ML14176A688
| ML14176A688 | |
| Person / Time | |
|---|---|
| Site: | Robinson  |
| Issue date: | 10/30/1981 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML14176A689 | List: |
| References | |
| 50-261-81-25, NUDOCS 8111170478 | |
| Download: ML14176A688 (7) | |
See also: IR 05000261/1981025
Text
4
numbers for Part 21 evaluations, for writing a procedure for
Regulatory Compliance to use in evaluation and for changing
QAP 104 to delineate responsibility between Regulatory Compliance
and QA/QC.
Until these changes can be reviewed for adequacy, they
will be carried collectively as an open item (261/81-15-251).
d. Inadequate Reading List for QA/QC Personnel
The licensee uses required reading lists for qualificatic~n of"QA/QC
personnel.
The reading list currently being ised is lacking many of
the accepted regulations, guides, and standards with which personnel
should be familiar in order to be trained.
A prime example is the
reading of 10 CFR 50.59, in that QA/QC personnel are required to make
surveillance reports on changes conducted under 10 CFR 50.59.
The
licensee is in the process of completely updating all training being
given to QA/QC personnel and provided a target date of January 1, 1982
for having the revised reading list in use. Until the revised training
can
be
reviewed,
this item will
be carried as an open item
(261/81-15-25).
6. Design, Design Changes and Modifications (37700)
This functional are'a was reviewed by the Performance Appraisal Section team
inspection and is documented in IE Inspection Report, Management Appraisal
30-261/81-05
(PAS)
dated August 13,
1981..
The inspector reviewed the
results of this report and determined that this functional area is similar
to that normally inspected by
Region II,
consequently
no additional
inspection is required at this time.
Discussions with the NRC resident
inspector also identified that his inspection effort routinely includes
monitoring of selected design modifications in progress as documented in
monthly inspection reports.
7. Implementation, Audit Program (40704)
This functional area was reviewed by the Performan-a Appraisal Section team
inspection and is documentated in IE Inspection Report, Management Appraisal
50-261/81-05
(PAS)
dated August 13,
1981.
The inspector reviewed the
results of this report and determined that this functional area is similar
to that normally inspected by Region II
and no additional inspection is
required at this time.
8. Training (41700)
This functional area was reviewed by the Performance Appraisal Section team
inspection and is documentated in IE Inspection Report, Management Appraisal
50-261/81-05
(PAS)
dated August 13,
1981.
The inspector reviewed the
results of this report and determined that this functional area is similar
to that normally inspected by Region II
and no additional inspection is
required at this time.
PDR ADOC 0 8 0 0
5
9. Requalification Training (41701)
This functional area was reviewed by the Performance Appraisal Section team
inspection and is documentated in IE Inspection Report, Management Appraisal
50-261/81-05
(PAS)
dated August 13,
1981.
The inspector reviewed the
results of this report and determined that this functional area is similar
to that normally inspected by Region II
and only limited additional
inspection was performed.
The licensee's requalification program was reviewed for meeting the revised
grading criteria for annual requalification examinations.
Based on this
review one unresolved item was identified. As stated in NUREG 0737, the
NRC requires individuals to make greater than 70% in each section and
greater than 80% overall on their license examinations or retake the entire
examination. The licensee is not requiring an entirely new examination for
individuals making less than 80% overall. This problem will be carried as
an unresolved item (261/81-25-05) pending NRC management review.
10.
