ML19270F483
| ML19270F483 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 02/08/1979 |
| From: | Howe P CAROLINA POWER & LIGHT CO. |
| To: | Ippolito T Office of Nuclear Reactor Regulation |
| References | |
| NG, NUDOCS 7902140181 | |
| Download: ML19270F483 (1) | |
Text
.
Carolina Power & Light Company FILE: NG-3514(B)
February 8, 1979 Office of Nuclear Reactor Regulation ATTENTION:
Mr. T. A. Ippolito, Chief Operating Reactors Branch No. 3 United States Nuclear Regulatory Commission Washington, D. C.
20555 BRUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 AND 2 DOCKET NOS. 50-325 AND 50-324 LICENSE NOS. DPR-71 AND DPR-62 DISTRIBUTION OF NRR CORRESPONDENCE
Dear Mr. Ippolito:
Carolina Power & Light Company has retained the LIS Division of NUS Corporation to provide us with assistance in non-proprietary licensing related issues involving our nuclear power plants.
The purpose of our contract with NUS is to provide us with the most up-to-date information concerning non-proprietary licensing issues and to help us in expediting our resporsts to information requests by the NRC staff.
To facilitate this transfer of information we would appreciate your office adding NUS to the standard distribution list for non-proprietary letters which you send out concerning our Brunswick Steam Electric Plant.
Please continue to distribute proprietary letters only to CP&L. Please address the copies to:
NUS Corporation (LIS) 2536 Countryside Boulevard Clearwater, Florida 33515 Yours very truly, W
P. W. Mcwe Vice President Technical Services Department DLB/gts
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Method of Accomplishment The preceding objectives were accomplished during a meeting on November 13, 1978.
a.
Attendees were:
F. D. Carpenter, Manager, Quality Systems Department T. R. Colandrea, Director, Quality Assurance Division R. C. Dahlberg, Director, Fuel Engineer Division A. E. Dohna, Senior Project Engineer, QA C. R. Fisher, Acting Director, Licensing B. M. Gregory, Senior Project Engineer, QA S. L. Koutz, Director, Plant Engineer Division W. J. Mahler, Manager Purchasing D. Pettycord, Senior Project Engineer for QA J. H. Rusk, Manager, Quality Operating Branch J. C. Stumpf, Director, Planning and Economics b.
The VIB organization was described and its relationship to NRC Region IV and the NRC Headquarters component of the Office of Inspection and Enforcement.
c.
The LCVIP was described including its objectives, its implementation structure, and the mure significant program changes relative to GAC.
d.
The conduct of VIB inspections was described and how our inspcctions are documented including the report, responses to reports, how proprietary information is handled, the Public Document Room, and the White Book.
e.
The purpose, scope, and status of the NRC's two year program for evaluation of the ASME inspection systems as an acceptable independent third party were discussed, f.
Our previous inroections of GAC were reviewed and the management personnel were advised ci the necessity to obtain NRR:QA3 approval of QA Program cha.ges prior to their implementation.
g.
The Director, Planning and Economics described GAC's current domestic nuclear activity as comprising about two-thirds of their effort, mostly on advanced reactor designs.
Subsequent to this meeting, discussions with GAC Licensing personnel dealt with their ongoing and future cctivities.
. REPORT DETAILS (Prepared by J. M. Johnson and C. J. Hale)
A.
Persons Contacted.
P. L. Boortz, QA Analyst D. J. Harris, Component Manufacturing QA Manager
- W. R. Horning, Senior Systems Analyst, Management Systems R. Kerr, Senior Quality Engineer
- J. H. Lewis, Project Licensing Engineer
- P. A. Miller, Manager, Records Control Branch
- D. Pettycord, Senior Project Engineer, Quality Assurance S. Roy, Department Clerk, Quality Assurance Records
- J. H. Rusk, Manager, Quality Operations Branch
- Denotes those present at exit meeting.
B.
Management Meeting 1.
Objectives The objectives of this meeting were to accomplish the following:
Meet with the General Atomic Company's (GAC) nanagement and a.
those persons responsible for the administration of the GAC QA Program.
b.
