IR 05000395/1980035
| ML19351G162 | |
| Person / Time | |
|---|---|
| Site: | Summer  |
| Issue date: | 12/31/1980 |
| From: | Belisle G, Frederickson P, Ruhlman W, Skinner P, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19351G155 | List: |
| References | |
| 50-395-80-35, NUDOCS 8102230206 | |
| Download: ML19351G162 (13) | |
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NUCLEAR REGULATORY COMMISSION
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101 MARIETTA ST., N.W SUITE 3100
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ATLANTA, GEORGIA 30303 i
Report No. 50-395/80-35 Licensee: South Carolina Electric and Gas Company P. O. Box 764 Columbia, SC 29218 Facility Name: Summer Docket No. 50-395 License No. CPPR-94 Inspection at Summer site near Winnsboro, South Carolina.
Inspectors:
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Approved by: M Mf
/2/2//Fo C. H. Uprigh ec Chief, RONS Branch Date Signed SUMMARY Inspection on November 24-25, 1980 Areas Inspected This routine, announced inspection involved 33 inspector-hours on site. This inspection reviewed the overall operations QA program including implementing procedures.
Actual implementation of the program will be reviewed during a future inspection. The QA program areas covered by this inspection were QA/QC administration, audits, document control, maintenance, design change and modifi-cations, surveillance testing, procurement control, receipt storage and han Iling, records, tests and experiments, and test and measurement equipment.
Results
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Of the eleven areas inspected, no violations or deviations were identified.
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d DETAILS 1.
Persons Contactcd
. Licensee Employees B. Amick, QC Inspector, Level II
- 0. Bradham, Manager, V.C. Summer Station
- B. Croley, Technical Support Supervisor
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- E. Evans, SCE&G/QA P. Fant, Inspection Coordinator, QC
- T. Frady, SCE&G/QA
- A. Koon, Technical Services Coordinator J. LaBorde, Lead Engineer (Nuclear Operations)
F. Lamphere, Office Supervisor
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- C. Ligon, Administrative Supervisor C. Lorick, Lead System Supervisor, Electrical
- D. Moore, Manager, QA
- A. Smith, SCE&G/QA l
- S. Smith, Maintenance Supervisor
- J. Wactor, Senior Engineer, Nuclear Engineering G. Webb, Engineer, Nuclear Engineering K. Woodward, Assistant < Operations Supervisor Other licensee employees contacted included technicians and office personnel.
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NRC Resident Inspector l
- J. Skolds
- AttenGed exit interview e
2.
Exit Interview f
The inspection scope and findings were summarized on November 25, 1980 with
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those persons indicated in paragraph I above. The inspection and findings
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were also discussed with Mr. T Nichols, Vice President and Group Executive, Power Production Systems and Operations, and Mr. W. Williams Jr., General Manager, Nuclear Operation on December 1, in Atlanta, Ga.
Since this
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inspection was conducted to verify ' the Operations QA Program prior to issuance of an Operating License, there were no violations identified.
3.
Licensee Action on Previous Inspection Findings Not inspected.
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Unresolved Item.
- Unresolved items were not identified during this inspection.
5.
QA/QC Administration (35740)
References:
(1) FSAR, Chapter 17.2 (2) FSAR, Volume IV, Table 3.2.1 (3) Operational QA Plan, Revision 3 dated 6/80 (4) FSAR, Appendix 3A
(5) AP-102, Procedure Review, Approval and Revision, Revision
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1 dated 7/1/80 (6).AP-1200, Inspection of Activities Affecting Quality, Revision 2 dated 1/3/80
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a.
Program Review The referenced documents were reviewed with respect to the licensee's accepted QA Program. The inspection was to verify that the licensee's program clearly defined those structures, systems and components and other items and services to which the QA/QC controls are to oe 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 controls for audits was also conducted to verify that methods were established to issue, revise and control QA/QC procedures; to periodically evaluate the effectiveness - of the QA/QC Program and to provide emphasis where needed in problem areas; and to provide management with an evaluation
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of the overall effectiveness of the QA Program.
