ML19273B525

Responds to NRC 790221 Ltr Re Violations Noted in IE Insp Repts 50-324/79-02 & 50-325/79-02.Corrective Actions: Requirement of Written Bases on All Mod Packages & Closed Items Will Be Removed from Log of Open Items

ML19273B525
Person / Time
Site:	Brunswick
Issue date:	03/14/1979
From:	Furr B CAROLINA POWER & LIGHT CO.
To:	James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II)
Shared Package
ML19273B523	List: ML19273B525
References
GD-79-654, NUDOCS 7904090062
Download: ML19273B525 (12)

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CfB&L Carolina Power & Light Company

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March 14, 1979 on MAR l6 P 4 : 42

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File: NG-3513 (B) .. Serial:..GD-79-654 MJ C . $

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Mr. James P. O'Reilly, Director U. S. Nuclear Regulatory Commission Region II 101 Marietta Street, Suite 3100 Atlant5, Georgia 30303 ERUNSWICK STEAM ELECTRIC PLANT, UNIT NOS. 1 & 2 LICENSE NOS. DPR-62 AND DPR-71 DOCKET NOS. 50-324 AND 50-325 RESPONSE TO IhTRACTIONS OF NRC REQUIREMEh7S

Dear Mr. O'Feilly:

Brunswh k Steam Electric Plant has reviewed IE Inspection Reports 50-324/79-02 and 50-325/79-02 and find that it does not contain any infomation of a proprietary nature.

The report identified eleven (11) items which appear to deviate from NRC requirements. The one item satisfactorily closed during the inspection is incorrectly identified in Appendix A of the report -

as Item J. This item requiring no response should be Item K in Appendix A and is correctly identified in Paragraph 5.b of the body ~

of your report. The ten (10) items requiring a response, one (1) unresolved item for which a response was requested, and Carolina Power & Light Company's responses to them are addressed in the . .

following text.

Infraction A. 10CFR50, Appendix B, Criterion XIII, states in part:

"Heasures shall be established to control the bandling, storage, shipping, cleaning, and preservation of material and equipment."

The accepted Quality Assurance Program (letter dated September 11, 1975), Para;;raph 6.A, states in part: " Packaging, shipping, receiving, storage, and bandling of BSEP items are in accordance with applicable requirements of ANSI N45.2.2-1972. . ." ANSI N45.2.2-1972, Section t.

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2, states in part: " Measures shall be . . . implemented for the g packaging, shipping, receiving, storage., and handling of specific ._._

items . .

. 2.2 Procedures and instructions shall be generated, 4 .m L used, and maintained current; these shall contain . . . a basis for

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packaging design, shipping requirements, receiving, storage and ~

handling procedures, implementation thereof, and inspection, in j accordance with this standard." ., .,y~ ,

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Mr. James P. 6'Reilly 42-t Contrary to the above, as of January 10, 1979, measures had not been established to control activities in accordance with the require-ments of the accepted QA Program in that, as examples not to be considered as all inclusive, the requirements for packaging delineated in Sections 3.1, 3.5, and 3.7 were not met; the shipping requirements

1. . . of Section 4.3 were not met; the receiving activities were not in accordance with the _rquirements of Section 5.2; the storage of material was not in accordance with the requirements of Sections 6.1, 6.2, 6.3, 6.4, and 6.6; and, the handling activities did not

- - comply with the requirements of Sections 7.2 and 7.5.

Carolina Power & Light Company Response A review of Al-1 (Haterial Requisition, Receiving and Storage) is presently in progress to identify in detail where AI-1 it fails will be to rewritten meet the requirements of ANSI N45.2.2-1972. 15, 1979. A along with additional procedures as necessary by June training program will be implemented to retrain plant Stores personnel on these new procedures. The training of all Stores personnel in their respective jobs will be completed by July 15, 1979.

It is presently considered that to fully comply with the require-ments of ANSI N45.2.2 as we understand them based on your inspection, substantial changes may be required in our warehousing capabilities.

