ML20030B629
| ML20030B629 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 07/10/1981 |
| From: | Leasburg R VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| Shared Package | |
| ML20030B623 | List: |
| References | |
| 385, NUDOCS 8108180369 | |
| Download: ML20030B629 (11) | |
Text
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s VinoINIA ELECTRIC AND Powen CoMPANC, P!
Ricuxoxn,VIHOINIA 20261 July 10, 1981
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R.H.LEAMBUNO vics Penenosar Ncca. man OrmeArnone Fr. James P. O'Reilly, Director Serial No. 385 Office of Inspection and Enforcement N0/RMT:acm U. S. Nuclear Regulatory Commission Docket Nos. 50-338 Region II 50-339 101 Marietta Street, Suite 3100 License Nos. NPF-4 Atlanta, Georgia 30303 NPF-7
Dear Mr. O'Reilly:
We have reviewed your letter of June 16, 1981 in reference to the inspection conducted at North Anna Power Station between April 27 - May 1, 1981 and reported in IE Inspection Reports Nos. 50-338/81-07 and 50-339/81-08.
Our responses to the specific infracti ns are attached.
We have determined that no.ieroprietary information is contained in the reports.
Accordingly, the Virginia Electric and Power Company has no objection to these inspection reports being made a matter of public disclosure.
The information contained in the attached pages is true and accurate to the best of my knowledge and belief.
Very truly yours, 2
R. H. Leasburg Vice President - Nuclear Operations Attachment City of Richmond Commonwealth of Virginia d
Acknowledged before me this /d day of _b. M, 19 <f/
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/7.
C 7 h 9 3, -
Notary PU;11c My Commission expires:
4 - > 6,19 V SEAL cc: Mr. Robetc A. Clark, Chief Operating Reactors Branch No. 3 Division of Licensing 8108180369 G10806 PDM ADOCK 05000338 G
PDR L
Page 1 RESPONSE TO NOTICE OF VIOLATION ITEM REPORTED DURING NRC INSPECTION CONDUCTED FROM APRIL 27 THROUGH MAY 1, 1981 A. NRC COMMENT 10 CFR 50, Appendix B, Criterion II and the Accepted Quality Assurance (QA)
Program, Section 17.2.2 require the indentification of the structures, systus, and components to be covered by the QA Program. The intrcduction to Appendix B statea that QA comprises all those systematic actions necessary to provide adequate confidence that a structure, system, or component will perform satisfactorily in service.
Control of consumable / expendable items used in those structures, systems and components covered by the QA Program is one aspect of those systematic actions to be included in the QA Program.
Contrary to the above, the licensee has not established a program for the control of consumable / expendable items used in the structures, systems and components covered by the QA Program.
This is a Severity Level V Violation (Supplement I.E.).
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION i
The Notice of Violation is correct as stated.
2.
REASONS FOR THE VIOLATION This violation is a result of a misunderstanding of the scope and complexity of a program for consumable / expendable items control.
It was initially considered that the control of shelf-life of certain components was intended and a program, as suca, was implemented. Since then, the total scope of the program necessary has been identified but not implemented.
3.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The scope of the consumable / expendable item QA Program has been identi-fied. The responsibility for the development and implementation of a program for the control of these items has been assigned to the Super-intendent of Maintenance.
4, CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FUR 31ER VIOLATIONS Ihe program for control of these items will be developed and implemented.
This program will be described in a revision to the QA Manual and imple-mented by either revising existing procedures or by the development of new Station procedures, as required.
5.
DATE WHI" FULL COMPLIANCE WTLL BE ACHIEVED This program will be implemented by 12/31/82.
1 Attachmtnt 1 Page 2 B.
NRC COMMENT Technical Specification 6.8.1 requires that procedures identified in Appendix A of Regulatory Guide 1.33, Revision 2, le provided.
Section 8 of this Guide requireq procedures to ensure that tools, gauges, instruments, controls and other measuring and testing equipment are properly calibrated at specified periods to maintain accuracy.
Contrary to the above, Periodic Test 1-PT-32.7.1, Safety Related Instrumenta-tion Calibration, Revision 2, dated Feburary 1981, does not ensure that equip-ment is calibrated at specified periods.
Although it specifies a two year calibration frequency for-safety related instruments not covered by Technical Specification, the Periodic fest permits indefinite extension of the calibra-tion frequency.
