ML19225C660
| ML19225C660 | |
| Person / Time | |
|---|---|
| Site: | Crystal River  |
| Issue date: | 05/18/1979 |
| From: | Kellogg P, Mcdonald J, Ruhlman W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19225C658 | List: |
| References | |
| 50-302-79-04, 50-302-79-4, NUDOCS 7908010650 | |
| Download: ML19225C660 (29) | |
See also: IR 05000302/1979004
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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Report No.
50-302/79-04
Florida Power Corporation
Licensee:
3201 34th Street, South
St. Petersburg, Florida 33733
Facility Name:
Crystal River 3
Docket No.
50-302
License No.
Inspection at Crystal River Unit 3 near Crystal River, Florida
f/ / 79
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277 2
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Date sig ed
Inspectors:
kW 77
A. Mc nald, J
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Date Si'gne'd
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Date Signed
W. A. Ruhlman
Accompanying Personnel:
D. Quick (Exit Interview Only)
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e (Exit Interview Only)
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Approved by:
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Date Signed'
nief, RONSB
P.
Inspection on February 12-16, 1979
Areas Inspected
announced inspection involved 105 inspector-hours on-site in
of QA program-periodic review; QA audits; procarement, design
This routine,
changes / modifications; records and document control; receipt, storage a
the areas
handling of equipment and materials; training for compliance engineers,
mechanics and electricians.
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Results
Of the seven areas inspected, no apparent items of noncompliance or deviations
were identified in one area; eight apparent items of noncompliance were found in
six areas (infraction-failure to apply required program controls on supplies-
Paragraph 7.b; infraction-failure to maintain records that provide the bases
for determining that a change did or did not involve an unreviewed safety
question-Paragraph 8.b;
infraction-failure
t,
follow procedures, four
examples-Paragraph 8.c,
8.d,
8.e;
infractia--failure to distribute /use
documents-Paragraph 8.g;
infraction-failure
to
maintain
records
as
required-Paragraphs
8,f, 9.b and 10.e; infraction-failure to establish /
implement storage and handling controls-Paragraph 10.c; infraction-failure
to certify inspec'. ion personnel-Paragraph 10.d; deficiency-lack of evaluation
statement in QA audit reports-Paragraph 6.e).
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DETAILS
1.
Persons Contacted
Licensee Employees
- G. Beatty, Plant Manager
- J. Clapp, Manager-Quality Program Audits
- J. Colby, Production Engineer-Mechanical Engineer
- J. Cooper, Nuclear Compliance Engineer
- Q. DuBois, Directcr-Quality Programs
- E. Froats, Manager-Quality and Reliability Engineering
- P. McKee, Technical Services Superintendent
- V. Nichols, Operations Superintendent
- W. Nisula, Purchasing Agent
- R. Roget , Stores Supervisor
- D. Shook, Manager-Nuclear Engineering
K. Vogel, Assistant Operations Supervisor
- G. Westafer, Maintenance Superintendent
- G. Williams, Nuclear Compliance Plant Engineer
Other licensee ar
yees contacted during this i.upection included
compliance enginerr, technicians, operators, power stores, quality
assurance, training and office personnel.
- Attended exit interview.
2.
Exit Interview
The inspection scope and findings were sunnarized on February 16, 1979,
with those persons indicated in Paragraph I ebeve.
The inspectors informed the licensee that the items which required
attention (iden* ified in Paragraphs 5.c, 6.d, 8.i, 8.j , 9.c,
management
a later
10.h, 10.i, 10.j, and 11) would be inspected at
10.g,
10.f,
In addition, the inspector follow items (Paragraphs 5.d and P.k)
date.
would be inspected to ensure implementation. The licensee acknowledged
the inspector's statements.
3.
Licensee Action on Previous Inspection Findings
(Closed) Inf raction (302/78-25 01). Failure to provide a training program
for non-licensed operators in a. cordance with Technical Specification 6.4.1.
The licensee program hao been implemented as stated in his
response to the item contained ia his letter (3-0-3-a-2, CS-78-243)
dated November 30, 1978. This ites is tit. sed.
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4.
Unresolved Items
Unresolved items are matters about which more information is required to
or may involve noncompliance or
determine whether they are acceptable
New unresolved items identified during this inspection are
deviations.
discussed in Paragraphs 5.b ani 8.h.
5.
QA Program-Periodic Review
References:
a)
Crystal River 3 Safety Listing, issued 1/77
Safety-Related Engineering Procedure No. 1, Safety
b)
Identification and Design Input Requirements, Revised
3/78
c)
QAP-2, Preparation and Control of Administrative
Procedures, Revision 2, dated 11/77
Inspection Items
a.
The changes made to the licensee's QA procedures during the period
(March 1978 through January 1979) were reviewed with respect to
The
accepted QA Program.
implementation of the
maintaining the
"Q" list was reviewed for consistency with the
licensee's current
In
used in the safety-related operations of the facility.
addition, selected personnel were interviewed during the conduct of
items
documented in this report to
other areas of the inspection as
assure that changes in procedures were understood and available for
The accepted QA Program was changed during the period since
the last inspection of this area, so that aspect of revision control
use.
changes reviewed are those listed
specific
inspected.
The
and those noted in the other areas of the
was
under references above
inspection documented in this report.
In addition, the Program documents were reviewed to ascertain that
had been established for making
precedures and responsibilities
A review was also conducted to verify
changes to such listings.
methods were established to issue / revise / control QA/QC proce-
dures, to periodically evaluate the effectiveness of the QA/QC
that
program and provide emphasis where needed in problem areas, and
provide management with an evaluation of the overall eftectiveness
of the QA program.
and one
identified one unresolved itee, une item,
The inspector
item which are documented in Paregraphs 5.b, 5.c
inspector follow
and 5.d, respectively.
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b.
Safety-Related Consumable / Expendable Items
The licensee's listing of safety-related structures, systems and
include consumable / expendable
components (reference a), did not
items that accomplish safety-related functions.
The inspector noted examples including chemical additives used to
establish LCO chemistry conditions; chemical reagents used to
verify LCO chemistry conditions; fuel oil used by the diesel gener-
ators; lubricants used in safety-related pumps; and snubber fluid.
Until the licensee completes a review of consumable /erpendable
items that affect the functioning of safety-related structures,
systems and components; determines what portion (s) of his estab-
lished QA program will be applied, and establishes these QA measures,
this unresolved item is designated (302/79-04-01).
QAP Revision Control
c.
