ML18139A719
| ML18139A719 | |
| Person / Time | |
|---|---|
| Site: | Surry  |
| Issue date: | 07/03/1980 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML18139A716 | List: |
| References | |
| 50-280-80-10, 50-281-80-11, NUDOCS 8009050436 | |
| Download: ML18139A719 (5) | |
Text
APPENDIX A NOTICE OF VIOLATION Virginia Electric and Power Company Surry Units 1 and 2 License Nos. DPR-32
& DPR-37 Based on the NRC inspection May 5-9, 12-16, and 20-23, 1980, certain of your activities were apparently not conducted in full compliance with NRC requirements as indicated below. These items have been categorized as described in correspond-ence to you dated December 31, 1974.
A.
As required by Technical Specification 6.4, procedures shall be written and followed.
B.
Contrary to the above, procedures were not followed in that:
(1)
Sections 4.2.12 and 4.2.16 of' Final Design Controlling Procedure DC-79-522 collectively required cable 1VB45 conductor MS 110C4 and cable 1VB43 conductor MS 110C4 to both be connected to terminal 8 of terminal Board 6J.
The inspector observed both cables to be connected to terminal 9 as of May 8, 1980.
(2)
Administrative Procedure 29, Section 29.8.3 requires all shift personnel to read a required reading file within a period specified on each item and to initial a required reading cover sheet. It was identified that these requirements were routinely missed from August 1979 through February 1980.
(3)
Administrative Procedure 37, Section 37.1.2 requires that supervisor shall assure that their controlled drawings are updated to reflect the latest revision received.
The inspection found two drawings in two locations where the wrong revision and approximately twenty-four drawings in two locations could not be located as of May 16, 1980.
(4)
Administrative Procedure 29, Section 29.1.6 requires that each signifi-cant event shall be logged. On May 11, 1980, the steam driven auxiliary feedwater pump was removed from operation and not logged.
This is an infraction.
As required by 10 CFR 50, Appendix B, Criterion XVI Measures shall be estab-lished to assure conditions adverse to quality are corrected and reported to appropriate levels of managment.
The Topical Quality Assurance Program (TQAP) Section 17.2.16 states that corrective action measures are established and through these measures, assurances confirmed that significant adverse quality conditions are identified, documented, their cause determined and corrective actions have been taken.
s 009 o 5 of3G,t
. Virginia Electric and Power Company Surry, Units 1 and 2 Appendix A Notice of Violation Contrary to the ab6ve, measures were not identified, corrected or reported to appropriate levels of management in that:
(1)
The SyNSOC-1979 audit approved March 20, 1980 Part C, Item 5, identified no formal program existed for analyzing trends; it was not called a finding nor was any corrective action taken as of May 20, 1980.
(2)
Administrative Procedure 51, Section 51.3.2 and 51.3.3 requires each supervisor who maintains an unused procedure depository to establish procedures that ensure only current procedures are in the depository and that adequate supplies of unused procedures are on hand.
QA audit S-79-27 conducted on March 12, 1980 identified the lack of procedures but concluded that due to a low error rate the existing "system" was working.
Consequently, this is not an open item, no corrective action was taken as of May 20, 1980.
(3)
Four audits were inspected:
S-79-17, conducted September 25, 1979; S-79-2 conducted April 4, 1979; S-79-4, conducted August 29, 1979; S-79-6, conducted June 6, 1979,, and it was ascertained by direct questioning of QA personnel during May 16-20, 1980, that appropriate levels of management were not informed of the corrective actions as of May 20, 1980.
This is an infraction.
C.
As required by 10 CFR 50, Appendix B, Criterion VI measures shall be estab-lished to control the issuance of documents which prescribe all activities affecting quality.
The TQAP Section 17.2.6 states that Section 6 of the NPSQAM list and defines certain documents that require stri.ct administrative controls.
The NPSQAM Section 10 paragraph 4.2 and Section 16 paragraph 6.5.4.b.(6) both make reference to the use of technical manuals by personnel or as reference material.
Contrary to the above, as of May 20, 1980, measures have not been estab-lished for the control of vendor technical manuals used in the performance of maintenance on safety related systems. No reference is made in the NPSQAM, Section 6, list of controlled documents to vendor technical manuals; however, procedures CAL-SW-039, Channel F-SW-106D return from recirculation spray heat exchanger HXlD and IMP-C-Nl-17 Replacing the Intermediate Range Nuclear In-strumentation Detector both make references to steps to follow in the vendor technical manuals.
This is an infraction.
D.
As required by 10 CFR 50.59 changes can be made in the facility without prior Commission approval unless the proposed change involves an unreviewed safety question.
A written safety evaluation is also required which provides th~
bases for the determination that the change does not involve an unreviewed safety question.
Virginia Electric and Power Company Surry, Units 1 and 2 Appendix A Notice of Violation Contrary to the above, jumpers were installed in limit switch compartments of the Containment Spray discharge valves MOV-CS-lOlA and 101Bl in July 2, 1978, without a safety evaluation being performed/documented as of May 20, 1980.
This is an infraction. applicable to Unit 1.
E.
As required by Technical Specification 6.1.c.2.b the minimum qualification for membership to SyNSOC will be an engineering graduate or equivalent with combined nuclear and/or conventional experience in power station design and/or operation of eight years.
Contrary to the above, two members were appointed as alternates to the SyNSOC without the required eight years experience in nuclear and/or con-ventional power station design and/or operation. Both had previous military experience in nuclear weapons; one had experience from May 1972 to July 1979 and the other had experience from June 1975 to May 1979. This nuclear weapons
~xperience was not equal to experience in nuclear power station design and/or qperation.
