ML19247A092
| ML19247A092 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 03/23/1979 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19247A091 | List: |
| References | |
| 50-338-79-08, 50-338-79-8, NUDOCS 7907300010 | |
| Download: ML19247A092 (8) | |
Text
-
1 APPENDIX A NOTICE OF VIOLATION License No. NPF-4 Virginia Electric and Power Company North Anna Power Station Unit No. I Based on the NRC inspection, January 29 - February 2, 1979, c*rtain of your activities wer. apparently not conducted in full compliance with NRC require-items have been categorized as described ments as indicated below. These in correspondence to you dated December 31, 1974.
As required by 10 CFR 50, Appendix B, Criterion XVI, " Measures shall be established to assure that conditions adve-se to quality such as A.
failures, malfunctions, deficiencies, deviations, defective material and equipment, and nonconformances are promptly identified and corrected.
condition adverse to quality, The identification of the significantand the corrective action taken shall be the cause of the condition, documented and reported to appropriate levels of management." The Section 17.2.16, states in part:
accepted Quality Assurance Program,
" Verification of the proper implementation of corrective action measures and closecuts of corrective action documentation is assured through
. and the corrective actions the monitoring and auditing effort taken are resorted to appropriate levels of both offsite and onsite management.
Contrary to the above, procedures have not been established to ensure corrective action is taken to resolve conditions adverse that prompt This lack of procedures contributed to the lack of response, to quality.
slow response or corrective action completion dates being exceeded for 30 of 51 audit findings reviewed.
This is an inf raction.
As required by 10 CFR 50, Appendix B, Condition XVIII, "A comprehensive system of planned and periodic audits shall be carried out to verify B.
compliance with all aspects of the quality assurance program and to determine the ef fectiveness of the program.
The audits shall be p-rformed in accordance with the written procedures or check list; by appropriately trained personnel not having direct responsibilities in the areas being audited".
The accepted Quality Assurance Program (Section 17.2.18) states in part: "The general audit policy specifies audits be conducted in otation and system quality assurance that accordance with a formal preplanned and scheduled system to ensure an adequate and meaningful quality assurance / control program is in effect Pg)fgg Udh//QjgU/A o
790730 488 23n/
, Appendix A Virginia Electric and Power Co.
Notice of Violation License No. NPF-4 as comitted to by the accepted Program, states 1.
'3udits shall include an evaluation of design quality in part:
assurance poiicies, practices, procedures and instructions; the effectiveness of implementation; and actions taken to correct deficiencies in the program.
Contrary to the above, the design change audit check list is inade-include the evaluative considerations in that it does not quate required by Section 11.4 of ANSI N45.2.11.
ANSI-N45.2.12 (Revision 3, Draf t 4-1974), as comitted to by the states in part:
'The audit report shall be 2.
accepted Program, issued within thirty days af ter the post-audit conference.
and shall respond as 4.5.1 By Audited Organization.giving results of the review and requested by the audit report, investigation.
the System Nuclear Safety and Operating Contrary to the slave, Quality Assurance-Operations and Mainte-Comittee (SNSOC) annua :
program provides no system to delineate the duties nance audit and qualification of the auditors, to provide written procedures or check lists, and to specify reporting requirements and respotise times as required by ANSI-N45.2.12.
.his is an Inf raction.
T As required by Technical Specifications 6.4.1 "A retraining and replace-ment training program for the facility staff shall be maintained under C.
the direction of the Superintendent - Station Operations and shall Section 5.5 of meet or exceed the requirements and recomendatins 6:
and Appendix A of 10 CFR Part 55." hocedure ADM-12, ANSI N18 1-1971 Paragraph 12.2.1 requires all regular employees receive retraining and recertified in the listed areas at least once per calendar year.