Describe the Licensee Contractor / Vendor Inspection Program (LCVIP) organization, c.
Describe the LCVIP, its implementation, and the more significant changes in the LCVIP.
d.
Describe the Vendor Inspection Branch (VIB) inspection methods and documentation.
Describe the NRC evaluation of the ASME system of inspection.
e.
f.
Summarize our previous inspections of GAC.
g.
Determine the current and projected GAC involvement in domestic nuclear power plants.
3.
(0 pen) Deviation (Report No. 77-01):
Elements of the QA Program have not been audited at least once each year, specifically training and QA records.
Reinspection disclosed that an audit report of training was issued in February 1978, and an audit report of records was issued November 15, 1978.
Audits have been scheduled on a yearly basis; however, the GA committed action was to audit training in July 1977, and July 1978, and QA records in February 1977, and February 1973, which was not accomplished to provide yearly auditing. Also, the committed preventive action of yearly scheduling has not assured that audits will be performed of the required areas on a 12 month basis.
(See Notice of Deviation Enclosure, Item A.3.)
4.
(Closed) Deviation (Report No. 77-01):
Certain audit activities affecting quality were not performed in compliance with procedures of the GA Quality Assurance Manual.
The committed corrective action was to assure compliance with the QA Manual in signing and dating commitments to corrective action by responsible management; however, reinspection indicated that instead the QA procedure was revised modifying this requirement.
- Also, refresher training was committed to be given to all qualified QA auditors as preventive action.
Four (4) auditors were not given refresher training, and now this requirement for yearly refresher training for recertification of auditors has also been deleted from the QA procedural requirements. The QA Manual was revised as conmitted to require yearly audit scheduling.
(See Notice of Deviation Enclosure, Item A.4.)
5.
(0 pen) Deviation (Report No. 77-01):
Seven (7) new employees hired between June 1975, and March 1977, had not been required to attend QA indoctrination training session.
Reinspection indicated that the committed retrofit of QA indoctrination for GA employees was not completed by August 1, 1977, and, in fact, has not yet been completed for some quality-affecting employees hired in 1975.
Also, the ccmmitted preventive action indicated resumption of regularly scheduled training sessions, but sessions have not been scheduled to the required frequency, and a number of employees (approximately 45) have not received QA training, although they have been employed more than 60 days.
(See Notice of Deviation Enclosure, Item A.5.)
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3.
Findings i
The GAC personnel were attentive during the presentation 5
a.
m i and particularly interested in how the NRC would be verifying implementation of 10 CFR Part 71, Appendix E.
b.
During discussions with GAC Licensing it was found that technical effort is ongoing in each of the following areas:
core seismic program; graphite design criteria; fuel performance verification; time dependent release (fission products); maximum heat flux model; Regulatory Guide compli-
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ance; general design criteria; siting criteria; radioactive release methodology; and selection of design basis accidents.
Each of these areas are being considered for two besic plant options, defined by GAC as the Steam Cycle and the Gas
-Turbine.
The ultimate use of this technical information would be in a licensing application either directly in a Safety Analysis Report or in the form of a referenced topical report.
GAC personnel could not state, however, when a reactor order (and subsequent license application)
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might occur.
No deviations or unresolved items were identified in this c.
area of the inspection.
C.
Action on Previous Inspection Findings a
1.
(Closed) Deviation (Report No. 77-01):
Quality Assurance and Engineering Departments do not have procedures covering all elements in ANSI N45.2.9 for control of records.
Reinspection disclosed that Quality Assurance and Records Control Branch (RCB) of Engineering procedures have been issued. Also, Records Study i
s progress reports were made on September 1,1977, and October 20, 1977.
However, the RCB procedure was issued on March 31, 1978, rather than by the committed date of Sep+2mber 30, 1977.
(See Notice of Deviation Enclosure, Item A.1.)
t 2.
(0 pen) Deviation (Report No. 77-01):
Duplicate records of design specifications were not being stored in separate remote locations. Reinspection disclosed that duplicate design records sent to a separate remot? locaticq did not include all design records. Of four (4) word documeats checked (including specifica-
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tions), three (3) were missing from the duplicate file. Also, RCB procedures were issued on March 31, 1978, rather than by the committed date of September 30, 1977.
