ML19330B812
| ML19330B812 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 07/10/1980 |
| From: | Gody A, Hinckley D, Shafer W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| To: | |
| Shared Package | |
| ML19330B801 | List: |
| References | |
| 50-312-80-15, NUDOCS 8008070021 | |
| Download: ML19330B812 (50) | |
See also: IR 05000312/1980015
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U. S. NUCLEAR REGULATORY COMMISSION
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OFFICE OF INSPECTION AND ENFORCEMENT
REGION V
Report No. 50-312/80-15
Docket No. 50-312
Licensee:
Sacramento Municipal Utility District
P. O. Box 15380
Sacramento, CA, 95813
Facility Name:
Rancho Seco, Unit 1
Inspection at:
Rancho Seco Site, Clay Station, California, and
Sacramer to Municipal Utility District General Offices,
Sacramento, CA
Inspection Conducted:
April 14-18, 21-25, and May 5-8, 1980
Inspectors:
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A. I . Gody /'
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Date Signed
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D. G. HinckJ'ey, [~
Date Signed
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R. Hunter [
Date Signed
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W. D. Shafer
Date Signed
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J. D. Woessndr
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Date Signed
Accompanying Personnel:
H. L. Canter, Region V (Resident)
G. B. Zwetzig, Region V
- A. B. Johnson, Region V
- B. H. Faulkenberry, Region V
- J. E. Gagliardo, PAB
- H. D. Thornburg, RCI
- Present only during exit interview on May 8,1980
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Approved by: /,l_/jlb,,9 /('_.9
K// -9[
1
W. D. Shafer,
ting Chief, PAB
Date Signed
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Inspection Summary
Inspection on April 14-18, 21-25, and May 5-8, 1980; Report No. 50-312/80-15
Areas Inspected:
Special announced inspection of the licensee's management
controls over licensed activities.
The inspection involved 497 inspector
hours at the site and in the corporate office by five NRC inspectors.
Results:
Of the eleven areas inspected, no items of noncompliance or
deviations were found in two areas; eighteen apparent items of noncompliance
were found in nine areas (deficiency - failure of MSRC to review meeting
minutes, paragraph 3; infraction - failure of PRC to review NRC enforcement
findings, paragraph 3; infraction - failure to perform audits, paragraph 4;
infraction - failure to perform audits, paragraph 4; infraction - failure to
perform timely audits, paragraph 4; infraction - failure to review
modifications, paragraph 5; deficienty - failure to provide administrative
procedures for preventive maintenance, paragraph 6; infraction - failure to
have procedures for S-R maintenance, paragrah 6; infraction - failure to
inspect maintenance activities, paragraph 6; infraction - failure to control
mechanical measuring devices, paragraph 6; deficiency - failure to provide
adequate storage of records, paragraph 6; infraction - failure to review
procedures, paragraph 8; infraction -failure to give examinations, paragraph
9; infraction - failure to implement non-licensed personnel training,
paragraph 9; infraction - failure to train fire brigade members, paragraph
11; infraction - failure to classify fire protection material and equipment,
paragraph 11; infraction - failure to provide receipt inspection of Class I
items, paragraph 12; deficiency - failure to provide followup training of
security personnel, paragraph 13); and five deviations were found in three
areas (failure to respond to audit findings, paragraph 4; failure of QA to
perform documentation review, paragraph 4; failure to review audit program,
paragraoh 4; failure to provide fire strategy procedures, paragraph 11;
failure to provide adequate storage of Class 1 items, paragraph 12).
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DETAILS
1.
Persons Contacted
The following lists (by title) the individuals contacted during this inspec-
tion.
The matrix to the right of the listing indicates the areas (number
corresponds to paragraph number in the report) for which that individual
provided significant input. Other individuals were contacted during the
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inspection but the extent of their input to the inspection effort was not
significant to the findings delineated in this report.
Title of Individual
Corporate Office
3
4
5
6
7
8
9 10 11 12 13
^ General Manager
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- Asst. General Manager &
Chief Engineer
X
X
X
X
X
X
X
X
X
X
- Asst. General Manager, Operations X
X
,
- Manager, Engineering Department
X
X
- Manager, Generation Engineering
X
X
X
X
X
X
X
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- + Director, Quality Assurance
X
X
X
X
X
X
X
X
X
- Director, Security
X
Manager, Purchase & Stores
X
,
Supervisor, Drafting
X
Supervisor, Licensing
X
- + Supervising Special Agent
X
Special Agent
X
- Sr. Quality Engineer
X
X
X
X
X
X
X
QA Auditor
X
Design Engineer
X
Review Engineer
X
Principle Buyer
X
Fire Protection Engineer
X
.,
- + Manager, Nuclear Operations
X
X
X
X
X
X
X
X
X
- + Superintendent, Nuclear Plant
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Supervisor, Engineering &
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4
Quality Control
X
X
X
X
X
X
X
X
X
+ Supervisor,. Nuclear Operations
X
X
X
X
X
X
X
X
X
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Supervisor, Nuclear Engineering
X
Supervisor, Mechanical Engineering
X
X
Supervisor, Electrical Engineering
X
X
X
,
Supervisor, Training
X
X
X
X
X
X
Supervisor, Mechanical Maintenance
X
X
+ Supervisor, Electrical /I&C
X
X
X
X
X
X
Supervisor, Document Control
X
X
Supervisor, Administration
X
X
X
+ Attended Exit on April 21, 1980
- Attended Exit on April 25, 1980
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- Attended Exit on May 8, 1970
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Title of Individual
Corporate Office
3
4
5
6
7
8
9 10 11 12 13
- Supervisor, Nuclear Maintenance
X
X
X
X
X
X
- Technical Assistant
X
X
X
X
X
X
X
X
X
Safety Technician
X
X
X
X
X
- + Senior Quality Engineer
X
X
X
X
X
X
X
X
X
QA Engineer
X
X
X
QC Coordinator
X
X
X*
X
Outage Coordinator
X
X
X
X
Mechanical Engineer (2)
X
X
X
I&C Engineer
X
X
4,
Mechanical Foreman (2)
X
X
Electrical Foreman (2)
X
X
X
Warehouse Foreman
X
4
Shift Supervisor (3)
X
X
X
X
X
X
X
X
X
Senior Control Room Operator (2)
X
X
X
X
X
Control Room Operator (2)
X
X
X
X
X
Auxiliary Operator (2)
X
X
X
X
Equipment Attendant (2)
X
X
X
Mechanic (3)
X
X
X
X
Electrician (2)
X
X
X
X
I&C Techician (2)
X
X
X
X
Nuclear Engineering Technician
X
Nuclear Plant Inspector
X
+Special Agent
X
Watch Commander (3)'
X
Lieutenant (Vanguard)
X
Security Officer (4)
X
+ Attended Exit on April 21, 1980
- Attended Exit on April 25, 1980
- Attended Exit on May 8, 1980
- Not available for interviews
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2.
Inspection Scope and Objectives
The objectives of the inspection were to determine how the licensee
controis and performs licensed activities; the results of which will
provide input to an evolution of licensees from a national perspective.
The inspection effort covered licensed activities in selected functional
areas.
In each of the functional areas the inspectors reviewed written
policies, procedures, and instructions; interviewed selected personnel
and reviewed selected records and documents to determine whether:
a.
The licensee had written policies, procedures, or instructions to
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provide management controls in the subject area;
b.
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The policies, procedures and instructions of (a) above, were adequate
to assure compliance with the regulatory requirements;
The licensee personnel 'who had responsibilities in the subject areas
c.
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were adequately qualified, trained, and retrained to perform their
responsibilities;
d.
The individuals assigned responsibilities in the subject area,
understood their responsibilities; and
The requirements of the subject area had been implemented and appro-
e.
priately documented.
This report contains the enforcement findings which document identified
items of noncompliance, deviations, or unresolved items.
The corrective
actions for these findings will be evaluated by the Regional Office, who
will also process enforcement action and closeout the items.
3.
Committee Activities
The objective of this portion of the inspection was to determine the
adequacy of the licensee's management controls associated with activities
conducted by the Plant Review Committee (PRC) and the Management Safety
Review Committee (MSRC).
a.
Documents Reviewed
(1) Administrative Procedures (AP)
AP 1, Responsibilities and Authorities, revisior, 4
AP 2, Review, Approval and Maintenance of Procedures,
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revision 8
AP 22, Reporting of Reportable Occurrances, revision 3
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(2) Quality Assurance Procedures (QAP)
QAP 1, Organization, revision 4
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QAP 19, System Auditing, revision 3
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(3) Quality Control Instructions (QCI)
QCI 1, Processing of Nonconforming Reports, revision 6
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QCI 2, SMUD Nuclear Operations Quality Assurance Audit
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Program, revision 10
QCI 8, Backshift and Weekend Visit Program, revision 1
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(4)
Rancho Seco Technical Specification (TS), Section 5
(5) Charter for SMUD Management Safety Review Committee, amendment 8
(6)
Charter for Rancho Seco Plant Review Committee, April 12, 1980
(7)
Selected PRC meeting minutes for 1979 and 1980
(8) Selected MSRC meeting minutes for 1979 and 1980
(9)
Selected Reportable Occurrence Reports for 1979 and 1980
(10) Licensee correspondence
To D'R (Reid) from SMUD (Mattimoe), July 22, 1976
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To DDR (Reid) from SMUD (Mattimoe), September 23, 1976
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(11) Quality Assurance Trend Analysis, September 17, 1979
(12) Summary of MSRC Audit Activity, December 1978 - September 1979
b.
Findings
(1)
Items of Noncompliance
(a)
Item 50-312/80-15-01
TS 6.5.2.10.a states that " minutes of each MSRC meeting
shall be prepared, approved, and forwarded to the General
Manager within 14 days following each meeting."
Contrary to the above, the minutes of the meeting held on
September 20, 1979 were not approved by the cornmittee.
Interviews indicated the licensee's interpretation of the
TS requirement was if the committee were to approve the
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meeting minutes prior to forwarding them to the General
Manager, the committee would have to meet at least once
every 14 days:
once for the initial meeting, again within
14 days to approve the minutes of the first meeting, 14
days later to approve the second meeting's minutes, et
cetera.
To avoid this perceived problem, the licensee
decided the preparation and initial approval would be by
the committee secretary, the minutes would then be
forwarded to the General Manager, and later approved by
the committee at the next regularly scheduled meeting.
The committee charter was written to reflect that inter-
pretation.
Contrary to this interpretation and the committee charter,
MSRC meeting minutes were typically not approved at the
next regularly scheduled meeting.
Minutes of meetings 87,
88, and 89 were not approved until meeting 91.
