ML19344B387
| ML19344B387 | |
| Person / Time | |
|---|---|
| Site: | Rancho Seco |
| Issue date: | 08/06/1980 |
| From: | Walbridge W SACRAMENTO MUNICIPAL UTILITY DISTRICT |
| To: | Engelken R NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION V) |
| Shared Package | |
| ML19344B385 | List: |
| References | |
| NUDOCS 8010090190 | |
| Download: ML19344B387 (19) | |
Text
.
1 IL 3 (El 1LI '
SACRAMENTO MUNICIPAL UTILITY DISTRICT O 6201 S Street, Box 15830. Sacramento, California 95813; (916) 452-3211 August 6, 1980
-r ~ ~
.l: R Q
Mr.
R.
H.
Engelhen, Director U.S.
Nuclear Regulatory Commission
.;g Region V
", ); b 1990 N.
California Boulevard Suite 202, Walnut Creek Plaza
- j 'J[(.-
y'o"'/
Walnut Creek, CA 94596 A
v
~!. TTT\\}.
Dear Mr. Engelken:
NRC Management Inspection of Rancho Seco Docket No. 50-312 The District is submitting a response to the ap-parent items of noncompliance as requested by your letter of July 16, 1980.
NRC Region V requested a response within 20 days of our receipt of your transmittal.
The response was due on August 6, 1980.
The District requested additional time (45 days) because of the magnitude and complexity of the corrective actions.
Subsequent discussions with Mr.
Jess Crews of the NRC Region V office arrived at the follow-ing:
the majority of the responses to be submitted on August 6, 1380, with the remainder on or before September 1, 1980.
The responses to the apparent items of noncompliance identified in your Notice of Violation, Appendix A, are sub-mitted as Attachment No. 1 to this letter, and the apparent items of nonconformance to our commitments to the Commission identified as Notice of Deviations, Appendix B, as Attachment No. 2 to this letter.
Those items that were deferred until September 1, 1980, are indicated in each attachment.
The District believes that our management control systems are adequate to properly operate the Rancho Seco plant in conformance to the Federal Regulations and the changes instituted as documented by Appendices A and B responses will continue to demonstrate our commitment to safe operation of 1
the facility.
Each item has been carefully reviewed and either ccrrective action formulated or the District has pre-sented the circumstances covering our position that the notification was improper.
Should you have any questions concerning our response, we will be glad to discuss them with you.
Sincerely yours, 7
i
)
h I. /J 4 /l,/c i u4-
- /
fi e
r V:-n i
Wm.
C. Walbridge General Manager Attachments - 2 j
k p4 ;(r;; r;.y;;cn s t r. ! *, 9
- t o r t ruAN
- r. o c. <. 0 0 l 'd THE HEART of Cati 8010000190
ATTACHMENT NO. 1 NOTICE OF VIOLATION Docket No. 50-312 License No. DPR-54 A.
Technical Specification 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 th~e committee. The licensee had amplified the requirement in the MSRC charter by requiring that..."the minutes of each regularly scheduled and emergency meeting of the MSRC shall be approved at the next regularly scheduled meeting." The minutes for the September 20 meeting were not reviewed or approved-at a subsequent meeting.
This item is a deficiency.
Response
As of July 22, 1980 the Management Safety Review Committee h6s completed ninety seven formal meetings.
The item of noncompliance states that the meeting minutes of the September 20, 1979 meeting were not approved by the committee and three meeting minutes were not approved at the subsequent meeting. This meeting was not the typical in-session meeting.
It was a " walk-around" meeting and " conference telephone" meeting with the MSRC nembership. These special meetings are the result of urgent scheduling needs, significant safety issues or NRC response requirements.
that have pre-established deadlines. Such meeting are held to a minimum.
The meeting was properly recorded, documented and sent to all MSRC members for review.
Not having the meeting minutes approved at the subsequent meeting was an oversight by the Committee Secretary (Technical Assistant).
The three meetings, Nos. 87, 88 and 89, wera properly recorded, documented and sent to all MSRC members for review within the required time period.
However, since they were not approved at the next regularly scheduled meeting this conflicts with the written charter. The minutes were approved at a later meeting but not at the subsequent meeting.
