ML19317F227
| ML19317F227 | |
| Person / Time | |
|---|---|
| Site: | Oconee  |
| Issue date: | 05/14/1974 |
| From: | Jape F, Robert Lewis NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19317F223 | List: |
| References | |
| 50-287-74-05, 50-287-74-5, NUDOCS 8001080938 | |
| Download: ML19317F227 (14) | |
See also: IR 05000287/1974005
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RO Inspection Report No. 50-287/74-5
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Licensee: Duke Power Company
422 South Church Street
Charlotte, North Carolina
28201
Facility Name: Oconee Unit 3
Docket No.:
50-287
License No.:
CPPR-35
Category:
B1
Location: Oconee County, South Carolina
Type of License: B&W PWR, 2568 Mwt
Type of Inpection:
Routine, Announced, Test and Startup
Dates of Inspection: April 29 - May 2, 1974
Dates of Previous Inspection:
February 11-15 and 25-28, 1974
Inspector-in-Charge:
R. C. Lewis, Acting Chief
Facilities Test and Startup Branch
Accompanying Personnel:
R. C. Parker, Reactor Inspector
Facilities Test and Startup Branch
K. W. Whitt, Reactor Inspector
Facilities Test and Startup Branch
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Other Accompanying Personnel:
None
Principal Inspector:
b.
(w '.
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F. Jape, Reactor Inspector
Date
Facilities Test and Startup Branch
Reviewed By:
F 6. L.M
I~ N-k
R. C. Lewis, Acting Chief
Date
Facilities Test and Startup Branch
1
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8001080 7 3 8
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SUMMAAY OF FINDINGS
I.
Enforcement Action
Ncne
II.
Licensee Action on Previously. Identified Enforcement Matters
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Not inspected. This was not within the scope of this inspection.
III.- New Unresolved Items
Deficiencies and weaknesses identified in the implementation of the
Oconee 3 operational quality assurance (QA) program are identified
and grouped as unresolved items to relate to the criteria to Appendix
B to 10 CFR.50.
Deficiencies are grouped in this manner to fat. litate
resolution and closeout.
74-5/1 Quality Assurance Organization (Details, paragraph 3.a)
74-5/2 Quality Assurance Program - Training (Details, paragraph 3.b)
74-5/3 Design Control (Details, paragraph 3.c)
74-5/4 Procurement Document Control (Details, paragraph 3.d)
74-5/5 Instructions Procedures and Drawings (Details, paragraph' 3.e)
74-5/6 Control of Purchased Material, Equipment and Services
(Details,- paragraph 3.f)
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74-5/7 Identification and Control of Materials, Parts and Components
(Details, paragraph 3.g)
74-5/8 Control of Special Processes (Details, paragraph 3.h)
74-5/9
Inspection (Details, paragraph 3.1)
74-5/10 Test Control (Details, paragraph 3.j)
74-5/11 Control of Measuring and Test. Equipment (Details, paragraph 3.k)
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-74-5/12 Handling, Storage and Shipping (Details, paragraph 3.1)
74-5/13 Inspection, Test and Operating Status (Details, paragraph 3.m)
74-5/14 Nonconforming Materials, Parts and Components (Details,
paragraph 3.n)
74-5/15 Corrective Actions (Details, paragraph 3.o)
74-5/16 Quality Assurance Records (Details, paragraph 3.p)
74-5/17 Audits (Details, paragraph 3.q)
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VI.
Status of Previously Reported Unresolved Itecs
Not inspected. This was not within the scope of this inspection.
V.
Unusual Occurrences
None
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VI.
Other Significant Findings
None
VII. Management Interview-
A management exit interview was held on May 2, 1974, to' discuss the
inspection findings. The following personnel attended that meeting:
Duke Power Company (DPC)
-.
J..E. Smith - Plant Superintendent
.J. W. Hampton - Assistant Plant Superintendent
J. O. Barbour - Quality Assurance Manager, Operations
R. M. Koehler - Staff Engineer
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D. C. Holt - Assistant Nuclear Test Engineer
3.- W. Cox - Station Senior Quality Assurance Engineer
O. S. Bradham - Technical Support Engineer
J. W. Davis - Maintenance Engineer
S. A. Holland - Assistant Operating: Engineer
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A.
