ML19344E905
| ML19344E905 | |
| Person / Time | |
|---|---|
| Site: | Farley  |
| Issue date: | 08/06/1980 |
| From: | Belisle G, Ford E, Upright C NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19344E892 | List: |
| References | |
| 50-348-80-14, 50-364-80-16, NUDOCS 8009120071 | |
| Download: ML19344E905 (35) | |
See also: IR 05000348/1980014
Text
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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101 MARIETTA ST N.W..sulTE 3100
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ATLANTA. GEORGIA 30303
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Report Nos. 50-348/80-14 and 50-364/80-16
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Licensee: Alsbama Power Company
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600 North 18th Street
Birmingham, AL 35202
Facility Name: Farley
Docket Nos. 50-348 and 50-364
License Nos. hTF-2 and CPPR-36
Inspection at Farley site near Dothan, Alabama and at Company Offices in Birming-
ham, Alabama
Inspectors:
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4
G. A. Belisle "-
Date Signed
wA2 L Le
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E. J
ord
Date Signed
bT R. Me(sTtt/
Date Signed
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W. A. Ruhlman
Date Signed-
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Approved by:
.!f.Uprip,
ng Section Chief, RONS Branch
pte/ Signed
SUMMARY
Inspection on June 9-13 and 16-20, 1980
Areas Inspected
This routine, announced inspection involved 165 inspector-hours on site and at
the company offices by 4 region based inspectors.
Overall management was
reviewed by inspecting 36 aspects of the overall quality assurance program
within the following 22 areas:
receipt, storage and handling of equipment and
materials; QA/QC administration; QA for startup testing program; QA program
annual review; maintenance; design changes and modifications; surveillance
testing; procurement control; records; test and experiments; test and measuring
equipment; offsite review; operating staff training; training and retraining of
non-licensed personnel; requalification training; audits; docunent control;
operational staffing; preoperational test records; offsite support staff; house-
keeping and cleanliness; and, organization and administration.
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Results
Of the 22 areas inspected, no items of noncompliance or deviations were identi-
fied in 20 areas; 3 items of noncompliance were found in 2 areas (Infraction -
failure to provide definitive or prompt corrective action for identified material
storage inadequacies - paragraph Sb; Deficiency -failure to control consumables
in safety-related systems - paragraph 6a; Deficiency - failure to follow proce-
dure
paragraph 6b).
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DETAILS
1.
Persons Contacted
Licensee Employeess
- L. Bailey, OQA Engineer
R. Berryhill, System Performance Superintendent
C. Buck, Staff Engineer
L. Enfinger, Administrative Superintendent
S. Gates, Plant Instructor
- R. George, Engineering and Licensing
- G. Grove, OQA Engineer
G. Hairston,III, Plant Manager
F. Holloway, Shift Supervisor
J. Hudspeth, Document Control Supervisor
K. Jones, Material Supervisor
J. Kale, QA Engineer
D. Mansfield, Startup Superintendent
- R. Mcdonald, Vice President Nuclear Generation
- J.
McGowan, Manager OQA
W. Petty, Manager QA (D&C)
W. Shipman, Maintenance Superintendent
- L.
Sims, Supervisor, Nuclear Generation
n. stinson, system feriormance supervisor
J. Thomas, I&C Supervisor
L. ihrd, Startup Supervisor
R. Wiggins, Training Sector Supervisor
J. Woodard, Assistant Plant Manager
Other licensee employees contactec included technicians, operators, and office
personnel.
NRC Resident Inspector
- J. Mulkey
- Attended exit interview
2.
Exit Interview
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The inspection scope and findings were summarized on June 20, 1980 with
those persons indicated in paragraph I above. At the conclusion of the
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site inspection on June 17, 1980, site personnel were briefed on the inspec-
tion activities. The June 20, 1980, meeting included a summation of the
total inspection effort and was held at the Birmingham Offices of the
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licensee.
The licensee was informed of the items of noncompliance in
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paragraphs 5b, 6a, and 6b; the unresolved items in paragraphs 8b, 10d, 26a,
20c, 20d, and 10c; the inspector follow-up items in paragraphs 15b, 7b,
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21c, 25, 21d(1) and 21d(3); and the open items in paragraphs 26b,12c, Sc,
12d, 26c,10e, 7c, 21d(2) and 24c.
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The licensee acknowledged the inspection findings.
3.
Licensee Action on Previous Inspection Findings
Not inspected.
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4.
Unresolved Items
Unresolved items are matters about which more information is required to
determine whether they are acceptable or may involve noncompliance or
deviations.
New unresolved items identified during this inspection are
discussed in paragraphs 8b,10d, 26a, 20c, 20d, and 10c.
The following abbreviations are used throughtout this report:
Accepted QA program means Chapter 17.2 of Farley FSAR, Amendment 66
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5/9/77
Administrative Procedure
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APC0
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Alabama Power Company
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DCCA
Daniels Construction Company Associates
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JUMA
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Joint Utility Management Audit
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M0QA
Manager Operations Quality Assurance
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MMA
Major Modification or Addition
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NORB
Nuclear Operations Review Board
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Operational Quality Assurance
OQA
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OQA PIL -
Operational Quality Assurance Policy Implemental List
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OQAP
Operational QA Program - Means Chapter 17.2 of Farley FSAR
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OQA PM
Operational Quality Assurance Policy Manual
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Production Nuclear Section
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Plant Operations Review Committee
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PQAE
Plant Quality Assurance Engineer
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Plant Services Approved Supplies List (Approved Bidders List)
PSASL
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Quality Assurance
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Startup Standard
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TA
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Temporary Alteration
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TDDS
Test Data Deficiency Sheet
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5.
Receipt, Storage and Handling Program (38702/35747)
References:
(a)
FNP-0-AP-20, Receipt Inspections, Revision 3 dated 2/78
(b)
FNP-0-AP-21, Identification and Control of Materials,
Parts and Components, Revision 3 dated 11/77
(c)
FNP-0-AP-22, Nonconformance Control / Deficiency Reporting,
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Revision 2 dated 9/77
(d) FNP-0-AP-23, Handling, Storage and Shipping of Materials,
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Components and Equipment, Revision 1 dated 11/78
(e) Bi-Weekly Audit 79-07, Material Control, conducted frca
March 29 through April 18, 1979
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a.
Program Review
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References (a) through (d) were reviewed with respect to the require-
ments of the accepted QA Program and ANSI N45.2.2 as committed to in
that Program. The reeiew was conducted to verify,that required admin-
istrative controls '.ad been established for receipt of safety-related
items, for dispositioning accepted and rejected items received onsite,
for controlling these items during their receipt, handling and storage,
and that the established controls required marking for traceability to
related quality assurance certifications and other documentation. No
items of noncompliance or deviations were identified as a result of
this review.
b.
Implementation
The inspector selected six items which had been received onsite (the
same six items identified in paragraph 12.b) to assure that they had
been handled in accordance with the program controls. The inspector
also reviewed three nonconforming items and verified that they were
segregated and controlled as required. The inspector observed portions
of two receipt inspections (for PO's 60297 and 61780) and a portion of
a shipping damage inspection while they were being conducted. The
inspection also included a tour of the onsite warehouse to verify that
required storage conditions were met and that atmospheric and house-
keeping requirements were enforced.
No items of r.oncompliance or
deviations were identified during this portion of the inspection.
The inspector, in the company of the Material Supervisor, drove to
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Complex III on the far side of the construction project where additional
Unit I and 2 materials were being stored. During the tour the inspector
found that this warehouse did not meet QA Program requirements for
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Level A or B storage. The inspector found items stored there (a part
length control rod drive assembly, the reactor vessel seal rings (3),
drums of lithium hydroxide resins and boric acid crystals, a flux
thimble) which require a level B storage. The licensee informed the
inspector that this item had been previously identified during a
bi-weekly QA audit. Reference (e) was obtained and the inspector con-
firmed that item FNP-NC-18-79/7(11) had identified these inadequacies
in April of 1979. The associated Corrective Action Report (CAR) 372
was then reviewed. The CAR confirmed the validity of the finding and
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stated that it could be corrected in one of two ways: "(1) Assuming
warehouse space from DCCA and upgrading this space to Level A.