(See Notice of Deviation Enclosure, Item A.2.)
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. c.
Documents to verify implementation of topical commitments and procedural requirements, and to satisfy the intent of the Objectives section above:
(1) QA Audit Report 78038; QA Audit Report 402 and CAR (Corrective Action Request) 402-1; QA Audit Report 78033; QA Audit Report 78035 and CAPS 78035/1 and 78035/2; QA Audit Report 78033.
(2) thnagement Audit tio. 378.
(3) Auditor qualifications for nine (9) auditors, including certifications for both Lead Auditors and Auditors.
3.
Findings In this area of the inspection, no unresolved items were identified.
One (1) deviation from commitment was identified.
(See flotice of Deviation Enclosure, Item B.)
E.
_T_rai ni ng 1.
0_hjectivas The objectives of this area of the inspectior, were to verify that:
a.
A training program meeting commitments is er,tablished, delineated by procedures, and implemented.
b.
Training is performed and documented for inspection and examination and testing personnel, including certification as required.
c.
Training and testing are performed and documented for personnel who perform, write procedures, or evaluate nondestructive examinations, including certification of qualification, and results of tests (including eye tests),
as applicable.
d.
Training is performed and documented for audit personnel, includir.g certification of lead auditors as required.
e.
Training is performed and documented for Quality Assurance personnel, and personnel in other quality-affecting depart-ments, in applicable procedures, codes, standards, and other requirements.
_7_
D.
Audits 1.
Objectives The objectives of this area of the inspection were to verify that:
a.
An audit system is established, delineated by procedures, and implemented, has organizational independence, authority, and meets commitments.
b.
Audits are scheduled and performed at required intervals of all quality-affecting activities.
c.
Auditors are qualified and independent of direct responsibil-ity for activities being audited.
d.
Audit reports are properly documented, distributr.d, and contain scope, identification of auditors and persons contacted, summary of inspection, and delineation of nonconformances.
Audit records show proposed / accomplished correccive action e.
for nonconformances (and preventive action as aoplicable) and verification of implementation.
f.
A system exists to evaluatt cad report periodically to management the effectiveness of the quality assurance program.
2.
Method of Accomplishment Tne preceding objectives were accomplished by an examination of:
a.
Ceneral Atomic Topical Report No. GA-A13010A, Amendments 3 and 4:
Section 17.18, Audits; Section 17.16, Corrective Action; Table 17-3, Codes and Regulation Compliance; and Section 17.2.6, Management Review of the Status and Adequacy of the QA Program.
b.
Implementing procedures to satisfy '.opical commitments and to satisfy the intent of the Objectives section above:
(1) Quality Assurance Manual:
Quality Procedure (QP) 18, Audit Procedures; QP 16, Corrective Action.
(2) Quality Division Instructions (QDI): QDI 18-1, Quality System Audits; QDI 18-2, Auditor Qualifications.
F.
QA Records 1.
Objectives The c'fectives of this area of the inspection were to verify that:
a.
A QA records system meeting commitments is established, delineated by procedures, and implemented for all quality records (e.g. design, procurement, licensing, QA, manu-facturing).
ti.
QA record storage in single or dual facilities is described and complies with codes, standards and regulations consistent with NRC Reg. Guide 1.88.
c.
Receipt and reproduction (e.g. microfilm, microfiche, etc.)
are control.ed and include a list of required records, identification of records received, review for legibility and completeness, a filing system, controlled access and accountability.
d.
QA records in the storage facility are legible, complete, identifiable to the item, listed in an index showing retention time and location, retrievable, and have not deteriorated.
e.
The QA record storage system is periodically audited for conformance to the above system and requirements.
2.
Method of Accomplishment The preceding objectives were accomplished t'y an examination of:
a.
General Atomic Topical Report No. GA-A13010A, Amendments 3 and 4:
Section 17.17, Quality Assurance Records; and Table 17-7, Codes and Regulation Compliance, b.