Procedures (42700)
References:
(a) Regulatory Guide
1.33, Quality Assurance Program
Requirements
(b) 10 CFR 50.59, Changes, Tests and Experiments
(c) GP3B, Reactor Trip Recovery, Revision 5, dated 6/81
(d) GP4, Power Operation, Revision 6, dated 8/81
(e) OP25,
Reactor Coolant System Operation, Revision 3.2,
dated 7/78
(f) OP40, Component Cooling System, Revision 2.4, dated 7/78
(g) OP14, Auxiliary Feedwater System, Revision 15 dated 8/81
(h) OP28,
Charging and Volume Control,
Revision 10,
dated
2/81
(i) OP42,
Safety
Injection
and
Containment
Spray,
Revision 17, dated 10/80
(j)
OP23,
Reactor Control and Protection Systems,
Revision
5.3, dated 7/78
(k) Al-20, Component Cooling Heat Exchanger A/B Outlet High,
Revision 7, 6/81
(1) A2-4, Accumulator Tank A Hi/Low Level, Revision 3, dated
4/81
(m) A3-8, Pressurizer Protection Hi Pressure, Revision 3,
dated 4/81
(n) B1-35, Reactor Coolant Pump's Hi Vibration, Revision 7,
dated 3/81
(o) C1-39, Condensate Storage Tank Level Hi/Lo, Revision 4,
dated 8/81
(p) A3-35, Volume Control Tank Hi/Lo Level
(q) E1-1,
Incident Involving Reactor Cooling Systems
Depressurization, Revision 28, dated 6/81
6
(r)
E1-7, Station Blackout, Revision 9, dated 6/81
(s) AP 1, Malfunction of Reactor Control System, Revision 3
dated 6/81
(t) AP 1.9, Malfunction of Reactor Coolant System Pressure
Control, Revision 1, dated 5/79
(u) MI 10-6, Repair Process for Disassembly, Inspection and
Reassembly of Reactor Coolant Pump,
Revision 26, dated
8/81
(v) MI 10-14,
Component Cooling
Heat
Exchanger
Tube
Plugging, Revision 19, dated 3/73
(w) MI 11-1,1, Reactor Coolant Temperature OPAT Protection,
Revision 1.10, dated 2/78
(x) MI 11-13, VCT Level, Revision 1.16, dated 2/78
(Y) MI 11-33,
Boron Injection Tank Level,
Revision 1.16,
dated 2/78
(z) MI 10-21,
Disassembly, Repair, and Reassembly of Steam
Driven Auxiliary Feed Pump, Revision 4, dated 5/79
(aa) Administrative Procedure 8.0,
Plant Records,
Revision
106, dated 7/81
(bb) Administrative Procedure 10.0,
Personnel Training and
Retraining, Revision 98, dated 3/81
(cc)
Technical Specifications Section 6
(dd) Administrative Instructions in their entirety
For References (c)-(bb),
the inspector verified that review and approval
were in accordance with Technical Specifications,
license changes were
reflected in the procedures,
temporary changes were properly approved and
did not conflict with Technical Specifications, changes were in conformance
with
10 CFR. 50.59 requirements,
technical
content. was adequate,
and
controlled copies were current as to revision.
Based on the above review and actual observation of procedure use, two open
items and one inspector followup item were identified.
a. Procedure for Control of Temporary Procedures and Changes
AI.5.3, Deviations From Established. Procedures Revision 98 dated 3/81
does not present any formal mechanism for keeping track of temporary
changes once they have been instituted and sent to the PNSC for review.
When a temporary change is made,
the operators :make a pen and ink
change directly on the working copy in order to maintain awareness of.
the change. This is an acceptable method but should be documented.:
The licensee provided a target date of October 31, 1981 for changing
their procedure to requ ire this documentation.
This change will be
reviewed in a subsequent inspection and will be carried as an open item
(261/81-25-06).
0s
7
b. Quorum for PNSC Review
Technical Specification 6.5.1.6 requires that for a quorum the
Chairman/Vice Chairman plus three additional members must be present.
AI 3.4, Quorum,
Revision ;86,
dated 12/80 states that for special
meetings (as opposed to monthly meetings) a member may be considered
present if he is in telephone communication. The NRC position is that
telephone communication may be us'ed only when there is an emergency
condition or no reasonable way of convening all needed persons for a
special condition. Th.e inspector reviewed the special meetings for a
two-year period and determined that the licensee was following the NRC
position, but the procedure was not requiring that adherence.