This
could be done when DCCA leaves the plant site at the completion of
Unit 2 construction. Any DCCA warehouse space would have to be upgraded
to a Level A storage area. (2) Building a new warehouse which would
be more conveniently located on the plant site. This new warehouse
would have Level A storage area. See PCR 79-412-0U." This CAR was
filled-out on 5/29/79 and the estimated completion date given was
5/18/82. This CAR had been accepted by the QA department. However,
contrary to the requirements of 10 CFR 50, Appendix B, Criterion XVI
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and 17.2.16 of the accepted QA program, no immediate corrective action
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was taken or proposed to deal with the identified inadequacy (such as
an engineering evaluation to determine what storage requirements were
necessary and then obtaining the minimum requirements for the identified
items). This failure to obtain prompt corrective action constitutes
an item of noncompliarce (348/80-14-01).
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6.
QA/QC Administration Program (35740/35751/92706)
References:
(a) FSAR Section 17.3
(b) Joint Utility Management Audit (JUMA) dated 12/79
(c) OQA-AP-02, Development and Implementation of Procedural
Guidance, Revision 8 dated 4/78
(d) OQA-AP-03, Control of Guidance Documents, Revision 8
dated 4/78
(e) GO-PNS-13, Control of Operating Quality Documents
(f) FNP-0-AP-12, Control of Special Processes During Opera-
tion, Revision 1, dated 8/79
(g) Documents in OQA File A35, 95, 2, LOG 79-869
The inspector reviewed the licensee's
"Q" List (FSAR Section 17.3) to
determine if the structures, systems, components and services to which the
QA program applies are deff ned and if procedures exist for changing the
list if required. The inspector also reviewed the licensee's procedures to
assure that administrative controls for QA documents exist to: ' provide for
review and approval prior to issuance; provide methods for making changes
and revisions; and, establish controls for distribution and recall. Since
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the JUMA is one vehicle used by the licensee to assess the overall effective-
ness of the QA program, the referenced audit was reviewed. Followup of
audit findings was conducted to verify that, where necessary, methods exist
for and actions are taken to modify the QA program to provide increased
emphasis in defined " weak" or " problem" area. A review of reference (g)
was also conducted. These documents included the following:
Subject
Documents
Plant Performance
FNP Monthly Reports September, 1978-December,
1978 (Nuclear Generation Section File No. 91
A20.1)
NRC Audit Results
NRC Audit Findings Summary September 1,
1978-December 31, 1978 (letter from J. R.
Campbell
to
F. L. Clayton, Jr.,
dated
September 24, 1979)
OQA Audit Results
Analysis of OQA and NRC Audit Findings (letter
from J. R. Campbell to F. L.
Clayton, Jr.,
dated September 24, 1979)
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Licensee Event Reports
Licensee Event Reports (letter from J. R.
Campbell
to
F. L. Clayton, Jr.,
dated
September 24,1979)
NORB Reconnendations
Summary of NORB recommendations (letter from
J. R. Campbell to F. L. Clayton, Jr. , dated
September 24, 1979)
a.
Failure to define or Control Certain Consumable Items
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The licensee's "Q" List (FSAR Sectian 17.3) includes certain consumable
items such as tendon grease, concrete, rebar, and structural steel.
In addition, while not listed in FSAR Section 17.3, the licensee also
controls other consumable as if they were "Q" list items (diesel oil,
weld rod).
Still other items are controlled through purchase and
warehouse issue, but not controlled through use nor listed in the FSAR
(grease and oil used in safety-related pumps and motors; gasket material
used to assure closure of safety-related pressure bcundaries).
The inspector made a tour of the licensee's facilities and conducted
interviews with maintenance supervisors and craftsmen. The inspector
found two examples in the maintenance shop where grease was :.tored in
open containers in an open locker; the grease was slightly contaminated
with foreign material. Two additional plastic bowls were found in the
maintenance " Grease Locker" that were unmarked; two cans of oil were
found in the same area, also unmarked. In the Operations Department
grease and oil storage area, the inspector found two cans of oil that
were unmarked. Based on the above unmarked containers and statements
by both supervisors and workers that positive checks are not performed
prior to usage to determine that only the specified grease or oil is
used, the inspector was unable to verify that only the correct lubricants
had been used in safety-related equipment.
However, no cases of
improper lubrication were known or found during thic inspection.
A large quantity of gasket material, unmarked and uncontrolled, w=:
found in the maintenance shop. Two persons interviewed indicated that
they normally drew gasket material from the warehouse before working
on safety-related systems; however, they also stated that they had, on
few occasions, used the material stored in the shop for such jobs.
a
Again, ahile no controls were in place to preclude the use of improper
gasket material, neither those interviewed nor the inspector knew of
or found cases where improper gasket material had been used. While
only these specific items were reviewed, other items which affect the
safety-related functions of safety-related structures, systems and
components are also not listed on the "Q" list and are not afforded
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the controls of the QA program such as snubber fluid, resins, chemicals
used in or to determine acceptability of the primary system, gasses.
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used in the primary system, packing material,
"O" rings, and nuclear
fuel. The last example is cont rolled, but is not listed.
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The failure to' list and adequately control grease and oil.and gasket
material is an item of noncompliance (348/80-14-02). However, since
no cases of improper usage were detected, a lower level of severity is
assigned.
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b.
Failure to Follow Procedure FNP-0-AP-12
During a tour of the maintenance shop on June 10, 1980, the inspector
found approximately one and one-half pounds of 7018 coated weld rod
and one-half pound of ER 309 electrode wire in an oven in a welding
area of the maintenance shop. Since these items had been drawn out
and not been used, they were required to be considered contaminated by
procedure FNP-0-AP-12, Paragraph 5.4.6.
The same procedure requires
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(Paragraph 5.4.7) such material to be stored in containers which are
clearly labeled in such a way as
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call attention to the fact that
the' contents are not for use on critAcal components. The container
found by the inspector was not labr 'ed or marked as required. This
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failure to follow procedure FNP-0-i..
12 is an item of noncompliance
(348/80-14-03).
On the same day (June 10,1980) that the 4,ove inadequacy was discovered
by the inspector, the weld material in question was remov. d and discarded.
In addition, a training session was conducted, and docu anted,- for all
welders on the requirements of FNP-0-AP-12. Since no i proper usage of
the weld material was found, a lower level ~of severit 7 is assigned.
Since both immediate and long term corrective actions ha te been completed
and verified, no response will be required for this : :em. This item
is closed.
7.
QA for the Startup Test Program (35501/35301)
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Reference:
SS-6, Test Procedure Development, Conduct, and Results
Approval, Revision 10 dated 3/80
a.
Implementation
The implementation of the management controls for the quality assurance
aspects of the Startup Test Program were reviewed by the inspection of'
three specific areas: inspection re:ponsibilities; corrective action;
and, audits.
During the review, the inspector determined by interviews that no
documented, independent inspection program was in effect for startup
testing activities. This area resulted in the referral of an item to
NRC management, a subsequent decision as to applicability, and a commit-
ment from the licensee. These items are discussed more fully in para-
graph 7.b below.
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Corrective actions were reviewed for Test Data Deficiency Sheet items
associated with startup procedure 064-5-015 on RTD/TC Cross Calibration.
Those TDDS's which required corrective action were reviewed and the
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inspector obtained copies of the associated work requests which directed
the required corrections. An item with respect to accountability of
TDD3's was observed which is discussed in paragraph 7.c below.
An audit of test activities was conducted during the period from
4/15/80 to 5/9/80 as documented in bi-weekly audit 80-07. No items of
noncompliance or deviations were identified with either the conduct of
this audit or processing of the findings.
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b.