Not having the meeting minutes approved was an oversight by the Committee Secretary (Technical Assistant).
Such oversights are a direct result of the increased workload, due to NRC regulations required by the Three Mile Island incident. The staff of the Technical Assistant is being increased to prevent recurrence of this problem. This will alleviate the Technical Assistant of many day-to-day
E operations and allow more time to be put into the MSRC affairs. The Committee Secretary will properly schedule review of the subsequent minutes at each committee meeting.
The only neeting left to be approved (Special Meeting of September 20,,
1979) was reviewed and approved by the MSRC on August 4, 1980.
Full compliance has been achieved as of this date.
op" be responsible B.
Technical Specification 6.5.1.6.e states that the of " investigations of all violations of the Technical Specifications and shall prepare and forward a report covering evaluation and recom-mendations to prevent recurrence...."
Contrary to the above, as of this inspection the PRC did not review, or investigate, or have under their cognizance a subgroup or some other group review or investigate NRC reported violations of Technical Specifications. An example is the three violations reported in IE Inspection Report 50-312/79/22 of December 27, 1979.
This item is an infraction.
Response
The District defers response to this item.
C.
Technical frecification 6.5.2.8.c requires that audits be performed under the cognizance of the MSRC which shall encompass "the result of all actions taken to correct deficiencies occurring in facility equip-ment, structures, systems or methods of operation that affect nuclear safety at least once per six months."
Technical Specification 6.5.2.8.b requires that 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."
10CFR50, 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, Housekeeping, 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 someone from the Nuclear Operations Department. The inspections and audits shall be documented in.accordance with-QAP No. 19, System Auditing."
Contrary to the above, at'the time of this inspection:
Audits of the licensee's corrective actions had not been performed.
Audits of the training of nonlicensed personnel (managers, super-visors, engineers, technicians, and maintenance personnel had not been f
conducted. AP700, Rancho Seco Training Program, was issued for implementation on May 30, 1977. Audits 0-195 and 0-251 conducted in 1978 and 1979 respectively, indicated the licensee's decision to r.ot audit nonlicensed training because AP 700 had not been implemented.
No action was taken when the licensee noted that the nonlicensed pro-gram had not been implemented.
Audits of housekeeping in unrestricted areas had not been conducted.
_This item is an infraction.
a
Response
This infraction covers the requirement to perform three Technical Specifi-cations required audits.
They are now scheduled as required by the Tech-nical Specifications and are included as MSRC directed audit items on the QCI No. 2 schedule.
The first audit to review all actions to correct deficiencies was conducted on May 15-June 9, 1980, the audit on perform-ance was conducted March 26-28, 1980, and the audit for housekeeping.is scheduled in August 1980. The District concurs that the two audits were not performed as required, but the remaining audit on performance, train-ing and qualifications was conducted as required and should not have been cited. Upon completion of the housekeeping audit in August, the District will be in compliance.
D.
10CFR50, 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.
1.
QA Manual, procedure QAP 19, System Auditing, specifies "on-site reviews shall be conducted periodically by Rancho Seco operations and engineering personnel in conformance to ANSI 18.7-1972." This is 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 prior to May 8,1980.
This item is an infraction.
Response
The Quality Assurance Manual QAP No.19, System Auditing, has been changed as follows:
_0N-SITE REVIEW l.
The on site review will be conducted by the PRC.
2.
The items of significance shall be reported by the PRC Chair-man to the Plant Superintendent for timely review and imple-mentation. _
l Full compliance will be achieved when QAP No. 19 is approved (August 29,1980).
- 2. : QA Manual, procedure QAP 19, System Auditing, requires audits be conducted in accordance with quality Control Instruction, QCI 2, Audit Program. QCI 2 stated that audits shall be conducted with specific attention to the subjects identified at the required frequencies.
It also stated that the frequency of audits can be varied by plus or minus 30 days.
Contrary to the above, audits of records and audit inplementation were not conducted at the required frequencies. The following are
-examples:
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 representa-tive stated that record controls were audited as part of the periodic independent consultant audit. The last two such audits were performed by a Joint Utility Audit Team in January 1979 and October 1979.