Minutes of
meetings 8C, 8/27/79, and 8/28/79 were not approved until
meeting 88 on 10/1/79.
(Note:
Regularly scheduled
meetings were assigned consecutive numbers; unscheduled
meetings were designated by the date they were held.) The
9/20/79 meeting occurred between meeting 87 on 9/7/79 and
meeting 88 on 10/1/79.
The minutes for 9/20/79 were not
approved at any subsequent meeting.
An additional circumstance with this September 20 meeting
was that it was not the typical in-session meeting.
It
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was either a "walkaround" meeting, a non-conference tele-
phone meeting, or a combination of both.
These were
special types of committee meetings used apparently on an
infrequent basis to handle uncomplicated and normally
urgent issues.
Both types consisted of one member, usually
the committee secretary, contacting a sufficient number of
individual committee members to establish a quorum to
obtain their approvals or concurrence on an item under
review.
Contact was made by a face-to-face meeting or a
telephone call with each member.
Minutes were then
prepared documenting the walkaround or the collection of
individual telephone calls as a meeting.
The minutes of
September 20 stated that all MSRC members, except onc, had
been contacted and gave their approval of a proposed
change to the TS regarding secondary plant chemistry.
These mi' utes were not approved by the committee and the
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proposed change was not reviewed at a subsequent meeting.
(b)
Item 50-312/80-15-02
.TS 6.5.1.6.e states that the PRC be responsible for
" investigations of all violations of the Technical
Specifications and shall prepare and forward a report
covering evaluation and recommendations to prevent
recurrence..."
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Contrary to the above, the PRC did not review or
investigate, or have under their cognizance a subgroup or
some other group review or investigate NRC reported viola-
tions of TS
them a repor;t covering evaluation and recommend
regarding NRC reported violations of TS.
Examples are
50-312/79-22the three violations reported in IE Inspection Report
of December 27, 1979.
An infraction of TS 6.8.3.b
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changes to procedures approv,ed by two members of
plant management staff.
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An infraction of TS 6.8.3.c, failure to review
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temporary changes to procedures within seven days
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A deficiency of TS 6.5.2.8.b, failure to audit the
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qualifications of the plant operating staff.
did not review NRC inspection reports or in
reported violations of TS.
All but one of the PRC members
interviewed indicated that they frequently read the reports
particularly when a report referenced activities in their
,
area of responsibility.
never seen an NRC inspection report.One PRC member claimed t
Various mechanisms, which were available to licensee
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personnel to use for reporting to management violations of
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TS, were either not reviewed by the PRC or were reviewed
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for reasons other than for potential violations.
included QA audit reports, Reportable Occurrence Reports
These
and Noncomformance Reports.
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QA audit reports were not reviewed by the PRC.
audit reports which impacted upon their area
Individual
bility.
potential violations of TS.Two audit reports examined containe
0-261 reported evidence of
violations of the environmental TS; 0-268 reported evidence
of violations of an administrative procedure, AP-4,
Clearances.
Neither of these examples were reviewed by
the PRC.
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Licensee representatives stated that the principal means
for licensee personnel to report potential violations of
15 was through the use of Reportable Occurrence Reports
The procedure for com
restricted their use,pleting these reports, AP-22,
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however, to identifying only report-
able occurrences as defined in the TS and Regulatory Guide 1.16.
Violations of items under TS Section 6, such as
violations of procedures required by TS 6.8, would not be -
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reported using AP-22 as written. _Furthermore, their was
no assurance that procedure violations reported on the
Reportable Occurrence Reports would be reviewed by the
PRC.
All of the reports were screened by the PRC Chairman.
Those which were designated as not reportable were normally
not submitted to the PRC for review.
Of the Reportable
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Occurrence Reports examined (a majority of the ones
submitted during the past 12 months) more than one third'
were not marked with the designation indicating whether
they were considered reportable.
However, the inspector
did not identify any potential violations of the TS which
had not been reviewed by the PRC.
The licensee had, in part, identified this limitation in
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the use of AP-22.
A revision 3 to the procedure in
September 1979 added a space to the form for TS violation,
"yes" or "no," but did not change the wording of the
procedure.
This revision did not, however, have a signifi-
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cant impact.
The old forms were still in wide use, the
vast majority of new forms did not have the ncw "yes" or
"no" spaces. marked, and training in the use of the forms
was apparently insufficient.
Several persons interviewed
stated that they were unaware of the procedure and lacked
familiarity with it's use.
A licensee representative
stated that it was their intention to write a new revision
which would, as a minimum, add a space to the form for
procedure violation, "yes" or "no".
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Several licensee management persons stated that
Noncomformance Reports (NCRs) were used periodically to
report potential TS violations.
These reports, however,
were generally not reviewed by the PRC unless they were
designated as requiring a 10 CFR 50.59 review.
There was
no procedure requirement, or other assurance, that the PRC
would review these unless they had the 50.59 desigration.
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(2) Deviations
Item 50-312/80-15-03
The licensee committed in correspondence of July 22, 1976, to
the following:
"A management audit conducted by one member of
the MSRC (with assistance as needed) is made annually on Quality
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Assurance.
No member of Quality Assurance is a member of the
team.
This mangement audit reviews conformance to the ' orange'
book and its attendant documents." This commitment was estab-
lished clearly distinct from the use of outside consultants as
amplified in further correspondence of September 23, 1976.
This letter referenced " independent audits being performed by
outside consulting firms retained expressly to audit QA
implementation."
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Contrary to the above commitment, the licensee failed to audit
the QA program.
Interviews and records indicated that essentially two methods
were employed to perform periodic reviews or audits of the QA
program.
These included audits by an outside independent audit
team and a periodic trend analysis of audit findings.
The most recent outside, independent audits were performed in
January 1978 and October 1979 by the Joint Utility Audit Team.
This audit did not appear to meet the requirements of the above
commitment.
No member of the MSRC was a member of the team and
the audits were less frequent than annual.
A trend analysis of audit findings was performed in accordance
with the requirements of QCI 2, paragraph 5.5.
The only
analysis performed under this requirement was compiled by QA in
May 1979, reviewed by an MSRC member.in September 1979, and
reviewed by the entire committee in March 1980.
This activity
also did rot meet the requirements of the above commitment.
It
was the only trend analysis which had been conducted since the
facility began operating and the scope of the analysis was
narrower than the above commitment.
Furthermore, the analysis
was written by the QA Department, eliminating the independence
required for an audit.
(3) Unresolved Items
None.
4.
Quality Assurance Audits
The objective of this portion of the inspection was to determine the
adequacy of the licensee's management controls associated with quality
assurance audit activities.
a.
Documents Reviewed
(1) Administrative Procedures (AP)
AP 3, Work Request, revision 15
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AP 4, Administrative Clearance Procedure, revision 2
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AP 700, Rancho Seco Training Program, revision 2
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-(2) Quality Assurance Procedures (QAP)
QAP 1, Organization, revision 4
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QAP 4, Procurement Document Control, revision 5
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QAP 19, System Auditing, revision 3
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QAP 23, Housekeeping, revision 1
(3) Quality Control Instructions (QCI)
QCI 1, Processing of Nonconforming Report, revision 6
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QCI 2, SMUD No: lear Operations Quality Assurance Audit
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Program, revision 10
QCI 3, Stop Work Directive, revision 0
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QCI 8, Backshif t and Weekend Visit Program, revision 1
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(4) Rancho Seco Technical Specification (TS), Section 6.0
(5) Charter for SMUD idanagement Safety Review Committee, amendment 8
(6) Memorandum to file fron L. G. Schwieger, Responsibilities and
Duties of Quality Assurance, April 27, 1979
(7) Rancho Seco FSAR, Appendi < 1B, Quality Assurance Program
(8) Memorandum of Understanding, Independent Review of Participating
Public Power Utilities Nuclear Quality Assurance Programs,
November 21, 1977
(9)
Licensee Correspondence
To DDR (Reid) from SMUD (Mattimoe), July 22, 1976
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To 00R (Reid) from SMUD (Mattimoe), September 23, 1976
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(10) Summary of MSRC Audit Activity, August - December 1978
(11) Summary of MSRC Audit Activity, December 1978 - September 1979
(12) Memorandum to MSRC Chairman from L. G. Schwieger, Position
Paper Outling the Quality Assurance Interpretation of the MSRC
Delegated Audit Functions, February 24, 1976
(13) Memorandum to MSRC Chairman from L. G. Schwieger, Audits During
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Refueling, January 25, 1980
(14) MSRC Report, Quality Assurance Trend Analysis, September 17,
1979
(15) QA Audits
0-37, Independent Review, September 10, 1975
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0-74, Bechtel Audit #1, May 1976
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0-165, Maintenance Program, January 13, 1976
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0-368, Independent Review, January 1,1978
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0-190, Material Control Procedure and Documentation, June
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27. 1978
0-194, Operational Logs and Records, July 20, 1978
.
0- 95, Selection and Training of Nuclear Power Plant
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Personnel, July 18, 1978
0-200, Backshif t and Weekend Visit Program, August 11,
.
1978
0-201, Maintenance Program, August 25, 1978
.
0-218, Radiological Safety and Control, November 29, 1978
.
0-223, Maintenance Program, January 26, 1979
.
0-226, Minutes of MSRC, February 14, 1979
.
0-235, Surveillance Program and Records, April 12, 1979
.
0-239, Control and Accountability for Special Nuclear
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Material, April 27, 1979
0-244, Material Control Procedures and Documentation,
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May 18, 1979
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0-247, Operational Logs and Records, June 25, 1979
.
0-251, Selection and Training of Nuclear Power Plant
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Personnel, July 14, 1979
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0-253, Reportable Occurrences, August 22, 1979
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0-256, Design Review, September 26, 1979
.
0-260, Maintenance Program,' October 22, 1979
.
.0-261, Audit Implementation (Independent Review), October 12,
.
1979
e
'0-265, Backshift and Weekend Visit Program, November 19,
.
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0-268, Clearance Procedures, December 21, 1979
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0-278, Speciai Diesel Engine Inspection and Maintenance,
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February 27, 1980
0-294, Logging of Operational Transients, April 30, 1980
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0-295, Control of Measuring and Test Equipment, April 30,
.
1980
0-296, Minutes of PRC, April 30, 1980
.
0-298, Minutes of MSRC, May 2, 1980
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(16) Training ~and auditor certification records for four members of
.the'QA Department
b.
Findinos
(1) Items of Noncomoliance
(a)
Item 50-312/80-15-04
TS 6.5.2.8.c requires audits be performed under the
cognizance of the MSRC which shall encompass "the result
of all actions taken to correct deficiencies occurring in
facility equipment, structures, systems or method of
operation that affect nuclear safety at least once per six
months."