Inspection of Startup Testing
Personnel who conduct this testing program are qualified and certified
to the requirements o'f ANSI N45.2.6 as specified in the licensee's
accepted QA Program. During discussions with personnel conducting the
actual testing program, the inspector was told that critical items and
parameters are routinely monitored by both the Startup Engineer and
the Startup Supervisor. However, such dual verification is not required
by the licensee's procedures nor is it documented. And, since it is
conducted by the line :upervisor, it does not meet the independence
requirement of the licensee's accepted QA Program.
While Section 17.2.2 of the accepted QA Program clearly states that
the Program applies to preoperational activities, Section 17.2.10 of
that Program contains a statement that inspection activities will be
nnnanre.a auring np mu nn nr th, plant _ Wh n t hi s matte r wa s refe rrRL .
to NRC management for review, the Program's commitment to ANSI 45.2
(which includes inspection activities), the stated (17.2.2) applica-
bility to preoperational activities, and a definition of operational
activities (page 17.2.2) which included preoperational testing were
combined to require inspection of startup/preoperational testing
activities. When this position was given to the Vice President-Nuclear
Generation, he stated that:"The remaining preop tests on Unit 2 FNP
will be reviewed and will include a second signoff on certain key
steps, if required."
As of the end of this inspection (June 20, 1980), only six areas
remained to be completed that are safety-related (vessel work, inte-
grated safeguards test, manipulator crane work, post accident ventilat-
ion system testing, fire protection, and penetration room ventilation)
according to a test flow chart reviewed by the inspector. This area
will be reviewed during a subsequent inspection and is designated as
Inspector Follow Item 364/80-16-12.
c.
Test Data Deficiency Sheet Accountability
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There were twelve HDS's attached to the procedure reviewed by the
inspector. The Startup Superintendent was questioned to determine if
any additional "lDS's existed for that particular procedure. While
the TDDS's were sequentially numbered, the inspector determined that
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there were no currently established controls to assure that all required
TDDS's were included with the procedure. The licensee gave a target
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date of July 20, 1980 for establishing a method to assure that all
Test Data Deficiency Sheets remain with their " package." This item
will be reviewed during a subsequent inspection and is designated Open
Item 364/80-16-24.
8.
Quality Assurance Program Review (35701)
Reference:
Operations Quality Assurance Policy Manual, Revision 15
dated 11/79
a.
Program Review
The licensee had not submitted any changes to his accepted QA Program
since the last NRC inspection of this area in October 1979. However,
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a proposed Amendment 73 to the FSAR was in preparation during this
inspection to document recent job and title changes associated with a
reorganization. The inspector reviewed the referenced Policy Manual
changes which included procedures OQA-AP-01 through 0QA-AP-11. The
Farley Nuclear Plant (FNP) Administrative Procedures (AP's) which
implement QA Program elements were also reviewed, including all changes
thereto, as a part of the inspection of the functional areas documented
elsewhere in this report. During all of these reviews, responsible
personnel charged with implementing the procedures were interviewed to
determine that the issued procedures were understood and followed. As
a result of these reviews, two items associated with procedures in the
referenced Policy Manual were identified which will require additional
inspection.
These items are discussed in paragraphs 8.b and 8.c
below,
b.
Lead Auditor's Input to Corrective Action
The accepted QA Program includes a commitment to comply with ANSI
N45.2.12Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.12" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process., Draft 3, Revision 4. Paragraph 4.4.6 of that Standard requires
that an audit report shall be written and proeide " recommendations for
correcting nonconformances or improving the gaality assurance program
as appropriate." The licensee's procedure for :onducting and documenting.
audits, 0QA-AP-06, does not provide any written instructions on this
specific aspect of the audit report but states (7.1) that the Audit
Team Leader shall compile the findings into an audit report using the
fo rmat in Appendix A of the procedure. Appendix A of the procedure
has a Section F which deals with recommendations as reproduced below:
F.
Recommendations (as applicable)
1.
Program:
(Changes or clarifications that are needed in
quality assurance program and why needed)
2.
Corrective action:
(Specific information which audited
organization may not have which
will assist in corrective action)
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The lead auditors interviewed indicated that this section is rarely
used. In discussions of this matter with the Vice President of Nuclear
Generation, the inspector was told that APCO did not want QA auditors
making recommendations for corr 4ctive actions on a routine basis, but
only in those cases specified by the procedure in Appendix A.
The
licensee further stated his opinion that the current guidance.given in
Appendix A relative to this matter was in agreement with Paragraph
4.4.6 of the Standard and that no exception was necessary.
Since the current words in the licensee's procedure (Appendix A)
appea
to be more restrictive that those in Paragraph 4.4.6 of the
Stand ied and are in fact implemented as written in that Appendix, this
mattr.. will be referred to NRC management to determine if the licensee
is :.n compliance with his coraitment, without exceptions, to ANSI
N46.2.12Property "ANSI code" (as page type) with input value "ANSI</br></br>N46.2.12" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process..
Until this review has been completed, this item is Unre-
solved on Unit 1 (348/80-14-04) and Open on Unit 2 (364/80-16-04). No
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action is required by the licensee at this time on this item.
c.
Include New Organization In OQA-AP-06
The current titles used in Section 7.4 of procedure 0QA-AP-06 are not
consistent with the titles used since the plant was reorganized. The
licensee stated that the procedure would be revised and issued with
correct, titles by August 20, 1980. Until this action has been completed
and verified, this is designated Open Item 348/80-14-19; 364/80-16-19.
9.
QA Program: Maintenance (35743/62702)
References:
(a) AP-12 Control of Special Processes During Operations
(b) AP-13 Bypass of Safety Functions and Jumper Control
(c) AP-14 Safety Clearance and Tagging
(d) AP-15 Maintenance Conduct of Operations
(e) AP-31 Inspection of Activities Affecting Quality
(f) AP-38 Use of Open Flame
(g) AP-44 Cleanliness of Fluid Systems
(h) AP-52 Equipment Status Control and Maintenance Authori-
zation
(i) AP-53 Preventive Maintenance Program
a.
Review Conducted
The referenced documents were reviewed with respect to the licensee's
accepted Quality Assurance Program.
The review was concerned with
preventive and corrective maintenance programs, equipment control,
cleanliness and housekeeping. The licensee's practices were reviewed
to assure that a preventive maintenance program had been established
and that a PM schedule had been developed.
The licensee's corrective maintenance practices were reviewed to
verify that.
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(1) Written procedures had been established for initiation of routine
and emergency maintenance.
(2) Criteria and responsibilities had been established for approval
of maintenance requests, for designating activities as safety /-
non-safety-related, for designating inspection hold points, for
performing required inspections, and for determining required
functional testing to be performed following completion of the
activities.
(3) ' Administrative controls require: approval of maintenance requests;-
identification of personnel performing and inspecting _the work;
identification of the malfunction or failure which necessitated
the work; identification of' the maintenance performed including
any post-maintenance testingI that materials used are identified
along with any measuring or test instrumentation; and that records
verifying the above are prepared, assembled and transferred to
records storage.
'
(4) Responsibilities had been assigned for the review of the records
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generated including an assessment to identify repetitive failures
or marginal performance and for transfer of these records as
required.
(5) Work control procedures adequately covered special controls
necessary for activities such as welding, cutting or use ef
j
ignition sources.
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(6) Work control procedures require a firewatch with the capability.
of communication with the control room if welding, cutting, or
use of ignition sources are to be performed in the proximity of
flammable material, cable trays or process equipment.
,
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Equipment control practices were reviewed to assure that established
controls were in place which specify_ responsibility and authority for
release of equipment or systems for maintenance, checking such releases
'
as necessary to assure compliance with the Technical Specifications,
and the indication of equipment status for those systems under repair.
Controls were also reviewed to assure that required testing of redundant
components is accomplished prior to return to service, and that indepen-
<
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dent verification of both maintenance and post-maintenance lineups is
performed.
Controls of special processes were reviewed to assure they included:
a requirement that only qualified procedures and personnel will be
used, a requirement that a current file of special processes is main-
'
tained which includes the qualification records of procedures and
personnel, and responsibilities have been assigned to assure that the
,
,
above requirements are met.