The purpose and scope of the quality assurance inspection that
had been perfor- ' was explained by the inspectors.
(Details,
paragraph 2)
B.
The unresolved items identified in Section III above were discussed.
Specific deficiencies are described in the report details.
DPC stated they would be' responsive to the inspection findings,
however, there were two items that they would pursue through
the Directorate of Licensing (DOL), as follows:
1.
The DPC letter of April 27, 1973, states that a program of
of inspections to observe for signs of wear, deterioration
or loss of efficiency for safety-related structures, systers
and components will be included in their operational QA
program. DPC stated they would seek relief from this
commitment through DOL.
2.
Technical specification 6.1.2.2.i(2) states that the
Nuclear Scfety Review Committee (NSRC) shall review
proposed changes in equipment or systems which may constitute
an unreviewed safety question defined in 10 CFR 50.59, or
which are referred by the operating organization.
DPC's
position is that if the Station Review Committee (SRC)
determines that a modification does not constitute an
unreviewed safety question then NSRC review is not required.
The inspectors stated that position was not consistent with
the technical specification requirement.
DPC stated that
they would resolve this matter with DOL.
C.
The inspectors stated that prior to issuance of an operating
license, Regulatory Operations wc
'd be required to make a
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finding that the FSAR and DPC letter commitments, with regard
to operational quality assurance, had been implemented. A pre-
licensing inspection will be made to determine if the types of
deficiencies identified in this report have been corrected.
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. DETAILS
Prepared by:
E. 6, .
eb
5 N/7/-
R. C. Lewis, Acting Chief
Date
Facilities Test and Startup
ranch
$!lE!lk
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R. C. Parker [ Reactor Inspector
Date/
Facilities Test and Startup
Br nch
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K. W. Whitt, Reactor Inspector
Date
Facilities Test and Startup
Branch
Dates of Inspection: April 29-May 2, 1974
Reviewed By: [. [<
LLt d a
.5////V-
R. C. Lewis', Acting Chief
Date
Facilities Test and Startup
Branch
1.
Individuals Contacted
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Duke Power Company (DPC)
J. E. Smith - Plant Superintendent
R. M. Roehler - Staf f Engineer
J. W. Cox - Station Senior Quality Assurance (QA) Engineer
O. S. Bradham - Technical Support Engineer
~~
R. C. Adams - Instrumentation and Controls Engineer
C. L. Thames - Health Physics Supervisor
R. P. Bugert - Training Supervisor
J. O. Barbour - QA Manager, Operations
D. C. Holt - Assistant Nuclear Test Engineer
2. -Discussion
The purpose of this inspection was to determine whether DPC's operational
-quality assurance commitments as stated in the Oconee Nuclear Station
Final Safety Analysis Report (FSAR), DPC letter (Ltr) to Directorate
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of Licensing . (DL)' dated April' 27, 1973, and DPC Ltr to DL dated
July 31,1973, had been implemented.
The quality assurance Department
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' Operational Quality Assurance Manual (0QAM) and the Steam Production
, Department - Administrative. Policy Manual (APM) were reviewed to
determine if quality assurance requirements had been imposed to
satisfy the DPC ' commitments . Administrative procedures, quality
control procedures and certain other quality assurance and steam
production procedures were examined to determine whether requirements
had been implemented.
. The inspection was conducted on a sampling basis.
Therefore, deficiencies
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identified 'are not considered to be all inclusive. .It is expected
- that DPC will make a thorough review of the-implementation of operational
QA commitments and resolve all identified deficiencies, including those
' listed below, prior to the licensing of Oconee Unit 3.
3.
Findings
a.
Quality Assurance Organization
Implementation of'the DPC operational quality assurance organization
described to AEC, Directorate of Licensing, on March 28, 1974,
was reviewed.
Quality assurance and technical functions which
are related to quality assurance are identified in Section 1.4,
" Organization for Operational Quality Assurance," of the OQAM.