Based on the inspector's review four areas or items were at variance with or did not fully implement specific requirements of the accepted
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QA Program as described in paragraphs 5.b through 5.e below.
b.
Review of Adequacy of Administrative Organization i
i Reference (3), Section 3.2.1, requires the organizational relationships to be reviewed " periodically." The licensee's program does not provide a specific audit or frequency for accomplishing this activity. The licensee stated that the required review would be accomplished during
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i the annual review of the QA Plan and that Section 2.2.4.2 of the Plan would be revised to document that approach. Until the required revision has been effected,- this ites (395/8d-35-01) is open.
c.
"Q" List and Consumable / Expendable Items During the NRR review of the accepted QA Program, two questions (421.16 and 421.66) with respect to the lack of a "Q" List were opened; these questions have been combined and remain as an open issue in the
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SER for the plant. The specific questions did not include a need for
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in sion of consumable and expendable items, but these types of items ceing routinely included on accepted "Q" Lists. Until'NRR has resolved this issue with the licensee, this item (395/80-35-02) is open.
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d.
Determination of "Q" and "non-Q" The licensee's current procedures allow non-QA/QC personnel to make the determination of whether a specific maintenance activity is safety-related ("Q") or non-sa fety-related ("non-Q"). Since there is no definitive guidance available to readily make such a determination (see item 5.c above), and since items designtted as non-Q receive no further review (except by ex post facto sample audit), the inspector stated that the requirementa for control of all safety-related maintenance could be bypassed.
The licensee stated that a further evaluation of current practices would be completed and that changes would be made if considered appropriate or necessary.
Until the evaluation has been completed and reviewed, this item (395/80-35-03)
is open.
e.
Distribution and Review of Audit Responses and Corrective Actions The Nuclear oafety Review Committee (NSRC) currently receives and reviews audit reports through the Group Manager of Quality Assurance who is a member of the NSRC and who is charged with making the committee aware of this item; current Program documents do not delineste distri-bution of responses from, nor corrective actions made by, the audited organization. Since the review function of the NSRC includes the requirement to evaluate these additional areas, the licensee will modify his Program documents to state that responses and corrective action followup reports will receive the same distribution and review as the audit reports. Until the required revisions have been completed, this item (395/80-35-04) is open.
6.
Audits (35741)
References:
(1) FSAR, Section 17.2.18 (2) Technical Specifications, Section 6.0 (3) OQAP, Section 15.0, Audits, Revision 3 dated 6/80 (4) QAP-18, Control for Audit Schedules and Status, Revision 1 dated 6/80 (5) QAP-19, Internal SCE&G/QA Audits, Revision 1, dated 6/80 (6) QAP-20, External SCE&G/QA Audits, Revision 1 dated 6/80 (7) QAP-21, SCE&G Quality Assurance Audit Report Preparation, Revision I dated 6/80 (8) OQAP, Section 3, Administrative Controls, Revision 3 dated 6/80 (9)
QAP-2, Indoctrination, Training and Certification, Revision 1 dated 6/80 (10) OQAP, Section 3.0, Administrative Controls, Revision 3 dated 6/80 (11) OQAP, Section 12.0, Nonconformance and Corrective Action Control, Revision 3 dated 6/80 (12) QAP-5, Quality Assurance Review of Bidder Proposal, Revision 1 dated 8/21/80.
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Program Review The referenced documents were reviewed with respect to the licensee's accepted QA Program and ANSI 45.2.13-1977 as committed to by the Program.
The inspection was to verify establishment of an audit program including qualifications and independence of audit personnel; corrective action taken for identified deficiencies; requirements for conducting audits; periodic review of the audit program to determine status and adequacy; requirements for audit responses; and require-ments for the use of checklist / procedures in conducting audits.
Based on the inspector's review, four areas or items were at variance with or did not fully implement specific requirments of the accepted QA Program as described in paragraph 6.b through 6.e below.
b.