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Cleanliness and housegeeping controls were reviewed to verify that
appropriate procedures had been developed and implemented to assure
.
that open systems were not degraded and that cleanliness and house-
keeping programs had been implemented.
In any case, where the in-office review indicated' inadequate coverage,
the area was further investigated during the implementation phase of
the inspection.
b.
Implementation
i
.
The licensee's maintenance activities were reviewed at the plant site
with respect to requirements of the referenced documents. The inspector
selected completed corrective maintenance activities and reviewed these
to assure that the required controls had been employed. The inspector
also selected equipment on the preventive maintenance schedule and veri-
fied that the required maintenance had been performed as scheduled.
Further inspection of this area is documented in Inspection Repart No.
50-348/80-06.
The inspector also reviewed the qualification records of five welders,
five planners, and five maintenance mechanics.
No items of noncompliance or deviations were identified; however, aspects
of housekeeping noted in this inspection are discussed in Paragraph 25.
10.
Design Changes and Modifications (35744/37700/37702)
References:
(a)
AP-8, Design Modification Control, Revision 4, dated
1/79
(b)
AP-9, Procurement Document Control, Revision 8, dated
8/79
-
(c) AP-13, Bypass of Safety # unctions and Jumper Control,
Revision 0, dated 3/77
(d)
AP-52, Equipment Status Control & Maintenance Authoriza-
tion, Revision 3, dated 9/79
(e)
SS-17, Temporacy Alteration Control, Revision 5, dated
S/78
(f) PNS-11, Design Change and Design Control, Revision 3,
dated 5/79
(g) PNS-42, Organizational Interfaces for Farley Nuclear
Plant Design Changes on Operating Unit (s), Revision 0,
dated 2/80
(h)
J. M. Farley Technical Specifications
a.
Program Review
The inspector reviewed the licensee's design change controls, as set
forth in the above referenced documents, with respect to the accepted
quality assurance program.
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The-licensee's practices were reviewed to verify the following:
(1) Procedures- have been established for initiating design changes,
for assuring that the proposed change does not involve an unre-
viewed safety question or a change in technical. specifications,
for provision for docuoenting completion of reviews, evaluations
and approvals prior to implementing the design change,_and for
assuring that fire protection guidelines are met.
-(2) Procedures have been established which identify the organization
g
responsible for performing design work, delineate the responsi-
bilities and methods for conducting safety evaluations, define
the design interfaces (internal or external), identify / sign
t
input requirements and define the responsibilities for
sput
review and approval.
(3) Methods, procedures, and responsibilities for independent design
verification are established.
(4) Responsibility for final approval of design documents is assigned.
(5) Review of design change is commensurate with original design
review.
(6) Administrative controls are established to control changes to
design change documents, recall obsolete documents, release and
,
distribute . approved design change documents, incorporate design
changes into plant procedures, operator training, and plant
drawings. These controls should identify the responsible indi-
viduals to communicate with the design organization (s).
(7) Controls require implementation and post-modification testing in
accordance with approved procedures.
,
(8) Responsibility has been assigned for identifying post-modification
i
testing requirements and for reporting design changes / modifications
to the NRC in accordance with 10 CFR 50.59.
,
(9) Controls have been established which require review and approval
.
of temporary modifications, the use of approved procedures when
performing temporary modifications and which assign responsibility
for procedure approval.
l
(10) A formal record of the status of temporary modifications is
maintained and reviewed periodically.
j.
(11) Controls require evaluation of the need for independent verifica -
tion of installation and removal of temporary modifications where
,
appropriate and functional testing of equipment following instal-
lation or removal of temporary modifications.
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(12) Controls have been established to ensure that records verifying
the above are prepared, assembled and transported to records
storage.
b.
Implementation
.
The inspector selected five safety-related design changes fo,r review
as follows:
PCN 78-131, minor departure from design dealing with a blank
installed in the AFW line.
PCNs78-113 and 114, minor departures from design dealing with
the service water battery system (s).
PCRs79-354 and 355, modifications to the No. I and No. 2 seal
housings on the reactor coolant pumps.
For the items selected, na inspector verified that documentary evidence
was available on site te e.pport the licensee's conformance to design
change requirements.
Design inputs encompassing codes, str adards ,
regulatory requirements, and design bases were verified.
Additionally, the inspector discussed the design change program with
a f fi ra angin=aring.suppnre cupervi__ _
rite r"pe mirian -d * L carpar=*=
sion.
As a result of these discussions and reviews the inspector identified
two unresolved items - Paragraphs 10.c and 10.d.
Three open items are
discussed in Paragraphs 10.d and 10.e.
c.
Failure to Perform Prior Safety Evaluation
j
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Reference (a), Section 6.11, requires completion of the design change
<
package review including safety evaluation review per 10 CFR 50.59
before implementation o.f the design change.
During review of PCN 78-131, the inspector noted that while the imple-
mentation is Signed off as completed on 10-12-78, the safety evaluation
checklist for PCN 78-131 was not completed until 5-30-79.
During
discussion of this finding with the licensee, the inspector was informed
that licensee personnel had identified a similar problem during their
internal audit 79-06 and had documented it as an audit concompliance,
FNP-NC-15-79/6(9).
This internal item was answered in Corrective
Action Report (CAP.) No. 366. Since the action of CAR No. 366 was not
completed and re-audited, this ites wi?1 remain unresolved pending
completion, re-audit and NRC evaluation (50-348/80-14-09).
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d.
Classification of Proposed Changes
During the program review the inspector noted that the licensee applies
four different classificaticas to a proposed chanFe to structures,
systems or components. These classifications art: Major Modification
of Addition (MMA), Reference (a); Minor Departure From Design (MDD),
Reference (a); Temporary Alteration (TA), References (c) and (e): and
"Non Replacement-in-Kind' Parts and Material for Safety-Related Equip-
ment ...", Reference (b), Paragraph 6.1.1.
The required processing
, for each of these classifications .aay differ in both scope and depth.
I
Due to the uncertainty introduced by these various classifications,
these definitions, along with Technical Specification 6.5.3, " Technical
Review and Control", will be referred to NRC management for review and
determination of the applicability of the review process to each classi-
fication. This item is unresolved on Unit 1- and open on Unit 2 pending
NRC management action (50-348/80-14-05, 50-364/80-16-05).
e.
Differences Between Proposed Farley Unit 2 Technical Specifications
and Standard Technical Specifications
During the program review the inspector noted that the licensee's pro-
posed Technical Specifications for Unit 2 are different from the
Standard Technical Specifications in the following areas:
(1) Section 6.5.1, differences in member of personnel on the PORC,
quorum requirements, responsibilities, authority and records.
(2) Section 6.5.3 of the proposed Technical Specifications is a
section dealing with technical reviews and control. The Standard
Technical Specification has no section specifically dealing with
this review.
Due to these differences and the upcoming licensing of Unit 2, Technical Specification 6.5.1 will be referred to NRC management for review and
comparison with Standard Technical Specifications and this item is
open for Unit 2 (50-364/80-16-22). Technical Specification 6.5.3 will
also be referred to NRC management for review and comparison with
Standard Technical Specifications and this item is open on Unit 2
(50-364/80-16-23).
No items of noncompliance or deviations were identified in these areas.
,
11.
Surveillance Testing and Calibration Control (35745/61725)
References:
(a) AP-5 Surveillance
(b) AF-11 Control and Calibration of Test Equipment and
Instrumentation
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a.
Program Review
The referenced documents were reviewed with respect to the licensee's
accepted Quality Assurance Program. The review' was concerned with
surveillance testing and calibration of in plant safety-related instru-
ments not specifically controlled by technical specifications..
The licensee's practices were reviewed to verify the following:
(1) A master schedule for surveillance testing / calibrations / inservice
inspections was developed which included frequency, responsibility
and status for each test / calibration / inspection.