Until
the licensee changes the procedure to require adherence to
NRC
position, this item will be carried as an open item (261/81-25-07).
c. Conflict in Technical Specification 6.2
Technical Specification Figure 6.2-2 requires the Senior Control
Operator to hold an SRO license. The words in Technical Specification 6.2 only requires the Shift Foreman to hold an SRO and the Senior
Control
Operator to hold an
RO license.
This conflict will be
clarified, as part of a change to the operating organization submitted
in a Technical Specification change to NRR for approval.
Until this
change is approved, this item will be carried as an inspector followup
item (261/81-25-08).
11.
Personnel Qualification Program (30701)
References:
(a) Technical Specification Section 6
(b) ANSI 18.1,
1971, Selaction and Training of Nuclear Power
Plant Personnel
The inspector reviewed the administrative controls for every position at the
site against the licensee'; cowmitments in references (a) and (b).
Also
using references (a) and (b),
the inspector reviewed the background and
qualifications for every manager, supervisor, foreman, director and operator
on site as well as a sample of five workers from each technician, QA/QC,
specialist, and craftsmen area.
Based on this review one inspector folloVup item was identified.
The
inspector noted that the site QA/QC Director and two QA/QC specialists had
transferred into operations QA from construction QA with no formal training
in the regulatory guides, standards, or audit/surveillance techniques they
would encounter.
The licensee identified a similar item in audit QAA
125-10. Until the NRC can evaluate the response to the corporate QA
findings, this item will
be tracked as
an inspector followup item
(261/81-15-25).
8
12.
Offsite Support Staff (40703)
References:
(a) Technical Specifications-Section 6
(b) ANSI 18.1-1976, Selection and Training of Nuclear Power
Plant Personnel
(c) 10 CFR 50,
Appendix B, Quality Assurance Criteria for
Nuclear Power plants
(d) Licensee Letter OQA-81-026, dated 3/18/81
(e) ANSI
18.7-1976,
Administrative Controls
and Quality
Assurance for the Operational Phase of Nuclear Power
Plants
The inspector reviewed the following position descriptions to verify that
they describe the responsibilities, authority and lines of communication
which meet the requirements of References (a)-(e)
and the Corporate QA
Program Manual: Manager-Corporate Quality Assurance; Principle Specialist,
Performance Evaluation; Manager-Operations QA/QC; Senior Specialist, QA/QC;
Director,
QA/QC Operating Plants; Manager,
Engineering Support Nuclear
Plants; Principle Engineer,
Mechanical; Principle Engineer, Electrical;
Project Engineer. The inspector interviewed six of the individuals listed
above and reviewed the background and qualifications of all individuals
holding the above positions.
The inspector reviewed the results of audits performed by the corporate
group and observed an audit being performed at the site. The inspector and
audit team found many deficiencies in the area of corrective action systems.
These items were identified by the PAS inspection in IE Report 50-261/81-05
(PAS) dated August 13, 1981.
Based on this review and the interviews conducted
, one open item was
identified.
As part of the qualification for Lead Auditors in the
Performance Evaluation Section, individuals are required to complete a
reading file which contains the regulatory requirements and commitments of
the licensee. An individual must complete this reading file prior to being
considered for Lead Auditor but is never directly questioned as to content.
The Auditors interviewed by the inspector appeared knowledgeable as to the
contents of regulatory and licensee requirements, but no direct method has
been established to insure transfer of knowledge. In addition, the required
reading file is not part of an approved procedure.
Until the licensee
establishes a formal method for determination of knowledge transfer and the
reading file becomes part of an approved procedure, this item will remain
open (261/81-25-10).
13.
Maintenance (62700)
This functional area was reviewed by the Performance Appraisal Section team
inspection and is documentated in IE Inspection Report, Management Appraisal
50-261/81-05
(PAS)
dated August 13,
1981.
The inspector reviewed the
results of this report and determined that this functional area is similar
- .