No such audits were performed during the first quarter of 1980. Audits of records, conducted via the Joint Utility Audits, were not, there-fore, conducted on an annual basis.
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 M45.2.12.4.
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.
These items are an infraction.
Response
The Joint Utility Audit is now scheduled on an annual basis to be conducted during the 4th quarter of the year. One item that is included on their audit agenda is an audit of records. The audit is scheduled for October 1980 and the District will be in compliance both with frequency for conducting the Joint Utility Audit and the requirement to audit QA records at the completion of this audit.,
3.
QA Manual Procedure f!o. 4. Procurement Document Control, stated in part:
"When procurement of Class I or selected Class II components, parts, materials is necessary from an unapproved supplier, the receiving inspection requirements of QAP flo.10 for an unapproved supplier must be met before the article can be used."
QA Manual, Procedure QAP 10, Receiving Inspection, stated in part:
"A receiving inspection will be performed on all Class I or selected Class II items including contractor furnished materials.
If an item is purchased from an unapproved supplier the RIDR will indicate the acceptance requirements. The acceptance requirements may be docu-mented on a Certificate of Conformance."
Contrary to the above an Agastat relay, model 7012PC, was purchased from an unapproved supplier and installed on April 16, 1980. 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. This relay was installed on Diesel Genera-tor A as a replacement for Agastat relay, Model 2412 Pfl.
The licensee issued a nonconformance report (flCR) on the Agastat relay on April 14, 1980, identifying that the relay had been purchased from an unapproved supplier; however, the dispositioning of this item through the flCR program was not addressed in QAP 10.
This item is an infraction.
Response
The Agastat relay, Model 7012PC was purchased as a commercial replace-ment component in conformance to the. District's Quality Assurance Manual, QAP flo. 4, Procurement Document Control, requirements:
General Requirements 4.
fluclear Operations requistions operating supplies, spare parts and stock replacement it<.ms when they are adequately identified by a parts number and may be purchased without detailed specifications when obtained as the original manufactured item.
The original purchase of this Class I spare part was made to replace an existing Model 7012PC relay in the diesel generator.
Subsequently, Agastat relay Model 2412Pfl was not performing as desired (timing accuracy was questionable) and it was decided to replace it with the Model 7012PC to improve performance.
Use of this component as a replacement for Agastat relay Model 2412PN was properly identified on a flCR.
The flCR reviews the component for form, fit and function as a proper replacement item and identified the testing to be performed for acceptance of the relay for its intended fonction, flCR S-1905 was properly identified as an accept item which states: :
a: _
"A disposition indicating that the nonconformance does not substantially affect safety, interchangeability, service life, or performance; and that the material can be used for its intended purpose.
This disposition requires Engiieering Review Board approval."
The District does not agree that this item constitutes a violation of the QA Program.
What was done to properly qualify the component for its intended use was both logical and in agreement with our Quality Assurance Program.
Its selection Tor use in the particular circuit i
improved its performance and reliability. We do not feel that the NCR program must be referenced in QAP f o.10.
The use of the NCR at Rancho Seco is well documented (over 2000 have been written since start of operations). The District does not agree this item is an infraction.
4.
0A Manual, Procedure OAP 2, Design Review, Item 1 under General Require-ments, specified that changes in plant equipment, systems, components
...cannot be made unless appropriate safety reviews have been made as required in 10CFR50.59 and implemented in conformance with the Techni-cal Specifications. Administrative Procedures, and the Quality Assur-ance Manual.
Rancho Seco Configuration Control Procedure, ECP-1, Section 4.1, required engineering and management reviews and approvals for plant changes.
Section 3.1, Step 3.1.3 required an approved Engineering Change Notice (ECN) be issued prior to a Drawing Change Notice (DCN).
Section 3.2, Step 3.2.1, required an ECU be issued for all configura-tion changes that require plant modification; and Step 3.2.2 required department manager level approval for any changes to Class I systems or equipment.
Contrary to the above, Class I system modifications were made without providing the appropriate enginearing and management reviews and approvals as required.
The following are examples:
Torque switch setpoint valves for safety feature valves were changed using abnormal tags 0415, 0416 and 0493.
