McIntosh, Manager, McGuire Nuclear Station

T. Parker, Training Supervisor, McGuire Nuclear Station

• F. Pope, Administration Supervisor, Document Control

• D. Rains, Superintendent of Maintenance L. Reed, Senior Instructor

1. N. Rutherford, Licersing

• W. Sample, Projects and Licensing

1. H. Tc:ker, Manager, Nuclear Production Division R. Wilson, Senior Instructor

• L. Weaver, Performance Engineer

1. J. Wells, QA Manager

• R. Wilkinson, Superintendent of Administration Other licensee employees contacted included technicians, operators, mechanics, and office personnel.

NRC Resident inspector i

1. M J. Graham

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• Attended exit interview on June _ 9.1981

1. Attended exit interview on June 12, 1981

2.

Exit Interview The inspection scope and findings were summarized on June 3,1981 on site and June 12, 1981 at the company offices with those persons indicated in paragraph 1-above. The licensee was informed of the inspection findings as indexed in paragraph 25. The licensee acknowledged the inspection findings.

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3.

Licensee Action on Previous Inspection Findings (92702)

The following terms are defined and used throughout this report:

Accepted Quality Assurance Program Duke Power Company

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Quality Assurance Program, Duke-1-A, Amendment 4 dated 6/78 APM Administrative Policy

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Manual DPC Duke Power Company

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DPCCQAP Duke Power Company

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Corporate Quality Assurance Program DPCDEDQAP

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Duke Power Company Design Engineering Department Quality Assurance Program DPCSPD

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Duke Power Company Steam Production Department GET

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General Employee Training NSM

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Nuclear Station Modification NSRB

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Nuclear Safety Review Board QA

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Quality Assurance QC

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Quality Control R0

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Reactor Operator SRO

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Senior Reactor Operator SD

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Station Directive SSRG

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Station' Safety Review Group WR

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Work Request (

Items of noncompliance from Inspection Reports 50-369/80-08, 50-370/80-05, 50-413/80-09, 50-414/80-09, 50-491/80-07, 50-492/80-06 and 50-493/80-06 were reviewed with respect to the licensee's letters dated August 15, 1980, November 11, 1980 and January 29, 1981.

a.

(Closed) Infraction (369/80-08-03, 370/80-05-03, 413/80-09-03, 414/80-09-03, 491/80-07-03, 492/80-06-03, and 493/80-06-03): Corporate system of audits of all aspects of the QA Program. The inspector reviewed QA-230, Departmental Audit Scheduling and Follow-Up, Revision 8 dated 3/81.

Paragraph 5.1.4.1 of this procedure states that a department 31 l

audit shall be performed o,ce every calendar year at each QA record storage facility. The inspector revieweo the results of audits of the record storage for the McGuire, Catawba and General Office facilities (audits 0-80-12, CD-81-7 (CN), E-80-6 respectively) to insure annual audits were being performed. Construction activities on Dockets 491, 492 and 493 have been suspended indefinitely. The inspector reviewed QA-210, Departmental Audit Procedure, Revision 11 dated August 1980.

Paragraph 4.1 assigns to the lead auditor the responsibility of main-taining a documented system to assure that applicable elements of the QA program are audited on an annual basis.

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(Closed) Infraction (369/80-08-02, 370/80-05-02, 413/80-09-02, 414/

80-09-02, 491/80-07-02, 492/80-06-02, 493/80-06-02):

Failure of departmental procedures to implement ANSI N45.2.9-1974 for corporate records vault.

The inspector reviewed QA, Steam, and Design Engineering Department records procedures for the required ANSI N45.2.9 information on the control of records. All procedures had a method for the receipt and preservation of records and a reference to the corporate records vault which is described in detail in the records canagement policy and procedures manual.

c.

(Closed) Infraction (369/80-08-01, 370/80-05-01, 413/80-09-01, 414/80-09-01, 491/80-07-01, 492/80-06-01, 493/80-06-01): Failure of temporary record storage iacilities to meet ANSI N45.2.9-1974 fire protection requirements. The inspector verified that quality records have been located in the corporate vault which meets the requirements of DPC's

commitment for record storage protection.

4.

Unresolved Items Unresolved items are matters about which more information is required to i

determine whether they are acceptable or may involve violations or devia-l tions. A new unresolved item identified during this inspection is discussed

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in paragraph 23.

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5.

QA Program Annual Review (35701)

References: (a)

Accepted QA Program (b)

QA 100, Preparation and Issue of Quality Assurance Procedures, Revision 4 dated 3/78 (c)

QA 101, Quality Assurance Records Storage Vault (General Office), Revision 2 dated 10/80 (d)

QA 112, Certification of Quality Assurance Analysts, Revision I dated 8/79 (e)

QA 130, Qualification and Training of Lead Auditors, Revision 6 dated 4/81 (f)

QA 150. Trend Analysis, Revision 2 dated 5/78 (g)

QA 160, Performance of Corporate Quality Assurance Audits, Revision 0 dated 11/78 (h)

QA 410, Processing of QA Records for Purchased Items, Revistor 5 dated 5/79 (i)

QA-501, Placing, Reviewing and Verifying Quality Assurance Requirements on Station Procedures, Revision 3 dated 3/78 (j)

QA 504, Quality Assurance Records, Operations, Revision 8 dated 3/80 (k)

QA 506, Quality Assurance Review of Nuclear Station Modifications / Nuclear Problem Reports, Revision 4 datea 4/79 (1)

QA 510, Quality Assurance Review of Station Work Request, Revision 3 dated 3/81 (m)

Duke Power Company Quality Assurance Department Corporate Quality Assurance Program The inspector reviewed references (b) through (m) to verify that they are in

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conformance with reference (a).

Based on this review one violation was identified. The inspector identified that the Station Directives are not being reviewed as required by the QA Program commitment to ANSI N18.7-1976, Section 5.2.15.

The following represents a list of Station Directives not being reviewed.

This list is not intended to be all inclusive.

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5 Station Directive Title Date 2.1.3 Control of Microfilm Program approved 8/78 2.1.4 Correspondence Distribution Revision 5, 5/79 and Control 2.4.0 Control of Materials, Parts Revision 3, 6/78 and Components

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3.8.0 Health Physics Program dated 3/79 3.10.0 Control of Chemistry Revision 3, 3/79 Program 3.1.3 Action to Be Taken in Case approved 5/77 of Exceeding of Limits 3.1.10 Investigation of Unit Trips dated 10/77 The failure to review procedures as required by the licensee's commitments constitutes a violation applicable to Unit 1 only (369/81-17-01) and an open item applicable to Unit 2 (370/81-05-09).