TS 6.5.2.8.b requires audits be performed under the
cognizance of the MSRC which shall encompass "the
performance, training and qualifications of the entire
facility staff at least once per year."
10 CFR 50, Appendix B, Criterion XVIII, requires planned
and periodic audits to verify compliance with all aspects
of the QA program and to be performed in accordance with
written procedures.
QA Manual, procedure QAP 23, House-
keeping, states that " periodic inspections and audits of
both the controlled area and unrestricted area...by an
audit team consisting of a Quality Assurance auditor and
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someone from the Nuclear Operations Department.
The
inspections and audits shall be documented in accordance
with QAP No. 19, System Auditing."
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Contrary to 'the above, the required audits had not been
performed.
An examination of audit records and interviews indicated
that audits of corrective actions had not been performed.
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The QA Department was assigned responsibility in QAP 19
for conducting the annual audits on performance, training,
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and qualifications. .The two most recent audits were
0-195, completed July 18, 1978, and 0-251, completed July
14, 1979.
Both of these audits reported the auditor's
decision to defer an inspection in the area of training of
non-licensed personnel (managers, supervisors, engineers,
technicians, and maintenance personnel) due to the lack of
implementation of AP 700, Rancho Secc Training Program.
AP 700 had been issued for implementation on May 30, 1977.
Portions of the program were implemented at the time of
its issuance; other portions were still not in effect
nearly three years after the program was to have commenced.
Examination of audit records indicated that housekeeping
audits had not been performed in uncontrolled areas.
Audit 0-258, Radiological Safety and Control, October 9,
1979, addressed housekeeping for certain controlled areas
only.
The checklist (guidance) for this periodic audit
did not address the issue of housekeeping.
The inspector
did not see any other audits or audit checklists which
addressed housekeeping. Interviews confirmed that such
audits were.not performed.
(b)
Item 50-312/80-15-05
10 CFR 50, Appendix B, Criterion V requires activities
affecting quality be prescribed by documented instructions,
procedures, or drawings and be accomplished in accordance
with these documents.
QA Manual, procedure QAP 19, System Auditing, requires
audits be conducted in accordance with Quality Control
Instruction, QCI 2, audit program.
QCI 2 states that
" audits shall be conducted with specific attention to the
subjects (attachment No. 1) at the required frequencies."
It also states that the frequency of. audits can be varied
by plus or minus 30 days.
Contrary to the above, audits of records and audit
implementation were not conducted at the required
frequencies.
Records
.
Audits of records were prescribed by QCI 2 to be
performed by the MSRC during the first quarter of
each year to the requirements of ANSI N45.2.9-1974.
There were no records in evidence of audits
specifically dedicated to the subject of records or
record controls.
A licensee representative stated
that record controls were audited as part of the
periodic independent consultant audit.
The last two
i
such audits were performed by a Joint Utility Audit
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Team in January 1978 and October 1979.
No such
audits were performed during the first quarter of
19'80. , Audits of records, conducted via the Joint
Utility Audits, were not, therefore, conducted on an
~
annual basis.
An examination of SMUD documents brought into question
the-adequacy and appropriateness of using the Joint
Utility Audits as audits of QA records.
A QA position
paper of February 1976 defined the items which were
to be audited by the independent consultant as those
under TS requirement 6.5.2.8.a, "the conformance of
facility operation to all provisions contained within
the Technical Specifications and applicable license
j
conditions at least once per year." The position
F
paper, regarding audits of records, stated only that
j
it was done per MSRC audit item 1 in QCI 2.
The
q
cover sheet for the most recent Joint Utility Audit
stated that the audit was conducted to the require-
,
ments of MSRC audit item 3, " Audit Implementation."
The document defining the scope of the Joint Utility
Audits was the Memorandum of Understanding.
This
stated that "the scope of the audits will be limited
to implementation of the utility's quality assurance
program in response to regulatory requirements and as
described in Chapter 17 of the applicable SAR and
reflected in the Quality Assurance Manual." Record
controls were not emphasized over other QA program
elements in these Joint Utility Audits.
Personnel
training, design review, MSRC meeting minutes, and
PRC meeting minutes were covered in the Joint Utility
Audits and were also subjects of individual, specific.
and periodic QA audits.
The results of both Joint Utility Audits as they
pertained to records were that " Records are not being
stored in accordance with provisions of ANSI N45.2.9 -
1974Property "ANSI code" (as page type) with input value "ANSI N45.2.9 -</br></br>1974" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.."
(Quotation from audit 0-261).
Corrective
action was not prescribed or taken by licensee manage-
ment.
Interviews indicated that the finding was
common knowledge by licensee manaoement and that an
internal audit dedicated to record controls could
only re enforce what was already well known and would
be a waste of time.
Audit Implementation
.
These audits were prescribed by QCI 2 to be performed
by the MSRC during the fourth quarter of each year to
the requirements of ANSI N45.2.12.4.
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Examination of records and interviews indicated that
implementation of the audit program was audited as
part of the Joint Utility Audits.
These were
performed, as previously stated, in January 1978 and
in October 1979.
No audit was performed in the
fourth quarter of 1978.
The audits were not done on
an annual basis as prescribed in QCI 2.
The requirements of QCI 2 and the utilization of the
Joint Utility Audits appeared to conflict.
Audit
implementation was scheduled to be audited in the
fourth quarter, records in the first quarter.
The
-
licensee representative stated that both areas were
covered by the Joint Utility Audit and that schedule
changes were being considered to handle the conflict'.
The Joint Utility Audit received wide application to
many of the licensee's commitments and requirements.
As stated in the previous section on records, the
licensee used the audit to meet the requirements of
TS 6.5.2.8.a.
It also used the audit to meet a
commitment in correspondence of July 22, 1976 to
perform an annual management audit by one member of
the MSRC on conformance of the QA program to the
" orange book" and its attendant documents.
(See
Section 3 of this report.)
(c) Item 50-312/80-15-06
10 CFR 50, Appendix B, Criterion V requires activites
affecting quality be prescribed by documented instructions,
procedures, or drawings and be accomplished in accordance
with these documents.
QA Manual, procedure QAP 19, System Auditing, specified
that "on-site reviews shall be conducted periodically by
'
Rancho Seco Operations and Engineering personnel in con-
formance to ANSI 18.7-1972." This was further amplified
by "the Manager of Generation Engineering and Manager of
Nuclear Operations will periodically assign personnel from
their staff to conduct on site reviews."
Contrary to the above, interviews and records indicated
that these reviews had not been performed.
QAP 19 and FSAR, paragraph 18.15, specificed two audit
programs:
QA audits and onsite reviews. ' Interviews
indicated that the principal reason for establishing the
requirement'for onsite reviews was to provide expertise in
the area where QA Department personnel were weakest:
operations.
According to the QA Director, none of the QA
-
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'
.
.
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-
,
personnel had operational experience. The onsite reviews
were-designed, in part, to fill this void.
ANSI N18.7-1972 requires audits of selected aspects of
plant operation be performed in accordance with appropriate
written instructions.
These audits "should include verifi-
cation of compliance with internal rules, procedures (for
example, normal, off-normal, emergency, operating,
maintenance, surveillance, test, security, and radiation
control procedures and the emergency plan)..."
Records
and interviews indicated that many operational activities
such as compliance to normal, off-normal, emergency, and
operating procedures had not been audited.
In two areas, fire protection and health physics, members
of Generation Engineering and Operations had assisted QA
personnel in conducting QA program audits.
This assistance
did not appear to have been performed under the separate
onsite review program; and neither area involved plant
operations per se.
One licensee representative stated that the Backshift and
Weekend Visit Program, MSRC audit item 29, constituted
fulfillment of the onsite review requirement.
This program,
however, was again part of the separate QA audit program;
its scope ~ appeared too limited (backshifts weekends only)
to assess conformance to the requirements of ANSI N18.7-1972.
Furthermore, in the two Backshift and Weekend Visit audits
examined, neither a member of Generation Engineering or
Operations was part of the audit team.
(2) Deviations
,
(a)
Item 50-312/80-15-07
The licensee committed in correspondence of July 22, 1976
and September 23, 1976 to the provisions of WASH document
1284 and its attendant documents, including ANSI N45.2.12 -
1974, Requirements for Auditing of Quality Assurance
Programs for Nuclear Power Plants.
ANSI N45.2.12 - 1974 requires an audited organization to
4
respond to an audit report in writing within thirty days
after receipt and, in the event that corrective action can
not be completed within 30 days, the response is to include
a scheduled date for the corrective action.
Examples of initial response data versus the audit report
and the date for which a response was requested is as
follows:
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Audit
Audit Report
Corrective Action
Date of
'
Initial
Report
Date
Requested By
Written
Response
0~168
1-1-78
2-19-78
3-9-78
0-190
6-27-78
7-31-78
12-4-78*
0-256
9-26-79
10-25-79
11-7-79
0-258
10-9-79
11-16-79
l-9-80
- Response was made on all findings except one (item 6).
On that finding, no written response was submftted as
requested.
';
One cause for the lack of timely responses to audits
appeared to be that there were no licensee instructions or
procedures which duplicated, elaborated upon, or directed
personnel to the requirement in the ANSI standard.
QAP 19
,
stated only that "all organizations shall provide prompt
corrective action to rectify quality assurance inadequacies."
QCI 2 did not address the requirement.
Licensee personnel,
other than some QA auditors, were unaware of the ANSI
standard's requirements.
An additional requirement of ANSI N45.2.12-1974 is that
each audit report provide a summary of audit results
including an evaluation statement regarding the effective-
ness of the QA program elements which were audited.
Contrary to this requirement, none of the audit reports
examined contained such a statement.
(b)
Item 50-312/80-15-08
FSAR, Appendix 1B, paragraph 18.14, states that a
" Documentation Control Center is maintained on the site to
establish a central point for controlling all records that
represent objective evidence of the quality status of all
aspects of the Rancho Seco Nuclear Generating Station." It
defines records as those including the quality aspects of
plant operating activities.
It further stated that "all
documentation is reviewed for completeness by Quality
Assurance Engineering prior to filing in the Documentation
Control Center."
Contrary to the above, the Documentation Control Center
was maintained only for documents pertaining to construc-
tion and modification of the facility, not for records of
pount operating activities.
Furthermore, QA did not
review all documentation for completeness.
For example,
QA did not rev.iew for completeness training records for
onsite personnel, surveillance records, reactor physics
.
~
.
. '
-17-
,
.
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'
and chemistry records, or operating logs.
Some of these
records were the subjects of periodic audits, but none
were routinely reviewed for completeness.