We had authorized and designed Level 1 storage facilities for Brunswick Also, the in 1978, and these are scheduled for completion in 1979.

Company Materials Management Section (CMMS) is presently performing a study to address the requirements of ANSI N45.2.2shall This survey and bethose actions completed needed to implement the requirements.and if modifications are found to be required, prior to June 15, 1979, they will be fully implemented prior to December 31, 1980.

Additionally, the following actions have been taken relative to 2 the inadequacies discussed in Paragraph 7.b.(1), (2) and (3) of the report.

7.b.(1) Warehouse H (a) The bags of salt have been removed. ,

(b) Stainless steel piping has had the ends capped, carbon bands removed or tape applied between bonding and pipe, and piping has been removed

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from floor / ground.

(c) Resolution to this item will be included as part of the study indicated above.

• - (d) Covers have been placed on the MG set motors.

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(e) Warehouse H is being cleaned to properly implement the housekeeping requirement. Most of the

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~ *~~ ~ ' Mr. ~ James F. O'Ke111y -J- ---- - 9 identified items have already been corrected, and the remaining items will be completed by July 15, 1979. ~The revisions to AI-1 will include the requirements for the cleanliness control / housekeeping program.

(f) Food is no longer being prepared outside the office area of Warehouse H.

(g) As a temporary measure for controlling rodents, poison has been located in various areas within the plant. A formal control program will be implemented prior to July 15, 1979.

(b) The requirement for humidity controls will be addressed in the CMMS Study being performed.

(i) These valves were originally purchased as safety-relief valves, but due to a change in plans, no safety-relief valves of this type are installed nor have ever been installed at the Brunswick Plant. These valves are not Q-list material.

(j) The subject of Q-list segregation will be addressed as part of the CMMS Study.

(k) Level segregation will be addressed as part of the study.

(1) Bags and packaging open to atmosphere have been sealed. The carbon filter packages have been secured.

(m) Q-list wire reels now have wire cecured.

(n) Segregation will be addressed in the CMMS Study.

(o) Receipt inspection areas will be addressed in the CMMS Study.

(2) Warehouse C (s) Warehouse C is under control of Radiation Control and Test and is not at present a part of Stores Warehousing. The bay in question is used by Maintenance along with three other bays. The Q-list parts have had QA Hold Tags attached until disposition is determined, and e lock has been attached to this bay under Maintenance control. The future use of Warehouse C will be considered in the Corporate Materials Management

• Section Study addressed in the text of Item A response.

Mr. James P. O Rei y (b) All four bays used by Maintenance have been locked and the keys are under Maintenance control.

See Item (a) above for further information.

(c) Stainless steel pipe has been capped and removed from the ground and identified.

(d) Currently it is not planned to use Warehouse C as a Level A or B storage area; therefore, no

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temperature controls would be necessary. If it is determined that Warehouse C should be a Level B area, the necessary heating controls would be installed.

(3) In Plant Warehouse (a) An inspection of Q-list valves stored in the Stockroom was made and no open valves were found.

(b) Shelf-life control will be resolved as indicated

' in response to Infraction D.

Infraction "The B. 10CFR50, Appendix B, Criterion 11, states in part:

applicant shall establish at the earliest practicable time, consistent with the schedule for accomplishing the activities, a quality assurance This program which complies with the requirements of this appendix.

program shall be documented by written policies, procedures, or instructions and shall be carried out throughout plant life in ."

accordance with those policies, procedures, or instructions. .

The accepted Quality Assurance Program (letter dated September 11, 1975), Paragraph 12, states in part: "The applicable requirements of N45.2.3-1973 are followed at BSEP. . ." (Letter dated February 27, 1975) Paragraph 10 states in part: "The requirements for collec-tion, storage, and maintenance of QA records at BSEP will be in accordance with ANSI N45.2.9-1974. . ."