Certain of the functions, ' examples of which are listed below,
were not implemented by written instructions as required by
Criterion V to Appendix B to 10 CFR 50:
(1) Performing company QA audits;
(2) Maintaining qualification and certification records for QA
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and QC personnel;
.(3) Performing destructive tests, and
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(4) Conducting appropriate training for QA and QC personnel,
b. - Quality Assurance Program - Training
Paragraph 6.1.1.5 of the Technical- Specifications requires that
retraining and . replacement of station personnel shall be in
accordance with Section 5.5 of ANSI N18.1.
DPC has submitted
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to AEC, DL', a-proposed retraining program for licensed' operators.
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Since DL had not completed their evaluation of the adequacy of
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the proposed retraining program, a review of the implementation
was not. conducted during this inspection. The training program,
excluding retraining, is deficient as follows:
(1) A training program and schedule has not been implemented for
the training of non-licensed personnel such as instrument
or mechanical maintenance personnel.
(2) A training program .and schedule has not been delineated in
writing for the training.of replacement licensed operators.
(3) A training program, including radiological health and safety
for administrative 'or clerical personnel, has not been
implemented.
c.
Design Control
Section III of DPC Ltr of April 27, 1973, states that if the
station superintenimnt approves a proposed modification and
determines that the modification might affect the proper functioning
of the structures, systems, or components involved; might involve
a change in the station's technical specifications; might involve
an unreviewed safety question; might require further design
review or might otherwise violate license or regulatory require-
ments, the request for the modification is forwarded to the
Assistant Vice President, Steam Production, and to the Nuclear
Safety Review Committee (NSRC) .
The'following examples of
deficiencies were identified in this area:
(1) Section 3.4 of the APM and Administrative Procedure (AP) 10
permits modifications to safety related systems that are
described in the FSAR to be made before they are reviewed by
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the NSRC. This is contrary to Technical Specification -6.1.2.2.i(2).
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(2) The.0QAM ar. . M do not specify the acceptance criteria for
making a determination of the adequacy of a modification, as
required by Criterion III of Appendix B to 10 CFR 50.
d.
Procurement Document Control
Section IV of DPC Ltr of April 27, 1973, states that the originator
of a purchase requisition is responsible for entering the
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appropriate procurement information on the requisition. Purchas,e
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requisitions are approved by the plant superintendent and are to
be retained.
The following examples of deficiencies were
identified in this area:
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(1) Neither the OQAM nor the APM requires that changes to procurement
' documents be subject to the same degree of control that was
imposed on the preparation of the original document, as re-
quired by Criterion IV of Appendix 13 to 10 CFR 50.
(2) The OQAM does not require that procurement of safety related
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materials be only from approved vendors as required by
Criterion VII of Appendix B to 10 CFR 50 and the DPC Ltr.
(3) The OQAM does not contain provisions for source inspection
-and audit during the procurement of safety related material
as required by Criterion VII of Appendix B to 10 CFR 50
and the DPC Ltr.
e. . Instructions, Procedures , and Drawings
Section V of DPC Ltr of April 27, 1973, states that basic
written instructions and procedures for activities affecting
quality are prescribed by the operational quality assurance
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program. The following examples of deficiencies were noted in
this area:
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(1) The OQAM nor APM does not state, or require' implementing
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instructions to state the responsibilities and authorities
of station operators.
(2) Section 3.3.2.4 of the APM permits maintenance activities
to be performed in accordance with appropriate sections of
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vendor manuals, instructions, or approved drawings which
have not received licensee approval.
This is contrary to
Criterion V of Appendix B to 10 CFR 50 and Technical Specification 6.4.1.e.
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Control of Purchased Material, Equipment, and Services
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Section VII of DPC Ltr of April 27, 1973, states that the
Design Engineering Department is responsible for the initial
evaluation and periodic auditing of vendors. Upon receipt at
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the station, materials, parts, and components are placed in a
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contro11ad. designated arca and a receipt inspection is conducted.
