IR 05000395/1985038

Insp Rept 50-395/85-38 on 850930-1004.No Violations or Deviations Noted.Major Areas Inspected:Qa Program Review, Offsite Support Staff & Offsite Review Committee

ML20134A327
Person / Time
Site:	Summer
Issue date:	10/23/1985
From:	Belisle G, Runyan M NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
To:
Shared Package
ML20134A325	List: IR 05000395/1985038 ML20134A323
References
50-395-85-38, NUDOCS 8511040347
Download: ML20134A327 (10)

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• k UNITED STATES

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NUCLEAR RECJLATORY COMMISSION

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Report No.: 50-395/S5-38

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Licensee: South Carolina Electric and Gas Company Columbia, SC 29218 Docket No.: -50-395 License No.: NPF-12 Facility Name: Summer Inspection Conducted: September 30 - October 4, 19S5

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Inspectar: .hc%

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Date Signed Approved by: < g 5 /o[f /T.G.-

G. A. Belishr,VActing Section Chief Date ffigned Division of Reactor Safety SUMMARY Scope: This routine, unannounced inspection entailed 33 inspector-hours on site-in the areas of quality assurance (QA) program review, offsite support staff, and offsite-review committe Results: No. violations or deviations were identifie .

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REPORT DETAILS Persons Contacted Licensee Employees

• H. Babb, General Manager, Nuclear Training

• W. Baehr, Manager, Corporate Health Physics and Environmental Programs S. Bailey, Associate Manager, Procurement Engineering Group J. Bannister, Senior Engineer, Construction J. Barker, Senior Staff Health Physicist A. Bashore, Site Manager, Construction

• 0. Bradham, Director, Nuclear Plant Operations

• R. Clary, Manager, Nuclear Engineering

• Clonts, Assistant Site Manager, Construction

• S. Crumbo, QA Engineer S. Cunningham, Associate Manager, Project Engineering

• H. Donnelly, Senior Licensing Engineer T. Effinger,. Associate Engineer, Nuclear Systems T. Frady, Associate Manager, Procurement Systems G. Higgenbotham, Associate Staff Health Physicist S. Hunt, Associate Manager, Surveillance Systems

• A. Koon, Associate Manager, Regulatory Compliance D. Lavigne, Manager, Nuclear Quality Control (QC)

F. Leach, Manager, QA C. Ligon, Nuclear Safety Review Committee Secretary G. Moffitt, Associate Manager, Columbia Engineering B.'Mullinax, Associate Manager, Nuclear Systems

• D. Nauman, Director, Nuclear Services

• K. Nettles, Group Manager, Technical Services

• A. Paglia, Manager, Nuclear Licensing J. Proper, QA Supervisor, Operations J. Todd, Structural Engineer l *D. Warner, Manager, Nuclear Fuel Management

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l *M. Whitaker, Group Manager, Regulatory and Support Services f *R. Whorton, Associate Manager, Licensing Systems J. Woods, Group Manager, Construction Other licensee employees contacted included office personne Other Organizations D. Grand, Electrical Engineer, Gilbert Commonwealth

• Williams,-Special Assistant, Nuclear Operations, Santee Cooper

• Attended exit interview B.

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NRC Resident Inspec~ tor P. Hopkins Exit Interview

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The inspection scope and findings were summarized on October 4,1935, with those persons indicated in paragraph 1 above. The inspector described the areas inspected and discussed in detail the inspection finding No dissenting comments were received from the license Unresolved Item: Use of' Telephone to Meet NSRC Quorum Requirements, paragraph The licensee did not identify as proprietary any of the materials provided to or reviewed by the inspector during this inspectio . Licensee Action on Previous Enforcement Matters This subject was not addressed in the inspectio . Unresolved Items Unresolved items are matters about which more information is required to determine whether they are acceptable or may involve violations or deviations. One new unresolved item identified during this inspection is discussed in paragraph . QA Program Review (35701)

References: (a) 10 CFR 50.54(a)(1), Conditions of-Licenses (b) FSAR Section 17.2, ~ Quality Assurance During the Opera-

. tions Phase (c) 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants The inspector reviewed the licensee QA Program required by references (a)

through (c) determine if these activities were conducted in accordance with regulatory requirement The following criteria were' used during this-review to assess overall acceptability of the established program:

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Personnel responsible for -preparing implementing procedures understood the significance of changes to these procedure Licensee procedures were in conformance with the QA Progra . . .