Outdated References and Titles Reference (3), Section 15.3.1 lists Section 3.6.2.1 as a cross reference; Section 3.6.2.1 does not raist. The security function has been deleted from responsibilities of the Group Manager, Quality Assurance and Security, but his old title is used throughout the QA Plan and imple-menting procedures. Section 14.0 of the Operational Quality Assurance Plan is referenced as a cross reference between the plan and 10 CFR 50, Appendix B in FSAR Table 17.2-1; Section 14 does not cover all of the arear of Appendix B.
These examples are typical, not all inclusive, and were known by the licensee prior to this inspection. The documents ace being revised, as necessary, to assure that references and titles and position descriptions are accurate. Until these revisions hav,e been completed, this item (395/80-35-05) is open.
c.
Specification of Audit Response Time Neither reference (3) or (5) include the requirement from the accepted Program's endorsement of ANSI N45.2.12 (Section 4.5) for a maximum of thirty days for response to an audit. The current Program documents and their implementing procedures allow the lead auditor to specify the allowable time for the audited organization to respond.
The licensee indicated that the thirty day period would be specified as a maximu', but that the flexibility to obtain faster responses would be m
retained. Until the required time period for responses has been'specified, this item (395/80-35-06) is open.
d.
Clarification of OQAP Section 15.3.2, on Technical Audits Section 15.3.2 of reference (3), as currently written, appears to state that the annual overall effectiveness evaluation audit is optional.
This statement will be reworded to clearly state that it is the use of technical personnel. (to supplement the audit team) that is optional.
l Until this item has been rewritten, this item (395/80-35-07) is open.
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Escalation Procedures
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The current Program documents do not specify either the procedures or the criteria for the escalation of items to higher management. Such items as overdue responses, inadequate responses, inappropriate or
incomplete corrective action, and missed corrective action compl'etion dates are currently all within the purview of the Lead Auditor.
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Although the Manager of Quality Assurance orally described criteria and methods for escalation in each of the above cases, none of the i
items are described in writing or required by current Program documents.
Until these methods and criteria have been delineated in writing and incorporated into the Program, this item (395/80-35-08) is open.
7.
Document Control (35742)
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References:
(1) FSAR Chapter 17.2.6
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(2) OQAP, Section 5.0, Document Control, Revision 3 dated
6/80 (3) QAP-17, Review of Documentation, Revision 1 dated 7/80 (4) QAP-3, Review of Design Change Documents, Revision 1
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dated 7/80 (5)
AP-301.1, Document Control Procedures, Revision 5 dated
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7/80 (6) PEP-119, Preparation and Review of Drawings for
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Design / Modification Changes, (Under Review)
a.
Program Review
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The referenced oocuments were reviewed with respect to the licensee's accepted QA Program and ANSI 18.7-1976 as committed to by that Program.
The inspection was to verify that admin'istrative control had been established for the indexing, issuance and revision of drawings.
Based on the inspector's review two areas or items were at variance with or did not fully implement specific requirements of the accepted QA Program as described in paragraphs 7.b and 7.c below.
b.
Control of Drawings Under Revision Paragraph 5.2.4 of reference (5) provides instructions for incorpora-ting interim changes to drawings pending receipt of a drawing revision.
Filing the amended drawing with the latest revision, without anno-tating on the latest revision that a system change has taken place, permits the unmarked latest revision to possibly be inadvertently used to perform work.
Until this problem area is corrected, this item (395/80-35-09) is open.
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Document Receipt Acknowledgement Paragraph 5.3.2 of reference (5) requires expeditious acknowledgement of document receipt. Without a fixed time frame for acknowledgement, only the monthly audit will determine whether the recipient actually received the document.
Until a fixed time frame for receipt acknowledgement is established, this item (395/80-35-10) is open.
8.