. A model 7012PC Agastat relay was installed in the starting circuit of the "A" emergency diesel generator using abnormal tag 0515.
The licensee's abnormal tag program required only first level super-vision to document changes made to. safety systems.
The Shift Super-visor was also required to acknowledge the abnormal condition; however, the Shift Supervisor signature indicated recognition that an abnormal taa had been placed on a safety system but did not constitute an engineering review or department manager level approval.
This item is an infraction.
Response
Our QA program permits a. NCR to be written to identify the situation, provide a proper disposition which can if necessary include a DCN to be written to provide the desired drawing update. The NCR also provides the cechanism to initiate a safety analysis when required.
Both the torque switch setpoint values and replacement of the Model-7012PC Agastat relay'are properly shown on drawings that describe the plant configuration. The Ouality Assurance Program requires a DCN to be issued to provide a drawing update to the as-built condi-tion.
It is the District's position that we are in conformance to the Federal Regulations as we have delineated them in the-Rancho Seco control documents.
We do not agree this is an infraction.
5.
QA Manual. Procedure QAP 28, Fire Protection, stated in part that "all fire protection material and equipment shall be classified in accord-ance with QAP No. 3, Quality Assurance Classification.
Amendmc it No.19 (February 28,1978) to Facility Operating License No.
DPR-54. Paragraph 6.7 states in part that "the licensee has elected to meet NRCs fire protection QA criteria by applying their existing QA program under 10 CFR Part 50, Appendix B, to fire protection."
Contrary to the above, fire protection material and equipment had.not been classified prior to May 8, 1980.
This item.is an infraction.
Response
QAP No. 3. Quality Assurance Classification, has been modified as of June 26, 1930 to include the fire protection system.
E.
Technical Specification 6.8.1 requires written procedures be established and mainiained covering designated activities including the applicable procedures recommended in Appendix A of Regulatory Guide 1.33, November 1972.
1.
Appendix A of Pegulatory Guide 1.33, Section A, reconnends Administra-tive Procedures for typical safety-related activities.
QA Manual Procedure QAP.24, Procedure Requirements, required proce-duces in accordance with Regulatory Guide 1.33, including preventa-tive maintenance.
Contrary to the above, an administrative procedure was not provided to control the safety-related preventative maintenance program prior to May 9, 1980.
.The licensee's Administrative Procedure Index identified AP 650, Preventative Maintenance Program, as the controlling procedure for P
preventative maintenance; however, AP 650 was never issued.
This item is a deficiency.
Response
Rancho Seco has been operating with a preventative maintenance pro-gram which has been computerizeifor scheduling purposes. The intent of the procedure will be to describe the system and the mechanisms to control the activities of the program.
The Administrative Procedure AP 650, " Preventative Maintenance Pro-gram," is being written. The procedure will describe responsibilities and details to control the preventative maintenance activities. The procedure will be preparei, reviewed and approved within 60 days.
Full implementation of the activities will be completed within an additional 60 days.
The intent of the procedure will be to describe the system and the mechanisms which are_in effect.
The procedures will control and explain the activities of the program.
2.
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, at the time of this inspection, the licensee performed safety-related maintenance activities without approved procedures.
Work Request 47323, RPS Channel B Power / Imbalance / Flow Function Generator Module. Adjusted break points and slopes.
l Work Request 47445, S-lC, Inverter C Low Voltage.
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.
This iten is an infraction.
Response
-The District defers response to this item.
t 3.
Administrative Procedure 8, Records Management, required records be l
maintained in accordance with ANSI N45.2.9-1974 for temporary and L
permanent records, including storage.
Contrary to the above, operating 109 books, surveillance test results, administrative, maintenance, and-testing procedures; and changes' made i
thereto since the beginning of facility operations were stored in the administration building in standard file cabinets which did not meet the requirements of Section 5.6, ANSI N45.2.9.
This item is a deficiency.
Response
The District defers response to this item.
F.
10CFR50, Appendix B, Criterion X, reouires a program for inspection acti-vities affecting quality be established and executed by or for the organi-zation performing the activity to verify conformance with the documented instructions, procedures, and drawings for accomplishing the activity.