6.

QA/QC Administration Program (35751, 35740 and 35301)

References:

(a) QA 100, Preparation and Issue of Quality Assurance Procedures, Revision 4 dated 3/78 (b) QA 100, Performance of Corporate Quality Assurance Audits, Revision 0 dated 11/78 (c) QA 210, Departmental Audit Procedure, Revision 11 dated 8/80 (d) QA 230, Departmental. Audit Scheduling and Followup, Revision 8 dated 3/81 (e) DPC McGuire Nuclear' Station Nuclear Safety Related Structures, Systems and Components Manual, Revision 3 dated 7/19 (f) QA 509, Preparation and Issue of Quality Control Proce-'

dures, Revision 6 dated 4/79 The inspector reviewed the licensee's program documents, references (a)-(f),

to verify that they define the structures, systems, components and activi-ties to which the program applies and that procedures exist for making changes to these documents.

The inspector also reviewed the program to assure _that administrative controls for QA Department procedures, inspection and audit activities, and manuals exist to provide the following:

review and approval prior to issuance, methods and proccdures for changes and revisions; and, methods and controls for distribution and recall.

Based on this review, no violations or deviations were identified.

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7.

Personnel Qualification Program (36701, 36301)

References:

(a) Technical Specification, Section 6.3 (b) ANSI N18.1 1971, Selection and Training of Nuclear Power Plant Personnel (c) APM 2.5, Qualifications and Training of Personnel, Revision 17 dated April 1979 (d) SD 2.5, Qualifications and Training of Personnel, Revision 2 dated March 1978 (e) SD 3.1.5, Activities Affecting Station Operations or Operating Indications, Revision 2 dated September 1977 (f) Regulatory Guide 1.8, September 1975, Personnel Selection and Training The inspector reviewed whether the licensee has a QA program rela, ting to personnel qualification that is in conformance with regulatory requirements and licensee commitments.

The inspector verified that qualifications have been established for personnel in the onsite organization.

The inspector reviewed the qualifications of the plant manager, operations superintendent, technical services superintendent, maintenance superintendent, two operating engineers, three shift supervisors, three reactor operators, two health physics technicians, and three maintenance personnel.

Based on this review, no violations or deviations were identified.

8.

Design Changes and Modifications Program (37702, 35744)

References:

(a) QA 506, Quality Assurance Review of Modifications, Revision 4 dated 4/79 (b) QA 501, Placing, Reviewing and Verifying Quality Assur-ance Pequirements on Station Procedures, Revision 3 dated 3/78 (c) DPCSPD APM 3.4, Modifications, Revision 16 dated 7/78 (d) DPCSPD APM 4.4, Administrative Instructions for Modifi-cations, Revision 16 dated 7/78 (e) DPCSPD APM 4.6, Administrative Instructions for Problem Reports, Revision 17 dated 4/79 (f) DPCCQAP, Chapter 3. Design Control, Revision 0 dated 3/77

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(g) SD 4.4.1, Processing Nuclear Station Modifications, Revision 2 dated 3/81 (h) DPCDEDQAP, Revision 50 dated 4/81 (1) SD 4.4.0, Processing Design Changes, Revision 10 dated 12/80 The inspector reviewed the references listed to assure they meet the

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requirements of the accepted QA Program and ANSI N45.2.11-1974 as endorsed by that Program. The inspector verified the following aspects of the NSM program:

Procedures have been established for control of design and modification

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change requests

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Procedures and responsbilities for design control have been established

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Administrative controls for design document control have been established

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Administrative controls assure that design changes are incorporated into plant procedures, operator training and the updating of drawings

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Controls have been developed that defina channels of communication between design and responsible organizations Administrative controls require design documentation and records be

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collected and stored

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Controls require implementation of approved design changes be in accordance with approved procedures

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Controls require post-modification testing be performed per approved test procedures and the results evaluated

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Responsibility has been assigned for identifying post-modification testing requirements Responsibility and method for reporting design changes to the NRC in

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accordance with 10 CFR 50.59 has been identified.

Similar methods and controls were also verified for use of temporary modifi-cations (jumpers and disconnected leads).

Based on this review two items contributing to a violation and three inspector followup items were identified and are discussed in the following paragraphs.

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a.

Failure to Control Temporary Modification Installation During the performance of TP/1/A/2600/08, RTD Bypass Flow Verification, Revision 0 dated 10/80, a jumper was installed on INC PG 5310, RTD Bypass Flow Loop A, under the direction of the engineer performing the test. WR 83294 was issued March 26, 1981, by the engineer to provide instrumentation technicians to assist in performance of this test.

This work request was signed off as being completed oy the job super-visor on April 24, 5 81. A jumper was observed to be in place by the inspector on the mornings of June 3 and June 4, 1981.

Neither the procedure being used to perform the test nor the work request issued for support of this test references the installation of a jumper.

Reference (i) states in part that a temporary station modification includes installed jumpers.

All temporary modifications installed shall be documented on the work request. Although a temporary jumper may be specified in a procedure, it will be considered a temporary modifications and shall be documented on a work request.

In addition, for temporary modifications remaining in place past a shift change, the temporary modification will be identified with a tag.

The installation of this jumper on ICN PG 5310 without the controls required by reference (i) is combined with the item discussed in paragraph 8.b to collectively constitute a violation and is applicable to Unit 1 only (369/81-17-02).

b.

Failure to Document Temporary Modification Removal Reference (i) requires that for removals of temporary modifications, the individual documenting removals on the work request shall be personally responsible for documenting removal in the log.

The inspector reviewed the log for temporary modifications and randomly selected 11 outstanding temporary modifications for inspection. Of these, six had been cleared without the log being updated to indicate their removal. Of these six, three were applicable to safety-related systems (tag 0544, WR82799; tag 0737, WR 19337 and tag 0938, WR 101254). This failure to update the log for temporary modifications to indicate an accurate status combined with the item discussed in para-graph 8.a to collectively constitute a violation applicable to Unit 1 only (369/81-17-02).

c.

Temporary Modification Control After Unit Licensing Reference (i) details the requirements to be used for control of temporary modifications such as installed jumpers, lifted leads and installed blank flanges.

The objective paragraph of this directive states in part that the directive applies to physical modifications for j

nuclear stations prior to licensing.