Maintenance (35743)
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References:
(1) OQAP, Section 11, Inspection, Revision 3 dated 6/80 (2) AP-013, Housekeeping Control, Revision 2 dated 4/79 (3) AP-400, Conduct of Maintenance Activities, Revision 0 dated 1/80 (4) QPC-13, Housekeeping Inspection During Operations Phase, Revision 0 dated 5/80
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(5) AP-101, Development of Safety and Non-Safety Related
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Procedures, Revision 7 dated 1/80 (6)
GMP-100.1, Maintenance Group Preventive Maintenance Program, Revision 1 dated 5/79 (7)
GMP-100.2, Controlling Procedure for Troubleshooting and Corrective Maintenance, Revision 1 dated 7/79
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GMP-100.3, Material and Tool Control (in/around) NSSS and Critical Components, Revision 0 dated 4/79 (9)
GMP-100.4, General Cleaning Procedure for Safety-Related Assemblies and Sub-Assemblies, Revision 1 dated 4/80
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(10) AP-403, Use of the Equipment Hold Tag, Revision 1 dated 7/80 (11) AP-401, Maintenance Work Request, Revision 2 dated 1/80
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(12) QCP-G1, Specification and Documentation of QC Inspection Requirements, Revision 1 dated 8/79 i
a.
Program Review The referenced documents were reviewed with respect to the licensee's accepted QA Program and ANSI 18.7-1976 as committed to by that program.
The inspection was to verify that administrative control had been established for the following: preventative and corrective maintenance programs for safety-related systems, structures and components; control of system and equipment during maintenance; cleanliness of systems and components; utilization of special processes such as welding; and general housekeeping practices.
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The inspector's review indicated one area where referenced documents did not include specific requirements of the accepted QA Program. The inadaquacy is discussed in paragraph 8.b.
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b.
QC Guidance in Hold Points
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Reference (12), Attachment I has a signoff by QC that states l
"... perform inspection specified by QC Procedure (s)." There are no I
definitive guidelines as to when or what operation's detailed in procedures require hold points.
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This will be followed as open item 395/80-35-11.
9.
Design Changes and Modifications (35744)
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References:
(1) FSAR, Section 17.2.3
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(2) OQAP, Section 6.0, Design Control, Revision 3 dated 6/80 (3) QAP-3, Review of Design Change Documents, Revision 1 dated 7/80 (4) AP-210, Plant Change Request, Revision 2 dated 7/79 (5) NE-103, Review of Drawings and Specifications, Revision
10 dated 4/80 (6) NE-113, Engineering Change Notices and Field Change Requests, Revision 17 dated 4/80 (7) NE-125, Start Up Field Report, SFR, Revision 5 dated 1/80 (8) AP-1500, Modification Control, Revision 0 dated 11/78
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(9) AP-1200, Inspection of Activities Affecting Quality, Revision 2 dated 1/80
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a.
Program Review f
The referenced documents were reviewed with respect to the licensee's accepted QA Program and ANSI 45.2.11-1974 as committed to by that Program.
The inspection was to verify that procedures existed for initiating a design change request, proper reviews and evaluations were required, a safety evaluation was required for each change to a safety-related or FSAR described system component or structure, design l
analysis and input specifications were identified, cou:munications via (
internal and external interface links existed, and specific design j
organizational responsibilities were delineated in writing.
The inspector's review indicated one area where referenced documents did not include specific requirements of the accepted QA Program. This inadequacy is discussed in paragraph 9.b.
b.
Plant Engineering Procednres l
The licensee is currently developing a set of plant engineering l
procedures (PEPS) that detail conduct of operations to be used for
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processing design changes by plant personnel.
The licensce plans to-implement these procedures in early 1981. Review of these procedures indicated the following deficient areas:
(1) The bases for all safety evaluations are not provided as part of the design change.
(2) Control of design modification documentation is not provided for the following:
recall of obsolete drawings; identification of drawings undergoing revision until new drawings are iscued to ensure o11y correct drawings are used by plant personnel; and
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i-8-distribution of modifications to training personnel to ensure plant personnel are aware of system modifications.