The licensee's procedures QAP-2, QAP-4, and QAP-14 collectively do
not establish measures to assure that revisions to Quality Admini-
distributed and entered in the required
strative Procedures
are
One change transmittal record dated October 1977 was
locations. Seven (7) of fifty (50) manual holders had not responded
reviewed.
their manuals had been updated and no action had
to indicate that
been taken to assure that the ren sions had actually been entered.
indicated to be
Two (2) of the seven (7) manuals which were not
updated by the change transmittal were reviewed and found to actually
be updated.
Until the licensee revises his procedures to establish seasures to
assure that revisions to Quality Administrative Procedures are
distributed to and entered in the controlled manuals this item is
designated (302/79-04-02). The licensee g
i a completion date of
April 1,1979, for this item.
d.
Revision to CR3 Safety Listing
The licensee's listing of safety-related structures, components and
Review and approval
systems is currently undergoing major revision.is governed by Section
(including QA audit) of the revised document
5.2 of reference c).
Until the major revision to the CR3 Safety Listing is complete,
this inspector follow item is designated (302/79-04-03).
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6.
QA Audits
Quality Program Policy 18.1, Quality Program Audits
References:
a)
and Evaluation, Revision 3, dated 6/77
Quality Procedure 18.50, Quality Audits, Reviews and
b)
Evaluations for Operations Phase, Revision 3, dated
7/77
c)
Quality Administrative Procedure 8, Quality Program
Audits, Revision 1, dated 7/77
a.
Program Review
The referenced documents were reviewed with respect to the licensee's
and ANSI N45.2.12, Draf t 4,
accepted Quality Assurance Program
The inspection
Revision 2,1976, as coccitted to by that Program.
was to verify that an audit program had been established which was
consister uith Technical Specification and QA Program requirements.
The inspector also reviewed the program to verify that responsibility
audit
had been assigned and provisions were made to assure that
personnel were properly qualified; special training / expertise was
provided when necessary; audit personnel were independent of direct
responsibility for the areas audited; corrective actions were taken
for inadequacies identified during audits; re-audits were specified
and conducted as necessary; audit reports and records of completed
corrective actions were issued to appropriate levels of management;
periodic reviews were made to determine status and adequacy; and,
The controls
that long-range audit plans / schedules were available.
governing audit conduct and reporting were reviewed to assure that
requirements existed and methods were established to assure that
conducted in accordance with written checklists /proce-
audits were
the audited organization is required to respond in writing
dures;
to all identified iaadequacies; responses are evaluated for adequacy
conflicts between
and timeliness of scheduled correc+ive actions;
the audited and auditing organizations are resolved; and, distribution
requirements are established.
In any case, where the in-of fice review indicated inadequate coverage,
was further investigated during the implementation phase
the area
The final conclusion with respect to seceptability
of the inspection.
of this area is given in Paragraph 6.b below,
b.
Implementation
The licensee s audit / surveillance program was reviewed at the
corporate offices in St. Petersburg, Florida and at the Crystal
to the requirements o'f ' he ref erenced
River Station with respect
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documents.
The inspector reviewed the audit schedule to verify
that scope and frequency were consistent with requirements and with
accomplishment of the audits. Fineteen (19) completed audits were
selected and reviewed to assure that checklists / procedures were
used by independent, qualified personnel during their performance
and that identified inadequacies were responded to by the audited
organization, evaluated for udequacy by the auditing organization
and that items were either corrected or being tracked using written
reports and responses distributed to and reviewed by appropriate
personnel. The auditt reviewed were:
QP 143
Inservice Inspection to ASME Sect .on XI
.
QP 144
Nonconformance and Corrective Action Controls
.
.
QP 145
Fire Protection
.
QP 146
Audits (Departments other than QPD)
QP 146.1
Audits (Departments other than QPD)
.
QP 147
Emergency Planning
.
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QP 148
Security
QP 149
Inspection Test and Operating Status
QP 150
Administrative Controls
.
QP 151
Quality Assurance Organization
.
QP 152
Test Control
.
QP 153
NGRC Independent Review Activities
.
QP 154
Nonconformance and Corrective Action Controls
.
QP 155
Conformance to Technical Specifications and Applicable
.
License Condition
QP 156
Plant Personnel Training and Qualification
.
QP 157
Environmental Technical Specifications
.
QP 158
Reportiag Requirements
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QP 160
Housekeeping
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Nonconformance and corrective Action Controls
.
QP 162
One item of noncompliance and one item requiring management attention
was identified as discussed in Paragraphs 6.c and 6.d, below.
Failure to Provide Evaluation Statement
c.
4, Revision 2 of ANSI N45.2.12 was given in the accepted QA
Draft
Section 1.7.6.7.1.s as the document controlling the acti-
Paragraph 4.4.4 of that standard
program,
vities of the FPC audit program.
states, "...a summary of audit results, including an evaluation
statement regarding the effectiveness of the quality assurance
program elements which were audited".
In reviewing the licensee's audit reports, the inspector noted that
no evaluation statement regarding the effectiveness of the quality
assurance prcgram elements had been provided for any of the audits
The lack of an evaluation statement constitutes an item
reviewed.
of noncompliance (302/79-04-04) .
d.
Audit Checklists
During the review of completed audits , the inspector compared
checklists to the standards referenced in FSAR
selected auditThis review indicated the checklist would not verify
Chapter 1.7.
the implementation of all the requirements of the standards.
The licensee acknowledged this finding and indicated the checklists
would be reviewed with respect to requirement of the standards
prior to their next utilization.
This item (302/79-04-05) will be reviewed during a subsequent
inspection.
Audit Finding Corrective Action
e.
It was noted during the review of audit reports that several findings
reply from
had apparently passed the required response dste without
the audited organization.
Further review indicated the licensee
had identified this area and had taken action to ensure more timely
Liter audit findings were
response f rom the audited organization.
being responded to in a timely manner and a tracking system had
been establist ed to follow responses.
Based on this apparently adequate action, the inspector had no
further question in this area.
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7.
Procurement
References
a)
Quality Program Policy 4.1, Control of Procurement
Documents, Revision 2, dated 6/77
b)
Quality Program Procedurc 4.50, Procurement Control
for Spare Parts, Materials and Services for Operations
Phase, Re"ision 4, dated 10/78
c)
Quality Program Procedure 7.50, Source Evaluation
and Selection-Spare Farts, Supplies and Services ,
Revision 4, dated 10/77
d)
Quality Prograr "rocedure 7.51, Source Surveillance
Inspection-SN re Parts, Supplies and "ervices,
Revision 2, dated 7/77
a.