A temporary modification log is

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currently being maintained by operations personnel to track temporary

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9 modifications; however, due to the ' limits imposed by the objective paragraph of this directive there is no procedure that addresses-control of temporary modifications for the unit'after licensing.

The ir'cector determined that current controls are adequate but the licen-see nuds to ensure that the controls for temporary modifications are extended to nuclear stations after licensing. Until this oversite is.

corrected, this ' item is identified as an inspector followup-item and. is applicable to Unit 1 only. (369/81-17-12).

d.

Conflict in Use of Should and Shall'(Variation Notices)

Reference (g) paragraph 9.b outlines the requirements for processing revisions to NSMs in progress by Design Engineering.

It further states that such revisions "shall" (denoting a requirement) be processed as a Variation Notice and documented as such. Guidelines are provided for -

using Variation Notices however the procedure states that these guide-lines "should" (denoting a recommendation) be followed.

In addition, reference (g) details the responsibilities of various personnel for processing NSMs.

The :tation coordinator is required to perform actions accordingly.

Several of his duties are that he '"should" perform some functions.

Discussions with plant personnel determined that the station coordinator is required to perform these functions.

Until the inconsistancy is clarified between the' required use of:

Variation Notices and the apparent relaxation of the guidelines, and the duties of the station coordinatcr are clarified this item is identified as an inspector followup item (369/81-17-13, 370/81-05-13).

9.

Tests and Experiments Program (37703, 35749)

References:

(a) APM 3.2.3, Special Testing, Revision 4 dated'12/74 (b) APM 4.2, Administrative Instruction for Permanent Station Procedures, Revision 18 dated 9/79 (c) APM 4.3, Administrative Instruction for Temporary Station Procedures, Revision 17 dated 4/79 (d) APM 4.4, Administrative Instruction for Modifications, Revision 16 dated 7/78 The inspector verified the following aspects of the test and experiments program:

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A formal method has been established to handle all requests or proposals for conducting special tests involving safety-related com-ponents

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Special tests will be performed in accordance with approved procedures

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' Responsibilities have been assigned for reviewing and approving special

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. test procedures

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A system, including assignment of responsibility has been established to ' assure that special tests will be reviewed Responsibilitie's have been assigned to assure a. written sa'fety evalua-

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tion required by 10 CFR 50.59 will be developed for any special test to

' assure that it does not involve an unreviewed safety evaluation.or change in Technical Specifications

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Based on this review, no violations or deviations were identified.

10.

Procurement (38701, 35746)

References:

(a) APM 2.4, Control of Materials, Parts and

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Components, Revision 18 dated 9/79 (b) MHP 1.2, Requisition for Materials,. Revision 6 dated

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tures, Systems and Components,. Revision 3 dated 7/79

(d) QA 410, Processing of QA Records for Purchased Items, Revision 5 dated 5/79 (e) QA 411, Filing of QA Records for Purchased Items, Revision 5 dated 10/80 (f)- QA 505, Processing of Procurement Documents for Opera-tional Nuclear Stations, Revision 12 dated 12/80 (g) QA 601, Vendor Evaluation, Revision 3 dated 12/80-(h) QA 602, Vendor Surveillance Procedure, Revision 5 dated.

10/78 (1). QA Approved Vendors List, dated 6/81 The taspector reviewed the licensee's procurement' program ' ith respect to

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w selected elements of the approved QA Program. The inspection was to verify that administrative controls had been established for the preparation, review, approval and revision of procurament documents and for qualification and audit of suppliers.

Implementation of the procurement program was verified by reviewing procurement documents of several safety-related items and verifying that they were prepared in-accordance with administrative

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Based on this review, no violations or deviations were identified.

11.

Receipt, Storage and Handling.(38702, 38700, 35747)

References:

(a) APM 2.4, Control of Materials Parts and Components, Revision 18 dated 9/79

.(b) MHP 3.1, Storage Methods and Areas, Revision 4 dated 10/79 (c) MHP 2.1, Receipt, Inspection and Control of Stores

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Stock, Capitol Stock and Non-Stock Items, Revision 4 t

dated 10/79

'i (d) SD 2.4.1, Control of Surface Applied Material Usage,-

Revision 1 dated 8/79 (e) QCG 1, Receipt, Inspection and Control of QA Condition Materials, Parts and' Components Except Nuclear Fuels',

Revision 15 dated 6/80 (f) QCK l', Control of Nonconforming Items,- Revision 12 date'd

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11/80 The inspector rcolewed the licensee's program for the receipt, storage and handling of equipment and material with respect to selected elements of the licer.see's accepted QA Program. The inspection was to verify that admin-istrative controls had been established for the following areas:. receipt

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irspection of safety-related materials; preparation and retention of

. required documentation; control of acceptable, nonconforming and condi-tional release items; control -of items in storage including levels of storage, identification of items, inspections, and maintenance; and control of handling activities.

Implementation of. the ' licensee's program was verified by observing the licensee's control of several safety-related

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Based on this review, one violation was identified.

Reference (d) imposes

restrictions on material used at the site which requires the use of a

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specific type of tape on'austenitic stainless steel to meet the surphur and halogen requirements of ANSI N45.2.2.

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Contrary to the above, three types of tape (standard masking tape, duct tape

and Scotch Filament Tape 898-2) not authorized by reference (d) were being

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used to cap approximately 20*s of the quality stainless steel pipe located in

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warehouse 5.

This failure to follow procedures constitutes a violation J'

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P-(369/81-17-04) applicable to Unit 1 and an open item (370/81-05-10)

applicable to Unit 2.

One of the three types of tape was subsequently

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determined to meet ANSI N45.2.2 requirements. The inspector also noted that-a work order' had been submitted prior to the completion-of.the inspection to cut off the affected pipe ends.

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Records' (39701, 35748, 39301)

References:

(a) APM 2.2,' Records Management, Revision 18 dated 9/79 (b) SD 2.1.1,. Control of Master File Documents, Revision 9 dated 4/81 (c) QA 101, Quality Assurance Records Storage Vault (General Office), Revision 2 dated 10/80 (d) QA 111, Interdivisional Transfer of-QA ' Records, Revision 1 dated 1/77 (e) QA 504, Quality Assurance Records, Operations, Revision 8 dated 3/80 (f) Records Management Policy and Procedures Manual, dated 5/81 (g) PR 931, Design Quality-_ Assurance Records, Collection, Maintenance, and Storage, Revision 5 dated 2/81 The inspector reviewed various administrative and quality procedures to '

verify that provisions had been made to maintain various types of. quality records, in both permanent and temporary storage, and that responsibilities had been assigned to carry out the records storage requirements.