This is a Severity Level V Violation (Supplement I. L.).
nESPONSE 1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The Notice of Violation is correct as stated..
2.
REASONS FOR THE VIOLATION Periodic Test, 1-PT-32.7.1, includes many calibration procedures that do not fall under the guise of Regulctory Guide 1.33, Rev. 2.
The number of celibrations presently included in the Periodic Test is so prohibitive that the procedure cannot be completed within the required period.
3.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED The instrument calibrations that are contained in 1-PT-32.7.1 are being reviewed to determine which ones arc required by Regulatory Guide 1.33, Rev. 2.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The instruments that are required to be calibrated by the Regulatory Guide will be scheduled at specified periods by the Periodic Test. The instru-ments that are not required to be calibrated will be deleted from the Periodic Test and added to the instrument periodic maintenance program.
Adm. 10.0, Administrative Control of Protection Instrument Channels, will be revised to include only the instruments that are required to be cali-brated in accordance with Regulatory Guide 1.33, Revision 2.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance will be achieved by 10/1/81.
Attachmtnt 1 Page 3 C. NRC COMMENT 10 CFR 50 Appendix B Criterion V and the accepted QA Program, Sectica 17.2.5 require that activities affecting quality shall be prescribed by instruc-tions, procedures and drawings.
The accepted QA Progrem endorses ANSI N18.7-1972. Section 5.4 of this standard requires periodic review of pro-cedures and the frequency of these reviews shall be specified.
Contrary to the above, periodic reviews and frequency of reviews are not spec-ified in that Nuclear Power Station Quality Assurance Manual (NPSQAM).
Pro-cedures 1, 8, 9 and 10 have not been periodically reviewed, and the frequency of review is not specified.
This is a Severity Level V Violation (Suyplement I.E.).
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The Notice of Violation is correct as stated.
2.
REA*0NE FOR THE VIOLATION This violation is the result of inadequate administrative cc.itrols.
3.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Sections 1, 8, 9 and 10 of the Nuclear Power Station Quality Assurance Manual have been reviewed and proposed revisions made where required.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS Additional instructions will be added to Section SA of the Nuclear Power Station Quality Assurance Manual to provide for periodic review of the Quality Assurcnce Manual.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance will be achieved by Dec. 31, 1981.
l l
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Attachm:nt 1 Prge 4 D. NRC COMMENT 10 CFR 50, Arnendix B Criterion XVII and the accepted QA Program, Section 17.2.17, require sufficient records to be maintained to furnish evidence of activities affecting quality.
I-The accepted QA Program endorses ANSI N45.2.12, Draft 3, Revision 4-1974.
Section 5.2 of this Standard requires audit records to be generated and maintained. Records shall include written replies to audits.
Contrary to the above, written replies for audits N-79-52 and N-80-02 were not maintained.
2.
Criterion XVII and Section 17.2.17 additionally require that the records shall include the results of qualifications of personnel.
Contrary to the above, mandatory attendance for system lectures required for Shift Technical Advisors (STA) qualifications were not maintained.
This is a Severity Level VI Violation (Supplement I.F.).
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION Both areas addressed by the Notice of Violation are correct as stated.
2.
REASONS FOR THE VIOLATION 1.
Failure to maintain written replies to audits N-79-52 and N-80-02 was the result of s3ministrative error.
2.
Although attendance tras documented for some system classes, other documentation could not be located. Since the training program for STA's was established for the first time last year, the docu-mentation requirements of the program had not been fully specified.
3.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED 1.
A search for the written replies to audits N-79-52 and N-80-02 was conducted.
Follow-up audits for audits N-79-52 and N-80-02 were conducted on August 1 and May 1, 1980, respectively. Both follow-up audits were satisfactorily closed indicating that written responses were available when the follow-up audits were conducted.
Since the responses to audits N-79-52 and N-80-02 cannot be located, documentation indicating that the replies to audits N-79-52 and N-80-02 were' lost and substantiating that the deficiencies identified in the audits were resolved, will be filed with audit reports N-79-52 and N-80-02.
2.
Personnel involved with the STA Training Program were contacted and requests for records made.
Complete attendance records for STA academic training were obtained from Virginia Polytechnic Institute and State University. Fifteen of thirty-eight STA system lecture attendance records cannot be located, final academic and systems
AttachmInt 1 Pagn 5
- erinations show that the present STA's met all training require-
- cats.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID Fl"ITHER VIOLATIONS 1.