Contrary to the above, as of January 10, 1979, the licensee had not established a program for activities which were being conducted in the housekeeping and records areas consistent with his accepted Quality Assurance Program submitted to meet the requirements of Appendix B, in that, as examples not to be considered as all inclusive, the ANSI N45.2.3 requirements were not implemented in the housekeeping areas as required by Section 1.1; in the control of site areas as described in Section 3.1; in the areas of fire prevention and protection as described in Sec.fon 3.2.2; and, ' e surveillance andWith inspection respect requirements o'f Section 3.5 were not being fully met.

to ANSI N45.2.9, the index requirements of Section 3.2.2 and the storage requirements of-Section 5.2 were . .: ,not implemented.

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Br. James P. O'Reilly .

Carolina Power & Light Company Response

A. With respect to ANSI N45.2.9-1974:

1. An in-depth study of the plant's document control program was initiated in 1978 and will, upon completion, address indexing, storage, and facility requirements.

This study is being performed by an independent third d to be completed a by party, Tera Corporation, and is expecteUpon completion of t July 1, 1979 evaluation will be made of the results and changes made as necessary.

2. The microfilming equipment was removed from the

. permanent vault on February 22, 1979.

3. Master copies of engineering drawings and master copies of vendor instruction manuals are in the process of being transferred to the permanent vault.

This will be completed prior to June 30, 1979.

4. Calibration records of safety-related instruments will be transferred to the permanent vault as soon as the listing of which instruments are in this category The resolution of this item is dependent is determined.

upon the actions required in Items C & H of your report.

5. Vault personnel have been instructed in those actions required in case of fire and procedural control will

.be provided by June 30, 1979.

6. The necessary controls of vendor instructionThese manuals

-will be established by revisions to AI-2.

revisions shall be made prior to June 30, 1979 7

In order to insure that all required QA records are being retained, a review of required QA records will

.be completed by June 30, 1979.

.B. With respect to ANSI N45.2.3-1973:

is underway by the A complete review of ANSI N45.2.3-1973 plant staff and the necessary controls will be implemente as dictated by this review.

and controls implemented by September 1, 1979.

1 .4 Jnfraction

.* .i C. 10CFR50, Appendix B, Criterion X11, states in part:instruments,

" Hessures shall be established to assure that tools, gages, i ffecting e and other measuring and testing devices used in activit es a d quality are properly controlled, calibrated, and adjusted at specifi

46- March"IEI'1979 '~

Mr. James P. O'Reilly periods. . .

" The accepted Quality Assurance Program (Corporate QA "A calibration program Manual, Part 2), Section 6.4, states in part:

shall be developed. . ." and "shall include: . . .d. The calibration frequency. . ." _

Contrary to the above, as of January 16, 1979, measures had not been established to assure that instruments used in activities affecting quality were properly calibrated at specified intervals in that:

- there was no program in effect for periodic calibration of Instrument and Control group safety-related instruments which are utilized in verification of Technical Specifica-tion values listed as Limiting Conditions for Operations; and,

- one procedure which had been used during the preoperational calibration of instruments in this category could not be used as currently written because it (MP3-3F) could not be physically booked up as it was during the original bench test and it incorrectly specified that out-of-specification reading obtained prior to adjustment be averaged with correct reading obtained after adjustment to provide the "as left" setpoint.

Carolina Power & Light Company Response Since these instruments do not actually perform a safety function, it has been a normal practice to calibrate them during installation or initial operation and recalibrate following any maintenance on the instruments. As a result, these instruments were not on a regular schedule for recalibration.

The list of instruments affected has now been identified with the exception of Environmental and Fire Protection instruments which are still being evaluated. These include instruments which are utilized in verification of Technical Specifications values but have no apecific surveillance requirements identified. Due to the number of instruments involved and the instruction that must be written, implementation will be as follows:

The listing of Environmental Technical Specification instruments and those required by the Fire Protection Program shall be determined by October 31, 1979, and included in the calibration program as indicated below.