(3) Unresolved Items
fJone.
5.
Design Changes and Modifications
The objective of this portion of the inspection was to determine the
adequacy of management controls associated with engineering, design
changes, and modifications.
a.
Documents Reviewed
(1) Licensee correspondence:
I
.
To SMUD (Mattimoe) from DDR (Reid), June 1, 1976
.
To DDR (Reid) from SMUD (Mattimoe), July 22, 1976
.
To 00R (Reid) from SMUD (Mattimoe), September 23, 1976
.
To SMUD (Mattimoe) from 00R (Reid), December 13, 1976
(2) Rancho Seco FSAR
.
Chapter 12, Conduct of Operations
.
Appendix 1B, Quality Assurance Program
(3)
Rancho Seco Technical Specification, Section 6.0, Administrative
Controls
(4) Quality Assurance Procedures (QAP)
.
QAP 1, Organization, revision 4
.
QAP 2, Design Review, revision 5
.
QAP 3, Quality Assurance Classifications, revision 3
QAP 6, Inspection Planning, revision 6
.
.
QAP 7, Configuration Control, revision 6
QAP 12, Testing Inspection, revision 3
.
QAP 13, Maintenance Inspection, revision 13
.
-
-
-
-
,
,
' '
.,
-18-
QAP 14, Calibration of Measurement and Test Equipment,
.
revision 3
QAP 17, Noncomforming Material Control, revision 9
.
.
QAP 20, Quality Control Instructions, revision 1
QAP 24, Procedure Requirements, revision 1
.
QAP 29, Construction Inspection, revision 1
.
(5) Quality Control Instructions (QCI)
.
QCI 1, Processing of Nonconforming Reports, revision 6
.
QCI 2, SMUD Nuclear Operations Quality Assurance Audit
,
Program, revision 10
QCI 5, Design Review and Processing of 50.59 Facility
Changes, revision 4
QCI 11, External Architectural / Engineering Design Review
.
Procedure, revision 1
(6) Administrative Procedures (AP)
.
AP 1, Responsibilities and Authorities, revision 4
AP 2, Review and Approval of Procedures, revision 8
.
.
AP 3, Work Request Procedure, revision 15
AP 8, Records Management, revision 0
.
AP 22, Reporting of Abnormal Occurences, revision 3
.
AP 26, Abnormal Tag Procedure, revision 3
.
AP 33, Calibration and Control of Inspection and Test
.
Equipment, revision 0
AP 700, Training Program, revision 2
.
(7) Plant Maintenance Procedure
M 125, Control of Plant Modifications, revision 0
.
(8) Engineering Configuration Procedures (ECP)
ECP 1, Rancho Seco Configuration Control Procedure,
.
revision 1
_
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.
,
.
-
ECP 3, Rancho Seco Vendor Drawing Control Procedure,
.
revision 1.
b.
Findings
(1)- Items of Noncompliance
(a) Rem 50-312/80-15-09
10 CFR 50, Appendix B, Criterion V, requires activities
affecting quality be prescribed by documented i,nstructions
and procedures and be accomplished in accordance with
these instructions and procedures.
QA Manual, procedure QAP 2, Design Review, Item 1 under
General Requirements, requires that changes in plant
equipment, systems, components... cannot be made unless
appropriate safety reviews have been made as required in
10 CFR 50.59, and implemented in conformance with the
Technical Specifications, Administrative Procedures, and
the Quality. Assurance Manual.
Rancho Seco Configuration
Control Procedure, ECP 1, Section 4.1, requires engineering
and management reviews and approvals for plant changes.
Section 3.1.3 requires that an approved Engineering Change
Notice (ECN) be issued prior to a Drawing Change Notice
(DCN).
Section 3.2, Step 3.2.1, requires an ECN be issued
for all configuration changes that require plant modifica-
tion; and step 3.2.2 requires department manager level
approval for any changes to Class I systems or equipment.
Contrary to the above, Class I system modifications were
made without the appropriate engineering and management
reviews and approvals as required in the following
instances:
Terque switch setpoint values.as provided on the
.
electrical drawings (table by valve number) were
changed and noted on the abnormal tags.
Abnormal
Tag 0415, 7/1/79, Valve SFV 20577 (2A122), set point
from 1.0 to 2.0; and Abnormal Tag 0416, 7/2/79,
Valve SFV 20578 (2B16), set point from 1.0 to 2.0;
and Abnormal Tag 0493, 3/3/80, Valve SFV 46203'(2A145),
set point from 1.25 to 2.0.
A model 7012 PC Agastat relay was installed in the
.
starting circuit of the "A" emergency diesel generator
to replace a model 2412 PN Agastat relay.
Abnormal
Tag 0515, 4/16/80, GEA "A" EDG cabinet, SK 6292F-87,
SH 4, model 7012 PC for old model 2412 PN, was issued.
-
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..
._____._____l___._._._________...,_._.__
.
,
.
.
.
-20-
.
.
(2) Deviations
I
None.
(3) Unresolved Items
(a)
Item 50-312/80-15-10
Technical Specification 6.5.1.6 states that the Plant
Review Committee shall be responsible for review of all
proposed changes or modifications to plant systems or
equipment that affect nu' clear safety (Class I); and 6.5.1.7
states that the Plant Review Committee shall recommend to
the Plant Superintendent written approval or disapproval
l
of items considered and render determinations in writing
with regard to whether or not each item considered
constitutes an unreviewed safety question.
!
The licensee's interpretation of this Technical Specifica-
tion requirement allows the Engineering Supervisor to
conduct the. initial review of the proposed changes to
determine whether the changes affect nuclear safety.
The
Plant Review Committee reviewed only those items referred
to it by the Engineering Supervisor.
Furthermore, the
Plant Review Committee did not appear to review the judg-
ments made by the Engineering Supervisor on proposed
changes to safety-related (Class I) systems.
The . actual determination made by the Engineering Supervisor
was on the applicability of the requirements of 10 CFR 50.59 to the change, that is, whether or not the change
was a change to the facility as described in the safety
analysis report.
This determination sas indicated on an
Engineering Change Notice (ECN) by a "Yes or No" checkmark
in the space entitled "Is 10 CFR 50.59 safety review
required?" The technical specifications requirement that
the PRC be responsible for review of all proposed changes
,
or modifications that affect nuclear safety was not
addressed by this determination.
The licensee processed the following changes and
modifications to Class I systems and equipment (including
structures) without the prior reviews and recommendations
of the Plant Review Committee.
The determination by the
Engineering Supervisor was indicated as a "No" on the ECN;
therefore, a 10 CFR 50.59 safety review was not required.
ECN/DCN A-2722, Control Room Air Conditioning
.
Charcoal Filter System, Class I, documented the
installation of a thermocouple, high temperature
alarm, :n the charcoal bed for detection of a high
.-_
temperature (fire) condition.
The activity was
.
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.
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completed using work requests (WR) 44551, 42308, and
44349 during the recent refueling outage.
ECN/DCN A-2784, Reactor Coolant System, Class I,
.
documented the installation of conduit and pulling
cable for the power operated relief valve (PORV)
power supply.
The activity was completed using work
requests (WR) 46054 and 46200 during the recent
outage.
ECN/DCN A-2742,' Reactor Coolant Systcm, Class I,
.
documented the installation of conduit, pulling
-
cable, and core drilling for power to the pressurizer
heaters.
The activity was completed using work
.
requests (WR) 44354 and 46195 during the recent
outage.
ECN/DCN A-2284, Reactor Coolant System, Class I,
.
4
documented the installation of a new reactor coolant
pump seal.
The activity was completed using work request 44351 during the recent outage.
ECN/DCN A-2823, Reactor Building Ventilation System,
.
Class I, documented the installation of a screen over
the building equalizing line to prevent debris from
entering the line and degrading the isolation valve
function.
This activity was completed during the
recent outage.
ECN/DCN A-2640, Equipment for disposal of irradiated
.
0 rings, orifice rods, burnable poison rods.
ECN/DCN A-2644, Electrical Distribution System, Class
.
I, documented the installation of ground wires at a
different, accessible location.
ECN/DCN A-2670, Fire Protection System, Class III,
~
.
documented the replacement of the motor driven fire
pump motor controller.
Other system modifications were made and documented
utilizing AP 26, Abnormal Tag Procedure.
This allowed the
change to be made by a field engineer and a shift super-
visor, which bypassed the PRC review and approval require-
ments.
The following five changes were made.
Torque switch setpoint values as provided on the
.
electrical drawings (table by valve numbers) were
changed and noted on the abnormal tags.
Abnormal Tag 0415, 7/2/79, Valve SFV 20577 (2A122),
set point from 1.0 to~2.0.
-
_ _ _ _ _ ,
.
'
-22-
o
.
.
.
Abnormal Tag 0416, 7/2/79, Valve SFV 20578 (2B16),
set point from 1.0 to 2.0.
Abnormal Tag 0493, 3/3/80, Valve SFV 46203 (2A145),
set point from 1.25 to 2.0.
Drawing E-203-05.
.
A model 7012 PC Agastat relay was installed in the
starting circuit of the "A" emergency diesel generator
to replace a model 2412 PN Agastat relay and to
improve the start-time of the diesel (timer erratic).
Abnormal Tag 0515, 4/16/80, GEA "A" EDG cabinet, SK
-
6292E-87, SH 4, model 7012 PC, old raodel 2412 PN.
Noncomformance Report (NCR) S-1905 was issued docu-
menting the modification.
I
The T saturation instrument power was modified
.
utilizing six capacitors to eliminate noise spikes.
Y
Abnormal Tag 3453 was issued on 4/2/80 and NCR S 1875
was written to document the modification.
.
The radiation monitor R-15042 (H7J894) power was
modified by placing a capacitor between the +14V
supply and J-box.
Abnormal Tag 3308 was issued on
4/11/78 and NCR 1305 was written, documenting the
modification.
The radiation monitor R-15019B (H4MRL) failure
.
position was bypassed.
Abnormal Tag 3383 was issued
on 3/6/79 and NCR 1870 was written, documenting the
modification.
Additionally a system modification was made and documented
utilizing only a NCR which bypassed the PRC review and
approval requirements.
NCR 1797 was issued documenting
the change of the time delay relay setpoint from 5 seconds
to 30 seconds ( 5) on the start circuit for the Reactor
Cavity Exhaust Fans (A-531A/B/C/D).
This matter is considered as unresolved pending review by
IE HQ.
(b)
Item 50-312/80-15-11
10 CFR 50.59(b) states that the licensee shall furnish to
the appropriate NRC Regional office, with a copy to the
Director of Inspection and Enforcement, annually or at
such shorter intervals as may be specified in the license,
a report containing a brief description of such changes,
tests, and experiments, including a summary of the safety
evaluation of each.
i
1
-
l
)
_.
