IR 05000483/1985013

Insp Rept 50-483/85-13 on 850520-23 & 0603-07.No Violation or Deviation Noted.Major Areas Inspected:Qa/Qc Administration,Audit Program & Implementation & Calibr & Surveillance Testing

ML20127K683
Person / Time
Site:	Callaway
Issue date:	06/21/1985
From:	Hawkins F, Sutphin R, Thomas Taylor NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III)
To:
Shared Package
ML20127K664	List: IR 05000483/1985013 ML20127K660
References
50-483-85-13, NUDOCS 8506270536
Download: ML20127K683 (7)

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U.S. NUCLEAR REGULATORY COMMISSION

REGION III

Report No. 50-483/85013(DRS)

icket No. 50-483 License No. NPF-30 censee: The Union Electric Company P.O. Box 149 St. Louis, M0 63166 Facility Name: Callaway, Unit 1 Inspection At: Callaway Site, Callaway County, M0 Inspection Cojduction: May 20-23 and June 3-7, 1985 Inspectors:

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. N. Sutphi%

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i Date 1Dp T.T.' Taylor (,/2 //8f Date /

r Approved By: F. C. Hawkins, Chief [s/2//Bf Quality Assurance Programs Section Date /

Inspection Summary Inspection on May 20-23 and June 3-7, 1985 (Report No. 50-483/85013(DRS))

Areas Inspected: Routine, unannounced inspection of previous inspection findings; QA/QC administration; audit program and implementation; and calibration and surveillance testing. The inspection involved 101 inspector-hours onsite and 4 ir.spector hours offsite by 2 NRC inspector Resul ts : No violations or deviations were identifie gje3 ADOCK 050 DR

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DETAILS 1. Persons Contacted Union Electric Company (UE)

• F. D. Field, Manager - Quality Assurance P. T. Appleby, Assistant Manager - Support Services

• A. P. Neuhalfen, Assistant Manager - Administration

• D. C. Poole, Assistant Manager - Operations and Maintenance R. L. Powers, Assistant Manager - Quality Assurance

• J. E. Davis, Superintendent - Compliance C. D. Nasland, Superintendent - Instrument and Control

• F. J. Forck, Supervisor - Operations Support QA J. C. Gearhart, Supervising Engineer - Operations QA

• J. V. Laux, Supervising Engineer - Technical Support QA

• J. R. Veatch, Supervising Engineer - Quality Systems QA W. R. Robinson, Supervisor - Compliance

• K. L. Wickes, Supervisor - Instrument and Control T. L. Shaw, Supervisor - Quality Control

• J. W. Knaup, Compliance Engineer

• W. A. Witt, Engineer, ISI

• A. Norton, Engineer, QA E. D. Andes, Engineer T. W. Stotlar, Engineer U. S. Nuclear Regulatory Commission

• H. Little, Senior Resident Inspector

• Denotes those attending the exit interview on June 7, 198 . Action on Previous Inspection Items (0 pen) Violation (483/84-44-01). Adequacy of procurement prccedure for level V commodities (commercial grade). The licensee has revised and reissued procedure WEP-ZZ-00001 (" Procurement Level V List Developnent, Control and Revision") as Revision 2 to provide for the identification of critical characteristics (i.e., important properties, attributes, or operability requirements for the item) and to indicate the basis for determining that commercial grade quality is acceptable for safety-related applications. This revision satisfactorily addresses the policy aspects of this item; however, it will remain open pending review of procedure implementatio . Program Areas Inspected Details of the program areas inspected are documented in Sections I and II of this repor '

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4. Unresolved Items Unresolved items are matters about which more information is required in order to ascertain whether they are acceptable items, violations, or deviations. An unresolved item disclosed during this inspection is discussed in Section II, Paragraph . Open Items Open items are matters which have been discussed with the licensee, which will be reviewed further by the inspector, and which involve some action on the part of the NRC or licensee or both. Open items disclosed during the inspection are discussed in Section I, Paragraph 1., 2., and Section II, Paragraph . Exit Interview The NRC inspectors met with licensee representatives (denoted in Paragraph 1) at the conclusion of the inspection on June 7,1985. The inspectors summarized the purpose, scope and findings of the inspectio The inspectors discussed the likely informational content of the inspection report. The licensee did not identify any of the proposed information as proprietar .

SECTION I Prepared By: R. N. Sutphin Quality Assurance / Quality Control (QA/QC) Administration Program The inspector reviewed the licensee's QA/QC administration program to verify that the program's scope and applicability had been defined, that controls for preparation, review, and approval of QA/QC procedures had been established, and that a mechanism for reviewing and evaluating the QA program had been establishe The scope and applicability of the QA/QC program had been defined by procedures that addressed classification of systems, componerts, and parts in accordance with commitments as outlined in Table 3.2-1 of the FSA The licensee had developed, released and implemented procedures to guide the preparation, revision, distribution, and control of quality assurance procedures, the quality assurance manual, project documents required for licensing, administrative procedures, plant operating procedures, and quality control procedures. The licensee had also developeo plans for the overall review and evaluation of the QA program including the use of outside consultants and contractors when appropriat Licensee personnel advised the inspector that new procedures and revisions to certain existing procedures are planned and include the following: Procedure QAP-ZZ-01830 is under development to address the preparation and control of quality assurance planning guides, Procedure WEP-ZZ-00011 is under development relative to the control of the parts Q-list data bas Procedure QE-343 will be revised to accommodate SNUPPS computer program requirement .