- Company policy
- Station Contingency
- Station Access Control and Security Procedure
- Radiological Health and Safety
- Protective Clothing and Equipment, Use of
- Industrial Safety
- Quality Assurance Control
- Station Familiarization Contrary to the above, the program did not provide for training to ass.ure 28 o a~ 63 regular cperatioas that proficiency was maintained in that employees had not received the required retrainia.g/ recertif station.
This is an Infraction.
) kh d [ j m h
L 1
fy
, Appendix A Virginia Electric and Power Co.
Notice of Violation License No NPF-4 As required by 10 CFR 50.59(b), "The licensee shall maintain records to the extent that such changes D.
of changes in the facility.
constitute changes in the facility as described in the safety analysis report
." and ".
These records shall include a written safety evaluation which provides the basis for the deter:ainatzon that involve an unreviewed safety question the change does not licensee did not C ntrary to the above, as of February 2,1979, the maintain records of changes in the facility including a written safety evaluation as follows:
Safety-related temporary modification to the chemical and volume control system (Jumper Log Serial 191) had no documented safety 1.
analysis.
One design change to the bearing cooling water system (DC-78-11) 2.
to the facility as described in the safety constituted a change This change had no d ~2mented safety analysis.
analysis report.
This is an Infraction.
all required by 10 CFR 50, Appendix B, Criterion XI, ".
As E.
testing required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures whicn incorporate the requirements limits contained in applicable design documents.
and acceptance Test results shall be documented and evaluated to assure that test requirements have been satisfied." The accepted Quality Assurance Program Section 17.2.11 states in part:
"The test program.
assures that safety related structures, systems, and components will The results are documented, perform satisf actorily when required.
evaluated, acceptance status identified Contrary to the above, as of February 2, 1979, the testing required to demonstrate satisfactory pe.rformance was not performed or documented in that:
Design Change DC-78-09 (Boric Acid Transfer Pump Insulation) was 1.
- however, completed and the pumps placed in service in August 1978; the te.;t procedure was not performed.
The test results of design change DC-78-06 (Casing Cooling Subsystem 2.
of Recirculation Spray ( stem) were not evaluated and documented meet the to indicate the acceptability of data which did not specified acceptance criteria.
This is an Inf raction.
J D[)f' WUM
$nd.@jl
(
488. m
e
, Appendix A Virginia Electric and Power Co.
Notice of Violation License No. NPF-4 As required by Technical Specification 6.8.2, "Each procedure of 6.8.1 above, and change thereto, shall be reviewed by the SNSOC and approved F.
." Technical by the Station Manager prior to implementation Specification 6.8.1 states in part:
" Written procedures shall be The applicable procedures covering a.
established.
recemended in Appendix ' A' of Regulatory Guide 1.33, November,1972 the following procedures which are listed as C ntrary to the above, requiring SNSOC review on the procedure index were not reviewed and no evidence of such a review was furnished:
Administrative Procedure 8.0, Fire Prevention Administrative Procedure 19.0, Adherence to the Health Physics Radiation Protection Manual Administrative Procedure 25.0, Operstion of the Station During Hazardous Conditions Administrative Procedures in the 29.0 series covering Condt et of Operations Administ rative Procedure 32.0, Nuclear Mate _ rial Control Adminis.rative Procedure 34.0, Administrative Controls for Fuel Handling Procedures for Implementing the North Anna Power St stion Planned Maintenance System, Electrical This is an Inf raction.
As reo" ired by 10 CFR 50, Appenaix B, Criterion XIII " Measures shall G.
be established to control the handling, storage, shipping, cleaning in accordance with work and and preservation of material and equipment deterioration." The inspection instructions to prevent damage or Section 17.2.0.2, Table
./.2.b accepted Quality Assurance Program, states in part that it " conforms as clarified in ANSI N45.2.2-1972,
" ANSI N45.2.2-1972, Section 7 (Handling), Paragraph 7.3, (Hoisting Equipment) states in part:
" Hoisting equipment used for bandling shall be certified by the manufacturer"; and Paragraph 7.4 (Inspection states in part: "An inspec-of Equipment and Rigging) states in part:
tion program shall be establisheu for eq.ipment and rigging."