(2) Responsibilities are assigned for maintaining the master schedule
and for assuring that all scheduled tests / calibrations / inspections
are performed.
l
(3) Formal requirements, methods and responsibilities are established
and defined for conduct, review and evaluation of tests / calibrations /
inspections.
(4) Included in the review and evaluation are procedures for reporting
deficiencies with required verification that LCO conditions were
satisfied.
(5) A master schedule for component calibrations had been established
that included frequency, responsibility and status of safety-related
components.
(6) Responsibilities are assigned to assure that the schedule is
maintained and schedules are satisfied.
I
(7) Formal requirements have been established for performing calibra-
tions in accordance with approved procedures.
In any case where the in-office review indicated inadequate- coverage,
the area was further investigated during the implementation phase of
the inspection.
b.
Implementation
!
The inspector ; elected 15 completed surveillance tests and 5 component
( alibrations for review.
The review was conducted to verify that:
,
.
Each of the tests / calibrations is included on the master schedule.
-
Procedures were prepared, approved and implemented in the perfor-
-
mance af the surveillances or calibrations.
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Discussions t ere held with the Maintenance Superintendent, Instrument
and Controls Supervisor, and System Performance Supervisor concerning
the program.
No items of noncompliance or deviations were identi'fied in this area.
Further inspection of this area is documented in Inspection-Report
50-348/79-37, 50-364/79-17.
12.
Procurement Control (38701/35746)
References:
(a)
FNP-0-AP-9, Procurement Document Control
(b)
FNP-0-AP-20, Control of Purchased Equipment, Material &
Services
(c)
GO-PNS-9, Administrative Control of Plant Services
Approved Suppliers List
(d)
GO-PNS-12, Procurement Document Control
(e)
OQA-WP-20, Reviews and ~dvaluations Involving Procurement
(f)
0QA-WP-23, Auditing of Onsite and Offsite Vendor Service
The inspector determined that the majority of the procurement process takes
place at the Company offices; therefore, the inspectior, effort other than
procedure review, was conducted offsite.
a.
Program Review
The inspector reviewed the referenced administrative controls to
assure that they provided the following: specific identification of
the item, required tests or special instructions; required technical
items; access to the supplier's plant or records; QA program and
documentation requirements; and, applicable provisions to comply with
Control of vendors was reviewed to assure that required
audits and other qualification practices were documented and completed.
The inspector also verified that responsibilities had been assigned
for initiation, review and approval, changes, and verification of
quality requirements relative to procurement documents. As a result
of this review, two open items were identified as discussed in Para-
graphs 12.c and 12.d below.
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b.
Implementation
The inspector selected six items which had been purchased and received
on site. For each item the inspector verified that the procurement
documents had been prepared as required, that the, purchases were from
qualified vendors, and that required documentatioh and QA requirements
had been included. The items selected were:
.
C & D Batteries-Float equalizer timer - PO 58432- X09322
400 hp motor - PO 52966 - X69334
Level switch - PO 52965 - X02966
Switeb. indicating DP - PO FNP 1 3202 - NPR-2775
Detector - PO 58408 - X11924
Weld Rod - P0 2288 - X-28946
No items of noncompliance or deviations were found.
c.
Control of Purchase Orders When a Vendor is Removed From the Qualified
Bidders List
During a review of the procedures referenced above, the inspector
determined that criteria and procedures had been developed for removing
a vendor from the approved bidder's list. However, the inspector did
not find any provisions to assure that any outstanding purchase orders
issued to such a vendor would be reviewed and items subjected to
app-apriate controls after delivery to assure that the required quality
would be achieved or maintained. The licensee stated that the required
procedural controls would be developed and documented by August 20,
1980. Until these controls have been established and reviewed, this
is designated Open Item 348/80-14-18; 364/80-16-18.
d.
Development of Guidance for Use With 0QA-WP-20
The decision to audit a vendor is based, in part, on a flow chart with
appropriate decision blocks which is an attachment to procedure OQA-
,
WP-20.
The body of the procedure does not give any criteria to be
used in making any of the judgements involved in " subjective" decision
blocks. The inspector determined that this lack of guidance is not
currently a problem since only one auditor is involved in makina the
decisions and, based on an interview with that individual, he is aware
of all the factors to be considered. However, since new personnel are
expected to be added and the current level of understanding needs to
be maintained, the licensee stated that non-mandatory guidance would
be developed and documented by January 1,1981. Pending completion of
that commitment, this item is designated Open Item 348/80-14-20;
364/80-16-20.
13.
Records Program (39701/35748)
References:
(a)
FNP-0-AP-4, Control of Plant Documents. Revision 4, dated
8/79
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(b) ANSI N45.2.9-1974, Requirements for Collection, Storage,
and Maintenance of Quality Assurance Records for Nuclear
,
Power Plants
a.
Progras
.
The site records management function was examined tc. verify that the
overall record program is in accordance with the licensee's accepted
Quality Assurance Program and ANSI N45.2.9-1974 as committed to by
that program.
This verification consisted of detailed discussions with records
management supervisory personnel concerning the components of the
program.
The inspector verified that retention periods had been
specified and records to be retained had been identified. The licen-
see's record storage procedures were reviewed to verify that the
facilities were described and that the locatian of records within the
facilities were identified.
b.
Implementation
The licensee's program for records was reviewed with respect to the
referenced documents.
The inspector selected 12 operations phase
records for Unit I and 11 constructioa phase records for Unit 2.
For
each of the records selected, the inspector verified that: the record
was stored in the designated location; that the record couM be retrieved;
that the record was listed on an appropriate index; ana, that the
record was stored as required by the Program Controls. The records
selected for review are listed below:
(1) FNP-1-IMP-201.36A, Pressurizer Safety Valve Line Temperature
TE-469, dated 11/8/77.
(2) FNP-1-IMP-201.38A, Temperature Control. System Delta T/Tavg, dated
9/14/79.
(3) FNP-2-IMP-212.8A, Ctat Cooler Service Water Discharge Temp Loop
3025A, dated 4/11/80.
(4) FNP-2-IMP-213.1A, Steam to AW Pump Line-Condensate Level Loop
3608, dated 2/27/80.
(5) APCO Purchase Order 36011, dated 7/27/79.
(6) APCO Purchase Order 54462, dated 2/20/80.
(7) Purchase Package FNP-2-625, dated 10/2/78.
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(8) Purchase Package FNP-2-908, dated 10/1/78.
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(9) QA Audit I 80-1221, dated 6/4/80.
(10) QA Audit I 80-1208, dated 6/3/80.
(11) Biweekly Composite Audit Report No. 79/14~,' I 79-5364, dated
9/6/79.
,
(12) Joint Quality Assurance Followup Audit Report I79-5356, dated
8/7/79.
,
(13) PORC Minutes, FNP-80-0280, dated 3/4/80.
(14) 'PORC Minutes, FNP-80-0606, dated 5/19/80.
(15) Charging Pump IC Annual Inservice Test, FNP-1-STP-4.6, Revision 0,
dated 2/11/77, completed 2/28/77.
)
(16) RHR Pump IB Inservice Test, FNP-1-STP-11.2, Revision 7, dated
'
10/10/79, completed 10/31/79.
(17) Phase II Test Procedure No. 052-5-010, Safety Injection Accumulators
Preoperational Test, Approved 10/12/79 - Unit 2.
(18) Phase II Test Procedure No. 024-5-004 Diesel Gene _rator Response
to LOSP and Safety Injection Signals, Unit I and Unit 2, approved
6/5/79.
(19) Phase I Test Procedure No. 548-3-001, Safeguard Slave Relay
Functional Test, Approved 6/4/77 - Unit 1.
(20) Phase I Test Procedure No. 064-2-006, Reactor Coolant System
Hydro, Approved 9/14/79.
(21) Construction Work Request, Work No. 48.06 Work Completion Approved
date 3/18/77
Of the areas inspected no items of noncompliance or deviation were identified.
)
14.
Tests and Experiments (35749/37703)
,
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Reference: AP-24
Test Control, Revision 2, dated 7/79
The licensee has not performed any tests or experiments as discussed in 10 CFR 50.59.