The loss of responses to audits N-79-52 and N-80-02 is considered an isolated event. A review of existing pracedures shows that ade-quate guidance is given to personnel. No ydditional corrective steps are considered necessary.
2.
Training personnel in charge of STA training have been informed to retain all STA quizzes, tests, and attendance records as per-manent records. An STA certification letter will be issued to personnel qualified to stand shift as a STA and will be maintained in personnel training files.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED 1.
Full compliance will be achieved by 8/1/81.
2.
Full ccepliance will be achieved by 9/1/81.
Attechmtnt 1 Page 6 E.
NRC COMMENT Technical Specification 6.4 states that the Station Manager is responsible for ensuring that retraining and replacement training programs for the facility staff are maintained and that such programs meet or exceed the requirements of Section 5.5 of ANSI N18.1-1971. Section 5.5 of ANSI N.18.1 requires a train-ing program be established which maintains the proficiency of the operating organization through periodic training exercises.
Section 3.2 of ANSI N18.1-1971 states the operating organization of a nuclear power plant consists of onsite personnel concerned with the day to day operation, maintenance, and certain technical services. Administrative Procedure ADM-12.0, Station Train-ing dated 4/80, implements the training program. Paragraph 12.2.2 of ADM-12.0 requires that offsite personnel retrain and recertify every 12 months.
Contrary to the above, retraining was not provided every 12 months for the operatin3 organization, in that three offsite personnel (two Stone and Webster Engineers and one Westinghouse engineer) had not received the required re-training within the specified retraining period of 12 months.
This is a Severity Level VI Violation (Supplement I. F.)
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION The Notice of Violation is correct as stated.
2.
REASONS FOR THE VIOLATION This infraction was the result of an administrative oversite.
During the last three years, approximately 15,000 offsite personnel have received General Employee Trainin3; and at the present time, 1350 offsite personnel are certified to enter the plant. Many of these people leave the plant between outages, and when they return, many are employed with different contractors. The Training Department has experienced difficulty in notifyina. the individual's employer of the necessary requalification due to the constant reshuffling of personnel.
3.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Upon discovery of the out-of-date training certifications, the individuals concerned were immediately notified and subsequently retrained satisfac-torily. Presently, the Training Department is in the process of search-ing the files of offsite personnel to find any other lapses in certifi-cation prior to the expiration date.
4.
CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS The Training Department has begun utilizing a computerized record keeping system which will simplify requalification requirements of all plant per-sonnel, including offsite personnel.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED Full compliance has been achieved.
AttachmInt 1 Page 7 F. NRC COMMENT 10 CFR 50, Appendix B, Criterion V and the accepted QA Program, Section 17.2.5 I
require that activities affecting quality be accomplished in accordance with documented procedures.
1.
The Nuclear Power Station Quality Assurance Manual, Section 4, Procurement Document Control, Revision 4 dated March 1980, requires that the requisi-l tioner list the Quality Assurance category on the purchase requisition.
Contrary to the above, the requisitioner did not record the Quality Assurance category on requisitions for purchace orders 42437 and 41159.
2.
The Vepco Development Policy Manual requires that the individual being trained, the supervisor, the Nuclear Training Supervisor and the Station Manager sign the end-of-step examination and the comprehensive examination given to auxiliary operators.
Contrary to the above, the Station Manager did not sign both the end of step 7 and the comprehensive examination for one individual and the Station Manager and the immediate supervisor did not sign the comprehen-sive examination for another individual.
This is a Severity Level VI Vivlation (Supplement I.F.).
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED VIOLATION 1.
The Notice of Violation is correct as ctated.
2.
The alleged violation is denied. Further investigation indicated that the tests were in fact signed off as required.
This was veri-fled by examining copies of the sign off sheets which were included in the individual's personnel records at the company offices.
The training records audited at the Station by the NRC QA inspector were for the most part complete. However, completed copies of the test cover sheets in question were not made for the individuals concerned prior to relaying to the company offices for processing.
2.
REASONS FOR THE VIOLATION 1.
The reason for the violation is unknown and is considered to be an isolated occurrence.
3.
CORRECTIVE STEfS *iAKEN AND RESULTS ACHIEVED 1.
