ML20003F295
| ML20003F295 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 01/09/1981 |
| From: | NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20003F289 | List: |
| References | |
| 50-324-80-39, 50-325-80-42, NUDOCS 8104200528 | |
| Download: ML20003F295 (6) | |
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APPENDIX A NOTICE OF VIOLATION Carolina Power and Light Company Docket Nos. 50-325 Brunswick 1 and 2 and 50-324 License Nos. DPR-62 and DPR-71 As a result of the inspection conducted on October 20-24 and 27-31,1980, and in, accordance with the Interim Enforcement Policy, 45 FR 66754 (October 7, 1980),
the following violations were identified.
A.
Environmental Technical Specification 5.4.1.1.a requires a semiannual report covering the previous six months' operation which includes a summary of the quantities of radioactive effluent released from the plant and potential doses, as outlined in the NRC Regulatory Guide 1.21.
Contrary to the above, the semiannual report covering the period January 1 to June 30, 1980, did not include the quantities or potential doses for radioactive effluent released from the plant on or about January 23, 1980; February 28,1980; March 2,1980; March 6,1980; and March 13, 1980.
This is a Severity Level IV Violation (Supplement I.D.3).
B.
10CFR50, Appendix B, Criterion XVI requires that measures be established to assure that conditions adverse to quality such as failures, deficiencies, deviations, and nonconformances are promptly identified and corrected. The accepted QA Program, FSAR Section 13.4.3.R.3, states that measures shall be established to follow up on corrective actions to assure proper implementa-tion and closeout.
Contrary to the above, measures had not been established nor had conditions adverse to quality been promptly corrected as of October 29, 1980, in that:
1.
Thirteen items identified by QA audits had exceeded established dates without completion of defined corrective action; eight items had no established corrective action that was satisfactory to resolve the identified problem; and three items had not received any response by the established due date. The above inadequacies represent 46 percent of the total number (52) of open items still outstanding as of this date.
2.
The controlling QA Procedure, QAP-2, On-site QA Surveillance, Revision 10, dated June 16, 1980, does not establish required measures because it does not specify the action to be taken when a response is not received and the required follow-up memorandum is ignored; nor does it specify the action to be taken when proposed corrective action is inadequate.
810.42005.27t
Carolina Power and Light Company Appendix A Brunswick 1 and 2 License Nos. DPR a and DPR-71 This is a Severity Level IV Violation (Supplement I.D.3).
A'similar item was brought to your attention in our enforcement correspondence to you dated December 5,1978 and September 4,1979.
C.
10CFR50, Appendix B, Criterion V and the accepted QA Program, FSAR Section 13.4.3.B.1, requires that activities affecting quality shall be prescribed i
and accomplished in accordance with documented procedures. Procedure OQA-2, Conduct of Plant Surveillance Program, Revision 4, dated December 6,1979, i
paragraph 4.3 requires that items discovered during the surveillance which l
require corrective action will be identified.
1.
Contrary to the above, Surveillance OQAS-80-13 (B) was not accom-plished in accordance with procedure OQA-2 in that 27-plant QA items were identified as either lacking corrective action or lacking a known status; an Action Item was not written identifying a need for corrective i
action.
2.
Contrary to the above, OQAS-80-14 (B) identified as a comment that several record books in use such as jumper log, administrative operating l
instructions, and annunciator status logbook contained obsolete portions i
of the Plant Operating Manual; an Action Item was not written identifying i
a need for corrective action.
3.
Contrary to the above, OQAS-80-4 (B) identified as a comment several I
problems with Periodic Tests (pts) such as changes being made, sign-offs being made without meeting acceptance criteria, equipment being used without being recorded, PT forms not being properly filled out, using pts of the wrong revision, and pts not being locatable; an Action Item was not written identifying a need for corrective action c
This is a Severity _ Level V Violation (Supplement I.E).
i i
D.
Technical Specification 6.5.4.1.c requires that results of actions taken to i
correct deficiencies occurring in methods of operation that affect nuclear safety shall be audited by the Operations and Maintenance Unit of the Corporate Nuclear Safety and Quality Assurance Audit Section at least once per six months.
Contrary to the above, corrective action on plant Quality Assurance items j
have not been audited at least every six months in that only two audits
[
(QAA-21-9 on 12/16/77 and QAA-21-13 on 11/9/79) have been conducted during the period from December, 1977, through October, 1980, covering the subject i
l area.
This is a Severity Level V Violation (Supplement I.E).
A similar item was brought to your attention in our enforcement correspondence to you dated February 21, 1979.