Inspection Items
The inspector reviewed the procurement area to verify that the
procurement specifications used in the purchase of components and
material from selected systems included proper approval, quality
control inspection requirements and quality record requirements.
The specific items selected were:
(1) Law Pump, purchase order 109962Q, item 5
(2) Boston Wire, pur-base order A32748Q, item 1
(3) Walworth Valve, purchase order 130982Q, item 1
(4) Fischer Control, purchase order 122888Q, item 1
(5) Farr Filters, purchase order PR3-128888Q, item 2
(6) International Gasket, purchase order 130977Q, items 1,2,3
(7)
ITT Grinnell, purchase order number 125410Q, item 1
(8) Boston Wire, purchase order A37878Q
(9) Lawrence Pump, purchase order PR3-6312Q
(10) Crane Valve, purchase order 740-2541Q
(11) Welding Wire, purchase order 740-4610Q
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(12) Valve Parts, purchase order 740-9178Q
(13) Diesel Spares, purchase order 740-9179Q
For the items selected, the inspector verified that documentary
evidence was available on-site to support their conformance to
In reviewing activities to assure that
procurement requirements.
these items were inspected upon delivery and that they were handled
in accordance with established controls in addition to being supplied
approved vendor, the inspector reviewed the warehouse and
by an
related activities.
As a result of this review, the inspector identified one item of
noncompliance (Paragraph 7.b below) concerning quality program
Additional items of noncompliance
requirements for documentation.
related to handling and storage controls are documented in Paragraphs
10.c ,10.d and 10.e.
Failure to Establish Documentation Control with Suppliers
b.
Sedion
ANSI N45.2.13-1976 was given in the accepted QA Program,
1.7.6.7.1.s as the document controlling the activities of procurement.
Paragraph 11 of that Standard requires the purchaser establish with the
suppliers controls which provide for the retention by the supplier of
quality assurance records of compliance.
Additionally, Section 8 of the Standard requires the purchaser to
establish with the supplier doce eent measures for the identification
controls and disposition of items and services that do not meet pro-
curement document requirements.
documents,
In reviewing thirteen (13) of the licensee's procut. ment
the inspector noted that in all cases but one (P.R. 740-2541Q), the
controls required by the Stacdards as referenced above were not
incorporated in procurement documents. This lack of program controls
constitutes an item of noncompliance (302/79-04-06) with respect to
10 CFR 50, Appendix B, Criterion IV.
The inspector identified during the review of Purchase Orders three
from Production Engineering and two
methods for initiation; one
methods irom the plant.
In all of these setnods, the checklists
utilized to ensure quality documentation requirements were deficient
with respect to the program controls described above.
8.
Design Changes / Modification
Modifi-
References:
a)
CP-114, Procedure for Control of Permanent
cations, Temporary Modifications, 'and Deviations,
Revision 16, dated 12/78
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Safety-Related Engineering Procedure (SREP) No. 1,
b)
Safety Identification and Design Input Requirements:
Revised 3/78
SREP No. 2, Design Development, Revised 3/78
c)
SREP No. 3, Interrace Design Control, Revised 3/78
d)
SREP No. 4, Design Verification, Revised 3/78
e)
f)
SREP No. 5, Document Approval anc Controls, Revised
3/78
g)
SREP No. 6, Design Control to Modification Approval
Record (MAR), Revised 3/78
b)
SREP No. 7, Design Auditing, Revised 3/78
i)
SREP No. 8, Corrective Action, Revised 3/78
j)
SREP No. 9, Control of Records Retention, Revised
3/78
Letter from Gilbert Associates to FPC, FC-569, dated
k)
2/21/79
1)
Letter f rom Babcock and Wilcox to FPC , CR-79-33,
dated 2/23/79
Inspection Items
a.
The referenced documents were reviewed with respect to the require-
the
ments of 10 CFR 50.59, applicable Technical Specifications,
licensee's accepted Quality Assurance Program and ANSI N45.2.11-1974,
The inspection was to verify that
as comitted to by that Program.
had been established for design changes / modifications
procedures
which defined the methods for initiation, documentation of the
required reviews and evaluations, and methods for assuring that the
proposed change did or did not involve sn unreviewed saf.ty question.
reviewed to
The licensee's current practices and procedures were
assure that responsibilities had been defined for performing design
identifying, reviewing and
saf ety evaluations,
work, conducting
requirements, controlling and documenting
approving design input
design interfaces and design interface coceunic at ions , final
approval of design documentr, and, proper review of all changes
made to design documents.
Controls were reviewed to assure that
the following elements were included: definition of comunications
channels between design organizations; completion and documentation
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of required Technical Specification reviews; requirements for
performance of post modification testing; requirements and proce-
dures to assure that proper reports were made to the NRC, that
appropriate drawings, procedures and training programs were updated;
and, requirements for review of completed modification and post
modification testing for acceptance. Safety-related design change
packsges were reviewed for four (4) systems. The specific items
reviewed were:
Modification Approval Record (MAR)
.
M-77-7-33
Diesel Generator Alarm Additions , Implemented
6/78
M-77-7-33A
Diesel Generator Alarm Additions, Implemented
.
7/78
M-77-8-10
Rotate Valve MUV-406, implemented 9/78
.
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M-77-12-6
Reactor Building Letdown Line Shielding, Currently
Pending Installation
.
M-78-1-1
Emergency Feedwater Turbine Bearing Oil Level
Sightglass Modification, Implemented 9/78
For the items selected, the inspector verified that documenta ry
evidence was available on-site to support their confo rmance to
design change requirements.
Design inputs encompassing codes,
standards, Regulatory requirements and design bases were verified.
and acceptance criteria stipulated in the design change
The test
procedures were reviewed as to their status and adequacy and that
the final modified equipment performance was reviewed and approved
indicating their conformance to Technical Specifications. Additionally,
operating procedures and as-built drawings affected by the selected
design changes were reviewed to verify their up-to-date revision
status.
Temporary modifications (jumpers /lif ted leads / bypasses) were reviewed
to assure that controls were established for proper approval and
for formal documentation of all such temporary acdifications. The
referenced documents were also reviewed to verify procedural require-
ments for independent verification of installation and removal.
inspector reviewed the jumper log and selected eighteen (18)
The
entries. Each was reviewed to determine that independent verification
of installation had been performed and that, where rer,uired, writteo
safety evalustions per 10 CFR 50.59 had been performed. The entries
selected were: Jumper Log, serial 9-08, 9-09, 9-10, 9-15, 7-22,
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11-16, 2-34, 2-35 and 2-36, all related to Control Room alarms for
heat tracing systems; 10-03, 10-04, 10-05, 10-06, 10-07, 10-08, all
related to reduction of setpoints of 480V ES Bus A undervoltage
relays; 9-04, boric acid transfer pump CAP-IC replacement; and
12-2, temporary tubing on VDU-457.