FSAR Appendix 1B, Quality Assurance Program, Sections 18.9.6, 18.1.10, l
and 18.2.2 required inspection activities during plant operation.
QA Manual, Procedure OAP 1, Organization, required Nuclear Operations to perform inspections (operations and maintenance) and to assist QA in audits and inspection activities, where expertise is needed; and required assur-ance that inspection planning be completed and documented.
Contrary to the above, inspection of preventative maintenance activities l.
and inspection of maintenance activities involving equipment control and functional testing were not executed by or for the organization performing i
the activity to verify conformance with documented instructions, proce-dures and drawings. These inspections had not been conducted prior to
~
May 9, 1980.
This item is an infraction.
l l
l
Response
l Most preventative-maintenance items are routine in nature and do not require variables data to be obtained, such as torque values, clearance criteria, etc. The maintenance is conducted by sending a journeyman
' mechanic into the plant and he performs these functions.
AP-3, Work Request, states "that minor equipment (such as tightening packing glands, adjustment of indicating switches, or minor control adjustments) may be made on non-safety related equipment without a work request."
-If the maintenance is on QA Class I equipment-it requires a work request to be written.
Engineering then reviews the work request and determines whether or not inspection is required (this includes a determination that a Maintenance Inspection Data Report-(MIDR) may or may not be required).
All of this is documented in Mn AP-3 work request procedure.
The AP-650, Preventative Maintenance, document will be a "how-to" type.
document eather than a quality assurance control document such as AP-3, Work Request Procedure.
The District does not agree that we are in nonconformance to 10CFR50, Appendix B, Criterion X.
We do have an inspection program as outlined above.
QA does use consultant support expertise when it is warranted to perform audits and inspections of selected activities (example:
health physics, fire protection, etc.). The District does not feel that special expertise must be recruited outside of QA to audit and inspect maintenance activities.
A separate, identifiable audit whose sole purpose was to audit preventa-tive maintenance is not being performed.
It is included as part of the QCI 2 Audit Program, Item 7, Maintenance Program.
This audit is per-formed on a six month interval and covers the preventative maintenance program as well as other portions of the maintenance program.
The District does not agree this item is an infraction.
G.
10CFR50, Appendix B, Criterion XII, requires measures be established to assure that tools, gages, instruments, 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.
QA Manual, Procedure QAP 14, Calibration of Test and Measurement Equip-ment, required calibration of devices used in operation of Rancho Seco; assigned responsibility for calibration activities to Nuclear Operations; and required an evaluation of devices found out of calibration.
Contrary to the above, prior to this inspection, measures had not been established for control of mechanical measuring devices such as torque wrenches, micrometers and dial indicators, This item is an infraction.
Response
The District disagrees that measures have not been established for control of mechanical measuring devices such as torque wrenches, micrometers, and dial indicators. These devices.are calibrated and controlled and are maintained to the required accuracy. We do concur that the program requires a detailed list of equipment to. ensure calibration intervals are beino met and objective evidence gathered to demonstrate compliance.
The development of a more formal program will be completed in 60 days.
H.
-Technical Specification 6.8.2 requires the applicable procedures recommended in Appendix A of Regulatory Guide 1.33-1972 be periodically reviewed.
Adminsitrative-Procedure 27. Internal Auditing, Section 3.4, specified that procedure reviews are required, at a minimum, within 24 months from the date of last review.
Contrary to the above, fourteen administrative procedures had not been
. reviewed within time requ'irements.
One example was AP-28, Post Trip Transient Report, which had not been reviewed since February 27, 1975.
This item is an infraction.
Response
The District defers response to this item.
I.
Technical Specification 6.4.1 requires a retraining and replacenent trair-ing 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 examina-tion approximately 52 weeks following the start of the requalification program.
Section 3.6.5. required periodic written quizzes to determine the individual's 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 at the time of this inspection, and only one quiz pertaining to lectures and reading assignments had been given in the last five years.
This item is an infraction.
Response
Oral examinations are not required by NRC regulations. Tne District has included oral examinations as a good training tool as part of the District's program. _ The reactor at the time in question, was not criti-cal. Rancho Seco was' in the refueling mode and the two licensed opera-tors were needed to perform duties vital to the refueling schedule. _ The
-oral examinations were postponed and were scheduled to be conducted prior to returning the reactor critical.