The referenced procedure was reviewed with respect to it's
,
applicability in this area.
1
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No items of noncompliance or deviations were identified.
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15.
Test and Measurement Equipment (35750/61724)
References:
(a) AP-11 Control and Calibration of Test Equipment and
Instrumentation
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(b) SS-16 Calibration and Control of Test Equipment, Revi-
sion 1, dated 1/79
a.
Program Review
e
The referenced documents were reviewed with respect to the licensee's
accepted Quality Assurance Program.
The review was concerned with
shop standards and portable measuring and test equipment.
The licensee * s practices were reviewed to verify the following:
(1) Criteria and responsibility for assignment of calibration frequency
have been established.
,
(2) An equipment inventory list has been established which identifies
the calibration frequency, standard and procedure for all equipment
to be used for any reason on safety-related structures, systens
or components.
(3) Formal requirements exist for marking the date of tne latest
inspection / calibration on each piece of equipment er otherwire
identifying the status of calibration.
(4) Systems are provided to assure that each piece of equipment is
calibrated on or before the date required and that new equipment
will be added to the list and calibrated prior to use.
(5) Controls have been established to prohibit the use of equipment
which has not been calibrated within the prescribed frequency.
(6) Controls have been established to ensure that when a piece of
equipment is found out-of-calibration, the acceptability of items
previously tested with the equipment will be evaluated and docu-
mented and the cause of the equipment being out-of-calibration
will be evaluated.
(7) Responsibilities have been assigned to assure accomplishment of
the above.
In any case where the in-office review indicated inadequate coverage,
the area was further investigated during the implementation phase of
the inspection.
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b.
Implementation
The inspector selected ten pieces of Measuring and Test Equipment and
verified the following for each piece:
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(1) Equipment was properly stored and controlled.
(2) The status of equipment was identified as required by procedures.
(3) A calibration procedure existed for each piece of equipment and
each piece was calibrated on schedule.
.
(4) The accuracy of each _ piece of equipment was traceable to the
National Bureau of Standards.
The inspector discussed the calibration program with the Instrument
and Control Supervisor and the Maintenance Superintendent. The inspec-
tor interviewed four technicians in the instrument shop and in the
calibration facility.
The inspector also toured the calibration
'
facility.
No items of noncompliance or deviations were identified in this area;
however, a concern was noted with respect to the current calibration
facility.
This facility was found to be of marginally acceptable
cleanliness and physical size and without adequate climate control.
No calibration failures could be traced to the physical facility.
Future calibration activities will be reviewed with respect to the
site calibration facility. This is considered an item for inspector
followup (50-348/80-14-11, 50-364/80-16-11).
16.
Offsite Review Committee (40701B)
References:
(a) Technical - Specification, Section 6.0, Administrative
Controls
(b) OQAPM, Appendix B,
Nuclear Operations Review Board
i
(NORB) (Charter) Revision 13 dated 12/78
The inspector reviewed the latest revision to the NORB Charter to verify
that it was consistant with technical specification requirements.
The
inspector also verified that NORB membership and qualifications are as
required, meetings are held at the required frequency, items reviewed
included persons that had expertise in the areas reviewed, meeting mem-
bership constituted a quorum, and items reviewed and the use. of consul-
tants at meetings was as required.
The inspector reviewed the minutes of 16 NORB meetings held from January
1979 to May- 1980.
No items of rioncompliance or deviations were identified.
17.
Operating Staff Training (41301)
References:
(a) FSAR, Section 13, Conduct of Operations
(b) FNP-0-AP-45, Training Plan, Revision 2, dated 5/78
(c) FNP-0-AP-27, Conduct of Operations Training Group,
Vol. I, Revision 2
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a.
Program Review
A review of the. licensee's documented training program was conducted
to verify the following:
(1) Training for the principal plant staff and licensed personnel is
consistent with FSAR training commitments.
(2) A documeated program has been established for indoctrinating
licensee personnel.
(3) On-the-job training requirements have been established for plant
personnel.
(4) Responsibilities for administering and evaluating the licensee's
training programs have been assigned.
b.
Implementation
The inspector reviewed the training records of at least two individuals
in each of the following classifications to verify implementation of
the initial training programs.
(1) Principal staff members
(2) Reactor operator / senior reactor operator
(3) Maintenance craftsman
(4) Instrument and control technicians
(5) Radiochemistry / radiation protection technicians
(6) Technical staff
(7) Female employees
The inspector interviewed individuals from selected job classifications for
which training records were reviewed to verify that training records reflect
actual training received.
The inspector noted that the training records were not filed using the same
consistency of logic as was employed by other groups within the organization.
While the system employed proved to have record retrievability, it was
found that the documentation of the system's workings was too general to
reflect practice.
Although not found in noncompliance, training as a whole was marginally
auditable. The inspector expressed this conce rn to plant management.
~
Within the areas reviewed, no items noncompliance or deviations, vere iden-
tified.
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18.
Training and Retraicing Progrsm, Non-Licensed Plant Parsonnel (41700)
Reference:
FNP-0-AP-45, Training Plan, Revision 2, dated 5/78
a.
Program Review
,
A review of the licensees training procedures was made to determine if
any changes were made since the last inspection. This area was ~ reviewed
with respect to providing implement ation of the licensee's commitments
for:
(1) Gene'ral employee training for new employees
(2) General employee retraining
(3) Temporary employee training
(4) On-the-j ob training for auxilia ry/craf tsmen, technicians, QA
personnel, and technical staff
b.
Implementation
The inspector reviewed training records for two individuals in each
category above to verify the described training program was provided.
-
The inspector interviewed one employee from each category above to
verify that the individual actually received the training which was
documented in the training records
Within the areas reviewed, no items of noncompliance or deviations were
identified.
19.
Requalification Training (41701)
Reference:
FNP-0-AP-45, Training Plan, Revision 2, dated 3/78
a.
Program Review
A change has been made to the licensee's requalification program since
the last inspection. As stated in APC0 letter of March 3,1980 desig-
nated FNP-80-0273 to NRC Operator Licensing Branch, "In the future,
all annual examinations will be given during the second quarter of
'
each year."
No other programmatic changes were identified by the
inspector.
b.
Implementation
The inspector reviewed the training records for NRC licensed Reactor
l
Operators and Senior Reactor Operators to verify that they included
l
copies of annual written examinations and the individual's responses,
documentation of attendance at all required lectures, documentation of
,
!
the required control manipulations, documentation of required addi-
tional training to satisfy deficient areas, documentation of completion
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of required procedure reviews and/or self-study. Additionally, the
inspector interviewed at least one operator from the following cate-
gories to verify that the training records reflect the actual training
received:
(1) Operators holding NRC Reactor Operator license.
(2) Shift supervisor holding NRC Senior Reactor Operator license and
actively engaged in operating or directing operation of the
facility.
(3) Operators or supervisors holding holding R0 or SRO licenses not
actively engaged in operating or directing operation of the
. facility.
Within the areas reviewed, no items of noncompliance or deviations were
identified.
20.
Audits (40702/40704/35741/35301)
References:
(a) OQA-AP-05, Audit Coverage Planning, Revision 13 dated
4/79
(b) OQA-AP-06, Auditing Implementation, Revision 14 dated
8/79
(c) OQA-AP-09, Corrective Action, Revision 14 dated 8/79
(d) OQA-AP-11, Analyses and Summaries of Audit Results,
Revision 10 dated 9/78
(e)
FNP-0-AP-7, Corrective Action Reporting, Revision 5
dated 12/78
(f) GO-PNS-10, Audits
a.
Program Review
The inspector reviewed the referenced documents to verify that the
scope of the audit program was consistent with the accepted QA Program
and the Technical Specifications. In addition, they were reviewed to
assure that responsibilities had been assigned for determining the
qualifications of audit personnel, the need for any special training,
assuring that corrective actions were accomplished and that reaudits
were conducted as required. The establishment of controls for issuance
of audit reports, periodic review of the audit program, preparation of
long range audit schedules, requiring responses in writing and the use
of checklists during performance of audits were verified.