The followa g examples of deficiencies were identified in this area:
(1)'The OQAM does not contain a, requirement and the quality
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control (QC) procedures'do not provide implementing
instructions for the performance of initial source evaluation
and periodic auditing of vendors as specified by the DPC Ltr.
(2)' The OQAM does not contain a requirerent and the QC procedures
do not provide implementing instructions for assuring that
- receiving inspections are performed in an area equivalent to
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the level of storage required for .the item.
(3) The OQAM does not require receiving inspections to include
physical properties, dimensions, weld preparation, lubricants
and oils or electrical insulation tests when the completed
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item was not inspected or examined at the vendor shop.
g.
Identification and Control of Materials, Parts and Components
Section VIII of DPC Ltr of April 27, 1973, defines the
system that has been established for the identification and
control of conforming and nonconforming materials, parts, and
components. It is stated that nonconforming parts are tagged
and segregated from conforming items to preclude inadvertent use.
The following examples of deficiencies were identified in this
area.
(1) The OQAM states that nonconforming items may be segregated.
Segregation is a requirement of the DPC Ltr.
(2) The OQAM does not require that corrective action of purchased
nonconforming items be performed in accordance with authorized
procedures and that documentation of the actions be made a
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part of the permanent records as required by Criterion XVI
of-Appendix B to'10 CFR 50.
(3) The 0QAM does not require that purchased nor ;onforming
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items be. reported to design and purchasing
.o prevent reor er
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of deficient items as required by Criter1 2 XVI of
Appendix B to 10 CFR 50.
h. LControl of Special Processes
'ection IX of the DPC Ltr of April 27, 1973, states that an
operational quality assurance program for'special processes
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.is performed by certified personnel utilizing approved,
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qualified written procedures.
Quality assurance requirements
have not_ been . formally established for verification of
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Inspection
Section X of the DPC Ltr of April' 27, 1973, states that the
operational. quality assurance program requires a program of
inspection for safety related structures, systems, and
components - to observe for signs of wear, deterioration, or
' loss of efficiency.
The following examples of deficiencies
were identified in this area:
(1) The OQAM and APM do not require an inspection program for
safety . related structures, systems and components to
observe for signs of wear, det'erioration, or loss of
efficiency as required by the DPC letter.
(2) Section 3.5.2.2 of the DQAM states that the station
senior qua'lity assurance engineer shall have the responsi-
bility for quality control inspections.
Section 3.5.2.3 of
the OQAM states that inspections may be performed by employees
of DPC or by employees of other organications contracted to
perform inspection functions.
Since all inspections are of
a QC nature, the inspections which may be performed by personnel
outside the QA department should be specified.
j. Test Control
Contrary to commitments made in the DPC Ltr of April 27,
1973, responsibilities and procedures for genet ' ton of a master
schedule to assure implementation of technical specification
-periodic test requirements have not been delineated in writing.
Section _3.2.2.2.2 of the APM requires that Group Heads shall
be responsible to the station superintendent for all periodic
tests assigned to f their particular groups. A program for
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assigning specific periodic test responsibilities to group
heads has not been delineated in writing as required by
Criterion V of Appendix B to 10 CFR 50.
k. ~ Control of Measuring and Test' Equipment
The DPC Ltr of April 27, 1973, and paragraph 2.3.3.3 of the
APM require separation' of controlled and noncontrolled alasuring
and test equipment in storage. These requirements have n1t been
implemented for electrical. measuring and test equipment.
. Paragraph 2.3.3.2 of the OQAM states, in part, that items and
. processes determined to be acceptable based on measurements
made with ' devices that are subsequently 'found to be out of
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calibration shall be reevaluated.
The 0QAM does not require
documentation of the reevaluation effort required by C,riterion
XVII of Appendix B to 10 CFR 50.
1.
Handling, Storage, and Shipping
Section XIII of the DPC Ltr.of April 27, 1973, states that
the operational quality assurance program establishes criteria
for the handling, storage, and shipping of items to assure
that the serviceability and QA traceability of . items are main-
tained.
Operational QA requirements have not been established
for the handling and shipping of safety related items to
assure that the serviceability and traceability are maintained
as required by the DPC Ltr.
m.