The instructions are being written and will be approved and implemented as each instruction is completed. The entire calibration program, including frequency of calibration require-sents, will be implemented by December 31, 1979.

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Hr. James P. O'Reilly Infraction "Activi- ,

D. 10CFR50, Appendix B, Criterion V, states in part:-  ;

1. ties affecting quality shall be prescribed by document +d 4..; &zetions, -

(, . and shall be accomplished in accordance with these 3 procedures. .

." The accepted Quality Assurance.

instructions, procedures. . _,_

[ Program (Corporate QA Manual, Part 2), Section 5.4.2,ista Tpart:

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q Define handling, storage, cleaning, and preservatTon requirements.

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? " Administrative Instruction 1 (AI-1), Section 5.4.1, states ind s . . .

part:

. . .Q-list material shall be stored so as."to meet or exceeSection 5.

the storage requirements set forth in Appendix A."All items with a shelf-life will of the same AI-l states in part:

be indicated. . . to remove these items at expiration of their shelf-life."

Contrary to the above, as of January 10, 1979, activities affecting quality were not accomplished in accordance with written instructions in that there was no segregation of Q-list no method existed for identification or control of shelf-life items.

Carolina Power & Light Company Response Procurement of spare parts has been computerized and provides However, this phase of the compu-means for identifying shelf-life. Until such time, terized program has not been fully implemented.

procedures to provide identification and control Theof shelf-life items procedures will be developed which is presently in progress. Full implementation of the will be completed by June 15, 1979.

program 1979.

to control shelf-life will be implemented by Au addressed in the study addressed in our response to Item A.

Infraction "Activi-E. 10CFR50, Appendix B, Criterion V, states in part: i ties affecting quality shall be prescribed by documented instruct on,

. . and shall be accomplished in accordance with these procedures. ." The accepted Quality Assurance instructions, procedures. .

30, 1977), Paragraph 5, states in part:

Program (letter dated March" Radiation survey /racasuring instruments of emanating / airborne radioactivity, as required for personnel safety, and chemical / radiochemical analysis instruments Operatingshall be g calibrated. . . as outlined in Volume VIII.of the Plant r i

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$ 16, 1979,'J ctivi tic _4 3,

Contrary to the above, as of January procedures ,

a affecting quality were not prescribed by documented s as follows

3 and/or not accomplished in accordance with procedurep Volume VIII of the Plant Operating Hanual $.ui ncI .cantain 7 procedures for calibration of radi,ation survey / measuring instruments; and,

Mr. James P. O'Reilly -o-Z-

Section 13 of the CP&L Radiation Control and Protection Manual which does 2cify a calibration program for chemical and radiochemical analysis equipment was not implemented

-- - in that:

1) no approved procedures existed for the calibration of

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the Chemistry Laboratory Conductivity Meter;

2) no records were maintained to document the calibration i of the resistance standard used to calibrate the

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' Conductivity Meter on the thermometer used when r calibrating the pH Meter; and r- 3) Volume III of the Plant Procedures Manual did not contain the required calibration procedures.

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i Carolina Power & Light Company Response The letter referenced in Item E will be retracted and resubmitted indicating that these instruments vill be included in the overall

~_~ plant calibration program and included in Section 6, " Calibration jy Control", of the CP&L Corporate Quality Assurance Manual. A revision to the Corporate Quality Assurance Manual, Section 6, will be made during the annual review / revision process, however, those instruments referenced in our letter will be considered to be part of Section 6

- - and will be controlled in accordance with this section.

- Section 13 " Calibration Program" of the CP&L Radiation Control

- and Protection Manual will be deleted and instruments shall be calibrated as required in the Corporate Quality Assurance Program as

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discussed above. This action will be accomplished prior to June 30, IA 1979.

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Procedures /it- cructions that were being used for calibration of This review

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pH Meters and conductivity bridges are being reviewed.

process shall be completed and necessary changes made prior to June 30, 1979.