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j Carolina Power and Light Company Appendix A Brunswick 1 and 2 License Nos. DPR-62 and DPR-71 t
1 E.
10CFR50, Appendix B, Criterion II requires that the QA Program provide for indoctrination and training of personnel performing activities affecting l
l quality as necessary to assure that suitable proficiency is achieved and maintained. The accepted QA Program, FSAR Section 13.4.3.D.7, states that j
QA program indoctrination and training of plant personnel will be conducted and, as appropriate, qualifications will be achieved, maintained, and documented. Paragraph 2 states that personnel training will include per-sonnel instruction in the performance and documentation of material inspections, process and test witnessing. Such training will be conducted in a formal atmosphere. Criterion V and Section 13.4.3.G.1 both require that activities be prescribed and accomplished in accordance with documented procedures and instructions.
l Contrary to the above, suitable proficiency of persons performing activities affecting quality were not achieved an51 maintained in that:
1.
Procedure QAI-2, Training Requirements for BSEP QA Surveillance Personnel, l
had not been revised since September, 1975; as a consequence, it referenced procedures for personnel training that no longer exists and i
it did not cover over 25 standards and procedures which are part of I
the current QA controls.
l 2.
Procedure QAI-2 was not followed with respect to Section 3.c because personnel had not received the required oral checkout by the QA Super--
visor following completion of the required training (readings).
3.
Decumentation of training was not complete in that additional training which had been conducted according to the QA Supervisor had not been i
recorded.
4.
Proficiency was not maintained by the program in that over 95 percent I
f the documented training had been completed with initial employment in the QA/QC area. For the five technicians / specialists in the QA/QC l_
group, two were initially trained in 1977 and three in 1978/1979.
5.
Formal training for test witnessing and process witnessing had.not
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j been completed in that all persons interviewed indicated that no formal training in assignment of QC hold points had been received.
i This is Severity Level V Violation (Supplement I.E).
F.
10CFR50, Appendix B, Criterion VI, requires that measures be established to control issuance of documents which prescribe all activities affecting l
quality. The accepted QA Program, FSAR Section 3.4.3.H.1, requires that i
measures shall be established to review documents prior to release to j
assure quality requirements are sufficiently, clearly, and accurately stated.
Contrary to the above, 20 documents were issued or revised without QA review.
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Carolina Power and Light Company Appendix A Brunswick I and 2 License Nos. DPR-62 and DPR-71 This is a Severity Level V Violation (Supplement I.E).
Similar items were brought to your attention in our enforcement correspondence to you dated February 21, 1979, and September 4,1979.
G.
Technical Specification 6.5.4.1.b requires that training and qualifications of the entire facility staff shall be audited by the Operations and Main-tenance Unit of the Corporate Nuclear Safety and Quality Assurance Audit Section at least once per twelve months.
In a letter dated rebruary 14, 1979, the licensee stated that the accepted QA Program would conform to ANSI N45.2.12-1977 (by committing to comply with Regulatory Guide 1.144 dated 1/79). ANSI N45.2.12-1977 states in part (Sections 4.3.2.2 and 3) that objective evidence shall be examined for compliance with quality assurance program requirements and that selected elements shall be audited to the depth necessary to determine whether or not they are being implemented effectively.
Contrary to the above, the qualifications and training of plant QA/QC personnel were not audited at least every twelve months by review of objec-tive evidence to the depth necessary to determine effective implementation.
The lack of QA/QC personnel training, as identified in item E of this Appendix, was not detected in either of the audits of this area conducted during the period from April,1979, through October, 1980. (QAA-21-9 of April 13,1979 and QAA-21-14S of March 10-14,1980).
This is a Severity Level V Violation (Supplement I.E).
H.
10CFR50, Appendix B, Criterion V and the accepted QA Program, FSAR Section 13.4.3.B.1, requires that activities affecting quality shall be prescribed and accomplished in accordance with dveumented procedures.
Co rporate Quality Assurance Audits are conducted per QAAP-1, Procedure for Corporate and ASME QA Audits, Revision 10, dated May 14, 1980. Paragraph 4.0 defines a finding as "A deficiency in characteristic, documentation or procedure which renders the quality of an item unacceptable or indeterminate..." and defines a concern as "...an isolated deviation which does not violate j
specific quality requirements..."
I Contrary to the above, findings (nonconformances) were incorrectly identified as concerns in two audits: QAA/21-13, December 7, 1979, Concern 5 which states in part "...a master surveillance schedule has not been established as described in Section 5.2.8 of ANSI N18.7-1976 and Section A.2 of NRC Regulatory Guide 1.33-1972...;" and QAA/21-14, April 4, 1980, Concern 3, which states in part"... a commitment was made for the PNSC to review these QAP changes in the accepted QA Program by March 1, 1980. Contrary to this commitment to NRC, audit of the PNSC Meeting minutes indicate that the required reviews have not been made."