.
,
.
-23-
.
!
-
The licensee Technical Specification 6.9.3 requires a
nunnthly report to be provided which includes a tabulation
of the facility changes, tests, and experiments required
pursuant to 10 CFR 50.59(b).
The licensee reports of May, June, and July,1979, included
a tabulation of facility changes and a brief description.
The reports, however, did not include a summary of the
safety evaluation of each change.
This matter is considered unresolved pending review by IE
HQ.
(c)
Item 50-312/80-15-12
10 CFR 50.59(a)(1) states that the holder of a license
authorizing operation of a facility may make changes to
the facility as described in the safety analysis report,
without prior Commission approval, unless the proposed
change involves a change in the Technical Specifications
or an unreviewed safety question.
10 CFR 50.59(b) states
that the licensee shall maintain records of changes made
pursuant to this section; and these records shall include
a written safety evaluation which provides the basis for
the determination that the change does not involve an
unreviewed safety question.
The licensec performed a safety evaluation providing the
justification for having two spent fuel assemblies in a
" fuel sipping" device and subjecting the two assemblies to
possible simultaneous failure.
Prior to the use of the
new fuel " sipping device," only one spent fuel assembly
was subject to failure during normal fuel handling activi-
ties.
The new spent fuel " sipping device" allowed two
spent fuel assemblies to be subject to possible failure
simultaneously during normal fuel handling activities.
In order to maintain the postulated offsite radioactive
release from the spent fuel building below the value
assumed by the safety analysis report, an administratively
controlled delay period of ten days was required by the
new safety analysis.
The radioactive release assumed by the safety analysis
report was based upon the failure of one spent fuel
assembly after a 72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> delay period (decay time).
The
72 hour8.333333e-4 days <br />0.02 hours <br />1.190476e-4 weeks <br />2.7396e-5 months <br /> delay period (decay time) was a physical limit due
to the time required for plant shutdown, cooldown, heat
removal, cavity flooding, etc.
The new safety analysis
imposed only an administrative limit of ten days (decay
time).
_
'
.
.
-24-
.
It was noted that the procedural controls allowed only one
spent fuel assembly to be located in the sipping device at
one time to reduce the possibility of the simultaneous
failure of two spent fuel assemblies.
The substitution of an administrative control for a
physical control and the provision for handling two fuel
assemblies simultaneously during normal fuel handling
cctivities appeared to be nonconservative.
This matter is
considered unresolved pending further inspection effort.
'
6.
Maintenance
The objective of this portion of the inspection was to determine the
adequacy of management controls over the corrective and preventative
maintenance activities.
a.
Documents Reviewed
(1)
Licensee correspondence:
.
To SMUD (Mattimoe) from D0R (Reid), June 1, 1976
.
To D0R (Reid) from SMUD (Mattimue), July 22, 1976
.
To 00R (Reid) from SMUD (Mattimoe), September 23, 1976
To SMUD (Mattimoe) from D0R (Reid), December 13, 1976
.
(2) Rancho Seco FSAR
.
Chapter 12, Conduct of Operations
Appendix 1B, Quality Assurance Program
.
(3) Rancho Seco Technical Specification, Section 6.0, Administrative
Controls
(4) Quality Assurance Procedures (QAP)
QAP 1, Organization, revision 4
.
.
QAP 2, Design Review, revision 5
.
QAP 3, Quality Assurance Classifications, revision 3
QAP 6, Inspection Planning, revision 6
.
.
QAP 7, Configuration Control, revision 6
.
QAP 9, Control of Special Processes, revision 2
_
'
,
.
_
_
-
i
,
-25-
,
.
.
QAP 12, Testing Inspection, revision 3
.
QAP 13, Maintenance Inspection, revision 13
.
QAP 14, Calibration of Measurement and Test Equipment,
.
revision 3
QAP 17, Noncomforming Material Control, revision 9
.
.
QAP 20, Quality Control Instructions, revision 1
QAP 24, Procedure Requirements, revision 1
.
QAP 26, Test Control, revision 1
.
l
QAP 29, Construction Inspection, revision 1
.
(5) Quality Control Instructions (QCI)
.
QCI 1, Processing of Nonconforming Reports, revision 6
QCI 2, SMUD Nuclear Operations Quality Assurance Audit
.
Program, revision 10
.
QCI 6, Qualification of Testing Laboratories, revision 0
(10/16/74)
QCI 108, Welding Inspection, revision 2
.
QCI 110, Welding Documentation Procedure, revision 0
.
(4/12/76)
(6) Administrative Prucedures (AP)
.
AP 1, Responsibilities and Authorities, revision 4
AP 2, Review and Approval of Procedures, revision 8
.
AP 3, Work Request Procedure, revision 15
.
.
AP 8, Records Management, revision 0
.
AP 22, Reporting of Abnormal Occurences, revision 3
AP 26, Abnormal Tag Procedure, revision 3
.
AP 27, Internal Auditing, revision 11
.
AP 29, Use and Control of Combustible Materials and
.
Ignition Sources, revision 2
_
.
.
.
4
.
-26-
.
.
AP 33, Calibration and Control of Inspection and Test
.
Equipmen.t, revision 0
AP 35, Tools and Equipment Control, revision 0
.
AP 301, Maintenance Procedure (Description and Format),
.
revision 1
.
AP 700, Training Program, revision 2
(7)
Plant Maintenance Procedures
.
.
M 20, Makeup and High Pressure Injection Pumps, revision 2
M 113, Welding Procedure, revision 13
.
M 114, Maintenance Cleanliness Control, revision 5
.
M 125, Control of Plant Modifications, revision 0
.
M 127, Reactor Building Equipment Access Door, revision 0
.
.
EM 102, Removal and Installation of K-3000 Circuit Breakers,
revision 1
EM 164, Testing of Moulded Case Circuit Breakers, revision
.
2
.
EM 168, Electrical Maintenance Inspection of Emergency
Diesel Generator, revision 3
.
EM 169, Electrical Testing of Control Rod Drive Stators,
i
revision 2
l
I 014, General I&C Maintenance and Surveillance Guidelines,
,
.
revision 0
I 110, Neutron Detector Removal and Replacement, revision 0
.
I 112, RPS Flow Channel Scaling, revision 4
.
b.
Findings
(1)
Items of Noncompliance
(a)
Item 50-312/80-15-13
Technical Specification 6.8.1 states that written
procedures shall be established covering the activities
recommended in Appendix "A" of Regulatory Guide 1.33,
November 1972.
~
-
.
a
-27-
.
.
Appendix "A" of Regulatory Guide 1.33, Section A,
recommends Administrative Procedures for typical safety-
related activities.
FSAR, Sections 12.2 and 12.4, and Appendix 1B of the FSAR,
requires preventative .naintenance programs and detailed
administrative procedures for the methods of maintenance
activities, including preventative maintenance.
QA Manual, procedure QAP 24, required procedures in
accordance with Regulatory Guide 1.33, including preven-
tative maintance,
s
Contrary to the above, an administrative procedure was not
,
provided to control the safety-related preventative main-
tenance program.
The licensee's Administrative Procedure Index identified
'
AP650, Preventive Maintenance Program, as the controlling
procedure for preventive maintenance; however, AP650 was
never issued.
-(b) Item 50-312/80-15-14
Technical Specification 6.8.1 states that written
procedures shall be maintained covering the activities
recommended in Appendix "A" of Regulatory Guide 1.33,
November 1972.
Appendix "A" of Regulatory Guide 1.33,Section I,
recommends procedures, instructions, or drawings for
performance of maintenance which can affect the performance
of safety-related equipment.
Contrary to the above, the licensee performed safety-
related maintance activities without approved procedures.
As an alternative to written procedures the licensee
utilized vendor / technical manuals; however, these manuals
were uncontrolled and did not receive management review
and approval.
,
The following activities required the use of vendor /
technical manuals for performing repairs to safety-related
i
equipment.
.
. Work Request 47323, RPS Channel B Power / Imbalance /
Flow Function Generator Module.
Adjusted break
points and slopes.
Work Request 47445, S-1C Inverter C Low Voltage.
.
.
.
e
y
-5
--
--
, +
,-+. - . mm - tre-
.
,-c
+
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-7*
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g
1
- - - - * * *=-
m,*
- - - - > =
,
,
. _ -
_
.
,
-28-
.
.
Maintenance procedure M20, Makeup and High Pressure
.
Injection Pumps, revision 2.
The procedure referenced
included vendor manuals in Sections 2.1 and 2.5.
Maintenance procedure EM 102, Removal and Installation
of K-3000 Circuit Breakers, revision 2.
The procedure
required the use of the ITE Manual IB-9.1.7-4, Issue
C.
Maintenance procedure EM 164, Testing of Moulded Case
Circuit Breakers, revision 2.
The procedure called
out the Westinghouse Manual (MB-3051) and calibration
-
curve, including the acceptance criteria.
(
Maintenance procedure EM 169, Electrical Testing of
The procedure required the
use of the vendor / technical manual and drawings
d'uring testing.
.
Instrument procedure I 014, General I&C Maintenance
and Surveillance, revision 1.
This procedure
referenced vendor / technical manuals and drawings to
be utilized during routine corrective and preventa-
tive maintenance and surveillance.
.
Instrument procedure I 112, RPS Flow Channel Sealing,
revision 4.
The procedure referenced the Bailey
Meter Company Instruction Manuals.
The inspector noted that the instrument department had few
detailed written maintenance procedures and that the
majority of the safety-related department maintenance was
performed utilizing the skills of the technicians and
vendor / technical manuals.
(c)
Item 50-312/80-15-15
10 CFR 50, Appendix B, Criterion X requires a program for
inspections of activities affecting quality be established
and executed by the organization performing the activity,
to verify conformance with the documented instructions,
procedures, and drawings for accomplishing the activity.
FSAR Appendix 18, Quality Assurance Program, Sections 1B,
9.6, 1B.1.10, and 1B.2.2 requires inspection activities
during plant operation.
QA Manual, procedure QAP 1, Organization, required inspec-
tion activities to be performed by Nuclear Operations
(operations and maintenance inspections); required assis-
tance to Quality Assurance in audit and inspection activi-
ties by Nuclear Operations where operational expertise is
_
,
_ _ .
. . -
.
4
,
'
.
-29-
o
.
'
.needed; and required assurance that. inspection planning be
completed by Quality Assurance and Nuclear Operations.
Contrary to the above, the following maintenance activities
were not routinely inspected or documented.
Preventative maintenance, including mechanical,
.
electrical, and instrumentation areas.