Since the incident in question is considered to be an isolated event and all purchasing for the requisitions mentioned has been completed with all the proper documentation available, there is no corrective action to be taken.
Attachmtnt 1 Page 8 4.
CORRECTIVE STEPS WHICH PILL BE TAKEN TO AVOID FURTHER VIOLAT10NS 1.
There has been increased emphasis on requisition review both at the Station and Corporate level. In addition, Quality Assurance audits in the past have not shown violations as noted in the comment to be a serious problem.
Therefore, no further action is required.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED 1.
Full compliance has been achieved.
I d
i k.
Page 9 RESPONSE TO NOTICES OF DEVIATION ITEMS REPORTED DURING NRC INSPECTION CONDLICTED FROM APRIL 27 THROUGH MAY 1,1981 A.
NRC COMNINT Vepco correspondence dated December 10, 1980, in response to NUREG 0737, Item II.B.4, Vepco stated that all licensed personnel, management of licensed personnel, and shift technical advisors would be trained in mitigating core damage and examined to the 80% level.
Contrary to the above, the inspector's review of completed test papers indicated that full credit was sometimes given for partially correct or incorrect answers and that partial credit was given at times to incorrect answers.
Generally accepted grading practices require marking off for partially incorrect answers and giving full credit only when the answer as totally correct.
The inspector regraded five licensed senior reactor operators and reactor operator examinations and concluded that four should have been graded below the 80% leve3.
In addition, the Nuclear Training Supervisor and Licensed Training Supervisor regraded the same five papers and found that all five scores were lower than original scores and two of the scores fell below the 80% level.
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED DEVIATION The above deviation is correct as stated.
2.
REASONS FOR THE DEVIATION Vepco contracted General Physics Corporation to administer the required training in mitigating core damage. The contractor was also responsible for the grading of all examination test papers.
3.
CORRECTIVE STEPS TAKEN AND RESULT" ACHIEVED l
To ensure that all the training requirements are satisfied, all licensed personnel, managers of licensed personnel, and shift technical advisors are being retrained and reexamined on reactor core parameters and core damage mitigation by the Training Department during annual requalifica-tion.
4.
CORRECTIVE STES WHICH WILL BE TAKE6 TO AVOID FURTHER VIOLATIONS Differences in interpretation of the answer key is an expected phenomenon when different people grade an examination. Training Department person-nel, when grading written examinations, will continue to be as exact and consistent as possible.
5.
DATE WHEN FULL COMPLIANCE WILL BL ACHIEVED All required Station personnel will be retrained and examined in mitigat-ing core damage by 12/31/81.
L
Attachmint 1
! age 10 B.
NRC COMMENT As stated in Vepco correspondence dated December 10, 1980 in response to NUREG 0737, in summary of all items, Vepco took no exception to Item II.B.4.
Item II.B.4 states in part a training program in mitigating core damage will be de-veloped by January 1, 1981, and implemented by April 1,1981 for managers and technicians in the Health Physics, Chemistry, and Instrumentation and Control specialty groups, commensurate with their responsibilities.
Contrary to the above, the mitigating core damage program for the above specialty groups had not been developed by the established date, January 1, 1981. As of May 1,1981, there had been no implementation of the program for these specialty groups.
RESPONSE
1.
ADMISSION OR DENIAL OF THE ALLEGED DEVIATION The above deviation is correct as stated.
2.
REASONG FOR THE DEVIATION The mitigating core damage training program required fcr the above speciality groups was not developed or implemented within the estab-lished time frame because the requirement was unintentionally overlooked.
3.
CORRECTIVE STEPS TAKEN AND RESULTS ACHIEVED Managers and technicians in the Health Physics, Chemistry, and Instru-mentation and Control specialty groups will be trained in mitigation of core damage, commensurate with their responsibilities, during annual emergency preparedness training. The periodic training and emergency preparedr. css program till be expanded to include classroom training in core damage mitigation for these particular groups. Retraining in this area will be conducted at least once per calendar year.
4.
CORRECTIVE ACTION TAKEN TO PREVENT FURTHER NONCOMPLIANCE The oversight is considered an isolated event and therefore no actions to prevent further noncompliance are believed to be necessary.
5.
DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED The required specialty group training in mitigating core damage will-commence in November 1981, and be completed by January 1, 1982.