The oral examinations were given to the individuals on April 23, 1980
_and April 25, 1980. The reactor was returned to power May 12, 1980.
.Section 3.6.5 is not mandatory for written quizzes and it is not the District's policy to routinely give quizzes on lectures and reading assignments..The eight hour examination given annuaily more than covers
the written examination requirements. The continual surveillance of the licensed operators by their supervision provides an academic review
~
of their performance.
Contrary to the citation, we provide an in-depth, examination to demonstrate the proficiency of the District's licensed personnel.
J.
Technical Specification 6.4.1 states in part:
"A retraining.and replace-ment training program for the facility staff shall be maintained...and shall meet or exceed the requirements and recommendations of Section 5.5 of ANSI N18.1-1971....
Section 5.5 of ANSI 18.1-1971 states in part:
"A training program shall be established which maintains the proficiency of the operating organi-zation through periodic training exercises, instruction periods, and reviews cover'.ag those items and equipment which relate to safe operation of the facility." Section 3.2 of ANSI 18.1-1971 states in part:
"The operating organization ~ of a nuclear power plant censists of onsite per-sonnel concerneo with the day to day operations, maintenance, and certain technical services.
The licensee's Adminsitrative Procedure AP 700, Rancho Seco Training Program, establishes general training requirements, primarily for the following non-licensed personnel: new employees, nuclear operations staff, nuclear operations, maintenance, technical support, chemistry, and health physics, Contrary to the above, the major portions of the non-licensed personnel training programs had not been implemented prior to May 8, 1980.
New employee training and retraining was the only program fully implemented.
This item is an infraction.
Response
The District _ contracted General Physics Corporation to perform an in-depth audit / study of the District's training program.
The purpose of the study was to compare the existing program to the requirements and recommendations of Section 5.5 of ANSI N18.1-1971 and provide recommenda-tions-in those areas which do not meet the specific requirements.
The recommendations made by General Physics Corporation included general upgrading of the program and increased staffing for the Training Deparl-ment.
Upon receipt of the-information, the District intends to act upon those recommendations which will assure compliance with ANSI N18.1 require-
-ments.
The increased staffing and upgrading of the Training Department program will be completed by January 1,1982.
The fistrict does not agree with the contention that only a minimal train -
I i
ing program is being performed. The training has and continues to include electrical, health physics, fire protection, quality assurance, security, I&C, maintenance activities,' safety, design control, plant operations, etc. The District.is confident that the extensive effort being made to train personnel in the performance of their job assignment is adequate to operate and maintain the plant in a s afe manner.
K.
Technical Specification 6.4.2 requires the licensee to maintain a train-ing program for the Fire Brigade which includes refresher classroom training on a quarterly schedule.
Contrary to the above, seven members of the Fire Brigade did not partici-pate in fire drills, which included' classroom training, during the 4th quarter 1979 and/or the 1st quarter 1980, This item is an infraction.
Response
The District defers response to this item.
L.
10CFR73.55 requires the licensee to implement his amended physical security plan no later than February 23, 1979.
The 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 train-ing was scheduled to be conducted May 27-30, 1980, which exceeds the 12 month requirements.
This item is a deficiency.
Response
Followup' training is now scheduled and in compliance with the 12 month interval.
Training sessions were given to site personnel and full compli-ance achieved on July 16. 1980. A tickler file has been set up to avoid recurrence, i
I l-,
L.
T ATTACHMENT NO. 2 NOTICE OF DEVIATIONS A.
The licensee committed in correspondence of July 22, 1976, and September 23, 1976 to the provisions of WASH document 1284 and its attendant docu-ments, including ANSI N45.2.12-1974, Requirements for Auditing of Quality Assurance Programs for Nuclear Power Plants."
Contrary to the above, licensee organizations audited by Quality Assurance did not respond as requested to four audit reports, numbers 0-168, 0-190.
0-256, and 0-258.
Furthermore, audit reports did not provide a summary of audit results including an evaluation statement regarding th'.ffective-ness of the QA program el-ments which were audited.