The inspector then selected
one (1) control cabinet (acnunciator/ events recorder ca. binet #5 in
Control Room) and verified that two (2) jumpers contained therein
(Jumper Log serial 11-20 and 9 008) were properly logged.
As a result of this review, the inspector identified: four (4) items
of noncompliance documented in Paragraphs 8.b, R.c,
8.d, 8.e, 8.f
Paragraph 8.h;
and 8.g; one (1) unresolved item documented u
two (2) items requiring management attention as discussed in Para-
graphs 8.i and 8.j; and, one (1) inspector follow item as presented
in Paragraph 8.k.
b.
Failure to Record Bases for Safety Evaluations
10 CFR 50.59 requires the maintenance of records of changes in the
facility as described in the safety analysis report. These records
are required to include a written safety evaluation which .;rovides
.
the bases for the determination that the change does not involve an
unreviewed safety question. The record of three (3) of five (5)
safety-related modifications reviewed included writter
safety
evaluations which did not provide the bases for the det: rmination
that the change did not involve an unreviewed safety question. The
three (3) pertinent records were for the following modifications:
MAR M-77-7-33
Diesel Generator Alarm Additions
MAR M-77-8-10
Rotate Valve MUV-406
.
MAR M-78-1-1
Emergency Feedwater Turbine Bearing Oil
Level Sightblass Modification
These examples of f ailures to maintain records which provide the
bases for the determination that the changes did not involve unre-
viewed safety questions constitute an item of noncompliance (302/
79-04-07).
c.
Failure to Follow Procedures
Appendix B,
Criterion V
requires that activities
affecting quality be accomplished in accordance with approved
procedures.
The
licensee's
accepted QA Program, Section
1.7.6.7.1.e also requires that written procedures be strictly
adhered to.
Sections 4.0 and 5.0 of reference (a) provide the
required controls to be applied to permanent modifications and
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temporary modifications , respectively.
Sections 1.1 and 1.2 of
reference (a) provide the definitions of permanent and temporary
modifications which determine which set of administrative con
Permanent modifications are intended to remain in
are required.
the as-changed configuration during normal plant operation.
Temporary modifications are short-term in nature and are not lef t
to a specific operation.
Contrary tc tbese
operative subcequentrequirements, boric acid transfer pump, CAP-
by a pump of different design in September 1977, and was left
operative until July 1978, was processed as a temporary modificatio
rather than as a permanent modification.
The instructions contained in MAR M-78-1-1 specified the replacement
safety-related emergency feed pump's turbine bearing oil
of the
level sightglass sensing lines with lines containing two elbows.
The sightglass elevations were required to be adjusted so that
inches
normal level was in the center of the sightglass and twoInspection of bot
above the center line of the sensing line tap. construction and sig
sensing line
Contrary to these requirements, the turbine bearing sightglass
sensing lines were installed with one elbow and the sightglass
elevation was not adjusted. Furthermore, the inspection did not
the nonconforming construction of the sensing lines or
document
ele"ation of the sightglasses.
These ex.-s.ples of f ailures to follow approved procedures collectively
raphs 8.d, 8.e. , constitute an item of nonconpliance (302/
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cith respect to 10 CFR 50 Appendix B, Criterion V.
70-04-08)
d.
Failure to Perform Specified Testing
10 JR 50, Appendix B, Criterion XI, requires that testing to
demonstrate satisf actory in-service performance be identified and
The licensee's
performed in accordance with written procedures.a
MAR M-77-8-10 (Rotation of MUV-406) specified that a
Approval of the completion
requirement.
3355 psig hydrostatic test was required.of this MAR was
testing had not been performed. The licensee reviesed this finding
during the course of the inspection and concluded that the specifie
actually required to satisfy
hydrostatic test requirement was not
ASME code requirements.
This failure to perform the testing specified in MAR M-77-8-10
8.e., constitutes an item of
collectively with paragraphs 8.c. ,with respect to 10 CFR 50, Appendix B,
noncompliance (302/79-04-08)
Criterion V.
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Failure to Delineate Functional Testing
e.
Criterion III, requires design control
measures be applied to the delineation of acceptance criteria for
The licensee's accepted QA program (FSAR
inspections and tests.
Section 1.7.6.7.1.c) comits to the design activity requirements of
Section 5.2.7.2 of ANSI N18.7e1976, which in turn references ANSI
N45.2.11-1974Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.11-1974" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Section 3.2 of AESI N45.2.11-1974 requires that
Section 4.1.4 of
design inputs include in-plant test requirements.
CP-114 requires that Engineering complete Part 2 of the MAR form to
include listing of the specified required functional testing.
Contrary to these requirements, safety-related MAR's M-77-7-33 and
M-77-7-33A did not have functional testing specified.
Additionally, no approved test procedure for demonstrating the
operability of these desigo changes was provided to the inspector.
failure to delineate the in plant test requirements to demon-
This
strate the operability of MAR M-77-7-33 nd MAR 77-7-33A constitutes
an item of noncompliance (302/79-04-08) with respect to 10 CFR 50,
Appendix B, Criterion V.
f.
Failure to Establish Design Record Submittal Plan
10 CF2 50, appendix B, Criterion XVII, r quires record retention be
consistent with regulatory requirements.
The licensee's accepted
QA Program (FSAR Section 1.7.6.7.1.q) requires a QA record program
consistent with Regulatory Guide 1.88.
Revision 2, October 1976, subscribes to the requirements of ANSI
N45.2.9-1974Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.9-1974" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.. Section 4.2 of the Standard requires that e specific
No such subaittal
submittal plan be established for QA records.
13, 1979.
During the coun- of the
plan existed as of Februarj
inspection, the licensee developed the required submitt.al plans for
design records maintained by Gilbert Associates, Inc. :.:d Babcox
and Wilcox Company, and presented these to the inspector.
This failure to establish a specific submittal plan for the transfer
of design records frem the suppliers (Gilbert Associates, Inc. and
Babcox and Wilcox Company) to the purchaser (Florida Power Corporation)
has been combined with similar examples to collectively constitute an
item of noncompliance (302/79-04-15). Both imediate corrective action
and action to preveat recurrence have been taken by the licensee with
the development of references k) and 1); therefore, no response to this
portion of the item is required.