Records storage procedures were also reviewed to ensure that they described the storage facilities, the filing systems used, and the methods of receipt, handling and disposal of the records.

In order to. verify implementation of these procedures, the inspector selected several plant work orders, purchase orders, operating procedures, surveillances and radiographs to verify indexing, retrievability and storage. Based on this review, three inspector followup items were identified and are discussed in the following para-graphs.

a.

Fire Loading Review of Satellite Record Storage Locations The inspector reviewed the location of the satellite record storage locations and the fire loading calculations performed as addressed in reference (a). Although, at present no areas appear to have a greater fire load than allowed with the fire protection equiprent utilized, no

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plan exists to insure that these satellite locations are reviewed for excessive fire load changes. The site is instituting a fire protection review process to evaluate each location for continued fire protection approval. This area will be reviewed during a subsequent inspection'and is identified as an inspector followup item (369/81-17-20, 370/81-05-20).

b.

Strip Chart Receipt Strip charts that are sent to master; files for record storage have only the ending date annotated on the chart box. The chart is assumed to f

begin at the ending date of the previously received chart.

The inspector noted two recorder charts which covered different time periods than was annotated in the Strip Chart Signout Log. The charts are as follows:

l Chart Actual Date Log Date I

1016 4/11/81 - 5/10/81 3/31/81 - 5/10/81 l

1026 3/30/81 - 4/27/81 3/3/81 - 4/27/81

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The missing strip charts were located; they had been. rejected by Master.

Files due to inadequate data identification.

The actual / log date.

discrepancy was caused by out of sequence receipt.of these strip charts. The system for receipt of strip charts will be reviewed during-a subsequent inspection and is identified as an inspector followup item (369/81-17-19).

c.

Conflict of Use of Should and Shall (Records Storage)

Reference (b), page 5, has several instances where the word "should" (denoting a recommendation) is used instead of the word "shall" (denoting a requirement). These discrepancies pertain to the require-ment to store quality records in approved fire protection cabinets.

The resolution of this discrepancy will be reinspected during a subse-quent inspection and is identified as an inspector followup item (369/81-17-14,370/81-05-14).

13. Document Control (39702, 35742)

References:

(a) APM 2.1, Document Control, Revision 16 dated 7/78 (b) SD 2.1.2, Drawing Aperture Card Distribution and Control, Revision 8 dated 4/81 (c) SD 4.2.1, Handling of Station Procedures, Revision 16 dated 3/81

-.

.

_ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _ _

.

m

The inspector reviewed the referenced procedures to verify that proper controls 'have been established for drawings, vendor _ technical manuals, technical specifications, and procedures affecting quality. In particular the inspector' selected several documents to verify the proper handling per

.the applicable procedures, to verify the accuracy of the master 'index for the various documents and to verify the' proper updating of. controlled drawings and other documents.

The selected' documents reviewed were the following:

Site Manual's Drawings

{

' Station Directive Manual MC-1711-14.01-Technical Specifications MC-1761-03.02 MC-1831-13.02 MC-1414-03.20 Vendor Manuals No. 1201.05-251 No. 1399.05-174 No. 2201.01-6 Based on this review,_ no violations or deviations were identified.

14. Audit Program and Implementation of the Audit Program (40702, 40704, 35741)

References:

(a) QA 130, Qualification and Training of Lead Auditors, Revision 6 dated 4/81 (b) QA 131, Quality Assurance Training, Revision 2 dated 10/80 (c) QA 150, Trend Analysis, Revision 2 dated 5/78 (d) QA 160, Performance of Corporate Quality Assurance Audits, Revision 0 dated 11/78 (e) QA 210, Departmental Audit Procedure, Revision 11 dated-8/80 (f) QA 230, Departmental Audit Scheduling and Followup, Revision 8 dated 3/81 i

(g) DPCCQAP, Chapter 18, Audits, Revision 1 dated 9/79 (h) DPCCQAP, Chapter-16, Corrective Action, Revision 0 dated 3/77 (i) APM 2.6, Review and Audit, Revision 9 dated 3/76

.

q

(j) Memo from J.

R'. Wells to L' C. Dail',

R.' L. Dick and.

.

W.- '0. Parker, Subject: QA Audit Responses, dated 3/81 The references were reviewed to verify that they met the requirements of the accepted QA. Program and ANSI N45.2.12 :(Draft ~3, Revision 4 -1974) as-committed to by that Program. The inspector verified the following aspects of the audit and audit implementation program:

-

The scope of the audit program has been defined and is consistent with the Technical Specifications

--

Responsibilities have been assigned in writing for the overall manage--

ment of the audit program

-

Methods have been defined for taking corrective action when deficien-cies are identified during ~ audits

-

The audited organization is required to respond in writing to audit findings

-

Distribution requirements for audit reports and corrective action responses have been defined

-

Checklists are required to be used in the performance of audits

-

Audits are conducted by trained personnel not having direct responsi-bility in the area being audited

-

The frequency of audits is in conformance with-Technical Specification requirements.

To verify the implementation of these aspects, the inspector reviewed the results of the following nine audits.

Audit 0-80-3 1979 JUMA 0-80-5 1980 JUMA 0-80-10 0-80-12 0-80-16 0-81-1 0-81-2 The ' inspector reviewed the training cecords of seven personnel in the QA audit division. The inspector reviewec the qualifications of four personnel designated as lead auditors.

Based on this review, no violations or deviations were identified

y

15. Offsite Support Staff (40703)

References:

(a) Technical Specifications (b) Quality Assurance Department, QA Program Manual (c) Design Engineering Department, QA Program Manual The inspector' reviewed the referenced documents to verify that the licensee has 1dentified positions and responsibilities in the ' company offices to perform the offsite function of Quality Assurance, Design, Engineering and Procurement ~.

The inspector interviewed individuals in each functional. area at the managerial. level and two levels below. During the interview, the inspector verified that each individual was qualified for his position and was aware of his responsibilities and authority in relation to the company organization and the Quality Assurance Program.

Based on this review, no violations or deviations were identified.