These deficent aspects of design modifications are identified as open item 395/80-15-12.
i 10.
Surveillance Testing and Calibration Control (35745)
a.
Program Review
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Documents were reviewed with respect to the licensee's accepted QA i
Program and ANSI 18.7-1976 and Regulatory Guide 1.33, Appendix A as committed to by that Program..The inspection was to verify that administrative control had been established for maintenance of a master schedule for conducting surveillance tests required by the Technical Specifications; for calibration of safety-related plant instruments not identified in the Technical Specifications; for use of approved procedures in the conduct of these tests and calibrations; and for review of test and calibration procedure results.
Surveillance testing program documentation is approximately 40 percent complete and is targeted to be fully complete and functioning 90 days prior to fuel load.
Based on the inspector's review two areas or items were at variance with or did not fully implement specific requirements of the accepted
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j QA Program as described in paragraphs 10.b through 10.c below.
b.
Calibration Procedures
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The calibration procedures reviewed (Nos. 240.012, 240.001 and 235.009)
did not include changes identified during the startup testing program.
This item will be followed as open item 395/80-35-13.
I c.
Safety Related Classification of Procedures
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Procedure ICP 100.024, Post Accident Hydrogen Removal Purge Exhaust Stack Flow FT8252 was not classified as a safety related procedure. A review of all calibration procedures should be performed to correctly identify safety related procedures and proper controls of the calibration of safety related equipment.
This will be followed as open item 395/80-35-14.
11.
Procurement Control (35746)
References:
(1) FSAR, Section 17.2.4 (2) ~ OQAP, Section 8, Procurement, Revision 3 dated 6/80 (3) OQAP, Section 14, Records, Revision 2 dated 6/80
(4) QAP-4, Review of Specifications and Bills of Material, l
Revision 1 dated 8/80
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-9-(5) QAP-5, Quality Assurance Review of Bidder Proposals, Revision 1 dated 8/80 (6) QAP-6, Quality Related Procurement by Requisition and On-Site Certification Review, Revision I dated 8/80 (7) AP-914, Materials Management, Revision 1 dated 8/80 The referenced documents were reviewed with respect to the licensee's accepted QA Program and ANSI 45.2.13-1976 as committed to by that Program.
The inspection was to verify that administrative controls had been established for the generation and approval of procurement documents and for the qualifi-cation of bidders and suppliers.
The inspector's review identified no areas where the referenced documents did not include specific requirements of the QA Program.
12.
Receipt, Storage and Handling of Equipment and Materials (35747)
References:
(1) FSAR, Section 17.2.13 (2) OQAP, Section 9.0, Material and Equipment Control, Revision 3 dated 6/80 (3) OQAP, Section 11.0, Inspection, Revision 3 dated 6/80 (4) OQAP, Section 12.0, Nonconformance and Corrective Action Control, Revision 3 dated 6/80 (5) QCP-R1, Receiving Inspection, Revision 0 dated 5/80 (6) AP-914, Materials Management, Revision 1 dated 8/80 a.
Program Review The referenced documents were reviewed with respect to the licensee's accepted QA Program and ANSI 45.2.2-1972 as committed to by that Program. The inspection was to verify that administrative controls had been established for receipt of safety-related items, for processing of these items received on site and for storage and handling of these iterr following receipt.
Based on the inspector's review one area was at variance with or did nat fully implement specific requirements of the accepted QA Program as described in paragraph 12.b.
i b.
Discrepancies in Classification of Inspection Items Reference (2), Paragraph 9.4.4 states, relative to the results of receiving inspections, that materials are classified as acceptable, conditional, hold or rejected. Reference (3), Paragraph 11.4 states that at the completion of required inspections, the items shall be clearly identified as acceptable, hold or reject. Them - is no condi-tional classification. Until the classification of items af ter receipt inspection is clarified. This item is open (395/80-35-15).