Failure to Distribute /Use Documents
g.
10 CFR 50, Appendix B, Criterion VI, requires that documents be
distributed to and used at the location where the prescribed
The licensee's j ,ceMed QA;.;p 3g TiAE
ac
activity is performed.
9 4 'i f
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.
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Section 1.7.6.7.1.f) requires that documents be available at the
start of the work for which they are needed. The in.pector inter-
viewed the technical staf f member who made the determination of
Jumper Log
whether or not the temporary modification listed as
serial 9-04 was safety-related. The staff member stated that he
made this particular determination (in September 1977) and others
for temporary modifications and that he did not have a copy of the
He further stated
Crystal River 3 Safety Listing available to him.
that he currently makes safety-related versus non-safety-related
determinations for permanent modifications and still does not have
access to a copy of the Crystal River 3 Safety Listing.
It was
noted that this document was distributed to the Crystal River Plant
Unit 3 by the corporate of fices on January 25, 1977.
This failure to distribute a document to and use the document at
the location of a prescribed activity constitutes an item of non-
compliance (302/79-04-09).
h.
Criteria for Making Safety-Related Determinations
The licensee's procedure CP-114 (reference (a)) does not give guidance
in the method for determining whether or not a modifiestion is
safety-related. The inspector discussed this item with the licensee
who concurred that a safety-related determination was a two-step
The first step is a check to see if the item "ueing modified
process.
is included in the Safe"; Louag.
The second step is a check of
the nature cf tne modification of an item not on the Safety Listing
to verify whether or not the accomplishment of the modification
will affect any item included in the Safety Listing.
Until the licensee revises his procedures to give an appropriate
method for making safety-rela:ed determinations for modifications,
this unresolved item is designated (302/79-04-10).
i.
Criteria for Performing 10 CFR 50.59 Safety Evaluations
In Section 5.1 of reference (s), the criteria for determining vbether
or not a safety evaluation need be performed to satisfy 10 CFR 50.59
is inaccurate.
This resulted in safety evaluations not being
perf ormed for the following temporary modifications: Jumper Log
serial 9-08, 9-09, 9-10, 9-15, 7-22, 11-16, 2-34, 2-35 and 2-36,
all related to Control Room alarms for heat tracing systems; 10-03,
10-04, 10-05, 10-06, 10-07, 10-08, all related to reduction of
setpoints fo 480V ES Bus A undervoltage relays; 9-04, boric acid
transfer pump CAP-IC replacement; and 12-2, temporary tubing on
WDU-497.
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provisions of this instruction were based upon incomplete
The
guidance given to the licensee during a previous NRC inspection.
Until the licensee revises his procedures to require written safety
evaluations for all modifications to which 10 CFR 50.59 applies,
this item is designated (302/79-04-11). The licensee gave April 20,
1979 as a completion date for this item.
j.
Changes to Safety-Related Determinations
The licensee's review and approval process for temporary modifi-
cations resulted in temporary modifications (Jumper Log serials
9-23 and 9-24) being downgraded from ss'ety-related to non-safety
The work request (serial 1186 for jumper 9-24) was annotated
related.
as non-safety-related and accomplished without the controls required
for a safety-related modification. There was no reflection of this
downgrading on the jumper log form.
Until the licensee revises his procedures to ensure that operations
and maintenance personnel are cognizant of changes to the safety
classification of maintenance and modifications , this item is
designated (302/79-04-12). The licensee pve a completion date of
April 20, 1979 for this item.
k.
Operational Information in Jumper Log
One shift supervisor and one assistant shift supervisor were simul-
taneously interviewed, while on watch, and were unable to describe
the operational significance of any of three specific jumper log
discussed.
Each jumper was designated as safety-related.
entries
It was noted that Jumper Log entries generally did not provide such
operational inf ormation.
Until a subsequent NRC inspection interview establishes that appro-
priate watchstanders understand the operational significance of
temporary equipment modifications, this inspector follow item is
designated (302/79-04-13).
9.
Records and Document Control
References
a)
Quality Programs Policy 6.1, Control of Doc.
.s
Af fecting Quality, Revision 2, dated 6/77
b)
Quality Program Policy 17.1, Quality Program Records
Control, Revision 2, dated 6/77
c)
Quality Program Procedure 17.50, Construction Records
Receipt and Control, Revision 4, dated 7/77
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Quality Program Procedure 17.51, Quality Records for
d)
Operation, Revision 2, dated 7/77
Quality Program Procedure 6.50, Nuclear Power Plant
Instruction Document Control, Revision 1, dated 7/77
e)
Quality Administrative Procedure (QAP) 5, Documenting
f)
Quality Programs Record, Revision 0, dated 1/75
QAP 6, Control of Quility Program Documentation,
g)
'
Revision 2, dated 7/77
QAP 9, Transmittal of Quality Records-Quality Programs
Department to Nuclear Plant Quality Document File,
h)
Revision 0, dated 7/77
Administrative Instruction (AI) 400, Plant Operating
Quality Assurance Manual Control Document, Revision 2
i)
dated 1/79
of Operations, Revision 20, deted
j)
AI-500, Conduct
1/79
AI 800, Conduct of Administrative Services, Revision 5,
k)
dated 12/78
Document Control Procedure (DC) 101, Introduction to
Document Control Procedure, Revision 5, dated 10/78
1)
DC-102, Control of Drawings, Specifications, Requirement
Outlines and Manufacturer's Manuals, Revision 2,
m)
dated 10/78
, Control of Quality Construction, Testing and
n)
DC- 4 C l>
Plant Operating Records
Engineering
Procedure
Notice 9,
Safety-Related
o)
Control of Records Retention, dated 3/78
Administrative Procedure Notice 10, Filing Systems
p)
Procedures, dated 3/78
Administrative Procedure Notice 6, Drawing Control
y
g)
'
Proctcure, dated 3/78
.
},,
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Administrative Procedure Notice 7, Generating Plant
v
r)
Drawing Maintenance, dated 3/78
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s)
Administrative Procedure Notice 8, Interim Drawing
Control, dated 3/78
a.
Inspection Items
The inspector reviewed the licensee's program for control, storage,
retention and retrieval of records and documents pertaining to
safety-related systems to verify that it was in conformance with
Technical Specifications 'i QA program requirements. By selecting
representative sample oi drawings (listed below), the inspector
a
the implementation of these controls at the locations
reviewedDrawings selected and the location (s) where each sas reviewed
given.
are listed below.
reviewed at the Corporate office, plant
Engineering Drawings were
record control of fice and satellite files at the plant.
