IR 05000416/1981001
| ML20003D277 | |
| Person / Time | |
|---|---|
| Site: | Grand Gulf  |
| Issue date: | 02/11/1981 |
| From: | Belisle G, Fredrickson P, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20003D275 | List: |
| References | |
| 50-416-81-01, 50-416-81-1, NUDOCS 8103260186 | |
| Download: ML20003D277 (9) | |
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION tj g
REGION 11 O
E 101 MARIETTA ST., N.W., SulTE 3100 b[
ej ATLANTA, GEORGIA 30303 o
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Report No. 50-416/81-01 Licensee: Mississippi Power and Light Company Jackson, MS Facility Name: Grand Gulf (
Docket No. 50-416
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License No. CPPR-118 Inspection at Grand Gulf site near Port Gibson, Mississippi
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Inspector:
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P. E.'Fredrickson Dat'e $1gne
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Approved by:
C. M. Upright, ng'S ion Chief, dat( Signed RONS Branch
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SUMMARY r... $-
Inspection on January 7-9', 1981 Areas Inspected This routine, announced inspection involved 38 inspector-hours on site in the
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. areas of preoperational testing quality assurance program and preoperati~onal
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l testing records.
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Results Of the two areas inspected, no violations or deviations were identified.
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DETAILS 1.
Persons Contacted Licensee Employees I. Ambrosino, Nuclear Support Manager R
J. Custer. Training and Administration Superintendent
- D. Hunt, Plant Quality Superintendent
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- C. Hutchinson, Start Up Manager A. McCurdy, Technical Superintendent
- T. Reaves, Jr., Manager QA
- G. Rogers, Site Manager
- C. Stuart, Assistant Plant Manager
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- R. Williams, Office Services Supervisor
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'*J. Yelverton, Operations QA Supervisor i
Other licensee employees contacted included office personnel.
NRC Resident Inspe~ctor
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u,Attendedix"it interview
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The following abbreviations and terms are used throughout this report:
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Accepted Quality Assurance Prog ~ ram - Operational Quality Assurance Manual -
MPL-TOP-1A, Revisio'n 1, dated 5/79
AP Administrative Procedure APO Off. Project Correspondence D&CR Discrepancy and Correction Report
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l MAR Monitoring Audit ~ Report
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MP&L Mississippi Power and Light Company
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l NP,M i Nuclear Plant Manager
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PQMR Plant Quality Monitoring Report i
QAFS Quality Assurance Field Supervisor
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TCN-Temporary Change Notice l
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Exit Interview The inspection scope and findings were summarized on January 9,1981, with those persons indicated in paragraph I above. Additional conversatione were l
held by telephone between A. Belisle, T. Reaves, Jr., and J. Yelverton on l
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January 12, 1981. These conversations were relative to the unresolved item i
identified in paragraph 5.a.
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Licensee Action on Previous Inspection Findings Not inspected.
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Unresolved Items Unresolved items are matters about which more information is requ~1 red to determine whether they are acceptable or may involve noncompliance or deviations.
One unresolved item identified during this inspection is discussed in paragraph 5.a.
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Preoperational Testing Quality Assurance (35301)
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References:
(a) Operational Quality Assurance Manual, MPL-Topical-1A, Revision 1 dated 5/79
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(b) QAP 18.10, Quality Assurance Audits, Revision 4 datedJ/80
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(c) QAP 18.20, Quality Assurance Monitoring Audits, Revision 1 dated 8/80
,(d) QAP 18.30, Quality Assurance Audits Planning and -
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Sch'e'duling, Revision 0 dated 8/80
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(e) QAP 18.40, Followup Action by Audits of MP&L (Grand-Gulf) by Other Groups, Revision 1 dated 8/80 (f) QAP 1.10F, Duties, Responsibilities and Authority ~
of the Quality Assurance Field Supervisor / Quality
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Assurance Operations _ Supervisor, Revision 4 dated
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(g) QAP 1.20F, Duties, Responsibilities and Authority of Site Quality Assurance Representatives, Revision 3 dated 6/80
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(h) QAP 1.30G, Duties, Responsibilities and Authority of General Office Quality Assurance Represen-tatives, Revision 4 dated 5/79 (i) QAP 2.40, Indoctrination and Training of Quality Assurance Personnel, Revision 3 dated 8/80
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(j). QAP 15.10, Stop Work Order, Revision 3 dated 12/78 (k) QAP 16.10, Corrective Action Request, Revision 5
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dated 8/80
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(1) QAP 16.40, Quality Assurance Section Manual Files and Status Logs, Revision 2 dated 6/80 (m) Documentation of Qualified Auditors and Lead Auditors to QAP 2.40, File 0290/0490/15800/
15840/15860, PMI 80/2818 (n) Review of Reissue of QAPM of 5/1/79, File Numbers 0290/0490/0491/15906,QACR-79/14 (o) Review of Quality Assurance Procedures, File 0290/0490/0491/15906, QACR 79/20 (p) Administrative Procedures (Desk Procedures) *PMI 78/973*
File Numbers 0290/0490/0491/15911,
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PMI-79/1726
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(q) QAP 15.20, Discrepancy and Correction Report, Revision 4 dated 10/80
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The inspector revjewed the referenced documents to verify the licensee's control over the, conduct of preoperational testing in the following areas:
authorities and responsibilities for managing the QA program; QA/QC review of plant activities; audits; and training and qualification of QA personnel.