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The QA program is described by Chapter 17 of the FSAR and is revised yearl The following program changes made in the 1984 and 1985 submittals were randomly selected to determine whether the changes were fully implemented:

Organizational changes were made as described in Figure 17.2-1 of the FSAR. In the 1983 program, the Quality Control Systems Group was in an ad hoc status located off site. In the 1985 program, the group was made permanent and located on site. Several title changes were also mad In the 1983 program, Section 17.2.2 stated that the QA program would be applied to certain non-safety-related activities, termed " quality-related." The 1985 program stated that " Quality Related Plans" will be generated to cover these activities which, in the interim, will still be subject to the QA progra In the 1983 program, the Director of Station QC was responsible for receiving inspection services. The 1985 program assigns this respon-sibility to the Associate Manager, QC System The 1983 program states that the Assistant Manager, Maintenance Services, is responsible for scheduling and planning wor The 1985 program assigns this responsibility to Scheduling and Outage Managemen Through interviews with personnel and the examination of documents provided by the licensee, the inspector determined tnat the above QA Program changes were fully implemente The procedures discussed in this report were reviewed to determined conformance with the QA Program. The inspector reviewed QA Program imple-mentation as a part of the inspection. Each specific area is detailed in other paragraphs of this report. Problem areas, if identified, are detailed in the, specific area inspecte . Offsite Support Staff (40703)

References: (a) 10 CFR 50.54(a)(1), Conditions of Licenses (b) FSAR Section 17.2, Quality Assurance During the Opera-tions Phase

.(c) 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (d) Regulatory Guide 1.33, Quality Assurance Program Requirements (Operations)

(e) ANSI N18.7 - 1976,-Quality Assurance for the Operational Phase of Nuclear Power Plants

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(f) Technical Specifications, Section 6, Administrative Controls

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The inspector visited the corporate office to determine whether the offsite support staff functions are performed by qualified personnel in accordance with licensee approved administrative controls, regulatory requirements, and industry guides and standards. The following criteria were used during this review to assess the adequacy of the offsite staff:

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Administrative controls were established to assign departmenta responsibilities, authorities, and lines of communication in conformance with the requirements of 10 CFR 50, Appendix B, and the licensee's approved QA progra Managers, group leaders, and staff members understood their respon-sibilities and authoritie The above personnel were qualified _for their related wor Quality assurance audits of offsite support staff activitie's were conducted satisfactorily and corrective actions for identified deficiencies were completed in a timely manne The documents listed below were reviewed to determine if the previously listed criteria had been incorporated into the licensee's offsite support staff operatio SCE&G Operational Quality Assurance Plan Section 2 Organization and Responsibilities Section 3 Administrative Controls AI-401 Quality Assurance Activities, Revision 0 AI-404 QA Personnel Assignment and Administration, Revision 0 AI-407 Documentation of Technical Personnel Training and Qualification, Revision 1 Technical Ser, ices Procedures, Nuclear Operations Department TS 100 Nuclear Engineering Organizational Responsibilities, Revisior 2 TS-101 Personnel and Indoctrination / Training Program, Revision 1 Management Directives Manual, Revision 19 Statement of Responsibilities Quality Services Group, Revision 3 Nuclear Services Group, Revision 4 Procurement Engineering Group, Revision 0

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Organizational Stre-ture, Nuclear Operations Department, Revision 3 Technical Policy Statements, Nuclear Services Division, Revision 0 Corporate Health Physics Procedures CHP-102 Personnel Indoctrination / Training Program, Revision 1 CHP-106 Organizational Structurm , Responsibilities and Duties, Revision 1 CHP-206 Interfacing Procedure for Corporate Health Physics, Revision 1 The inspector interviewed the following SCE&G personnel:

Design Engineering R. Clary, Manager, Nuclear Engineering G. Moffitt, Associate Manager, Columbia Engineering S. Cunningham, Associate Manager, Project Engineering J. Todd, Structural Engineer Procurement Engineering R. Clary, Manager, Nuclear Engineering S. Bailey, Associate Manager, Procurement Engineering Group D. Grand, Electrical Engineer, Procurement Engineering Group Construction

. J. Woods, Group Manager, Construction A. Bashore, Site Manager, Construction M. Clonts, Assistant Site' Manager, Construction J. Bannister, Senior Engineer, Construction Quality Assurance .

F. Leach, Manager, QA T. Frady, Associate Manager, Procurement Systems S. Crumoc, QA Engineer Nuclear Fuels Management

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D. Warner, Manager, Nuclear Fuels Management B. Mullinax, Associate Manager, Nuclear Systems T. Effinger, Associate Engineer, Nuclear Systems

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Health Physics and Environmental Programs W. Baehr, Manager, Corporate Health Physics and Environmental Programs J. Barker, Senior Staff Health Physicist G. Higgenbotham, Associate Staff Health Physicist A large percentage of the corporate staff is located on sit Several groups are almost evenly divided between onsite and offsite job locations and employees are often shif ted between the tw This appears to be a beneficial policy, promoting efficiency, quality, and moral It allows the corporate staff to perform their support function in a direct fashio The interviews referenced above were performed to assess the administration, indoctrination, and training of the corporate staff. All employees appeared to understand their responsibilities and authorities and could identify the documents which delineate this information. These documents provided a high degree of detail pertaining to organizational and administrative affair All . employees had received some form of training. This training consisted of classroom instruction, technical school and simulator training, required reading lists, and_on-the-job training. Though the primary emphasis was on new employees, some refresher training was conducte The majority of the technical staff are degreed engineers. A smaller, but significant, percentage are registered _ as professional engineers. The licensee encourages professional registration as a means of advancement in the organizatio The offsite support staff appeared to interface satisfactorily with the onsite staff. Offsite personnel located in the corporate office routinely visited the site to coordinate their wor Various departments and divisions within the corporate office appeared to communicate well and deliver a coordinated work effor The responsibility to audit offsite support staff functions was shif ted approximately one year ago from corporate to onsite QA. The following audits of the offsite support staff were reviewed:

II-28-84-M, Environmental Surveillance Program, Environmental Surveillance / Monitoring Group, October 29 - November 2, 1984 II-2-85-G, Nuclear Services - Technical Services, January 28 -

February 8,1985 II-23-85-K, Purchasing Activities,. August 21 - 22, 1985 Audit findings were significant in scope and depth, and corrective action for identified deficiencies was timely and well documente Within this area, no violations or deviations were identifie . ..