Quality Assurance Manual:
QP 17, Quality Assurance Records.
c.
Quality Division Instructions:
QDI 17-3.
d.
Records Control dranch (RCB) Procedures:
Sections 5 and 7.
e.
Documents to verify implementation of topical commitments and procedural requirements, and to satisfy the intent of the Objectives section:
_g_
2.
Method of Accomplishment The preceding objectives were accomplished by an examination of:
a.
General Atomic Topical Report GA-A13010A, Amendments 3 and 4:
Section 17.2.5, Training; Section 17.18, Audits; Section 17.10, Inspection; Section 17.9, Control of Special Processes; and Table 17-3, Codes and Regulation Compliance.
b.
Quality Assurance Manual:
Quality Procedure (QP) 20, Quality Assurance Training; QP 9, Special Procees Training; QP 10, Inspection.
c.
Quality Division Instructions: FAI 18-2, QDI-NDE 3801; QDI NDE 3817.
d.
Documents to verify implementation of topical commitments and procedural requirements, and to satisfy the intent of the Objectives section:
(.1) Certificates and their basis for three (3) NDE (Non-Destructive Examinatica) Enginters (one Level II and two Level III).
(2) Certificate for one (1) Source Inspector.
(3) Checklists showing completion of QA Division training for four (4) QA personnel.
(4) Records of initial QA Indoctrination including scope, frequency, attendance lists, and identification of GA personnel in quality-affecting positions who have not yet attended a QA Indoctrination Session.
(5) Certificates for nine (9) auditors.
3.
Findings In this area of the inspection, no unresolved items or deviations from commitment were identified.
a.
See related deviations identified in Notice of Deviation Enclosure, Items A.3 and A.5.
b.
Further examination will be made during a subsequent inspection to assure identification of all procedures related to training and to verify their implementation.
.- G.
Exit Meetinc A meeting was conducted with management representatives at the conclusion of the inspection on November 17, 1978.
In addition to the individuals indicated by an asterisk in Section A above, those in attendance were:
F. D. Carpenter, Manager, Quality Systems Department F. C. Dahms, Senior Project Engineer A. H. Dohna, Senior Project Engineer, QA C. R. Fisher, Acting Director, Licensing B. M. GregJry, Senior Project Engineer, QA P. S. Hunt, GCFR Systems Department Manager J. G. Kelly, Manager, Quality Engineering S. L. Koutz, Director, Plant Engineering Division W. J. Mahler, Manager, Purchasing The inspector summarized the scope and findings of the inspection and discussed the status of the deviations from the previous inspection.
Management representatives acknowledged the statements of the inspector.
It was explained that should GA be unable to meet a committed date for corrective action or wish to alter a committed corrective action, it would be appropriate to submit a written request including justification for such a modification.
. (1) Engineering RCB word documents indexed and in duplicate storage facilities:
N901984, Revision A (Reactor Core-Design Criteria).
P900102, Revision A and B (Design Specification-Helium Dryer Unit).
M900794, Revisions A and B (Mechanical Design and Design Verification of Incore Flux Map Unit).
E901088, Revision A (Incore Flux Mapping Signal Modifier Specification).
(2) Engineering RCB drawings indexed and in duplicate storage facilities:
M017768-001, Revision A and B (Hydraulic Panel).
M019369-001, Revisions A, B, E and F (Upper Structure Assembly).
M000797, Revision A and B (Tube Bundles for CEA Excitation Test).
M203681, I/. visions A and B (Tube Bundles for CE Excitation Test cross-referenced by M000797 above).
(3) QA Division records retrievable in duplicate storage facilities:
QA Audit 78016; QA Audit 402; Follow-up Audit 78001.
QP 17, Revisions C, D, E, and H.
(4) Remote storage of microfilm, cassettes and three (3) different radiog aphs.
3.
Findings In this area of the inspection, no unresolved items and no deviations from commitment were identified.
a.
See related deviation identified in Notice of Deviation Enclosure, Item A.2.
b.
It was noted that there is a time lag in the indexing of certain QA Division records which makes retrieval difficult.