As a result of this review, one unresolved /open item was identified as
discussed in paragraph 20.c below.
b.
Implementation
t
The inspector reviewed the licensee's audit schedule. Three recently
completed bi-weekly audits were reviewed to verify that they were
conducted in accordance with written checklif;e., the auditors were
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independent and qualified to perform the audit, identified deficiencies
were corrected or are being carried as "open", the audited organization
responded in writing as required, and that the audit report was distri-
buted as required. The following audits were reviewed:
.
80-05, Corrective Action, 3/17-4/9/80
80-07, Test Control and Unit 2 Fuel Receipt and Inspection,
4/15 - 5/9/80
80-09, Qualification and Training and Containment Tendon
Surveillance, 4/2 - 6/6/80
As a result of these reviews, one unresolved item was identified as
discussed in Paragraph 20.d below.
c.
Procedure for Escalation of Audit Findings
Criterion II of Appendix B requires that the QA organization have
sufficient authority and independence to not only identify quality
problems, but also to initiate, recommend or provide solutions, and to
verify their implementation. Criterion XVI requires that, for signi-
ficant conditions adverse to quality, appropriate levels of management
are to become involved. The licensee's accepted QA program includes
commitments to ANSI N45.2 and N18.7. The former requires (Section 19)
that responsible management shall take necessary action to correct
Amf4e4sne4me 4Aant;44eA hv snA4pe.
The 1strar requ4ree
n ur4tten
,
program (Section 4.2.1(9)) that includes provisions necessary for
effective functioning of the group. Although the word " escalation" is
,
not specifically mentioned in any of these requirements, the principles
embodied in its definition are included. The licensee does not currently
have a procedure that includes definitive criteria for escalation and
defined positions within the organization that would be used. Further,
the licensee stated that no such procedure is needed at this time.
Since the only examples found by' the inspector (see paragraph 20.d
below) that would clearly indicate a need for a formalized procedure
had been previously identified by the licensee, further inspection in
this area will be necessary to assure that all of the stated require-
ments are being met. Until : hat additional information can be obtained,
this is designated Unresolied Item 348/80-14-07 on Unit I and Open
Item 364/80-16-07 on Unit 2.
d.
Followup of Reaudit of CAR's 366, 375, 401, 469, 471 and 475
The above listed Corrective Action Reports (CAR's) represent proposed
corrective actions on five audit findings and one self identified
item. Since they were initially responded to at various times over
the last several months, the QA organization has been unable, unwilling,
or considered it unnecessary to carry out the Criterion II requirements
to assure implementation of corrective action. Instead, the licensee
administrative 1y closed these items to permit reaudit in these areas,
although the QA organization had previously rejected the proposed
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corrective actions. This action was documented in a memorandum dated
May 7,1980 from H. O. Thrash to W. G. Hairston, -III the body of which
is reproduced below:
"The following Corrective Action Reports (CARS), although previously
rejected, are hereby approved as completion r~eports:
CAR Number
Noncompliance Number -
366
FNP-NC-15-79/6
375
FNP-NC-21-79/6
401
FNP-NC-34-79/9
469
FNP-NC-2-80/18
471
FNP-NC-4-80/1
475
Self Identified
The purpose of this approval is to expedite the reaudit opportunity
and thereby provide additional input to management concerning
these areas.
By copy of this letter the Manager Operation Quality Assurance is
requested to reaudit the above listed noncompliances at the first
opportunity."
Until the reaudit of these items has been reviewed and evaluated, this
is designated Unresolved Item 348/80-14-08,
21.
Document Cont. col Program (35742/39702)
References:
(a) Startup Standard 12, Document Control, Revision 2
'
(b)
FNP-0-AP-4, Control of Plant Documents, Revision 4,
dated 8/79
(c) FNP-0-DCP-1, Document Control Procedures, Revision 3,
dated 6/78
a.
Program
The referenced documents were reviewed with respect to the licensee's
accepted Quality Assurance Program and ANSI N18.7-1972 as committed to
by that program.
The inspection was to verify that administrative
controls had been established to ensure that all locations where
drawings, technical manuals, FSARs, procedures and other controlled
documents were assigned had current as-built copies, that obsolete
documents were controlled, that changes to documents were incorporated
or indicated as pending, and that responsibilities for implementing
the above were in writing. As the result of this review, four open
items were identified as discussed in paragraphs 21.c and 21.d.
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b.
Implementation
t
The licensee's document control program was reviewed with respect to
,
j
the requirements of the referenced documents. The inspector selected
- representative sample of 6 drawing sets for a' total of 14 safety
related drawings and other controlled documents (Scoping, Index,,
.,
Precautions, Limitations and Setpoints, Emergency Plan, Technical
.
Specifications, FSAR) and verified that the Master Files and issued
,
,
copies were consistent with the master index.
!
'
During the inspection it was found that Unit 1 Control Room had an
obsolete copy of the Emergency Plan. The Shift Supervisor was able to
produce a current copy prior to the inspector leaving the area. In that
,
this was the only discrepancy in the sample and an acceptable copy was
j
l
available, an item of noncompliance is not issued
c.
Destruction of Drawings
It was noted that the Control Coordinator, while on the distribution
t
list for controlled drawings, did not maintain a current file. But
,
rather, after comparing latest revisions against " scoping" drawings,
!
would destroy the drawing. No citation is issued based on the Adminie
strative S perintendent's statement:
"I knew of no requirement for
9
recipient to keep prints".
To review Control Coordinator's future
destruction of controlled drawings this is designated Inspector Followup
Item (348/80-16-13).
'
d.
Inconsistent FCR/CN Tab Data on Drawings
l
An examination of drawings for both units showed several instances
i
where drawing tab data for the same drawings were not in agreement.
Further inspection revealed that the problem was generic to the site
'
and that a similar problem had been identified in an OQA audit (FNP-
NC-5-80/1(18).
The licensee has identified this problem and has procesed the following
solutions:
I
(1) For Unit 1, no remedial action is recommended as Unit I final
document turnover from Bechtel and SCSI is scheduled for comple-
tion in eight to nine months. At the completion of this effort,
each Unit I drawing will have been revised as necessary by Bechtel,
SCSI or vendors - as appropriate -. to reflect all change notices
~
pertinent to the status of the drawing.
Use of _ these final
turnover drawings in the future will eliminate the problem. By
inference any discrepancy between CNs, etc., referenced on the
Daniel document. tab and those incorporated through revision
i
blocks on the final turnover drawing will be those which were
!
included for history or information purposes only.
!
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To assure that required CNs have been incorporated, a review of prints
after completion of Unit 1 final drawing turnover will be conducted
(approximately April 1981).
This is designated Inspector Followup
Item (348/80-14-15).
(2) For Unit 2, complete the revision of Daniel QC procedure QCP
5.3.2.1A to require marking of drawing tabs with an "S"
or "H"
for status or history with respect to outstanding FCR/CNs.
Target date for completion is 7/4/80. This is designated Open
Item (364/80-16-25).
\\
(3) For Unit 2, review prints after the issuance of Unit 2 Operating
License to assure that required CNs have been incorporated.' This
review is based on the licensee's statement that Bechtel will
incorporate the required CNs prior to this drawing turnover.
This is designated Inspector Followup Item (364/80-16-16).
22.
Operational Staffing (36301/35301)
References:
(a) FSAR, Chapter 13, Conduct of Operations
(b) Technical Specification, Section
6,
Administrative
Controls
The inspector reelewed the operational staffing of the Farley sites with
respect to the referenced documents and the licensee's commitment to ANSI
18.1-1974Property "ANSI code" (as page type) with input value "ANSI</br></br>18.1-1974" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. as documented in the accepted QA program. The inspector reviewed
the qualifications of personnel in the following positions: plant manager,
assistant plant manager, operations superintendent, operations supervision,
section supervisors, maintenance superintendent, maintenance supervision,
technical superintendent, technical supervision, licensee shift supervisors.
unlicensed shift supervisors, instrument and control supervision, health
physics supervisor, health physics section supervisors and foremen, licensed
and unlicensed operators, training supervision, plant instructors, mechan-
ical, electrical and instrument techniciana, storekeepers and warehousemen,
welders, and quality assurance staff. The inspector verified that respon-
sibilities had been assigned to assure that the minimum educational, exper-
ience, and qualification requirements were satisfied for the personnel
reviewed.