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7 Offsite Review Committee (40701)

References: (a) 10 CFR 50.54(a)(1), Conditions of Licenses (b) FSAR Section 17.2, Quality Assurance During the Opera-tions Phase (c) 10 CFR 50, Appendix B, Quality Assurance Criteria for Nuclear Power Plants and Fuel Reprocessing Plants (d) Technical Specifications, Section 6.5.2, Nuclear Safety Review Committee (NSRC)

(e) Regulatory Guide 1.33, Quality A.ssurance Program Requirements (Operations)

(f) ANSI N18.7-1976, Quality Assurance for the Operational Phase of Nuclear Power Plants The inspector reviewed the licersee's offsite review committee, the Nuclear Safety Review Committee (NSRC), required by references (a) through (f) to determine' if the committee was 'in conformance with regulatory requirements, industry guides and standards, and the technical specifications (TS). The following criteria were used curing this review to assess the overall acceptability of the established program:

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The NSRC membership and qualifications were as required by the TS

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The NSRC held meetings at the required frequency with the required quoru The NSRC reviewed those items specified in the T The NSRC had cognizance of audits performed in the areas specified by the T NSRC meeting minutes were prepared and issued within the required timeframe The document listed below was reviewed to determine if the previous listed criteria had been incorporated into the licensee's NSRC charter:

Management Directive: State of Responsibilities, Nuclear Safety Review Committee, Number 6, Revision 4 The inspector. reviewed the completed minutes resulting from the following meetings:

NSRC Meeting N Date of Meeting 83-05-S1 August 16 - 17, 1983 83-05 September 20, 1983 83-06-S1 September 30-, 1983 83-06 November 15, 1983

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84-01-S1 December 7, 1983 84-01 January 17, 1984 84-02-S1 Janua ry 30, 1984 84-02-52- February 21, 1984 84-02 March 20, 1984 84-03-S1 March 28 - 29, 1984 84-03-S2 April 24 - 25, 1984 84-03 May 22, 1984 84-04-S1 June 19, 1984 84-04 July 17, 1984 84-05-51 August 23, 1984 84-05 September 25, 1984 84-06-51 November 29, 1984 84-06 December 11, 1984 85-01-S1 March 4, 1985 85-01 March 12, 1985 85-02-S1 April 9, 1985 85-02-S2 April 26, 1985 85-02-S3 May 15, 1985 85-02-S4 June 7, 1985 85-02 . June 18, 1985 85-03-S1- August 1, 1985 85-03-S2 August 30, 1985 85-03 September 17, 1985 Meeting numbers designated with an "S" were special meetings called to review a specific issu An SGE&G inter-office correspondence dated November 1, 1983, lists 11 full-time members of the NSRC and 8 alternate members. The. inspector reviewed the resume files for full-time and alternate members to determine whether the NSRC possessed expe"tise in review areas required by TS. All areas except chemistry / radiochemistry were well-covered by the staff's educational and experimental backgroun In the ' area of. chemistry and radiochemistry, one full-time and one al t'e rnate member had limited experience, though not meeting the level required by the TS. A violation is not warranted because the TS requires the NSRC to have expertise in only a majority of the eight areas listed. However, the NSRC would be expected to employ a ceasultant in the event of a review involving a highly technical chemistry or radiochemistry issu It was evident from the meeting minutes that all review areas required by the TS were being reviewed. Review items were regularly sent to the NSRC at least one week prior to the meetings and within several weeks after they had been reviewed by the Plant Safety Review Committe This kept reviews current and prevented backlog The NSRC is required by the TS to have cognizance of audits perf ormed in certain areas. Committee members were individually assigned areas and were responsible for giving periodic " shepherd's reports" summarizing all associated audit activitie . - . -

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The constitution of the meetings reviewed met quorum requirements. Meetings were held routinely more often than the requirement of once per six'menth Within this. area, one unresolved item was identified. The NSRC often calls

- special meetings on short notice usJally to approve a change to the TS. It has been the practice of the NSRC, on occasion, to conduct individual special meetings by telephone conversations in lieu of assembling a quorum in one location. Meetings 83-05-51, 84-03-S1, and 84-03-52, among others, used telephone conversations to meet quorum requirements. The issue is whether meetings conducted in this manner satisfy the intent of the quorum requirements specified in the TS. Pending further review by NRC, this item will be identified as Unresolved Item 395/85-3S-01- Use of Telephone to

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Meet NSRC Quorum Requirements. The licensee is not required to respond to this issue ~at this tim .

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