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A complete review of laboratory instruments used in activities affecting quality is in progress. Those instruments which require

- documentation, traceability, status indicators, and calibration frequency will be included in the overall plant calibration program

' -- by December 31, 1979.

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The required procedures will be developed and included as part of Volume VIII of the Plant Operating Manual.

~h " Infraction 10CFR50, Appendix B, Criterion II, states in part: ".

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The program shall provide for indoctrination and training of The accepted

- personnel performing activities af fecting quality. . ."

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Quality Assurance Program (Corporate QA Manual, Part 2), Section nw .

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• Mr.' James P. O'Reilly .

9.3.1, states in part: " Training plans shall be developed which provide personnel with adequate proficiency of performance

" of quality The accepted achievement and quality verification activities. ..11, 1975) further Quality Assurance Program (letter dated September "The qualifica-states in Paragraphs 2.A and 6.A respectively that:

tion of BSEP inspection, examination, and testing personnel will be in accordance with ANSI N45.2.6-1973. . ." and " Packaging, shipping, receiving, storage, and handling at BSEP items are in accordance with applicable requirements of ANSI N45.2.2-1972. . ."

Contrary to the above, as of January 16, 1979, there was no program for the indoctrination, training, and certification of receipt inspectors as required by Section 1.3 of ANSI N45.2.6 nor was there a program for demonstrating satisfactory ability in handling lifting equipment used in the warehouse as required by ANSI N45.2.2, Section 7.5.

Carolina Power & Light Company Response 4

A procedure is presently being written to document receiptThis proced inspector training and certification.

by June 15, 1979, and full' implemented by July 15, 1979.

A procedure to document proficiency in the use of lifting 15, 1979, equipment used in the warehouse will be completed by June and fully implemented by July 15, 1979.

Infraction 10CFR50, Appendix B, Criterion V, states in part:

" Activities C.

affecting quality shall be prescribed by... procedures...and

~ The shall be accepted accomplished in accordance with these... procedures..."

Quality Assurance Program (Corporate QA Manual, Part 2), Section 11.2.5, states in part: " Audits shall be planned, conducted, and Procedure QAAP-1, Paragraph reported in accordance with procedures..."

6.5.2.c states that the Manager - Corporate Nuclear Safety and Quality Assurance Audit shall "...c. Confirm that corrective action is accomplished as scheduled."

Contrary to the above, finding two on audit QAA/21-09 was closed before the corrective action was completed.

Carolina Power & Light Company Response In preparing Audit Report QAA/21-10, the Lead Auditor The iteminadver-consisted tently closed out an item identified in QAA/21-09. This sistake of two parts in which only one part had been completed.

had been identified prior to this inspection, and action already established to reopen the uncompleted position.

CNS & QAA Procedure QAAl-1 has been amended to require that whenever the lead auditor closes an item, he will assure that it is removed from the log of open items.

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Deficiency H. 10CFR50, Appendix B, Criterion XIV, states in part:

" Measures shall be established to indicate, by the use of markings such as. . . labels . . .the sta tus of inspections and testsThe performed accepted upon individual items of the nuclear power plant..."

Quality Assurance Program (Corporate QA Manual, Part 2), Section 6.5.2, states in part: ". . .Where practical, the calibration status shall be indicated on stickers or tags attached to or accompanying the equipment..."

Contrary to the above, as s' January 16, 1979, measures had not been established to indicate the status of calibration performed on individual items in that, except for instruments designated "M&TE",

there were no stickers on installed plant safety-related instruments.

Carolina Power & Light Company Response Resolution to this deficiency will be made as follows:

1. A review of safety-related systems shall be made to determine which instruments serve a safety function other than solely being pressure retaining. 'This list shall be developed by June 1, 1979.

2. These instruments shall be included in the plant calibration program as required by Section 6, Calibration Control, of the Corporate Quality Assurance Manual. This action will be implemented by December 31, 1979.