9
9
to that normally inspected by Region II
and no additional inspection is
required at this time.
Discussions with the NRC resident also identified
that their inspection effort routinely includes monitoring of maintenance in
progress as documented in monthly inspection reports.
14.
Maintenance Program (62702)
This functional area was reviewed by the Performance Appraisal Section team
inspection and is documentated in IE Inspection Report, Management Appraisal
50-261/81-05
(PAS)
dated August 13,
1981.
The inspector reviewed the
results of this report and determined that this functional area is similar
to that normally inspected by Region II and no additional inspection is
required at this time.
15.
Nonroutine Reporting Program (90714)
Reference:
TI 303,
Dissemination of Information/Feedback of Operating
Experience, Revision 3, dated 2/81
The inspector reviewed the licensee's program to ascertain whether responsi
bilities had been assigned for review and evaluation of off-normal operating
events, planned and unplanned maintenance activities, surveillance testing
and outage activities to assure conformance with regulatory requirements.
The inspector also reviewed the program to ascertain whether vendor
bulletins and circulars are reviewed for applicability. At this time there
are no formal procedures for review and evaluation of vendor items, but the
licensee follows an informal procedure whereby items are distributed through
responsible managers
and supervisors to an engineer who is a.ssigned
responsibility. In addition, all items are reviewed by PNSC for safety
significance.
The licensee is presently evaluating the need for formal
procedures.
Based on this review,
one open item was identified.
The licensee has
recently undergone a site and corporate reorganization.
There are now three
organizations on site (there used to be only one)
who are responsible for
review and evaluation of off-normal events for safety significance.
The
Regulatory Compliance group and the Onsite Nuclear Safety group are still in
the process of developing procedures to implement their chartered functions.
The third group, the Site QA/QC Organization, has changed its reportability
to Corporate Headquarters and has given some of its functions to the other
two groups.
At the present time, there is no formal method for the licensee
to transfer between sites internal findings, such as CQA audits and NCRs,
which may be generic.
Two of these organizations, Onsite Nuclear Safety and
QA/QC,
report directly to Corporate Headquarters.
Once the new organiza
tions are completely in place with operating procedures, transfer of generic
findings through a corporate focal point will probably take place. Until
the organizations can function as chartered and the NRC can review the new
operation for transfer of internal findings, this item will remain open
(261/81-25-11).
10
16.
Licensee Action on Previously Identified Inspector Items (92701)
a. (Open) Open Item (261/79-19-09):
Calibration Program for Safety
Related Instruments. The inspector reviewed the program the licensee
is developing for calibration of nontechnical specification safety
related instrumentation. This item was originally identified by the
licensee's Corporate QA Department in Surveillance Report OQAI 79-25
.with a scheduled completion date of January 1, 1980.
The item was
reviewed in three subsequent inspections (261/80-06, 22, 25) but had
not been completed. The program has progressed close to completion and
the licensee stated they will attempt to finish by January 1, 1982.
The licensee will be requested to specifically reply to this item in
the inspection report transmittal letter.
b.
(Open) Inspector Followup Item (261/79-19-19): Warehousing. This item
was reviewed in two previous inspections (261/80-06,
25) and most of
the areas were completed. In this inspection the final two areas of
concern were reviewed. SR-3, Storing Plant Material and Equipment,
Revision 2, dated 4/81, Section 4.2 addresses protection of parts and
materials
and
meets the ANSI N45.2.2 requirement for Section 3.
MP-1-5A, Overhead and Gantry Crane, Revision 0, dated 7/81 and TI 106,
Crane and Forklift Qualification, Revision 2, dated 9/81 meet the
procedure requirements of ANSI N45.2.2, Section 7. The only require
ment remaining is to perform the training.
The licensee is considering
a vendor group to perform this training by December 31, 1981. Due to
the extended time for completion, this item will be addressed in the
inspection report cover letter requesting a commitment for completion.