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Records (35748)
i References:
(1) FSAR, Chapter 17.2.17 (2) Technical Specification, Section 6.10 (3) OQAP, Section 14, Records, Revision 3 dated 6/80
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(4) QAP-16, Quality Assurance Records Accumulation and
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Retention, Revision 3 dated 7/30/80
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(5)
AP-301.2, Nuclear Operations Records Control Procedure,
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Revision 0 dated 1/80 (6) QA Records and Retention Chart, Revision 2 dated 12/79
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a.
Program Review l
The referenced documents were reviewed with respect to the licensee's accepted QA Program and ANSI 45.2.9-1974 as committed to by that Program. The inspection was to verify that administrative controls
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had been established for maintenance, storage and retention of required records generated during the operating phase and for turnover and control of records during the preoperational and construction phase.
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Based on the inspector's review one area was at variance with or did not fully implement specific requirements of the accepted QA Program as described in paragraph 13.b.
b.
Operations, Maintenance and Testing Index
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Reference (6), paragraph G, is the index for Nuclear Operations-Plant Staff Records. For the records section concerning operations, mainte-nance and testing (Paragraph G.5), no indexing subparagraphs have been
identified. The inspector verified that indexing work Is now in pro-I gress. This item is open (395/80-35-16).
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14.
Test and Experiments (35749)
References:
(1) FSAR, Section 17.2.11
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(2) OQAP, Section 3.0, Administrative Controls, Revision 3 dated 6/80 (3) OQAP, Section 4.0, Procedures, Revision 3 dated 6/80 (4) AP-101, Development of Safety aad Non-Safety Related Procedures, Revision 7 dated 1/80 The referenced documents were reviewed with respect to the licensee's accepted QA Program and 10 CFR 50.59. The inspection was to verify that a
formal method was provided to propose, approve and conduct test and experiments involving safety-related components, systems or structures differing from
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those operations described in the FSAR, approved procedures were provided for each test or experiment; and responsibilities were assigned to assure preparation and review of a written safety evaluation pursuant to 10 CFR 50.59.
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-11-The inspector's review identified no areas of concern at this time.
15.
Test and Measurement Equipment (35750)
References:
(1) FSAR, Section 17.2.12 (2) OQAP, Section
'0.0, Measuring and Test Equipment,
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Revision 3 dated 3/80 a.
Program Review The referenced documents were reviewed with respect to the license <'s accepted QA Program and ANSI 45.2-1971 as committed to by that Prograu.
The inspect.on was to verify that equipment lists were prepared to reflect use on safety-related structures, systems or components to include the calibration and adjustment frequency for each; that formal requirements existed to identify the status of calibration; and that a prohibition existed to prevent the use of uncalibrated or out of calibra-tion test and measuring equipment.
Based on the inspector's review one area was at variance with or did not fully implement specific requirements of the accepted QA Progran as described in paragraph 15.b.
b.
Mechanical Calibration Inconsistencies There is inconsistency in the mechanical calibration area in that some mechanical gear that is sent off site for calibratica has SCE&G calibra-tion stickers applied and other do not.
An example of this was the transducer readout unit used for calibration of torque wrenches. This will be followed as open item 395/80-35-17.
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Index of Findings for Inspection Report 50-395/80-35 Item Open Items Report Number Location
Review of Adequacy of AJainistrative 5.b Organization
"Q" List and Consumable / Expendable Items 5.c
Determination of "Q" and "aan-Q" 5.d
Distribution and Review of Audit 5.e Responses and Correcti: Actions
Outdated References and titles 6.b
Specification of Audit Responses Time 6.c
Clarification of Section 15.3.2, OQAP, 6.d on Technical Audits
Escalation Procedure 6.e
Control of Drawings Under Revision 7.b
Document Receipt Acknowledgement 7.c
QC Guidance on Hold Points 8.b
Plant Engineering Procedures 9.b
Calibration Procedures 10.b
Safety Related Classification of 10.c Procedures
Discrepancies in Receipt Classification 12.b of Items
Operations, Maintenance and Testing Index 13.b
Mechanical Calibration Inconsistencies 15.b i
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