Equipment control, including removal of equipment
.
from service for maintenance and return to service
following maintenance.
'
Functional testing before and after maintenance.
.
(d)
Item 50-312/80-15-16-
10 CFR 50, Appendix B, Criterion XII requires that measures
shall be established to assure that tools, gauges, instru-
ments, and other measuring and testing devices used in
activities affecting quality are properly controlled,
calibrated, and adjusted at specified periods to maintain
accuracy within necessary limits.
Quality Assurance Procedure 14, Calibration of Test and
Measurement Equipment, required calibration of devices
used in operation of Rancho Seco; assigned responsibility
to Nuclear Operations; and required an evaluation when
devices were found out of calibration.
Contrary to the above, measures had not been established
for the control . of mechanical measuring devices such as
torque wrenches, micrometers, and dial indicators.
(e)
Item 50-312/80-15-17
Technical Specification 6.8.1 states that written
procedures be established covering activities recommended
in Appendix "A" of Regulatory Guide 1.33, November, 1972.
Appendix "A" of Regulatory Guide 1.33, Section A,
recommends administrative procedures for typical safety-
related activities.
Administrative procedure, AP 8, Records Management,
required records to be maintained in accordance with
ANSI N45.2.9-1974 for temporary and permanent records,
including storage requirements.
.
.
/
.
.
.
-30-
.
Contrary to the above, administrative, maintenance, and
testing procedures, and changes made thereto since the
beginning of facility operations, were stored in the
administratinn building in standard file cabinets.
(2) Deviations
None.
(3) Unresolved Items
'
None.
7.
Review of Licensed Activities
i
The objective of this portion of the inspection was to determine the
adequacy of the licensee's management controls over licensed activities
and the adequacy of the program for reviewing, monitoring and auditing
,
the performance of licensed activities by all levels of management.
a.
Documents Reviewed
(1) Quality Assurance Program, Appendix 1B, Final Safety Analysis
Report (FSAR)
(2) Rancho Seco FSAR, Chapter 12, Conduct of Operations
(3) Technical Specifications, Section 6, Administrative Controls
(4) Administrative Procedures (AP)
.
AP 1, Responsibilities and Authorities, revision 4
AP 2, Review, Approval and Maintenance of Procedures,
.
revision 8
AP 3, Work Requests, revision 15
.
AP 8, Records Management, revision 0
.
AP 17, Logging of Operational Transients, revision 1
.
AP 21, External Plant Reports, revision 4
.
.
AP 22, Reporting of Reportable Occurrences, revision 3
AP 23, Control Room Watchstanding, revision 4
.
AP 24, Control of Special Orders
.
AP 25 Licensed NRC Operator Retraining revision 4
.
-
'
.
'
i
1
-31-
.
.
NP26,AbnormalTagProcedure, revision 3
'
.
AP 27, Internal Auditing, revision 11
.
.
AP 28, Post Trip Transient Report
AP 700, Rancho Seco Training Program, revision 2
.
(5) Quality Assurance Procedures (QAP)
QAP 1, Organization, revision 4
.
,
QAP 17, Nonconforming Mater:al Control, revision 9
.
(
.
QAP 18, Documentation Control Center, revision 1
.
QAP 20, Quality Control Instructions, revision 1
!
QAP 23, Housekeeping, revision 1
.
QAP 25, Clearance Procedure, revision 1
QAP 26, Test Control, revision 2
.
(6) Quality Control Instructions (QCI)
QCI 1, Process of Nonconformance Reports (NCRs), revision 6
.
QCI 5, Design Review and Processing of 50.59 Changes,
revision 4
QCI 8, Backshift and Weekend Visit Program, revision 1
.
QCI 10, 10 CFR21 Requirements, revision 2
.
(7)
Instrument and Control Abnormal Tag Log
'(8) Electrical Department Abnormal Tag Log
(9) Special Order Logs (Short and Long Term)
(10) Control Room Log, Entries from 12/8/79 to 3/1/80
(11) Shift Supervisor's Log, Entries from 12/79 thru 4/80
(12) Reportable Occurrence Reports 10/79 to 5/80
(13) NCR Status Reports, 12/79 and 4/80
(14) NRC Inspection Summary, 1975 thru May, 1979
_
c
1
_
.
.
.
,
-32
.
.
.
'
(15) Office Memorandums
NRC Enforcement Items, Schwieger to Raasch/ Rodriquez,
.
March 2, 1976
,
Results of AP 27 Audit, Colombo to Rodriguez, August 18,
'
.
1979
Surveillance Program, Price to McColligan, April 7, 1980
Distribution of NRC-Related Material, Mattimore to Staff,
.
January 17, 1980
-
,
Management Safety Review Committee (MSRC) Assignment
.
Commitments, April 17, 1980
.b.
Findings
(1)
Items of Noncompliance
None
(2) Deviations
None.
(3) Unresolved Items
Item 50-312/80-15-18
AP 1, Responsibilities and Authorities, Section 3.14.1.6
required the Senior Control Room Operator (SCRO) to remain in
the control room during normal or emergency conditions to
maintain command and control of the activities of control room
operators when the Shift Supervisor was not in the control
Section 3.14.2.1 gave the SCR0 the authority to direct
room.
the efforts of operators assigned to his shift.
.
Technical Specifications, Section 6.2.2, does not require an
SCR0 to maintain a senior license; however the licensee had
elected to have SCR0s with a senior license. When an SCR0
position could not be filled by a senior licensed operator, the
licensee placed a licensed operator into an acting SCR0 position.
This action was contrary to 10 CFR 50.54(1) which requires
individuals 'irecting licensed activities of licensed operators
lice'nsed as so..ior operators.
Control room log reviews indicated that the practice of using
licensed operators as Acting SCR0s had been in effect for some
time.
Discussions with licensee representatives indicated that
thel authority to upgrade a licensed operator to an acting SCR0
.
b
_ _ , , - - , , ,
-4
-
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TEST TARGET (MT-3)
-
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5 m HM
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MICROCOPY RESOLUTION TEST CHART
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,
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1.0
'!E8EM
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MICROCOPY RESOLUTION TEST CHART
- 4
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'
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.
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. _ _ . _ .
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.
.
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.
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-33-
,
.
'
'
was given to the Shift Supervisor on duty; however, management
provided no guidance in this area.
Additional record review will be necessary to ensure that the
licensee is operating within the regulatory requirements.
8.
Corrective Action System
The objective of this portion of the inspection was to determine the
adequacy of the licensee's management controls over the corrective action
system.
.
a.
Documents Reviewed
(1) Qual-Q/ Assurance Program, Appendix 1B, Final Safety Analysis
Report (FSAR)
(2)
Rancho Seco FSAR, Chapter 12, Conduct of Operations
(3) Technical Specifications, Section 6, Administrative Controls
(4) Administrative Procedures (AP)
AP 1, Responsibilities and Authorities, revision 4
.
.
AP 2, Review, Approval and Maintenance of Procedures,
revision 8
AP 3, Work Requests, revision 15
.
AP 8, Records Management, revision 0
.
AP 17, Logging of Operational Transients, revision 1
.
.
AP 21, External Plant Reports, revision 4
AP 22, Reporting of Reportable Occurrences, revision 3
.
.
AP 23, Control Room Watchstanding, revision 4
.
AP 24, Control of Special Orders
AP 25, Licensed NRC Operator Retraining, revision 5
.
AP 26, Abnormal Tag Procedure, revision 3
.
AP 27, Internal Auditing, revision 11
.
AP 28, Post Trip Transient Report
.
AP 700, Rancho Seco Training Program, revision 2
.
_
,
-
..
'
-34-
-
.
.
(5) Quality Assurance Procedures (QAP)
QAP 1, Organization, revision 4
.
QAP 17, Nonconforming Material Control, revision 9
.
QAP 18, Documentation Control Center, revision 1
.
QAP 20, Quality Control Instructions, revision 1
.
QAP 23, Housekeeping, revision 1
.
QAP 25, Clearance Procedure, revision 1
.
i
QAP 26, Test Control, revision-2
.
(6) Quality Control Instructions (QCI)
9
'
QCI 1, Processing of Nonconformance Reports (NCR's),
.
revision 6
QCI 5, Design Review and Processing of 50.59 Changes,
.
revision 4
QCI 8, Backshift and Weekend Visit Program, revision 1
.
QCI 10, 10 CFR21 Requirements, revision 2
.
(7)
Instrument and Control Abnormal Tag Log
(8)
Electrical Department Abnormal Teg Log
(9)
Special Order Logs (Short and Long Term)
(10) Control Room Log, Entries from 12/8/79 to 3/1/80
(11)
Shift Supervisor's Log, Entries from 12/79 thru 4/80
-
(12)
Reportable Occurrence Reports 10/79 to 5/80
(13) NCR Status Reports, 12/79 and 4/80
(14)
NRC Inspection Summary,-1975 thru May, 1979
(15)- Office Memorandums
NRC Enforcement Items, Schweiger to Raasch/ Rodriquez,
.
March 2, 1976
Results of AP 27 Audit, Colombo to Rodriguez, August 18,
.
1979
- .
-
.
!
.
<
.
'
'
.
-35-
,
.
~
.
Surveillance Program, Price to McColligan, April 7, 1980
Distribution of NRC-Related Material, Mattimoe to Staff,
.
January 17, 1980
Management Safety Review Committee (MSRC) Assignment-
.
Commitments, April 17, 1980
b.
Findinos
(1) Items of Noncompliance
Item 50-321/80-15-19
Technical Specification (TS) 6.8.2 requires the applicable
procedures recommended in Appendix A of Regulatory Guide
1.33-1972 be periodically reviewed.
.
Administrative Procedure 27, Internal Auditing, Section 3.4,
required a review of procedures be made, at a minimum, within
24-months from the date of last review.
Contrary to the above, a review of the following Administrative
Procedures showed they had not been reviewed within the required
time limit.
Procedure
Date of Last Review
AP 8
1/11/77
AP 14
10/15/76
AP 26
1/25/77
AP 28
2/27/75
AP 31
12/27/76
AP 33
5/2/77
AP 34
3/23/77
AP 35
4/5/77
AP 301
1/11/77
.
AP 305-3
8/2/76
AP 305-4
6/7/76
AP 305-5
7/18/77
AP 305-6
8/3/76
AP 305-9
10/5/76
AP 27, Internal Auditing, required the Technical Assistant (TA)
to perform an audit of procedures every six months. .The TA was
required to inform the Plant Superintendent of all procedures
that required review within the next six months and to inform
the Plant Superintendent of all procedures for which reviews
were deficient.