302-752, Revision 9
302-711, Revision 19
.
302-601, Revision 25
.
- 302-231, Revision 14
.
304-712, Revision 12
.
304-663, Revision 16
203-060 WD23, Revision 5
.
203-040 MT-11, Revision 1
.
- 209-106 SH-1, Revision 9
.
209-107 SH-3, Revision 4
.
209-139 SH-3, Revision 3
.
318-284, Revision 7
.
318-711, Revision 2
.
421-023, Revision 11
.
424-190, Revisic 2
.
- 244-048
.
- 208-027
.
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- Drawings under revision due to modifications.
With respect to the drawings reviewed, findings were acceptable.
Yhe licensee's program for records was reviewed at the Crystal
River Station with re.pect to the referenced documents.
The
inspector selected fifteen (15) operations phase records and two
(2) construction phase records. For each of the records selected,
the inspector verified that the record was stored in the designated
location; that the record could be retrieved; that the record was
listed on an appropriate index; and, that the record was was stored
as required bj the program controls. The records selected were:
Operations Pha_se
Werk I :. quest , WRT 0 2488
.
.
Surveillance Procedure SP-300 for December 16, 1977
MAR 76-6-20
.
M-1420
0-2905
Preventive Maint nance Procedures
.
PM-110 f or 10/9/70
Training Records
.
Waste Transfer Records
.
Tes t Procedure CF-7-3-220-00
.
Hydrostatic Test TP.7-1-201, 4R-5089
.
Instrusent and Cont rol Calibration Record
.
Quality Assurance Audit Reports
Licensee Event Report
.
Construction Phase
Construction Inspection Report IX11091
.
Concrete Pour TR-89, 2003025
.
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An item ef noncompliance was identified as dircussed in Paragraph 9.b
below.
The inspector also reviewed the licensee's operations and maintenance
recordkeeping systems to assure that the information documented was
sufficient to permit review by licensee personnel to detect long-term
equipment degradation or adverse trends.
The transfer of this
information to other organizations for evaluation was also reviewed.
An item requiring management attention was identified as discussed
in Paragraph 9.c below.
b.
Failure to Handle Records as Required
10 CFR 50, Appendix B, Criterion XVII, requires thst records be
maintained. Section 1.7.6.7.1.q of the licensee's accepted Quality
Assurance Program states that ANSI N45.2.9 requirements will be
met. The referenced section of the program also specifies d.aplicate
microfilm copies of all records. The records at the Central Files
did not contain all completed Preventive Maintenance Procedures
(PM-109 as an example); training records; waste transfer records;
instrument calibretion records; nor QA audit reports. In addition,
the duplicate copies of Licensee Event Reports were stored in a
one-hour file cabinet in Central Files and an open notebook in the
compliance of fice.
While original records were all located, duplicate microfilm copies
are not procersed for over one (1) year. The procedures governing
single record storage do not meet the requirements of Section 5.3
of ANSI N45.2.9.
Where single records are maintained, the storage
facilities do not meet those specified in Section 5.6 of ANSI N45.2.9.
These eramples of inadequate record retention practices have been
combined with similar exampler_ documented in Paragraphs 8.f and 10.e
of this report and collectively they constitute an item of noncom-
pliance (302/t9-04-15).
c.
Evaluation of Failures
The licensee participates in a reliability study computer-based
program.
Failures are entered into the data base as they occur.
The engineer responsible for entering data stated orally that the
reviews to determine comon or generic failures and poor performance
are conducted when data are processed into the system. His oral
description covered the items required by the accepted QA program's
cour.itment to ANSI N18.7-19'o, Section 4.1 and 5.2.1.1.
However,
the procedure covering the processing of the data, SP-299, Plant
Reliability Reporting, did not require the current practices.
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The licensee stated that . procedure would be updated to reflect
current practices meeting Paragraphs 4.1 and 5.2.7.1 of ANSI N18.7-
1976Property "ANSI code" (as page type) with input value "ANSI N18.7-</br></br>1976" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.. This item (302/79-04-14) will be reviewed during a subsequent
NRC inspection.
10.
Receipt, Storage and Handling of Equipment and Material
References)
a)
QOP-1.0, Organization and Responsibilities, Revision 2,
dated 1/78
b)
QOP-2.0, Training and Indoctrination of Production
Stores Department Personnel, Revision 1, dated 1/78
c)
QOP-3.0, Preparation and Control of Quality Operating
Procedures, Revision 1, dated 1/78
d)
QOP-4.0, Processing Plant Initiated Purchase Requisitions,
Revision 2, dated 10/78
e)
QOP-5.0, Inventory Control, Revision 3, dated 1/78
f)
QOP-6.0, Receipt, Quality Receiving Inspection and
Identification, Revision 6, dated 10/78
g)
QOP-7.0, Issue and Return of Quality Material,
Revision 3, dated 1/78
h)
QOP-8.0, Handling, Storage and Shipping, Revision 3,
dated 1/78
i)
QOP-9.0,
In Storage Maintenance and Inspection,
Revision 2, dated 1/78
j)
QOP-10.0, Maintenance and Control of Records, Revision
1, dated 1/78
k)
QOP-11.0, Transfer of Qulity Spare Parts f rom Construc-
tion to Production Stores, Revision 1, dated 1/78
1)
QOP-12.0, Purchases of Quality Material and Services,
Revision 2, dated 10/78
m)
QOP-13.0, Approved Bidders / Suppliers List,
"Q"
Orders and Other Documentation, Revision 1, dated
7/78
n)
QOP-14.0, Reporting of Defects and Noncompliance,
Original dated 7/78
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a.
Program Review
reviewed with respect to selected
The referenced documents were
elements of the licenzee's accepted Quality Assurance Program and
ANSI N45.2.2-1972, as committed to by that Program. The inspection
was to verify that administrative controls had been established for
the receipt of safety-related items which required shipping damage
inspection; receipt inspection; dispositioning, segregation and
identification of items; and, the documentation of these activities.
Storage procedures and practices were reviewed to assure tnat they
provided for levels of storage and appropriate environmental controls;
access, identificction, covering and preservation of items; periodic
inspections of the storage area; maintenance and care of items in
storage including controls for items with limited shelf life; and,
assignment of responsibilities for the above activities.