To verify the implementation of the previously stated program, the inspector
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reviewed two team audits,-six monitoring audits and four plant quality
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The inspector also' interviewed four qualified lead auditors and ---
l three ~ quality assurance personnel in training to become lead auditors.
Based on this review, one unresolved item and three inspector followup items were identified as discussed in paragraphs 5.a. through 5.d.
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Formally De"ine Current Practices
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The following is a list of audits and_ reports reviewed by the i
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inspector:
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Audit / Report Dates Conducted
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APO-80/165 6/4-5/80 l
APO-80/303, 80/384 10/27-30/80
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MAR 80/91 8/26-11/4/80 MAR 80/95 9/29, 10/1, 10/15/80
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MAR 80/59 7/3-9/80 t
MAR 80/29 4/11-16/80
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MAR 80/25 3/5-26/80 l
MAR 80/24 3/19/80 PQMR 00088-80 11/21/80 PQMR 00062-80 9/12/80 PQMR 00085-80 11/13/C0 PQMR 00001-80 1/8/81
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MAR 80/23 identified one nonconformance and D&CR 1185 was issued with a
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due date of 4/24/80 for the audited organization to respond to the nonconformance.
On 4/29/80, a memo was issued from the QAFS to the NPM (File: 0290/
0490/15830/0168, PMI 80/751) stating that the response to D&CR 1185 was delinquent.
On 5/19/81, another similar memo was issued (File:
0272/0168/15830/15850, PMI 80/840). On 5/22/80, a speedimemo from D.
Hunt to J. Yelverton was issued stating corrective action for D&CR 1185
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would be completed by 6/10/80.
On 6/27/80,.another memo wasiissued I
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0290/0490/0168/15830/15850, PMI l
80/0170) stating that corrective action for DCR 1185 was delinquent and l
a reply was requested by 6/27/80. On 6/20/80, another speedimemo was issued from D. Hunt to J. Yelverton requesting an extention until
7/7/80.
On 7/17/80, D&CR 1185 was verified as being completed and
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l The previous sequence of events is illustrative of two basic problem l
areas:
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-(1) During _ interviews with quality assurance lead auditors, the l
previopsly mentioned sequence of events was discussed. All the l
personnel interviewed stated that the audited organization is required to respond to audit findings (nonconformance) within 30 days. This requirement is not procedurally stated in references
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(a), (c), or (g).- No citation is issued for inadequate procedures because - the currenY ' practices are acceptable and, of all the --
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l audits reviewed, no due dates on the D&CR form exceeded this 30 l
day requirement.
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,(2) Quality assurance lead auditor personnel interviewed uniformally understood that when the audited organization did not respond within the required time, their supervisor was notified.
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notification by the lead auditor that.a response was not received, i
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a memo was sent by the QAFS to the audited organization stating the response was delinquent. Guidance provided in references (k)
and (q) is incomplete in that it does not address what the auditing organization is to do if the delinquent notice is ignored or if the response is inadequate to correct the nonconformance.
No citation is issued for inadequate procedure because of the audits reviewed, only one example was identified when the response due date had been exceeded and this is considered an isolated i
occurrence.
The licensee agreed to revise their existing procedures to correct the probelms identified.
A' target date of March 31, 1981, was given for these corrections. Until these corrections are imple-mented and reviewed, this is identified as unresolved item
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416/81-01-01.
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b.
Review Training Records During the interviews with quality assurance representatives discussed in paragraph 5.a., the inspector requested to review training records to verify qualifications of the personnel as lead auditors. These records are currently being stored in the company offices in Jackson,
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MS. These records will be reviewed during a subsequent inspection.
Until these records are reviwed and personnel qualifications verified, this is identified as inspector followup item 416/81-01-04.
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c.
Clarify Exceptions to ANSI N45.2.12 The licensee's accepted QA Program, Sections 18.5.3 and 18.5.4 state
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the objectives of the MP&L Audit system.
These sections generally
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require that audits include objective evaluation and eifectiveness of subjects being audited.