Background
Four audits were listed that were not properly addressed:
Audit 0-168: This audit was conducted January '.5-20,1978 by the Indepen-dent Audit Committee with Mr. W. Poling. TVA, as Lead Auditor.
The response to this audit was made on March 9, 1978 to the MSRC by the Quality Assur-ance Director, L. G. Schwieger. The MSRC accepted the response to the audit and reviewed the corrective action commitments that were made at the regularly scheduled MSRC meeting on March 9,1978.
Audit 0-190: This audit was conducted June 27, 1978.
All responses except one (item 6) were responded to on December 4, 1978.
Numerous discussions were held with the Manager of Purctusing to discuss this area of concern and how best to solve the discrepancies. Audit 0-244 in June 1979 again reviewed the areas of concern cited on Audit 0-190.
Audit 0-244 concluded all corrective action had been properly implemented.
It verified that the suppliers had been approved (t,is was the concern of item 6, Audit 0-190) as required by the Quality Assurance Program.
Audit 0-256: This audit was conducted September 26, 1978 and covered the area of design review.
We concur that considerable time was taken to close this audit (November 7, 1979). The delay resulted from the considerable changes made as a result of the audit. The evolutionary changes were discussed with Region V inspectors during this formative time.
Subsequent review ci ECN/DCU (50.59 packages) both by the PAB Team and Region V inspectors has demonstrated the design review program to be conservatively structured and in conformance to 10CFR50, Appendix B requirements.
Proper corrective action for this complex subject results only when a dedicated, disciplined program is developed that has support of engineering personnel.
This program is now in effect.
Audit 0-258: This audit was conducted October 9, 1979 and covered the area of radiological safety. Again, complexity of corrective action prevented an early solution to the problems cited.
In the case in question, final corrective action was not committed to until June 6,1980 because of dis-agreement.between Nuclear 0perations and Quality Assurance as to acceptable
T t
corrective action. The evolutionary status of corrective action is doc unented.
Response
i ANSI M45.2.12-1974 requires the following:
Section 4.5 Followup
" Management of the audited organization or activity shall review and investigate any adverse audit findings to determine and schedule appropriate corrective action including action to prevent-recurrence and shall respond as requested by the audit report, giving results of the review and investigation. The response shall clearly state the corrective action taken or planned to prevent recurrence.
In the event that corrective action cannot be completed within thirty days, the audited oraanization's response shall include a scheduled date for the corrective action. The audited organization shall previde a followup report stating the corrective action taken and the date corrective action was completed.
They shall also take appropriate action to sssure that corrective action is accomplished as scheduled."
The District will respond to audit corrective action requirements for all adverse findings within 30 days. The District does not concur that correc-tive action was not taken in a timely manner.
The cumplexity of correc-tive action required for these four listed audits warranted in-depth discussions, analyses and reviews to properly change existing programs.
We do concur that an audit summary as an identifiable separate item on the audit cover sheet was not available.
The audit cover sheet was changed
'on May 16, 1980 to include an audit summary.
He object that the PAB Team did not concentrate on the substance of the audit, the corrective action that was fonnulated and the viability of the program.
Instead, they chose to cite discrepancies of format and missing dates on responses.
Though these are important, we feel audits of this nature should concentrate on a program management review and not base findings on reporting sequences.
B.
Contrary to the licensee's commitment in the FSAR, Appendix 18, Paragraph 1B.14, a Documentation Control Center was not' maintained on site for quality related records of plant operating activities, and QA personnel did not review all quality related documentation for completeness.
Response
The District defers the response to this item.
C.
The licensee connitted in correspondence of July 22, 1976, to the follow-ing:
"A management audit conducted by one member of the MSRC (with assist-ance-as needed) is made annually on: Quality ~ Assurance. No member of e
r Quality Assurance is a member of the team.
This nanagement audit reviews conformance to the ' orange' book and its attendant documents." This commitment was established clearly distinct from the use of outside consultants as amplified in correspondence of September 23, 1976, which referenced " independent audits being performed by outside consulting firms retained expressly to audit QA implementation."
Contrary to the above commitment, the licensee failed to audit the QA program as required.
Response
The District does not agree that the interpretation of this deviation is l
correct. The evolution of this commitment was modified between July 22, 1976 and September 23, 1976.