No items of noncompliance or deviations were identified.
23.
Preoperational Test Records (39301)
The inspection results of this area are included in Records Program Para-
graph 13. No items of noncompliance or deviations were identified.
24. Offsite Support Staff (40703)
References:
(a) GO-PNS-42, Organizational Interfaces for Farley Nuclear
Plant Design Changes in Operating Unit (s), Revision 0,
dated 2/80.
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(b) OQAPM, Revision 16, dated 12/79
a.
Administrative Controls
The inspectors verified that administrative controls which describe
the responsibilities, authority and lines of communication are available
for personnel that perform the following offsite support functions:
(1) Design & Construction
(2) Technical Support
(3) Quality Assurance
(4) Procurement
(5) Interface Between Onsite and Offsite Support Functions
The inspector interviewed cognizant management personnel in the listed
areas to verify they were qualified for their related work and that
they understood their responsibilities and authorities.
b.
Review of Audits
'
The inspector reviewed the results of two audits in the areas of pur-
chasing and nuclear generation station. The specific audits reviewed
were A 34.94.7, Log 79-888 conducted on October 9,1979, and A 35.94.3,
Log 80-548, conducted on February 11, 1980.
c.
Technical Support
The inspector interviewed members of the offsite technical support
staff and management.
During these interviews the inspector noted
that the technical support staff functions as a project management and
review organization and that all the offsite design and engineering
work is accomplished by outside contractors. The licensee employs
seven to ten engineers on the technical support staff, which could be
insufficient if the need arose for a large scale engineering effort.
This area of adequate offsite engineering support is currently being
addressed by NRR as part of the TMI Lessons Learned effort. The
licensee recognizes the potential problems inherent in this situation
and has moved to strengthen contracts with the outside entities. The
licensee has also prepared a proposal to NRR describing the situation
and remedies.
'
This item concerning the size of the offsite technical support staff
is open on Unit 1 (50-348/80-14-10) and open on Unit 2 (50-364/80-16-10)
pending NRR acceptance of the licensee's proposed staffing.
,
No items of noncompliance or deviations were identified in these areas.
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25. Housekeeping / Cleanliness (54701)
References:
(a) OQAPM, Chapter 20, Cleanliness and Housekeeping, Revision
11, dated 4/1978
-
(b) FNP-0-AP-35, General Plant Housekeeping and Cleanliness
Control, Revision 5, dated 8/79
The inspector verified that administrative controls for general housekeeping
and cleanliness practices had been established.
The inspectors toured
accessible areas of Unit I auxiliary building including battery rooms,
switchgear rooms and the cable spreading room. The inspector toured the
following areas in Unit 2: containment spray pump rooms, charging pump
rooms, and the reactor vessel head area. The inspector also toured the
diesel building and the service water building. During the tour the inspector
noticed the following: a broom, rags and cable tray cover clamps scattered,
evidence of smoking and masonite boards on top of a cable run in the cable
spreading room; boric acid on the 121' level floor in p. passageway to the
batching area; and cans of solvent, rags and a flashli ht scattered in the
,
,
,
3
switchgear room. These are considered isolated cases, consequently, these
areas will be inspected at a later date.
This is identified as Inspector
Followup Item 348/80-14-14
26.
Organization and Administration (36700)
References:
(a)
OQA-AP-1, OQA Organization, Revision 8 dated 4/78
(b)
FNP-0-AP-3, Plant Organization and Responsibility
(c) OQA-AP-07, Qualifications and Training, Revision 8
dated 4/78
(d)
FNP-0-AP-18, Technical Group Conduct of Operations
(e) FNP-0-AP-63, Conduct of Operations Systems / Performance
Group
(f) Technical Specification 6.3.1
~
The inspector reviewed the organizational changes in both onsite and off-
site organizations which had been made since January 1979. The changes in
assignments are summarized below. The inspector reviewed the qualifications
of those persons indicated below, and also reviewed applicable procedures
to assure that their duties and responsibilities had been defined in writing.
An amendment was being prepared at the time of the inspection to include
these positions, some of which only involved a title, into the FSAR. Onsite
changes included:
D. N. Morey, III, Superintendent-Operations-Nuclear, 2/80
R. G. Berryhill, Superintendent-Systems and Planning-Nuclear, 3/80
L. W. Enfinger, Superintendent-Administrative-Nuclear, 3/80
H. Garland, Plant Supervisor-Maintenance-Nuclear, 3/80
R. D. Hill, Plant Supervisor-Operations-Nuclear,1/80
L. M. Stinson, Plant Supervisor-Systems Performance-Nuclear, 3/80
J. B. Hudspeth, Document Control Supervisor-Nuclear, 4/80
W. C. Carr, Plant Quality Assurance Engineer,1/80
.
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In the offsite organization, there was a new Manager of Operational Quality
i
Assurance, J. McGowan, who was appointed 1/80. As a result of the above
review, one unresolved item and two open items were identified as documented
,
in paragraphs 26.a through 26.c below.
4
a.
Applicability of Navy Experience for MOQA Qualification
,
Section 4.1 of OQA-AP-01 specifies the required qualification and
experience levels for the M0QA. Based on the onsite review of a resume
of the incumbent in the position, the inspector was able tu substan-
tiate all of the required qualifications and experiences with the
exception of two years of experience in quality assurance. The M0QA
had over twenty-two years of Navy experience, much of which had been
in the nuclear navy area in overhaul, commissioning, and inspection of
operations. At the conclusion of the inspection, this was identified
as an Unresolved Item (348/80-14-06) to be reviewed by NRC management.
Following a return to the Region II offices, the resume of the M0QA
was reviewed by NRC management and found to meet all the requirements
e
of 0QA-AP-01. This item is closed.
,
b.
Revision of FNP-0-AP-3
i
Procedure FNP-0-AP-3 had not been revised to reflect all of the organi-
zation and title changes which M came effective near the end of March
lioG. Gu Apsil 4, 1980, T
yvs.sy Chaos Nuiire-ffCN)1B .. ysoyared-
which outlined the revisions that would be necessary to this procedure.
I
Until these items have been incorporated into a revision of the procedure,
this is designated Open Item 348/80-14-17,364/80-16-17.
c.
NRC to Evaluate Current Size of the QA Staff
Neither the FSAR, Technical Specifications, accepted QA Program nor
current NRC guidance specify the number of persons needed to staff the
I
quality assurance department at Farley. Iiowever, as a part of the
Three Mile Island lessons learned studies, NRC is currently developing
criteria in this area. During this inspec. ion the PQAE was involved
in a study program aimed at obtaining an NRC license. The plant staff
for QA at the beginning of the inspection consisted of one QAE and a
QAE in training. During the second week of the inspection, another
QAE was transferred to the site from the Company offices in Birmingham.
i
At the Company offices the inspector found that the M0QA had one
i
qualified QAE and another QAE in training. During the reviews conducted,
j
the inspector found no cases where quality assurance activities had
not been accomplished. During discussions of the staffing levels with
.
the Vice President of Nuclear Generation he made a statement to the
inspector that he would " place as many people as necessary" at the,
Farley site to assure that required activities were accomplished. He
further discussed his intentions to increase the size of the staff and
to expand their role in plant activities. However, because Unit 2 is
,
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being considered for an operating license and because criteria are
currently under active development, this will be designated as an Open
,'
Item (364/80-16-21) and referred to NRC management for their review to
determine if specification of QA staffing levels is necessary for
Farley Unit 2.
.
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