16. Training (41700, 41301)

References:

(a) ANSI N18.1-1971, Selec_ tion and Training of Nuclear Power Plant Personnel (b) FSAR, Section 13.2, Conduct of Operations (c) APM 2.5, Qualifications and Training of Personnel, Revision 17 dated 4/79 (d) SD 2.5, Qualifications and Training of Personnel, Revision 2 dated 3/78 (e) SD 3.1.5, Activities Affecting Station Operations. or Operating Indicating, Revision 2 dated 9/77 (f) Regulatory Guide 8.13, Instruction Concerning Prenatal Radiation Exposure (g) Technical Specification 6.4 Training The inspector reviewed the training and retraining program for all non-licensed personnel and general employee training for all employees to verify that:

the program complies with regulatory requirements and licensee commitments; the program covers training in the areas of administrative controls and procedures, radiological health.and safety, industrial safety, security procedures, the emergency plan, quality assurance, formal technical training commensurate with job classification, firefighting and prenatal radiation exposure; and, audits conducted by the licensee in the areas of

,.

_ _

.

general employee training and documentation of training records were adequate. The inspector. reviewed approximately 200 training records of unit operating personnel and -contract personnel, and interviewed 20 people to verify by direct questioning that the licensee was meeting their commit-ments.

Based on this review, one violation, one open item and one inspector followup item were identified and are discussed in the following paragraphs.

a.

Failure to Properly Store Training Racords APM 2.2.3.5, Revision 18 dated 9/79, states in part records shall be.

stored such that they are protected from possible destruction and that the storage-facilities shall meet NFPA 232-1975 criterion, using as a minimum, one hour fire cabinets for storage of records. Records for certifying individuals applying for R0 or SRO licenses are being stored in a cabinet which does not meet the requirements of NFPA 232-1975.

This use of improper storage cabinets for training records constitutes a violation (369/81-17-05) applicable to Unit 1 and an open item (370/81-05-11) applicable to Unit 2.

b.

Retraining Time Frames Not Specified.

Reference (d) requires retraining of station -personnel in GET on a periodic basis. The only areas of GET:where " periodic" is defined-is in the emergency plan, security procedures and radiation protection.

Until such time that the licensee defines." periodic" for the remaining areas of training this item will be carried as an open item (369/81-17-08; 370/81-05-08). The licensee gave a target date of September 1, 1981 for defining periodic in other areas of GET.

c.

Misinterpretation of Grace Peried GET is required to be administered, in certain areas, on an annual basis with a three-month grace period for unusual circumstances. The McGuire training supervisor was interpretating this requirement to mean that an individual could receive GET every fifteen months and meet the requirement.

This interpretation is not correct.

The licensee has only been operating under the annual requirement for 1 years and the inspector did not identify.any violations. This item is identified as an inspector followup item (369/81-17-21; 370/81-05-21) and will be reviewed during a subsequent inspection to insure correct interpreta-tion.

17.

Requalification Training (41701)

References:

(a) Technical Specification 6.4, Training (b) FSAR Section 13.2, Code of Operations

.

18 (c) SD 2.5, Qualifications - an'd. Training 'of Personnel, Revision 2, dated 3/78 (d) SD 3.1.4, Conduct of Operations, dated 11/79 (e) SD' 3.1.5, Activities Affecting Station Operations and

-

Operating Indications, Revision 2, dated 9/77 (f) APM 2.5, Qualif.ications and Training of Personnel, Revision 17, dated 4/79 (g) ANSI N18.1-1971, Selection and Training of Nuclear Power Plant Personnel (h) Regulatory Guide 1.8, Personnel Selection and -Training (1)

10 CFR 55 Appendix A, Requalification Program for Licensed Operators of Production and Utilization Facilities The inspector reviewed the implementation and documentation of the accepted requalification program.

The specific areas' of review are as follows:

schedules for conducting required lectures; lesson. plans for six selected lecture areas; the evaluation by the licensee of the results of the most recent examinations and training to identify and correct any deficient

, areas; and, records of four shift supervisors and reactor operators.

The inspector attended four classroom training sessions and two. simulator sessions to verify technical content and method of instruction were ade-quate. The inspector interviewed two persons holding SRO licenses and three persons holding R0 licenses to insure that they have been receiving required-training and were being kept informed of industry topics related to'their plant. The inspector questioned licensed personnel onsite relative to the problem of the " bubbles" that were formed in the reactor coolant system to determine if training receivea was adequate to react to the abnormal condi-tion.

Based on this review, one followup item was identified. During the inspec-tion of the simulator classes it was observed that the pressurizer and reactor vessel models do not accurately reflect heat transfer, fluid flow and thermodynamic considerations.

Specifically, the models do not show thermal stratification that occurs due to a time lag between a lower temper-ature water coming in contact with a higher temperature mass of metal reaching an equilibrium temperature, such as occurred at North Anna during their steam dump malfunction and at St. Lucie during their cooldown on natural circulation.

The licensee is instructing the students about these effects, but until such time that the simulator accurately depicts these situations this ~ item will be carried as an inspector followup item (369/81-17-15,370/81-05-15).

t

18. Housekeeping / Cleanliness Program (54701)

References:

(a) Regulatory Guide 1.39, Housekeeping Requirements for Water-Cooled Nuclear Power Plants, Revision 1 dated 10/76 (b) APM 3.11, Housekeeping, Revision 18 dated 9/79 (c) SD 3.11.0, Housekeeping and Cleanliness, Revision 7 dated 4/81 The inspector reviewed references (b) and (c) to determine if the licensee had established housekeeping and cleanlinest :ontrels commensurate with the commitments in the accepted QA Program.

Based on this review, one violation was identified.

10 CFR 50, Appendix B Criterion V requires activities affecting quality shall be prescribed by documented procedures and these activities shall be accomplished in accord-ance w1th these procedures. The accepted QA Program, Table 17.0-1 states that DPC conforms to Regulatory Guide 1.39 (Rev. 1) which endorses ANSI N45.2.3-1973.

Reference (c) implements the cleanliness and housekeeping program for McGuire. Reference (c) states in part that for zone designa-tions of Level III and IV:

smoking or use of tobacco products is not permitted; level cleanliness signs shall be posted; garbage, trash, scrap, litter and other excess materials shall be collected, removed from the job site or disposed of in designated areas following accepted practices; and a log shall be maintained at the entrance (Level III zones) to log personnel and materials in and out of the area. Contrary to the above requirements, activities effecting quality were not accomplished in accordance with the approved procedures in that the following items were identified during the inspectors tour of various areas in the plant:

-

Various cabinets in the control room had cigarette butts, trash in bottom of panel, screws and excessive dust (Cabinets #7, 5, 2 and common HVAC panels)

-

Cable Room 801 - trash in cable trays, wire brushes, cigarette butts, paper and loose cable in cable trays and on tour of room

-

Fuel pool Area - trash on floor, cigarette butts, loose material being stowed in area, log not being properly maintained

-

Fire hoses improperly stored (IRF 168,1RF 167,1RF 176,1RF 163)

-

Safety Injecion Pump 1A area (posted as a zone III for work being performed) not cleaned to zone III requirements and log not being properly maintained

_-

-

Numerous areas have welding cables and other temporary lines hanging on and around valves and instruments

-

Although areas in most cases are posted, posting requirements of Reference (c) are not being followed.