This audit was performed by the licensee;
however, upper management's corrective action appeared
inadequate. .The inspector used the li.censee's audit, conducted
on August 16, 1979, to determine if corrective action had been
.
- -
- -
- -
-
.
.
--
- --
-
-
.
-
-
- - -
- - -
-
-
-
-
- - - -
-
-
,
'4
,
-36-
,
.
taken for those procedures identified as not reviewed.
The
, .
licensee's master copies-indicated the procedures had not been
reviewed.
(2) -Deviations
None
(3) Unresolved items
Item 50-312/80-15-20
.
10 CFR 50, Appendix B, Criterion XVI, requires measures be
established to assure that nonconformances are promptly identi-
fied and corrected.
,
4
QCI 1, Processing of Nonconformance Reports - (NCR's), Section
5.9, required the Manager, Nuclear Operations to be responsible
!
to insure prompt closure of NCRs.
The following number of NCRs were identified as open and
awaiting action.
One NCR over 5 years old
.
Two NCRs over 4 years old
.
.
Six NCRs over 3 years old
~
Thirteen NCRs over 2 years old and
.
Sixty NCRs over 1 year old
.
The Quality Assurance Department had implemented a tracking
system for NCRs and had sent upper management a memo listing
all open NCRs, identifying.the action required and the
individual responsible.
The QA memo of April, 1980, identified
254 NCRs still open.
Reportedly, the individuals assigned the
responsibility to ~ take action maintained their own tickler
system to ensure followup. There appeared to be no overview by
management and no time limits imposed to ensure prompt closure
of NRCs.
'
These open NCRs indicated that adequate measures to promptly
correct nonconformances were not effective; however, a clear
definition of prompt closure is necessary to determine licensee
compliance.
_
?
-
.
4
'
'
'
,
_37
.
.
.
9.
Training-
'
The objective of this portion of the inspection was to determine the
extent and adequacy of management's overview of licensed and non-licensed
training activities.
a.
Documents Reviewed
(1) Technical Specification, Section 6.0, Administrative Controls
(2) Administrative Procedures (AP)
,
AP 1, Responsibilities and Authorities, revision 3
.
AP 25, Licensed NRC Operator Retraining, revision 4
j
.
AP 700, Rancho Seco Training Program, revision 2
.
1
(3) Training records of selected licensed and non-licensed personnel
b.
Findings
t
(1) Items of Noncompliance
(a) Item 50-312/80-15-21
Technical Specification 6.4.1 requires that a retraining
and replacement training program for the operating staff
be maintained under the direction of the Training
Supervisor.
Administrative Procedure 25, Licensed NRC Operator
Retraining, Section 3.2.2,' required each licensed operator
to participate in an oral examination approximately 52
weeks following the start of the requalification program.
4
Section 3.6.5 required periodic written quizzes to deter-
a ---
-
mine the individuals knowledge of particular subjects
covered in lectures or reading assignments.
Contrary to the above, two licensed operators had not been
.
given oral examinations within time requirements.
The
i
requalification program cycle for these individuals started
in December 1978, and oral examinations had not been
conducted as of April 1980.
Also, the Training Supervisor
stated that only one quiz pertaining to lectures and
reading assignments had been given in the last five years.
(b)
Item 50-312/80-15-22
Technical Specification 6.4.1 requires the licensee to
.
maintain a retraining and replacement training' program for
_ .
the facility staff which meets or exceeds the requirements
s
N
v
m
-
wat
7-
m
w
e
-e7
'y
e v
-e-w
s
-
em
-
w
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e
9
.
-
,
4
'
'
-38-
..
,
.
and recommendations of Section 5.5 of ANSI-N18.1-1971.
Section 5.5 of ANSI N18.1-1971 requires a training program
be established which maintains the proficiency of the
operating organization through periodic exercises, instruc-
tions, reviews, and special training sessions.
It further
.equires the program provide means for evaluating the
effectiveness.of the training program.
Administrative Procedure (700), Rancho Seco Training
Program, establishes general training requirements,
primarily for the following non-licensed personnel:
new
employees, nuclear operations, maintenance, technical
support, chemistry, and health physics.
AP 700 was issued
May 30, 1977.
h'
Contrary to the above, the major portions of the
non-licensed personnel training programs had not been
fully implemented as of May 8, 1980.
New employee training
,
was the only program fully implemented.
General training
was being presented however, all personnel had not attended
training sessions as required.
There appeared to be no
formal system to readily identify those individuals who
were delinquent in training.
Specific training as
specified in AP 700 had only limited implementation.
Generally, there were no training outlines or records of
specific training in the individual personnel's-training
files as maintained by the Training Supervisor.
(2) Deviations
None.
(3) Unresolved Items
None.
10.
Inservice Inspection and Testing of Pumps and Valves
The objective of this portion of the inspection was to determine the
extent and adequacy of managenent's overview of the Inservice Inspection
(ISI) program and the Inservice Testing (IST) of Pumps and Valves.
a.
Documents Reviewed
(1) Technical Specification, Section 6.0, Administrative Controls
(2) Ten Year Inservice Inspection Plan
(3) Schedule of Examinations
(4) Examination Procedures (general review)
-
-
-
- -
-
-
-
-
-
- - -
- - -
- - - - -
-
-
-
-
-
- -
.
9 '.
'
-
,
- -39-
,
'
.: .
.
.
.(5) . Quality Assurance Procedures (QAP)
' QAP 17, Control of Nonconforming Material
.
_
QAD 21,-Inservice Inspection,-revision 3
.
(6) Surveillance Procedures (SP)
SP 203.05B, Quarterly DHR Pump P-261B Surveillance and
.
Inservice Test
SP' 203.06A, Quarterly DHR-A Loop Valve Inspection and
-
.
-
Surveillance
SP 213.01, Pump Files for Inservice Tests and Inspection,
.
revision 0
SP 214.01, Inservice Inspection of Valves (Draft)
.
SP 214.02, Inservice Testing'of Relief / Safety Valves,.
.
revision 0
(7). Audit 0-276, Part I, Inservice Inspection by B&W Construction
Company
(8) Audit 0-277, Eddy Current Inspection of OTSG Tubing During 1980
Refueling
b.
Findings
(1) Items of Noncompliance-
None.
(2) Deviations
None.
(3) Unresolved Items
None.
11.
Management of Fire Prevention / Protection
- The objective of this portion of the inspection was to determine the
extent and adequacy of management's overview of Fire Prevention / Protection
activities.
a.
Documents Reviewed
, ,
(1) Technical Specification, Section 6.0, Administrative Controls
,
.
-
e
k*-
-
--.-.
.--- ----- --
-.
-.----
a-
-,__.--___a
- - - _ - - - - - . - - - - - - - - _ ~ _ - - - _ _ _ _ - - - - _ _ _ - . - - - - _ _ _ _ _ - _ . - - - - . _ _ _ _ - - - _ . . _ _ . . . - - - _ _ - _ - - _ - _ _ - _ - - . _ - _ _ , .
-
--
.
.
'
.,
--40-
,
(2) -Administrative Procedures (AP)
AP 3,_ Work Request
.
AP 4, Clearance Procedure
.
AP 29, Use and Control of. Combustible riaterials and
.
Ignition Sources
AP 30, Entrance into Carbon Dioxide Fire Protected Rooms
.
AP 32, Fire Drills and Firefighters Training Program
.
AP34, Fire Safety Inspection Guide
.
.
AP 303, Surveillance Program
AP 305-15H, Training for Users of Respiratory Protection
.
Equipment
AP 305-15E,.MSA Self Contained Breathing Apparatus (SCBA)
.
AP 500, Emergency Plan
.
AP 700, Trainin3 Program, Rev. 2
.
(3) Quality Control Procedures (QAP)
.
QAP 3, Quality Assurance Classification
QAP 28, Fire Protection
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(4) Maintenance Procedures
M 113, Welding Procedure, revision 12
.
M 125, Control of Plant Mo'difications, revision 0
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EM 156, Fire Detection and Deluge System Testing, revision
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3
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EM 157, Fire Protection Cordox System Routine Testing
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EM 158, Resealing and Maintaining Fire Barriers for
.
Electric Cable
(5) Surveillance Procedures (SP)
SP 201.03A, Weekly Surveillance of Plant Fire Systems,
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revision 1
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.SP 201.03B, Monthly Surveillance of Plant Fire Pumps and
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Power Supplies, revision 5
SP 201.03C, Quarterly Surveillance of Plant Fire Pumps and
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Power Supplies, revision 0
SP 201.03D, Semi-Annual Surveillance of Plant Fire Pumps
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and Power Supplies, revision 0
SP 201.03E, Annual Surevillance of Fire Suppression
.
Systems, revision 1
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SP 201.03G, Refueling Internal Fire Suppression System
.
Surveillance, revision 2
(6) Safety Manual, Nuclear Operations
(7) Training records for selected fire brigade members
(8) Amendment No. 19 to Facility Operating License No. DPR-54
(February 28, 1978)
(9) NRC/ DOR letter of January 18, 1978,'to SMUD, requesting
additional information concerning the Fire Protection Program.
(10) SMUD letter of February 1, 1978, to NRC/ DOR, providing requested
information concerning the Fire Protection Program.
b.
Findinos
(1) Items of Noncompliance
(a)
Item 50-321/80-15-23
Technical Specification 6.4.2 requires the licensee to
maintain a training program for the Fire Brigade which
meets or exceeds the requirements of Section 27 of the
NFPA Code-1975, except refresher classroom training shall
be on a quarterly basis.
Administrative Procedure 32 required the Fire Brigades to
receive quarterly Fire Science /Firefighting classroom
training followed by a drill ~and critique.
A review of
training records of eight designated fire brigade members
(3 equipment attendants, 2 auxiliary operators, and 3
senior control room operators) revealed that seven of the
eight had not. participated in fire drills, and associated
classroom training, during the 4th quarter of 1979 and/or
the 1st quarter of 1980.
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(b). Item 50-312/80-15-24-
Admendment No. 19 to Facility Operating License No. DPR-54
'(February 28, 1978) states that "the licensee has elected
to meet NRC's fire protection QA criteria by applying
their existing QA program under 10 CFR 50, Appendix B, to
fire protection."
QA Manual, Procedure QAP 28, Fire Protection, stated in
part-that "all fire protection caterial and equipment
shall be classified in accordance with QA Manual,
Procedure QAP 3, Quality Assurance classification."
As of April 18, 1980, fire protection material and equip-
4
ment had not been classified.
This item appears to be
significant since major fire protection modifications had
just been completed.
A licensee representative stated the
modifications were made to at least the same criteria as
I
the original installations.