Contrary to the above, no inspection program had been established for handling equipment and rigging used for safety-related equipment, nor could it be determined that the handling equipment had been certified by the manufacturer.
I o
4
Appendix A Virginia Electric and Power Co.
Notice of Violation License No. NPF-4 This is an Infraction.
As required by 10 CFR 50, Appendix B, Criterion V, " Activities affecting quality shall be prescribed b. focumented instructions, procedures, cc H.
drawings of a type appropriate to the circumstances and shall be these instructions, procedures, or accomplished in accordance with drawings." fhe accepted Quality Assurance Program, Section 17.2.5 states in part:
"Section 5 of the Nuclear Power Station Quality Assurance Manual (NPSQAM) describes the sequence of actions and the requirements for developing, reviewing, approving, and controlling
." NPSQAM Section 5, Paragraph 5.0 states in part:
procedures "Each nuclear power plant shall be operated and maintained in accordance with written procedures all material or 1.
NPSQAM Section 7, Paragraph 4.3 requires that equipment purchased by receipt inspected by store personnel and accepted by the Quality Assurance Staff.
Contrary to the above, s :.ty related valves and pipe flanges were obtained from Unit 2 construction warehouse for use in Unit I without the required receipt inspection or QA acceptance.
The accepted Quality Assurance Program (17.2.6) states in part:
established describing the control of 2.
" Measures are
.to provide for their review, approval and issue documents,
." and ".
Instructions prior to release require that a copy of the appropriate procedure be available at the activity location prior to the cournencement of that activity.
as of February 2,1979, measures did not Contrary to the above, assure documents were approved for release and used at the location the design where the prescribed activity was performed in that change DC-78-09 (Boric Acid Pump Insulation) was implemented prior to the approval of the final design controlling yrocedure.
The accepted Quality Assurance Program Section 17.2.6 states in 3.
Procedures and drawings and changes thereto are part ".
pracessed, distributed and controlled by by the Station Records Section of the program further Department
." The same states in part ".
Section 6 " Document Control of the Nuclear Power Station Quality Assurance Manual lists and defines certain documents that require strict administrative control for distribution, revision and routing.
These documents are:
Station Procedures,.
Station Drawings.
b [, ul4
- s
- . v,s s
, Appendix A Virginia Electric and Power Co.
Notice of Violation License No. NPF-4 above Station Drawings were not controlled in Contrary to the that on February 2,1979, two of three safety-related drawings were maintained by the Electric Shop contained selected that later revisions than the same d:awings in the Station file.
This is an inf raction.
The accepted Quality Assurance Program Section 17.2.3 states in 4.
The Nuclear Power Station Quality Assurance Manual establishes measures for the selection and review for part:
application of materials, parts, equipment and suitability of are essential to the safety-rea!ted functions e.'
processes that The NPSQAM Section 3, the systems, structures and components.
Paragraph S.7.5 states in part:
"The materials required to complete the design changes shall be tabulated on the " Materials List" form.
Contrary to the above, as of February 2, 1979, measures were not established for the selection and review for suitability of in that the final design for design application of materials change DC-78-09 (Boric Acid Pump Insulation) required the installa-tion of a calibrated thermometer yet the materials list included It was noted that a metallic strip was installed, no thermometer.
t This is an Inf raction.
As required by 10 CFR 50, Appendix B, Criterion XVII, Suf ficient records shall be maintained to furnish evidence of activities af fecting I.
The records shall include at least the following: Operating quality.
Logs and the results of reviews, inspections, tests, audits, monitoring of work performance, and materials analyses.