3. As these instruments are identified or calibrated, status stickers / tags shall be attached to or accompany the instrument.

This action will be completed by December 31, 1979.

Deficiency I. 10CFR50, Appendix B, Criterion XVIII, states in part: "A comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the quality assurance program. .." The accepted Quality Assurance Program (letter"dated...The Februa ry 27, 1975) General Paragraph 3.A states in part:

CP&L Quality Assurance Audit Program conforms to, and QA audits are conducted in accordance with N45.2.12 (Draft 4, Rev. 1)." ANSI " Applicable N45.2.12 (Draft 4 Rev. 1) Paragraph 3.5.2 states in part:

elements of the qualf , assurance program shall be audited annually or at least once within the life of the activity, whichever is shorter..."

Contrary to the above, periodic annual audits were not carried out as required in that, as of January 16, 1979, audits for the elements of Organization and Responsibility, Procurement Control, Material and Equipment Control, General Plant Operating Procedures,

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Annunciator Procedures, and Document Control had not been audited

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~ - hr. James P. O'Reilly ,

during one or more annual periods between issuance of the Operating License (1974 for Unit 2, 1976 for Unit 1) and date of the inspection referenced above.

Carolina Power & Light Company Response A letter, Serial Number OQA-79-38, dated February 14, 1979, has been submitted to Mr. H. Denton, USNRC, from Mr. E. E. Utley, CP&L, to indicate a new commitment to Regulatory Guide 1.144, January 1979. This commitment indicates that CP&L shall follow the requirements of the Technical Speciiications for performing internal audits.

Deficiency J. 10CFR50.59 states in part: "

...(b) licensee shall maintain records _..These records shall include a written safety evaluation wht:h provides the bases for the determination that the change, test or experiment does not involve an unreviewed safety question..."

The accepted Quality Assurance Program (Corporate QA Manual, Part 2), Section 3.4.1.4, states in part: "...This safety analysis shall provide the technical data, supporting evaluations, and the safety questions considered and analyzed as safe that form the basis for the determination that the modification does or does not involve an unreviewed safety question."

Contrary to the above, as of January 16, 1979, the records of five (5) design changes revieced by the inspector did not include a written safety evaluation which provided the basis for the determina-tion that the change did not involve an unreviewed safety question.

Carolina Power & Light Company Response The plann modification procedure in existence at the time of the inspection required written bases only in those instances when the change did involve an unresolved safety question. Revisions to this procedure approved on February 9,1979, require written bases on all modification packages. All modification packeges developed after February 9, 1979, will include written bases concerning unresolved safety questions.

Unresolved Item Failure to Update Drawings / System Descriptions (Paragraph 9.c of 1&E Report 79-02)

Drawings and system descriptions were not updated and did not reflect as-built conditions. This item was identified by the licensee in Audit Report No. QAA/21-09 and Surveillance Report Nos. 241 and 292 which cover these findings. The Plant Manager stated that due to the large magnitude of work involved in this item (324-325/79-02-34),

the licensee would give responsibilities and completion dates for the following milestones in the response to this inspection report:

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Mr. James P. O'Reilly ..

(1) Completion of a review of all prints and establishment of a priority list for revisions.

(2) Completion of revision of frequently used safety-related prints.

(3) Completion of revision of infrequently used safety-related prints. The response need not address system descriptions as audit QAA/21-09 specifies a complete date of December 1, 1979, for these revisions.

Carolina Power & Light Company Response A review of all prints affected by Plant Modifications completed through 1978 will be reviewed and a priority list established by July 1, 1979. Completion of revision of the frequently used safety-related prints determined by the priority list will be completed by December 1, 1979. The date for completion of revisions of infrequently used safety-related prints will be transmitted to you by August 1, 1979, along with the plan for maintaining these prints up to date.

These corrective actions should correct and prevent recurrence of the violations cited in the Inspection Report 79-02.

Yours very truly, B J. Furr Manager Generation Department DCS:WJD:dej*

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