Pending review of the both new and revised procedures, this is considered an open item (483/85013-01). Audit Program and Implementation The inspector reviewed the licensee's audit program to verify that the activity was in conformance with regulatory requirements, commitments, and industry guides and standard Audit procedures, policies and schedules have been developed and imple-mented for the completion of the QA program audit requirements. Four groups in the site QA organization are conducting audits in their areas of responsibility: QA Operations, QA Operations Support, QA Technical Support and QA Quality Systems. Lead Auditors have been established for each group and schedules prepare .

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The inspector also verified (1) certifications of lead auditors who had conducted audits to date, (2) conformance to schedules, (3) contents of audit plans and checklists, (4) issuance of requests for corrective actions (RCA), and (5) processing of RCAs and their closecu During review of the audit activity the inspector had three observations: Revision 1 of Quality Assurance Department Administrative Procedure QAP-ZZ-01810 (" Quality Assurance Audits") contains several guideline statements permitting considerable flexibility and freedom for the auditors to vary from the audit plan, checklist and audit objectives during the course of the audit if in their judgement it is appropriat The inspector observed that this approach had the potential to thwart the overall audit program objectives and should be carefully monitored to minimize this potential affec The lead . ditor certification process included the use of a signature page to be igned by the certifying official which did not include any provision f ir the name of the person being certified. For record purposes the. inspector observed that either the form or approach should be modified to clearly provide the identity of the person being certifie With the exception of two minor details, the 1986 audit plan was identical to the 1985 audit plan. This results in a very predictable audit activity for 1986. The inspector observed that an effective audit function should not be completely predictable and suggested that the licensee review this aspect of their 1986 pla These three items are considered an open item for further NRC review (483/85013-02).

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SECTION II Prepared By T. E. Taylor Calibration and Surveillance Testing The licensee's calibration and surveillance program was reviewed to verify conformance with regulatory requirements and Callaway plant commitment The inspection consisted of direct observations of licensee activities, discussions with licensee personnel, and a review of procedures and record Documents Reviewed (1) Callaway Technical Specifications (2) Quality Assurance Manual (3) IDP-ZZ-00010, " Plant Instrument Out of Tolerance Notification,"

Revision 1 (4) APA-ZZ-340, " Surveillance Program Administration," Revision 5 (5) 00P-ZZ-04100, " Surveillance Requirement Tracking Procedure,"

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(6) APA-ZZ-00351, " Test Control Program," Revision 1 (7) Selected Surveillance Procedures (8) Selected Completed Surveillance Data Records Inspection Results The inspector reviewed the procedures and data records relative to the calibration and surveillance program and determined that they were adequate to meet the licensee's commitments. The inspector determined through observation of work and discussien with licensee personnel that the programs are being implemented in an adequate manne The licensee is in the process of implementing a computerized program for scheduling all technical specification and non-technical specification required calibration and surveillance activities for safety-related components. The inspector's review of the manner in which the licensee presently schedules the technical specification related component calibrations (i.e., instruments that require calibration for use in a surveillance procedure but are not a technical specification required calibration) indicated that the interim method being used may not ensure that all required calibrations are performed at the appropriate interval To schedule instrument calibrations, the licensee is presently using

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a combination of a manual schedule and the computerized schedul The manual schedule is a rolling window type which does not specify a calibration frequency, last date calibrated or calibration due dat Computer scheduling of all calibrations is tentatively scheduled for August 1985. This item is considered unresolved pending further NRC review (50-483/85013-03).

While reviewing calibration data records, the inspector noted Test Reports Nos. 22183 and 2182 on which auxiliary feed pump A and B discharge gauge Nos. AL-PI-0017 and AL-PI-0014 were documented as out-of-tolerance. The discharge gauges are used for obtaining data for surveillance procedure Nos. OSP-AL-P0001 A and B (Technical Specification, Paragraph 4.7.1.2.1). As required by the licensee's procedures, the appropriate departments were notified of the out-of-tolerance condition by way of a memorandum dated May 23, 1985. The individual assigned the task of performing the required evaluations received the memorandum with attached test reports on either May 28th or 29th. Although the evaluations had not been completed as of June 7,1985, recent test results indicated the pumps to be operable with no degradation since the last acceptable test. This item is considered open pending review of the licensee's evaluation of the indicated test report results (50-483/85013-04).

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