"The accepted Quality
" Quality Assurance records Assurance Program (17.2.17) states in part:
are maintained in accordance with the Technical Specificaton These records and the Nuclear Power Station Quality Assurance Manual.
include operating logs; results of reviews, inspections, tests, audits and material analysis monitoring of work performance,
." ANSI N45.2.12 (Draf t 3 Revision 4-1974), as comitted to by the "An audit report, which shall be signed accepted QA Program, states:
4.4.3 Persons by the audit team leader, shall provide:
contacted during pre-audit, audit and post-audit activities.
Contrary to the above, records documenting activities af fecting quality were not maintained for the following items:
Records of required design change package reviews were not completed for four (4) design changes, each oi which had been implemented 1.
f rom six (6) to nine (9) months prior to this inspection.
w000ff,)f 00 fi[ d n
, Appendix A Virginia Electric and Power Co.
Notice of Violation License No. NPF-4 No documentary evidence existed in 11 of 13 audits identifying 2.
those persons contacted for pre-audit conferences.
This is a Deficiency.
As required by 10 CFR 50, Appendix B, Criterion VI, " Measures shall be J.
These measures established to control the issuance of documents.
." The shall assure that documents are reviewed for adequacy.
accepted Quality Assurance Program, Section 17.2.17, states in part:
conform to for record transmittals.
"The requirements.1.88, August 1974
." Regulatory Guide 1.88 Regulatory Guide endorses ANSI N45.2.9-1974, ANSI N45.2.9 Paragraph 4.3 states in part:
1.
A As a minimum, a receipt control system shall include:
".records check list designating the required quality assurance records Contrary to the above, measures had not been established to control issuance of documents by construction to the licensee in that no the methods existed to designate the individual records included in any specific package of records material.
This is a Deficiency.
required by 10 CFR 50, Appendix B, Criterion X, "A Program for Asinspection of activities affecting quality shall be established and K.
executed by or for the organization performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity".
The accepted Quality Assurance
" Inspection procedures for Program, Section 17.2.10 states in part: effecting quality have been established an those activities included in the Nuclear Power Station Quality Assurance Manual Section 13, Paragraph 5.2.5 of the NPSQAM states, " Items in storage shall be periodically inspected to ensure the integrity of packaging, including end caps for piping, vapor barrier integrity, or preservatives when used." Additionally, paragraph 5.5.2 (3) states: "Where pipe caps are used, these caps shall be maintained in place until they interfere with the f abricated process."
Contrary to the above, the licensee failed to establish a procedure Add'tionally, pipe caps were not installed for the required inspections.
on s afety-related pipe in Level D storage to provide protection against the elements, airborn contamination, and physical damage.
This is a Deficiency.
L.
As required by 10 CFR 50, Appendix B, Criterion I, ".
The authority and duties of persons performing activities.
The shall be clearly established and delineated in writing.
t
, Appendix A Virginia Electric and Power Co.
Notice of Violation License No. NPF-4 quality assurance functions are those of (a) assuring that an appropriate" quality assurance progrs= is established and ef fectively executed.
17.2.1.2.3 states in The accepted Quality Ararance Program, Sectionduties and responsibilities of t part under the Control Engineer that he" 4) performs specific quality assurance for the Station Manater (e.g.
. procedure reviev functions
.) as specified in the Nuclear Power Station Quality Assurance Section 4.2.b states in part that the role of the Manual (NPSQAM).
Station Resident Quality Control Engineer is to " Provide on a continuous basis, objective specified quality assurance and quality control services (Eumples:
procedure reviews.
.)".
of assuring that Contrary to the above, the quality assurance functior:
an appropriate quality assurance program is establ:. i.-i and executed had not been performed as of January 31, 1979, f a that procedures implementing that quality assurance program had not been reviewed by the quality assurance organization.
Specifically, Administrative Procedures 12.0 (Station Training), 37.0 (Control of Work and Special Processes), 39.0 (Station Drawing Revision Distribution), 43.0 (Records Management), and 45.0 (Housekeeping) had not been reviewed.
This is a Deficiency.
f[O
[i'C,/[] lk lll l
! l[,
4'
- s s
t N
/
[
48a" 246