(2) Deviations
Item 50-312/80-15-25
NRC correspondence of January 18, 1978, tc the licensee stated:
"Your fire fighting procedures should be supplemented in order
to establish the necessary strategies for fighting fires in all
safety related areas and areas presenting a hazard to safety
related equipment.
These strategies should identify for each
area:
combustibles; methods of fighting fires; access and
egress routes; vital heat sensitive components and equipment;
system and equipment location; toxic hazards; ventilation and
smoke removal equipment operations.
In addition the validity
of the preplanning strategies should be tested by appropriate
full-dress drills to check the logic of the strategy, the
adequacy of the equipment, person.'el understanding and to
uncover unforeseen problems."
The licensee committed in corresponuance of February 1, 1978,
to the following:
"A program is being developed for the Fire
Protection Trainiig Course that will describe the necessary
strategies to be used for fighting fires at Rancho Seco.
The
training program will identify each area, combustibles, methods
of fighting fires, access and egress routes, vital heat sensi-
tive components and equipment, system and equipment location,
toxic hazards, amt ventilation'and smoke removal equipment.
Every type of room identified in the Fire Hazard Analysis will
be the subject of the quarterly drills.
The strategy to attack
each type of fire will be discussed during classrcom lectures
and be put to an appropriate test during the drill.
These
procedures will be complete within three months after NRC
acceptance of this reply."
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Amendment No. 19 to Facility Operating License No. OPR-54 was
issued on February 28,1978.
Paragraph 6.6 discusses fire
fighting procedures and addresses fire strategies; however,
portions of this paragraph were inadvertently omitted from the
Amendment.
As of April 18, 1980,. procedures addressing fire strategies had
not been written.
(3) Unresolved Items
None.
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12.
Procurement
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The objective of this portion of the inspection was to determine the
adequacy of management controls in the area of procurement.
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a.
Documents Reviewed
(1) Quality Assurance Procedures (QAP)
QAP 1, revision 4, Organization
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QAP 3, revision 3, Quality Assurance Classificatico
.
QAP 4, revision 5, Procurement Document Control
.
QAP 5, revision 4, Supplier Quality Assurance
.
QAP 8, revision 4, Identification and Control of Material,
.
Parts and Components
QAP 10, revision 6, Receiving Inspection
.
QAP 11, revision 0, Source Inspection
.
.
QAP 15, revision 1, Handling, Storage, Shipping, and Pre-
servation
QAP 17, revision 9, Nonconforming Material Control
.
(2) Administrative Procedure, AP.605, revision 5, General
Warehousing
b.
Findings
(1)
Items of Noncompliance
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Iten 50-312/80-15-26
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10 CFR 50, Appendix B, ' Criterion V, requires that activities
affecting quality be prescribed by documented instructions,
procedures, or drawings, and be accomplished in accordance with
these documents.
QA Manus', procedure QAP 4, Procurement Document Control,
states ir aart:
"When procurement of Class I or selected Class
II compo:.ents, parts, materials, is necessary from an unapproved
supplier, the receiving inspection requirements of QAP 10 for
an unapproved supplier must be met before the article can be
used."
.
QA Manual, procedure QAP 10, Receiving Inspection, states in
F
part:
"A receiving inspection will be performed on all Class I
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or selected Class II items including contractor furnished
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materials....If an item is purchased from an unapproved supplier
the RIDR will indicate the acceptance requirements. The accep-
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tance requirements may be documented on a Certificate of
Conformance...."
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Contrary to the above, an Agastat relay, model 7012 PC was pur-
chased from an' unapproved supplier. The relay was classified
QA Class I and no Certificate of Conformance was requested from
the supplier.
There was no Receiving Inspection Data Report
(RIDR) filed. The relay was installed on Diesel General A, on
April 16, 1980, as a replacement for Agastat relay, ocdel 2412
PN.
(2) Deviations
Item 50-312/80-15-27
The licensee committed to WASH document 1284, Guidance on QA
Requirements During the Operations Phase of Nuclear Power
Plants, in ~1etter to the NRC/ DOR of July 22, 1976 and September
23, 1976.
WASH docu=ent 1284 contains Regulatory Guide 1.38,
Quality Assurance Requirements for Packaging, Shipping,
Receiving, Storage and Handling of Items for Water-Cooled
Nuclear Power Plants, which states in part:
"The requirements
and guidelines ....that are included in ANSI N45.2.2-1972,
Packaging, Shipping, Receiving, Storage and Handling of Items
for Nuclear Power Plants.. .are generally acceptable and provide
an adequate basis for complying with the pertinent quality
assurance requirements of Appendix B to 10 CFR 50,...."
ANSI N45.2.2-1972, Section 2.7, Classification of Items,
requires the buyer to classify quality items into one of four
levels with respect to protective ceasures to prevent damage,
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deterioration, or contamination of the items.
Section'6.4.2,
Care of Items, requires that care of items in_ storage shall be-
exercised through specific measures.
Contrary to the above, on April 18, 1980, it was determined
that the licensee was not classifying Class I items into one of
the four levels identified in Section 2.7 of ANSI'N45.2.2.
It
was observed, on April 18 and May 6,_1980, that items in storage.
did not'have all covers, caps, plugs, or other closures intact.
Two Class I' valves, stock numbers 030342 and 033473, had protec-
tive covers partially or completely removed.
Other Class-I
items were observed wi-th no caps covering threads, welding
surfaces uncovered, and flange faces unprotected.
There were
no specific programs for. limited shelf life items and for
preventive maintenance on Class I' items.
(3) Unresolved-Items
(
None.
13.
The objective of this portion of the inspection was to determine the ade-
quacy of management contiols in the area of Plant Security.
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a.
Documents Reviewed' '
0) Modified Amended Physical Security Plan,-including Amendments 1
through 7, effective February 23,_1979.
(2) Security < Plan Implementation Procedures-(SPIP):
.
SPIP 1, Guidelines and Format
SPIP 2, Access Authorization
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SPIP 3, Material and Property Control and Personnel
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Searches
SPIP 4, Physical Barriers and Access Points
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SPIP 5, Badging Requirements and Procedures
.
SPIP 6, Security Force Organization
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SPIP 7, Security Force-Screening ar.d Physical Fitness
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SPIP 8, Security Force-Training and Requalification
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SPIP 9, Selection of Facility SMUD Employees
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SPIP 10, Guard Authority and Duties
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SPIP 11, Firearms and Weapons-Issuance, Use and Safety
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Requirements
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. SPIP 12, Communications
SPIP 13, Audits and Investigations
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SPIP-14, Testing and Maintenance of Security Equipment
SPIP'15, Internal Disturbance
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SPIP 16, Sabotage and/or Bomb Threat
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SPIP 17, Unauthorized Personnel in Designated Areas
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SPIP 18, Hostage Situation
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SPIP 19, Attack Threat'
.
SPIP 20, Security Lock and Key System plus Vital Area and
.
Equipment Control
SPIP 121, Alarm Annunciation and Annunicators, plus Special
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Purpose Detectors
SPIP-22, Security Forms and Reports
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SPIP 24, Duties of Guard Force Supervisor
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SPIP' 25, . Duties of Vehicle Patrol and Alarm Assessment
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Officers
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SPIP 26, Duties of Officers on Foot Patrol
SPIP 27, Escorts
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SPIP 28, Use and Control of Property
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SPIP 29, Use and Control of Non-lethal Chemical Agents
SPIP 30, Security Force - Performance of Duty
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SPIP 31, Civil Disruption
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SPIP 32, Sniper
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SPIP 33, Radiological Incidents and Nonsecurity-Related
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Emergencies
SPIP 34, Response to Alarms
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SPIP 35, Duties of Portal Search Officers
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$ PIP 36,DutiesofDefensivePositionOfficers
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SPIP 37, Inspection of the Ccntainment Building
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- SPIP 38, Compensatory Measures for Perimeter Alarm
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Deactivations
SPIP 39 Evacuation of Site
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SPIP 40, Loss of Onsite and Offsite Power
.
SPIP 41, Duties of Personnel on Firewatch
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SPIP 42, Duties of Security Helpers
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SPIP 43, Discovery of Breach of Perimeter Barrier
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SPIP 44, Vital Area Found Unlocked and Unattended or
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SPIP 45, Member of Security Force (MSF) Fails to-Perform
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Duties
SPIP 46, Fire, Explosion or other Catastrophe
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SPIP 47, Adversaries Have Commandeered Area of Plant
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SPIP 48, Security Alert
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SPIP 49, Security Emergency
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SPIP 50, Vital Area Intrusion Alarm Annunciates in CAS
SPIP 51, Multiple Loss of Communications System
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SPIP 99, Overall Physical Security Program Performance
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(Vulnerability) Test
(3) Safeguards Contingency Plan, submitted; May 10, 1978.
(4) - Quality Assurance ; ; ocedure, QAP 22, revision 2, Plant Security
and Visitor Control.
(5)- Security Drawing Control Procedure, July 13, 1978.
(6) Security Plan Evaluation Report, Docket No. 50-312.
b.
Findings
(1) Items of Noncompliance
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Item 50-312/80-15-28
10 CFR 73.55 requires the licensee implement his amended
physical security plan no'later than February 23, 1979.
lbe licensee's modified amended physical security plan, Section
1.3.3, states in part:
" Followup training which will discuss
significant changes and problems related to security will be
held for all site personnel at least every 12 months."
Contrary to the above, the last followup training was presented
to site personnel during the period February 12-14, 1979.
The
next followup training was scheduled to be conducted Mcy 27-30,
1980, which exceeds the 12 month requirement.
(2) Deviations
None.
(3) Unresolved Items
None.
14.
Unresolved Items
Unresolved items are matters about which more information is required in
order to ascertain whether they are acceptable items, items of noncom-
pliance or deviations.
The unresolved items identified in this inspection
are listed below:
Number
Subject
Paragraph
312/80-15-10
System Modifications Without PRC Review
5.b.(3)(a)
312/80-15-11
Summary of Safety Evaluations
5.b.(3)(b)
312/80-15-12
Control of Spent Fuel Assemblies in Fuel
5.b.(3)(c)
" Sipping Device"
312/80-15-18
Upgrading Licensed Operators to Acting SCR0s
7.b.(3)
312/80-15-20
Prompt Closure of Nonconformance Reports
8.b.(3)
15.
Management Meetings
Exit meetings were held at the site on April 21, 1980, and at the
corporate offices on April 25 and May 8, 1980, with licensee ranagement
(denoted in Paragraph 1).
The lead inspector summarized how the inspec-
tion findings would be handled.
The inspectors discussed the enforcement
fi 1ings of the inspection which are detailed in Sections b. (Findings) of
Paragraphs 3 through 13.
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