This is a Severity Level V Violation (Supplement I.E).
A similar item was brought to your attention with respect to your Shearon Harris facilities in our enforcement correspondence to you dated June 3,1980.
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'l Carolina Power and Light Company Appendix A Brunswick 1 and 2 License Nos. DPR-62 and DPR-71 I.
Technical Specification 6.8.1 requires th3t procedures be implemented.
1.
Procedure ENP-3, Section 3.20, requires when a modification has been declared operational that responsible personnel revise applicable procedures.
Modification 79-272, declared operational November 16, 1979, required four valves to be removed from the reactor recirculation system.
Contrary to the above, OP-2 valve lineup was not updated to reflect removal of these valves from the system.
2.
Procedure ENP-3, Section 3.20, requires when a modification has been declared operational all controlled drawings at the plant shall be stamped per the Drawing Notification Sheet.
Contrary to the above drawings FP-50554 (M-80-14), FP-9527-5757 (M-79-271),
FP-50530 (M-79-164), FP-5992 (M-79-057) and LL 90046 sheets I5 and I6 (M-80-04) were not stamped as required.
f 3.
Procedure ENP-3, Section 3.20, requires whan a modification has been declared operational that cognizant personnel (one of which is the i
Training Coordinator) be notified.
Contrary to the above, the Training Coordinator is not notified when mrdifications are made operational.
4.
Procedure RMI-3, Section 9.0, requires drawings to be stamped denoting modifications in effect.
Contrary to the above, drawings LL-9364-88 (M-79-065) and LL-9252-30 (M-79-094) were not stamped to indicate modifications in effect.
5.
Operating Manual, Volume 1, Administrative Procedures, Section 5.1 requires a period of time to be specified for usage of special procedures l
(SP).
l Contrary to the above, SP-79-37, SP-33A-D, SP-79-38, SP-80-2 and SP-79-22 did not specify a period of time for usage.
This is a Severity V Violation (Supplement I.E).
J.
10CFR50, Appendix B, Criterion III requires that measures be established to assure applicable regulatory requirements are translated into specifications, drawings, procedures, and instructions.
The accepted QA Program, FSAR Chapter 13.4.3.E.4, states that suitable design analysis as appropriate will be performed where applicable. ANSI N45.2.11-1974 as endorsed by the accepted QA Program, Section 4.2 requires design analysis to be performed.
Carolina Power and Light Company Appenjix A Brunswick 1 and 2 License Nos. DPR-62 and DPR-71 Contrary to the above, measures have not been established to assure that design analyses will be provided on modifications performed by the plant staff.
This is a Severity Level VI Violation (Supplement I.F).
K.
Technical Specification 6.5.3.3.a requires that the Corporate Nuclear Safety Unit (CNSU) review the safety analysis of modifications in the facility as described in the SAR.
Contrary to the above, the CNSU did not review the safety analysis for plant modification 79-57, which required an FSAR change.
This is a Severity Level VI Violatten (Supplement I.F) applicable to Unit 1.
L.
10CFR50, Appendix B, Criterion XV requires that measures be established to control materials,. parts, or components which do not conform to requirements in order to prevent their use.
The eccepted QA Program, FSAR Chapter 13.4.3.Q.1, requires that measures and procedures be established to control identification, documentation, segregation, review, disposition, and notifica-tion of the affected organization of nonconformances of material, parts, components, or services to prevent inadvertent use or operation. ANSI N45.2.2-1972 as committed to by the accepted QA Program, Section 5.3 requires a statement documenting authority and technical justification for conditional release of an item for installation.
Contrary to the above, measures have not been established to provide a statement documenting authority and technical justification for conditional release of an item for installation.
This is a Severity Level VI Violation (Supplement I.F).
Pursuanc to the provisions of 10 CFR 2.201, Carolina Power and Light Company is hereby required to submit to this office within twenty-five days of the date of this Notice, a written statement or explanation in reply, including: (1) admis-sion or denial of the alleged violations; (2) the reasons for the violations-if admitted; (3) the corrective steps which have been taken and the results achieved; (4) corrective steps which will be taken to avoid further violations; and (5)-
the date when full compliance will Le achieved. Under the authority of Section 182 of the Atomic Energy Act of 1954, as amended, this response shall be submitted under oath or affirmation.
JAN 0 91981 Date:
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