This list is not ir. tended to be all inclusive. This is a violation (369/

81-17-03) applicable to Unit 1 only.

19.

Test and Measurement Equipment (61724, 35750)

References:

(a) SD 2.3.0, Control of Measuring and Test Equipment, Revision 7 dated 1/80 (b) Accepted 0A Program, Section 17.2.12, Control of Measurine and Test Equipment (c) AFM ?.2. Testing, Revision 14 dated 9/77 (d) IP/0/B/3090/01, Station Test Equipment Calibration, dated 7/78 The inspector reviewed the listed references to insure they met the require-ments of the accepted QA Program and ANSI N45.2.4-1974 as committed to by that Program. The inspector verified the following aspects of the test and measuring equipment program:

-

Criteria and responsibility for assignment of the calibration / adjust-ment frequency have been established

-

An equipment inventory list has been prepared which identifies equip-ment used on safety-~ elated structures, systems or components and calibration frequency of each piece of equipment

-

Requirements exist to carking the latest calibration date on each piece of equipment

-

A system has been provided for assuring that equipment is calibrated before the date required

-

Requirements have been established which prohibit use of equipment which has not been calibrated within the prescribed frequency

-

Calibration controls have been established which require evaluation of the cause of an out of calibration and the acceptability of items calibrated

-

New equipment will be added to the inventory list and calibrated prior to being placed in service.

.

l

Based on this review, one open item was identified. Reference (a) states personnel using test and measuring devices shall ensure that calibration for test equipment has not expired.

Reference (a), Section G allows use of equipment for one week past the calibration due date. Section H.1 states that calibration frequencies shall be in accordance with or more conserva-tive than the manufacturers recommendations.

This apparent conflict in reference (a) is identified as an' open item (369/81-17-07, 370/81-05-07)

pending procedure changes to clarify use of equipment after calibration due date has past.

20.

Surveillance Testing and Calibration Control Program (61725, 35745)

References:

(a) Technical Specifications (b) APM 3.2, Testing, Revision 14 dated 9/77 (c) SD 3.2.1, Identifying, Scheduling and Performance of Plant Testing, Revision 6 dated 1/81 (d) DPCCQAP, Chapter 11, Test Control, Revision 0 dated 3/77 (e) IP/0/B/3090/01, Staticn Test Equipment Calibration dated 7/78 (f) CP 3.10, Control of Laboratory Instrumentation, Revision 4 dated 10/80 (g) CP 3.11, Chemical Data Quality Control Systems, Revision 2 dated 4/81 (h) HP 1005 Series, Calibration Procedures for Various Types of HP Instrumentation (1) PT/0/B/4600/27, Calibration Status of Counting Room Equipment, Revision 1 dated 5/81 (j) PT/0/B/4600/28, Calibration Status of Health Physics Portable Instruments, Revision 0 dated 3/81 The inspector reviewed references (b) through (j) to assure they met the requirements of the Technical Specifications, the accepted QA Program and ANSI N18.7-1976 as endorsed by that Program. The inspector reviewed the following aspects of the surveillance testing and calibration control program:

-

A master schedule has been established for the calibration / surveillance of safety and non-safety related equipment that includes the frequency for each calibration / surveillance as well as the group responsible for performance of this action

_

--

. _ _. _. -

~,

,

Responsibilities have been assigned for updating this master schedule:

-

.

-

Responsibilities have been established for conducting. calibration /.-

surveillance testing in accordance with approved procedures which -

include acceptance-criteria and required. verification that. limiting condition for operation requirements were satisfied.

The inspector reviewed 20 periodic test including references (1) and-(j) to assure.the above requirements are being. adhered to. The specific periodic-tests' reviewed are listed below:

PT/0/B/4700/05 Periodic Verification of Operability and, Calibration (for T/S Compliance of Radwaste Systems)

PT/1/A/4209/01A Centrifugal Charging Pump 1A Performance Test PT/1/A/4209/01B Centrifugal Charging Pump 1B Performance Test PT/1/A/4206/01B Safety Injection Pump IB Performance Test PT/1/A/4204/01B RHR Pump 18 Performance Test PT/1/A/4600/01 RCCA Movement Test PT/1/A/4208/01B Containment Spray Pump Performance Test PT/1/A/4401/01B Component Cooling Train 1B Performance Test PT/1/A/4409/10A Boric Acid Transfer Pump 1A PT/1/A/4458/04 YC Valve Movement Test PT/0/A/4100/01 Review of Operating Procedures PT/0/A/4700/02 Review of Emergency Procedures PT/0/A/4700/03 Review of Approved Periodic Test Procedures PT/1/A/4600/03A Semi-Daily Surveillance Items PT/1/A/4610/03B Daily Surveillance Items PT/1/A/4600/03D Monthly Surveillance Items PT/0/A/4700/11 Procedure for Verification of Chemistry Controlled Procedures (12 months)

PT/0/B/4600/54 Periodic Review of Health Physics Procedures

..

The inspector randomly selected non-safety related instrumentation used during the performance of these tests to assure that calibration / surveil-lance requirements were satisfactory.

Based on this review, no violations or deviations were identified.

21.

Procedures (42700)

References:

(a) Technical Specification 6.8 (b) APM 4.2, Revision dated 9/79 (c) Regulatory Guide 1.33, Quality Assurance Program Requirements (Operation), Revision 1 dated 2/77 (d) SD 3.1.28, Operations Handling of Procedures, Revision 5 dated 2/81 (e)

Final Safety Analysis Report (f) ANSI N18.7-1976, Administrative Controls for Nuclear Power Plants The inspector conducted a review of selected plant procedures in accordance with the guidance and requirements provided in references (a) through (f)

above to ascertain whether overall procedures are in accordance with regula-tory requirements. The following criteria were used during this review:

-

Required review and approval of procedures and temporary changes had been performed

-

Overall procedure content is consistent with references (a) and (e)

-

Records of changes in procedures are being maintained

-

Safety reviews pursuant to 10 CFR 50.59 were performed

-

The training department was appraised of changes to procedures

-

Administrative procedures were observed in the preparation and handling of procedures.