Inspection,' Test and Operating Status
Section XIV of the DPC Ltr of April 27, 1973, states that
procedures require that the operability of any item removed from
operation for mairtenance or testing be verified prior to returning
the item to ' normal service. The APM 'does not require that the
operability of items req 9ved from operation for periodic testing
be verified prior to retutr.ing the item to normal service.
Equipment control procedures do not require independent (two party)
verification to ensure that necessary measures, such as tagging
equipment for maintenance or modification or the use of jumpers
and bypasses not controlled by procedures, have been properly
implemented.
n.
Nonconforndng Materials, Parts, and Components
Section XV of the DPC Ltr of April 27, 1973, specifies the
system for haadling and documenting nonconforming materials,
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parts, and components.
It states that pr cedures require
the operability of any item removed' from operation for maintenance
or testing to be verified prior to returning the item to normal
service. The following examples of deficiencies were identified
in this area:
(1) Operational QA requirements do not specify that nonconformances
be promptly identified and corrected as required by Criterion
XVI of Appendix B to 10 CFR 50.
(2) The 0QAM does not require that corrective action be taken in
accordance with documented procedures as required by Criterion
XV of Appendix B to 10 CFR 50.
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(3) The 0QAM does not provide for feedback of defective cocponents
~te design and purchasing to prevent reorder of similar
defective items as required by Criterion XVI of 10 CFR 50.
o.
Corrective Action
- Section XVI of the DPC Ltr of April 27, 1973, states that conditions
adverse to quality are to be identified and corrected, and that
the cause of significant conditions adverse to quality will be
determined and corrective action taken to preclude repetition.
The OQAM nor APM does not contain a requirement for corrective
action. The procedure for handling of incidents, which was a part
of the old QA manual, provides instructions for assuring conditions
adverse to quality are corrected and the cause is determined.
It
also requires the cause of the incident and corrective action to be
reported to management.
However, this procedure has not been
incorporated into the new OQAM.
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QA Records
Section XVII of th'e DPC Ltr of April 27, 1973, states that the
operational quality assurance program requires that adequate
identifiable and retrievable records be maintained in order to
properly ' document all prases of the program.
The following
examples of deficiencies were identified in this area:
(1) Steam Production Department procedures for collection, storage,
and maintenance of QA records have not been approved for permanent
and temporary-QA records storage.
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(2) The.QA Department procedure for collection, storage, and main-
tenance of QA records is deficient in the following areas:
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(a) Description of the filing system is inadequate.
(b) The method of verify 1ng that records received in records
storage agree with the pre-established records checklist
has not been described.
(c) Instructions for storage of loose documents have not been
provided.
(d) Instructions to assure that special processed records are
stored in accordance with the manufacturer's recommenda-
tiens have' not been provided.
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(3) File' cabinets in designated temporary storage areas do not
meet. fire resistant requirements.
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(4) The permanent storage area does not have a dry chemical or
CO2 fire protection system.
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Audits
DPC Ltrs of April 27, 1973,. and July 31, 1973, provjde a
description of an audit program for DPC nuclear sta'. ions. These
letters state that the program is in compliance with the DPC APM
and Criterion XVIII of Appendix B to 10 CFR 50.
The following
examples of deficiencies were identified in this area:
. (1) The audit program submitted to DL specifies the frequency
of audits for various items to be audited by the station
QA group. The new OQAM states that the frequency of
level 1 audits (onsite QA) will be determined by the QA
. manager, operations.
In this respect, the OQAM does not
agree with the com=itment of the DPC Ltrs.
(2) A requirement for all safety related activities to be audited
annually has not been included in the OQAM.
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(3) Impler.enting procedures have not been written for dhe three
levels of audits.
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-Letter to Duka Power Company frca N. C. Moseley
dated MAY 1 6 1974
50-287/74-5
DISTRIBUTION:
' D-
%:. D. Thornburg, RO
~,
RO:HQ (4)
Directorate of Licensing (4)
DR Central Files
cc encl. only:
- PDR-
- Local PDR
.
- NSIC
- DTIE, OR
- State
t
- To be dispatched at a later date.
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