Handling activities were reviewed to determine that programs and
procco res had been developed for specification of routine and
special handling requirements; controllicg hoisting equipment; and,
inspection of rigging equipment as required by the program.
In any area where the program review identified weaknesses, these
areas were inspected as implemented during the inspection activities
documented in Paragraph 10.b below.
b.
Implementation
The licensee's receipt, storage and handling programs were reviewed
at Crystal River, Unit 3, with respect to the requirements of the
referenced documents.
The inspector selected seven (7) safety-
related items which had been received on-site and verified that
receipt inspections, dispositic 'ing, and storage had been accomplished
in accordance with the licenset's program.
The specific items
selected were:
Pump, item 5 of PO 109962Q
.
Wire, item 1 of PO A32748
.
Valve, item 1 of PO 130982Q
.
Controller, item 1 of PO 122888Q
.
Filter, item 2 of PO 3-128888
.
Gasket, item 1 of P0130977
.
Snubber, item 1 of PO 125410
.
The inspector then toured the warehouses and verified that required
storage and housekeeping controls were in use. During the tour,
the inspector selected three (3) items in storage and verified that
tagging / marking allowed traceability of the items to purchase,
receipt and p ocurement documents.
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The specific P0 and stock numbers selected were:
PO 3-13066Q, SN 6-52-60-237
.
P0 1279610, SN 01761797
.
P0 (Continuing) SN 01860831
.
In the environmental control warehouse, the inspector selected two
electric motors (serial numbers 6-26-80-471 and 6-32-80-479) to
review with respect to storage maintenance requirements.
As a result of the above inspection, two (2) items of noncompliance
and an example contributing to a third item of noncompliance were
identified as discussed in Paragraphs 10.c, 10.d and 10.e below.
for cor-
Five (5) items requiring additional management attention
discussed in Paragraphs 10.f, 10.g,
rection were ideritified as
10.h, 10.i and 10.j below.
Failure to Establish / Implement Storage and Handling Controls
c.
10 CfR 50, Appendix B, Criterion XIII, requires that storage and
handling controls be estaolished.
The licensee's accepted QA
program states that these controls will be (Section 1.7.6.7.1.m) in
accordance with written procedures which provide full conformance
with ANSI N45.2.2.
This was accomplished in several specific
instances observed as follows:
Section 6.2.1 of the Standard and Section 4.2.9 of QOP-8.0
require that e r t.:s s to storage areas be controlled; on
.
February 13, 1979, four persons who had not been authorized
were observed, unescorted and without the cognizance of stores
personnel, inside the safety-related material storage warehouse.
Section 6.2.2 of the Standard and Section 4.2.10 of QOP-8.0
require that cleanliness practices be enforced and that
.
accumulations of dirt, trash and discarding packaging material
not be permitted; on February 13 and 14, 1979, trash accumula-
tion was noted in the Environmental Control Warehouse.
Section 6.2.4 o
the Standard and 4.2.12 of QOP-8.0 require
that drinks be e) cluded f rom the storage areas. On February 13,
1979, drinks we'e not excluded from the warehouse as evidenced
by finding two (2) empty containers and observing one individual
in the process of consuming a sof t drink in the warehouse.
Section 6.2.5 of the Standard requires measures to be taken to
the entrance of rodents and small animals into the
.
prevent
warehouse; no rodent control system or service was in force on
February 13, 1979, and the physical construction of both the
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regular and the environmental
arehouse was of a type which
did not preclude their entrance.
Section 6.4.2(6) of the Standard requires the insulation
.
resistance testing on a periodic basis of stored rotating
electrical equipment; two electric motors (serial numbers
6-26-80-471 and 6-32-80-479) had been in storage for,
respectively four years and three years and had never been
meggered as required, according to the licensee, :nd no
records were available.
Section 7.4 of the Standard and Section 8.3 of Ireventive
Maintenance procedure 109 require the inspection of slings and
.
cables used to handle safety-related equipment. The Standard
additionally requires that the satisfactory completion of the
inspection be indicated on such equipment; the required inspec-
tion program and status indication system were not established /
implemented for slings and rigging used on safety-related
lifts outside the reactor building and the spent fuel pit
areas.
The five (5) examples of failures to establish and/or implement the
required storage and handling controls, collectively, constitute an
item of noncompliance (302/79-04-16).
Altk agh included as one citation, the Production Stores personnel
ve.. functionally responsible for all but the last example; the
Crystal River Unit 3 personnel do the required lif ting of both
warehouse and plant items and are, therefore, functionally respon-
sible for only the last example.
d.
Failure to Certify Inspection Personnel
10 CFR 50, Appendix B, Criterion X, requires that an inspection
program be established and executed.
The inspection program
comitted to by the accepted QA program, Section 1.7.6.7.1.j,
states that off-site FPC personnel shall be qualified to
ANSI N45.2.6-1973. Section 2.2 of that Standard requires that each
persen who verifies conformance of work activities to quality
standards shall be certified by his employer as qualified to perfor
his assigned work.
Section 2.2.3 required initial and periodic
evaluation (at intervals not to exceed two years, of job performance.
Neither of these ren -
ements were being act for personnel performing
receipt damage
m inspections of safety-related equipment
received at the w6
2se.
This failure to certify inspection personnel and to perform initial
and/or periodic
evaluations
is
an
item of
honcompliance
(302/79-04-17).
P00R Cfh' NiE
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Failure to Maintain Duplicate Records, or to Follow Procedures
e.
10 CFR 50, Appendix B, Criterion XVII requires that records of
activities af fecting quality shall be retained.
The licensee's
accepted QA program, Section 1.7.6.7.1.q, requires following of
written records procedures, duplicate microfilm storage of records,
and compliance with ANSI N45.2.9. Both ANSI N45.2.9 and the referenced
Section of the licensee's program define a document to be a record
when the document has been completed. QOP 10.0, Section 4.4 assigns
the Stores Supervisor the responsibility for control of records and
access to the file storage area.
QOP 10.0 does not contain a
description of the storage area or the filing system to be used nor
does it contain the method for verifying that records received are
in agreement with the transmittal document and with a nonexistent,
pre-established records checklist.
All of the stated procedural
inadequacies are requirements of the accepted QA program through
its commitment to ANSI N45.2.9 which specifies the contents of such
a procedure in Section 5.3.
In addition to the procedural inadequacies noted above, the current
procedure is not followed.
The files are located in a trailer
which is not under the control of the Stores Supervisor, so he can
not and does not control access to the files as required by QOP-10.0.
Further, only one copy of the receipt inspection and the associated
packing slips is maintained.