Comments of an editorial nature were provided to appropriate plant personnel. A listing of those procedures reviewed is provided below:

SD 3.1.19, Safety Tags, Lock-outs, and Delineation Tags, Revision 10 dated 2/81

-

..

.-

,

SD 2.3.0, Control of Measuring and Test - Equipment, Revision 7 dated 1/80 OP/1/A/6100/02 Controlling Procedures for Unit Shutdown, dated 1/81 OP/1/A/6250/06 Main Steam, dated 3/81 OP/1/A/6200/06 Safety Injection System, dated 3/81 OP/0/A/6100/09 Removal and Restoration of Station Equipment OP/1/A/6200/07 Containment Spray System dated 3/81 OP/1/A/6200/10 Upper Head Injection dated 3/81 OP/1/A/6100/05 Reactor Trip Recovery, dated 1/81 OP/1/A/6150/01 Filling and Venting of RCS, dated 5/81 OP/1/A/6200/04 RHR System, dated 3/81

"0P/1/A/6100/01 Controlling Procedure for Unit Startup, dated 3/81

• AP/1/A/5500/16 Malfunction of Nuclear Instrumentation System, dated 5/81

• AP/1/A/5500/08 Malfunction of Reactor Coolant Pump, dated 12/80

• AP/1/A/5500/04 Malfunction of Reactor Coolant Flow, dated 12/80

• EP/1/A/5000/04 Steam Generator Tube Rupture, dated 5/81

• EP/1/A/5000/02 Loss of Reactor Coolant, dated 4/81 PT/1/A/4150/01A Reactor Coolant System Leak Test, dated 3/81 PT/1/A/4150/01B Reactor Coolant Leakage Calculation, dated 7/80 PT/1/A/4208/01A Containment Spray Pump 1A Perfnrmance Test, dated 1/81 PT/1/A/4204/01A RHR Pump 1A Performance Test, dated 2/80 PT/1/A/4204/01B RHR Pump 1B Performance Test, dated 2/80 PT/1/A/4200/16 UHI Accumulator Valve Auto Isolation Verification, dated 2/80

__

_

MP/0/A/7150/11 Containment Spray Pump and RHR Pump Corrective Maintenance, dated 9/76 MP/0/A/7150/40 RC Full Flow Filter Removal, dated 8/78 MP/0/A/7150/35 RC Full Flow Installation, dated 6/78 MP/0/A/7150/30, UHI Valve Actuator Corrective Maintenance, dated 6/81

• Performed on simulator as part of the review.

Based on this review, no violations or deviations were identified.

22. Offsite Review Committee (40701)

References:

(a) Technical Specifications (b) APM 2.6, Review and Audit, dated 9/79 (c) Charter of the Nuclear Safety Review Board, Revision 1 dated 11/80 The inspector reviewed the operation of the NSRB to verify that it met the requirements of the Technical Specifications. The following aspects of the NSRB conduct of operations were reviewed to verify the following:

-

Membership and qualifications are as required by the Technical Speci-fications

-

Meetings covened are at the frequency required by the Technical Speci-fications

-

Meetings contained personnel having the necessary expertise for the agenda items being reviewed

-

Meetings contained agenda items required by the Technical Specifica-tions The inspector reviewed the qualifications of nine members of tne NSRB and verified their appointments to the NSRB as required by reference (a). The inspector reviewed NSRB minutes from October 2,1978 until May 18, 1981.

The licensee vas authorized for limited operation in January 1981, conse-quently only meeting minutes sinct ~ hat date were reviewed to the require-ments of reference (a).

Based on this review, three inspector followup items were identified and are discussed in the following paragraphs.

,

_

a.

NSRB Charter and Technical Specification Inconsistancies The charter of the NSRB does not reflect. the requirements of the Technical Specifications in the following ways:

(1) Meeting frequency: the charter allows the NSRB to meet once per six months.

Techni_ cal Specification 6.5.2.6 requires ~ meetings quarterly dur_ing the first year of operation following fuel loading and at least every six months thereafter (2) Quorum Requirements:

the charter allows a quorum to consist of the director or alternate and at least two other NSRB members or alternate members.

Technical Specification 6.5.2.7 requires at least the director, or alternate and four members including alternates.

These are two example and are not all inclusive of where the charter for the NSRB is less restrictive than the Technical Specification requirements.

Until the charter is reviewed.and updated this item is an inspector followup item (369/81-17-17, 370/81-05-17).

b.

Clarification of NSRB Review Function The NSRB director routes to individual members of the NSRB material for their review such as incident investigation reports, QA audits and responses, QA surveillance reports, significant deficiency reports,.

test procedure, OIE inspection reports and 55RG reports.

The individual members comment on these if required and return signed off data forms to the director indicating comments and proof of review.

However individual review of these items does not constitute the

" group" review required by the Technical Specifications. Until the NSRB indicates by incorporation into the' board minutes the results of these reviews, this is an inspector followup item '(369/81-17-18, 370/81-05-18).

c.

APM and Technical Specification Inconsistancies APM 2.6, Section 2.6.2.2.2(f) states that the quorum requirements of the NSRB shall consist of not less than a majority of the members or alternate members and shall include the director or his designated alternate.

Technical Specification 6.5.2.7 requires a quorum to consist of the Director or his alternate and four other NSRB members / alternates.

Presently there are nine members / alternates on the NSRB at McGuire so the APM requirement is accurate.

However to ensure that the Technical Specification requirements are adhered to until the APM is, revised, this is identified as an inspector followup item (369/81-17-16, 370/81-05-16). This example is not intended to be all inclusive.

-

"

,

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27

-

-

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'

23.

Independent Inspection (92.706)

.

.

The inspector reviewed the licensee's response to MUREG 0737 and the imple-mentation of the commitments in the arear of shif t technical advisor training, shift manning requirements, upgracing of recualification program, mitigation of core damage course ~s for required plant personnel, shift and - ~

relief turnover procedures, shift supervisor responsibilities and,how.ths

-

license is meeting the revised scope and criteria for licensing exams. ;Th_e inspector also did an indepth review of the " cold license" training prcgram for licensing operators.