It clearly establishes the use and need of an outside consultant to meet the requirement.
During this period, discussions were held with other utilities and the NRC in how best to meet this commitment. After numerous discussions were held with the other municipal utilities, the Joint Utility Audit Program was developed. The l
Chairman of the MSRC and the General Manager establish scope of each audit conducted by the Joint Utility Audit Team including specific items to be selected for review. We encourage your review of the correspondence, task assignments given and scope of these audits to verify the extent of the l
l program.
It is our opinion that audits performed by the Joint Utility Audit Team l
using independent qualified auditors under the guidance of the Chairman of the MSRC more than meets our letter commitments to the NRC.
It is the i
best solution we have found to meet our commitment and do not propose i
changing because of an auditor's opinion.
On this basis, we reject this item of deviation.
D.
The licensee committed in correspondence of February 1,1978, to the follow-ing:
"A program is being developed for the Fire Protection Training Course that will describe the necessary strategies to be used for fighting fires at Rancho Seco. The training program will identify each area, l
combustibles, methods of fighting fires, access and egress routes, vital heat sensitive components and equipment, system and equipment location, l
toxic hazards, and ventialtion 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 classroom 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."
Contrary to the above commitment, fire strategy procedures had not been developed as of.May 8, 1980.
Response
The correspondence of February 1,1978 has been the subject of several questions and answers between the District and the NRC.
Research from a
the available documentation indicated that Rancho Seco has not been notified that the fiRC has accepted the reply.
Compliance cannot be achieved until approval is obtained from the flRC.
E.
The licensee committed in correspondence of July 22, 1976 and September-23, 1976 to the provisions of WASH document 1284 and its attendant docu-ments including Regulatory Guide 1.38 which states in part:
The require-ments and guidelines....that are included in At1SI f145.2.2-1972 are l
generally acceptable and provide an adequate basis for complying with the I
pertinent quality assurance requirements of Appendix B to 10 CFR Part 50."
Af1SI 1145.2.2-1972, Section 2.7, requires the buyer to classify quality items into one of four levels with respect to protective measures to prevent damage, deterioration, or contamination of the items.
Section 6.4.2 specifies the requirements for care of items in stor ge.
Contraty to the above, the licensee had not classified Class I items into one of the four levels identified in Section 2.7 of ANSI fl45.2.2.
It was observed that items in storage did not have all covers, caps, plugs or l
other closures intact.
Two Class I valves, stock numbers 030342 and 033473, had protective covers partially or completely removed.
Other Class I items were observed with no caps covering threads, welding sur-l faces uncovered and flange faces unprotected.
In addition, there were no specific programs for limited shelf life items and for preventative l
meintenance on Class I items.
I
Response
l The District's commitment to Pegulatory Guide 1.38 which endorses ATISI l
fl45.2.2-1978 has never included delineation of individual components l
either in the plant or in storage into the various levels of environmental packaging requirements.
It has been the responsibility of fluclear Opera-tions ano Generation Engineering to comply with special handling, storage, shipping or preservation requirements.
Quality Assurance monitors the l
original purchase documents for proper incorporation of the requirements and performs audits in_the field to verify compliance of storage require-ments.
Inspection planning documents specify special design handling, storage, shipping or preservation requirements.
In our original commitment to WASH document 1284, we intended at that time to be judged on the merit of the program that is in effect as revealed l
by condition of the parts and components in storage at Rancho Seco. Our environmental conditions are unique and do not require the preservation requirement commonly found at other utility locations that have more adverse weather conditions. We have few items that would fall under limited shelf life items. These components are reviewed before use in l
the plant.
.We do not accept the contention that we are in nonconformance to the intent of WASH 1284.
Our program addresses the quality requirements of these documents and compliance is evidenced.by condition of the components and equipment..
9 W
~.
n A test program to verify. ccndition of the equipment is conducted when material quality is in doubt.
Extensive flDE is perfermed to qualify components when there is any question on acceptability.
The District's program stresses qualification before use and every effort is made to ensure qualification of the component for its intended use before release to the plant.
The District does not agree to this iten of deviation.
I l
l t
{
s 9 ?
- ~
4 c__