None of the receipt records are
duplicated or microfilmed.
The records are stored in one-hour
fire-rated cabinets.
Other purchase and stores documents related
to safety-related equipment are duplicated, according to the licensee,
but these duplicate record locations are not listed, audited or
allowable under the licensee's current QA program, which specifies
duplicate microfilm copies as the requirement.
Duplicate hard
copies woul.1 be allowable under ANSI N45.2.9 if the more stringent
requirement in Section 1.7.6.7.1.q of the licensee's program were
modified and if such duplicate locations r re designated, audited,
not subject to the same natural disaster (remote from each other).
These f ailures to naintain duplicate records and/or to follow the
provisions of current procedures and/or failure to have an adequate
procedure have been combined with similar examples to collectively
constitute an item of noncompliance (302/79-04-15).
Additional
examples are documented in Paragraphs 8.f and 9.b.
f.
Failure to Provide Required Housekeeping and Protective Caps
The licensee's accepted QA program, Section 1.7.6.7.1.a invokes the
controls of ANSI N45.2.2 in meeting the requirements of 10 CFR 50,
Appendix B, Criterion XIII for control of storage of safety-related
mid[d h
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materials. During a tour of the non-environmental control warehouse
tba week prior to this inspection, the Production Stores Supervisor
had drumented that the caps required on stainless steel piping and
fittings were inadequate and that the housekeeping in the warehouse
was not in accordance with ANSI N45.2.3 as required. The necessary
caps had been ordered, but had not yet arrived and been installed
as of the inspector's tour of the warehouse.
The program for
housekeeping was under develor: cat, but was not implemented as of
February 13, 1979, when this inspection was U formed.
f
S6ce this inadequacy was identified, documented and acknowledged
by the licensee and corrective actions were under way prior to tnis
inspection, no citation is issued. However, in order to determine
that these inadequacies are corrected in a tijnely manner, this item
(302/79-04-18) will be reviewed during a subsequent NRC inspection.
In a telephone conversation between the licensee and RII on February 22,
1979, the licensee gave a target. date of June 30, 1979, for achieving
complete corrective actions in these areas.
Failure to Provide a Weathertight Warehouse
g.
The licensee's accepted QA Program cocnits to ANSI N45.2.2 as noted
above. The larger of the two warehouses currently in use is designed
for levels B, C,
and D storage.
However, the warehouse is not
weathertight as required by Section 6.2.1 of ANSI N45.2.2 as endorsed
in the licensee's accepted yA Program.
This inadequacy had been
noted by the licensee prior to this inspection as evidenced by a
memorandum dated November 24, 1978, f rom Mr. W. R. Vatts to Mr. D. C.
Crockett.
That memorandum states that door repair and canopy
installation (leakage around the sides and through the top of the
doors were the major source of entry for rain and cold air) will be
started af ter the paving of the exterior receipt area has been
completed.
Since the inadequacy was identified, documented, and acknowledged
by the licensec :nd corrective setions were defined and planned
prior to this inspection, no citation is issued. However, in order
to determine that the planned corrective actions take place and are
effective in providing the required storage area controls, this
item (302/79-04-19) will be reviewed during a subsequent NRC inspec-
tion.
In a phone conversation between the licensee and RII on February 22,
1979, the licensee gave a target completion date of April 15, 1979,
for achieving complete corrective actions in this area.
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h.
Failure to Provide Adequate Space for Environmental Control
Storage
One of the requirements of the licensee's accepted QA program via
commitment to ANSI N45.2.2 and his own internal procedures is to
provide Level A environmental controlled storage for certain safety-
related materials.
Such storage is currently provided.
However,
the size of the current envircamental control warehouse does not
meet * ne additional requirement of Section 6.3.1 of the Standard
.
which calls for access without excessive handling of material. The
current warehouse is filled with material to such a degree that
adequate air circulation is not assured as :equired by Section 6.2.1
of the Standard and this filling requires that material be removed
from both aisles when virtually any material is to be withdrawn.
This inadequacy was also identified, documented and acknowledged by
the licensee prior to this inspection.
However, since additional
fossil generating units are curreutly under construction at this
location, the implementation of corrective action (building a
same
new, larger warabouse) was not yet defined. An engineering study
had been unoerway and was completed during this inspection and was
being reviewed by licensee management.
In a letter (REI PD-695)
dated February 14, 1979, FPC committed to correction of the noted
inadequacy. At the exit interview on February 16, 1979, the licensee
stated that the RII Project Inspector would be informed as soon as
a firm date for beginninr, of construction had been determined. To
assure tracking and subsequent review of the licensee's actions in
this area, this item (302/79-04-20) will be reviewed during subsequent
NRC inspections.
i.
Failure to Provide Controls for tems s .h limited Shelf Life
In a memorandum f rom the Stores Supervisor to Mr. M. Jemaings dated
Janua ry 24, 1979, the lack of a cu* rent program to control items
with limited shelf life was acknowledged and documented.
At the
exit interview conducted on February 16, 1979, the licensee gave a
target date of December 31, 1979, for implementation of the necessary
controls.
To verify that the licensee's program for control of
these items is adequate, this item (302/79-04-21) will be reviewed
during a subsequent NRC inspection.
j.
Training of New Warehouse Employees
On January 29, 1979, the licensee hired three (3) new employees for
the warehouse. These three (3) personnel had not yet received the
training required by the accepted QA program's commitment to ANSI
N45.2.2Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.2" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Section 7.5 for use of the warehouse's forklif t.
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One employee interviewed by the inspector had received the required
training, and was certified as a qualified operator.
Since the licensee will not te.
.a to use these new personnel
until the high work level acts
4es associated wita his scheduled
.e stated that these men would be
refueling and since the licen
appropriately trained and licensed prior to that time (April 23,
1979), this item (302/79-04-22) will be reviewed during a subsequent
NRC inspection.
11.
Training for Compliance Engineer, Mechanics and Electricians
In the process of reviewing the licensee's actions to close item 302/78-
25-01 (see Paragraph 3), the inspector noted that training was documented
as being conducted for compliance engineers, but no documented training
requirements existed.
Mechanics and electricians had defined training
courses which had not been implemented.
Section 1.4 of AI-100 and
Criterion II of Appendix B require that training be conducted.
Since
the licensee was conducting training in one case and had developed
programs in the cther areas and since licensee management stated that
required documentation / implementation would be accomplished by April 1,
1979, this item (302/79-04-23) will be reviewed during a subsequent NRC
inspection.
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