'

g Based on this review, one unresolved item was identified. Technical Specifi-

'

cation 6.3.1 commits the licensee to ANSI NB.1-1971 for training and qualification requirements.

ANSI N18.1-1971, Section 5.2.1 states that applicants for cold examinations shall have extensive operating experience

~_

at a similar reactor facility and that acquisition of this experience may be demonstrated by certification of satisfactory completion of an AEC -(NRC)

approved training program which utilizes a complete and accurate nuclaar power plant simulator as part of this program.

In addition, 10'CFR 55.-10

^

relates the information necessary in a license application. Subpart'(N(6)

'

requires evidence that the applicant has learned to operate the controls in a safe and competent manner. The NRC accepts a statement from an authurized

^

representative of 1.he facility as to the applicants certification.

Sub-part (d) requires the application and statement by applicant to contain complete and accurate disclosure as to all matters and things required to be'

i di v:l o sed. In addition,10 CFR 55.11 relates information for approval of x

the applications.

Sub-art (b) requires that the applicant has passed a N

written and operating t st ind in the case of a SRO that the applicant is,

able to operate and direct the licensed activities of licensed operatori,.

Contrary to the above, an Nividual in the McGuire operating staff, who only received a cold license certification on the R0 level with tha

'

following statement: Se " lacks the necessary depth of technical knowledge to effectively provide direction during operating situations", was ce'rtified

-

by DPC management as capable of performing at his assigned level yhich requires a SRO license and in the statement sent as part of the license application it was only addressed that the individual was certified, but

'

failed to mention that certification was only at the RD level. This i, tem is unresolved (369/81-2 7-06, 370/81-05-06) pending review by the NRC.

'

Licensee Action on Previously Identified Inspection Items (92701)

a.

(Open) Open Item (366/78-39-10):

Approval of revisions to design.

changes. Revision 19 to the APM is currently in the review process and until this revision is approved and issued this item cannot be closed.

b.

(0 pen) Open Item (366/78-39-11):

Establishment of external interfaEe and communications documentation. Revision 19 to the APM is currently in the review process and until this revision is approved and issued this item cannot be closed.

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1 et (Ope.9 Open'ite 1 (366/78 39-12): Design input inforcation. Revision 19

-c-toethe APM-is currently in;the review process and until this revision

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is approved at:d issusd'this?ltem cannot be closed.

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f4. (Closed) Oper Item (369/78-39-14): Calibration control. The inspector _ -

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.Testted' 413,?.1, Identifying, Scheduling and Farformance of Plant reviewed

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RE/191on 6~date'd 1/80.

This procedure provides guidance for

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tYee inip,hme'ntation ofc the ifalibration program. The inspector also h

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reviewed 'a master schedule for calibration of Technical Specification

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E JTClosed)? Inspector fdi1bup Iurirs(369/80-08-04,. 370/80-05-04, 413/80-

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' distribution and audit replies.gd9-04, 414fB0-09-04,%91/80-67;c04N492/s0-06 The_ licensee has submitted proposed

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,3 Amendment 5 to the accepted QA Prog' ram to the NRC on March 31, 1981.

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Audit distribution to appropriate leve~ls of management have been N

'f addressed adequately. _

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(Closed)

Inspector Followup Item (E9/80-08-05, 370/80-05-05,

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413/80-09-05, 414/80-09-05, 491/80-07-05, 492/80-06-05, 493/80-06-

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T.h 5 i

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N Records for qualification and ; training -of auditors. The inspector

,

/ 1 4 reviewed QA 130, Qualification _ and Training -of Lead Auditors,-

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Revision 6 dated April.1981.

Paragraph 5.8 addresses the qualifica-s'x tions and training of auditors.

The inspector also reviewed the N,

qualifications and trathilig of lead additors and auditors (prospective

,

T lead auditors). Construction activities en -Dockets 491, 492 and 493

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nave been suspended indefinitely. The audjtors that are in training now N]li 5 ;^

and the currently assigned lead auditors \\ apdit all DPC facilities and y;

their qualifications are satisfactory.,

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.

g.

(Closed) Open Item (369/78-39-15):

Inco'nsistency between procedures e

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and commitments in topical QA Program.

The inspector noted that

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proposed Araendment 5 to the CPC topical report, dated March 30, 1981 f ['

takes exception to the marking requirements of Appendix A, Section 3.9 F

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i ANSI N45.2.2-1972. Othernoects of this section are satisfactory.

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(0 pen) Open Item (369/7M 39-29): Written requirements to use informa-tion available to detect chronic failures and other unsatisfactory

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trends in test equipmens under the control of the McGuire Station.

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equipment at this time.

The expected program did riot materialize due Procedures have not been aeveloped to perform trend analysis for test A-s I

- to the increase in'the number of pieces of test equipment that are now

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required to operate.the McGuire Station.

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25.

Index of Findings of Inspection Report 50-369/81-17 and 50-370/81-05 Item Numbers Item Description Report Location 369/81-17, 370/81-05-VIOLATION

Failure to Review Plant Procedures 5.

Failure to Control Temporary Modification 8.a, Installation and Removal 8.b

Failure to Establish and Maintain Clean-18.

liness requirements

Failure to Use Unapproved Tape on Quality 11.

Stainless Steel Piping

Failure to Properly Store Training Records 16.a UNRESOLVED

06 Certification of Individual for 23.

SRO at R0 Level OPEN

07 Ccaflict of. Calibration Frequency in 19.

Administrative Procedure for Measuring and Test Equipment

08 Retraining Time Frame Not Specified 16.b

Failure to Review Plant Procedures 5.

Use of Unapproved Tape on Quality 11.

Identified Stainless Steel Piping

Improper Storage of Training Records 16.a INSPECTOR FOLLOWUP ITEMS

Temporary Modification Control /f ter Unit 8.c Licensing

13 Conflict in Use of Should and Shall 8.d (Variation Notices)

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ltem Numbers Item Description Report Location INSPECTOR FOLLOWUP ITEMS (Continued)

14 Conflict in Use of Should and Shall 12.c (Records Storage)

15 Simulator Does Not Accurately Model 17.

Pressurizer and Reactor Vessel Levels for Stratification Problems

16 APM and Technical Specification 22.c Inconsistencies

17 NSRB Charter and Technical Specification 22.1 Inconsistencies

18 Clarification of N3RB Review Function 22.b

Strip Charts Receipt 12.b

20 Fire Loading Review of Satellite Record 12.a Storage Locations

21.

Misinterpretation of Grace Period 16.c l

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