The licenses has taken m.ception to ANSI N45.2.12, Draft 4, Revision 2, Section 4.4.
This section states in part that audit reports will not contain an evaluation statement regarding the effectiveness of the quality assurance program elements.
Until _ the li.censee clarifies the existing procedures with program commitmentsp this item is identified as inspector followup item 416/
80-01-05.
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d.
Clarify QAP 16.10 to Reflect ANSI Standard Requirements
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Reference (k), Attachment: A, Section 1.F states that the date entered --
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identified during an audit) should be within 30 days of issue.
ANSI N45.2.12, Draft 4, Revision 2,. Section 4.5.1 specifically states that the audited organization shall respond to adverse audit findings l -
within thirty days.
Until reference (k) is clarified to meet the l
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. requirements of the ANSI Standard, this item is identified as inspector'
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- followup item a 416/81-01-06..
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Preoperational Test Records (39301)
References:
(a) Operational Quality Assurance Manual, MPL-TOP-1A Revision 1 dated 5/79 (b) AP 01-S 51-2, 0ffice Services Section, Safety
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Related, Revision 1 dated 3/80 (c) AP_01-S-05-1, Operation and Control of the Central Documents and Records Systems, Revision 0, TCN 5
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(d) AP 01-S-05-7, Correspondence Control, Revision 0, TCN 2 dated 12/80 (e) AP-01-S-G5-9, GGNS Search and Retrieval System, Non-Safuty Related, Revision 0 dated 9/80 q
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(f) AP 01-S-04-14, Training Records, Safety Related, Revision 1 dated 8/80 (g) Administrative Section Instruction 13-S-01-56, Operation of Central Records, Safety Related, Revision 0, TCN 2 dated 7/80 (
(h) Office Service Section Instruction 13-S-01-52, Permanent Hard Copy File Maintenance, Safety Related, Revision 1 dated 12/80
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(1) QAP 17.10, Quality Assurance Records, Revision 4 dated 8/80 l
(j) GGNS Record Type List, dated 10/80
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i The inspector reviewed the licensee's accepted QA Program with respect to the control of records, particularly those records to be generated during the preoperational test program. The referenced procedures were reviewed to i
verify that an index of records has been established, that adequate records
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receipt and retrieval storage controls have been established and that retention periods for the various records have been established.
The inspector also verified that the procedures established responsibilities for the implementation of the records program. To verify implementation, the inspector interviewed several records personnel concerning their duties and
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selected the following docume.ntito verify. records retrieval:
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-- MAR 80-91
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-- D&CR 1185 l
- MWO 1149
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- Trouble Ticket FY0029
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Based on this review, two open items and one inspector followup item were identified as discussed in paragraphs 6.a thru 6.c.
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Records Generated From Incoming Correspondence During the implementation review, the inspector observed that incoming
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correspondence was being routed to the responsible supervisors with the hard copy original being placed in the records storage ~ vault.
Records personnel perceived that any correspondence that a supervisor desired i
l to retain as a quality record would be transmitted to files in l
accordance with reference (c). A supervisor interviewed understood that with the original copy in files, he could retrieve the document at l
will and thus did not review his incoming correspondence for quality retention.
The records personnel (depending on each supervisor's action to identify quality correspondence) discard the correspondence I
in one year. This communication breakdown could lead to the loss of
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potential quality records. The licensee committed to a February 9, 1981, date for the clarification of reference (d) to insure that potential quality records are identified. Until this clarification has been made and reviewed, this item is open (416/81-01-03).
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Active to Inactive Trainira Record Transition Reference (f) differentiates active and inactive training records and states that the inactive records will be handled in accordance with reference (c).
This procedure does not delineate the time'.when l
inactive records will be transferred to control of the Office Services Section. The licensee committed to a June 30, 1981, date for revising reference (f) to show this transition timeframe. Until this revision is completed and reviewed, this item will be considered open (416/81-01-02).
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c.
Project Management Records Review The inspector noted that several quality records were being handled by the Project Hanagement Staff, which is located off-site. To complete the review gf the records management system for Grand Gulf, this off-site oppration will be reviewed during a future inspection. As such, this review is designated an inspector followup item (416/81-01-07).
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Index of Findings for Inspection. Report 50-416/81-01 i
Item Number Item Description Report Location
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i 416/80-01-UNRESOLVED ITEM
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Formally Define Current Practices 5.a r
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OPEN ITEMS.
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Active to Inactive Training Records 6.b Transition
Records Generated from Incoming 6.a l
Correspondence INSPECTOR FOLLOWUP ITEMS j
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Review Training Records 5.b
Clarify Exception to ANSI N45.2.12 5.c
'06 Clairfy QAP 16.10 to Reflect 5.. d ANSI Standard Requirements
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07 Project Management Records Review 6.c
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