This is an infraction.
F.
As required by Technical Specification 6.1.c.2.h.4(a) the SyNSOC is respon-sible to review violations of applicable codes and regulations.
G.
Contrary to the above, as of May 20, 1980, the SyNSOC does not regularly review all 0 IE reports containing items of noncompliance.
Individual mem-bers may review the reports due to normal distribution; however, the formal review of IE reports by all members, meeting as a body, of the SyNSOC was discontinued in May 1979.
This is an infraction.
As required by 10 CFR SO, Appendix B, Criterion X, a program for inspection of activities affecting quality shall be established.
The TQAP Section 17.2.10 states that inspection procedures for those activities affecting quality have been established and are included in the NPSQAM.
The NPSQAM
- Section 10, Paragraph 5.1 requires that inspections of materials and compon-ents shall be performed for each work operation where necessary to assure quality.
Contrary to the above, as of May 9, 1980, the required inspection of.wiring on Design Change.79-S22 did not verify the correct termination of conductors in cables IVB45 and 1VB43 in that these conductors were terminated on terminal 9 when they were required by the design change to be terminated on terminal 8.
The inspection was inadequate because the QC inspector had signified on the hold point check that these leads had been correctly terminated.
This is an infraction*applicable to Unit 1.
Virginia Electric and Power Company Surry, Units 1 and 2 Appendix A Notice of Violation H.
As required by 10 CFR 50, Appendix B, Criterion V, activities affecting quality shall be prescribed by documented instruction and procedures and shall be accomplished in accordance with these instructions and procedures.
The licensee's TQAP, section 17.2.5, states that activities affecting quality within the scope of the 10 CFR 50 Appendix.
These activities are accomplished in accordance with these instructions and procedures.
I.
The licensee's Nuclear Power Station Quality Assurance Manual Section 8.5.1, requires, in part, that storeroom personnel, at the time of the receipt in-spection, attach a tag to the item recording Quality Category (QC). Quality Assurance personnel are required to verify the information recorded on the tag.
Contrary to the above, activities affecting in accordance with prescribed procedures in the incorrect QC recorded on attached tags.
when the item was actually QC II:
quality were not accomplished that the following items had Each item was marked as QC I Deflector, discharge inboard manufactured by Bingham-Williamette Co.,
P/N 8320-A-33740, stock number 2938825.
Deflector, discharge inboard manufactured by Bingham-Williamette Co.,
P/N 8320-A-38434, stock number 2938826.
Deflector, discharge outboard manufactured by Bingham-Williamette Co.,
P/N 8320-A-33741, stock number 2938827.
Control unit, diode section manufactured by C&D Batteries, stock number 0715358.
Control unit, regulator section manufactured by C&D Batteries, stock number 071535 7.
Due to the unique function of the above components and the low probability of their use in a safety related system, a lower level of severity is assigned.
This is a deficiency.
As required by 10 CFR Appendix B Criterion III measures shall be established for the identification and control of design interfaces.
The TQAP Section 17.2.3 states that general procedures have been established to describe the design interface and that these procedures are being consolidated in the Nuclear Engineering Services Project Manual. ANSI N45.2.ll-1974 as committed to by the TQAP, Sections 5.1.1-5.1.4 state the requirements for External Interface Control.
Contrary to the above, measures were not established for the identification and control of design interfaces in that collectively sections 2.3, 2.6, 8.1, and 8.3 of the Engineering Services Project Manual do not address all the requirements of ANSI-45.2.11-1974, Sections 5.1.1-5.1.4 as committed to
Virginia Electric and Power Company Surry, Units 1 and 2 Appendix A Notice of Violation by the accepted QA Program as of May 20, 1980.
Since no problems with the control of these interfaces were found and o_nly documentation was lacking, a lower level of severity is assigned.
This is a deficiency.
J.
As required by 10 CFR 50, Appendix B, Criterion II, the licensee shall establish a program which complies with Appendix B.
This program is described by the licensee in VEP-1-3A, "Quality Assurance Program - Oper-ations Phase" (TQAP).
Section 17. 2. 0. 2 of the TQAP states that records will be controlled as required by ANSI N45.2.9-1974.
Section 5.6 of ANSI N45.2.9 requires either a storage vault or separate dual storage facility.
Section 5.3 of the standard requires that all storage locations be identified and controlled.
Section 17.2.7 of the TQAP requires that a copy of the purchase requisition and other pertinent documentation become a part of the station records.
Contrary to the above, the licensee's QA program for the control of records had not been established as necessary in that:
QA training, qualification and certification records, and purchase requistions and repeating purchasing
~equisition cards were not stored in either a vault or separate, remote, dual storage facilities.
Since all records were available for inspection and only the storage of these records were improper, a lower level of severity is assigned.
This is a deficiency.
K.
As requiretl by 10 CFR 50 Criterion XVIII audits shall be carried out to verify compliance with all aspects of the quality assurance program.
The TQAP Section 17.2.18 states that provisions are established requiring that audits be performed in those areas where the requirements of Appendix B to 10 CFR 50 are being implemented.
The VEPCO Quality Assurance Manual Section 4.0 states the audit requirements for Quality Assurance - Engineering.
Contrary to the above, VEPCO QA Manual, Section 4 does not address audits at the corporate offices in the areas of procurement, records or document control.
Since a major portion of activities in each of these areas are cond~cted and audited on site, a lower level of severity has been assigned.
This is a deficiency.