ML20080P169
| ML20080P169 | |
| Person / Time | |
|---|---|
| Site: | Kewaunee  |
| Issue date: | 08/22/1983 |
| From: | Giesler C WISCONSIN PUBLIC SERVICE CORP. |
| To: | Streeter J NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION III) |
| Shared Package | |
| ML20080P163 | List: |
| References | |
| CON-NRC-83-158 NUDOCS 8310060334 | |
| Download: ML20080P169 (8) | |
Text
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NRC-83-158 WISCONSIN PUBLIC SERVICE CORPORATION P.O. Box 1200, Green Bay, Wisconsin 54305 August 22, 1983 Mr. J. F. Streeter, Chief Engineering Branch 1 U.S. Nuclear Regulatory Commission Region III 799 Roosevelt Road Glen Ellyn, IL 60137
Dear Mr. Streeter:
Docket 50-305 Operating License DPR-43 IE Inspection Report No. 50-305/83-09(DE)
This letter refers to the routine safety inspection conducted by Mr. R. D.
Schulz on June 6-8, 1983, of activities at the Kewaunee Nuclear Power Plant.
The attachment to this letter provides our response to the Motice of Violation detailed in the referenced report.
Vety truly yours,
[ A k I O' C. W. Giesler Vice President - Nuclear Power js
- Attach, cc - Mr. S. A. Varga, US NRC Mr. Robert Nelson, US NRC 3
031006C334 830930 guG251983 PDR ADOCK 05000305 G
Mr. J. F. Strester August 22, 1983 ATTACHMENT Response to IE Inspection Report 83-09 A.
Technical Specification Section 6.5.3.8 requires that audits include conformance of the plant operation to the provisions contained within the Technical Specifications and applicable license conditions at least annually.
10 CFR 50, Appendix B, Criterion XVIII, requires that a comprehensive system of planned and periodic audits shall be carried out to verify compliance with all aspects of the Quality Assurance Program.
Contrary to the above, audits which are conducted to verify conformance of plant operation to the provisions contained within the Technical Specifications and applicable license conditions were not adequate, in that provisions contained in the Technical Specifications have been randomly audited with no program established to audit all the provisions within a specified time period.
RESPONSE
WPSC understands the concern of the NRC in regard to this non-compliance cita-tion, but feels that it is an improper citation.
In our opinion, we have met the requirements of 10CFR50, Appendix B, criterion XVIII and Technical Specification 6.5.3.8 with our Quality Assurance Program.
Based on the discussions concerning this issue which we have had with your inspectors, we believe that our difference of opinion lies in the interpretation of the above l
referenced reouirements by your inspectors.
Specifically, they have interpreted these requirements to mean that Quality l
Assurance Audits must cover 100% of the provisions of the Technical Specifications. On the other hand, we feel that an audit, by definition, need not cover 100% of the subject requirements, nor do we feel that the referenced requirements require 100% coverage.
Mr. J. F. Strceter August 22, 1983 Page A-2 We have, however, recognized certain areas where improvements can be made in our QA program in regard to auditing of Technical Specifications as a result of the discussions we have had with your inspectors; consequently, we intend to undertake the following actions:
1.
A formal review of the Technical Specifications and license conditions will be performed to ensure that all appropriate requirements are included in KNPP procedures and Directives, 2.
A revision will be made to the Quality Assurance Directive 5.7,
'" Revision and Control of Technical Specifications-Audit," to include a requirement that an annual review be performed to verify that changes to the Technical Specifications are incorporated into plant procedures as necessary, 3.
A formal review of the planning and scheduling program will be per-formed to verify that it includes all Surveillance Procedures, and 4.
A Ouality Assurance program will be developed which will cover the auditable provisions of the Technical Specifications over a five-year interval.
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l WPSC expects these actions to be completed by March 1,1984.
B.
10 CFR 50, Appendix B, Criterion II, requires that the Quality Assurance Program be documented by written policies, procedures, or instructions, and be carried out in accordance with these policies, procedures, or instructions.
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Operational Quality Assurance Program, Section 13, requires that plant personnel who will be performing inspection, examination and testing activities be qualified in accordance with ANSI N45,2,6-1973, l
" Qualifications of Inspection, Examination and Testing Personnel for the Construction Phase of Nuclear Power Plants". ANSI N45.2.6-1973 requires in Section 2 that each person who verifies conformance of work activities l
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Mr. J. F. Streeter August 22, 1983 Page A-3 to quality requirements be certified by his employer as being qualified to perform his assigned work and a documented certificate shall include the basis used for certification.
The WPSC Operational Quality Assurance Program committed to Regulatory Guide 1.58, Revision 1, position 6 on September 15, 1982.
This was in response to Generic Letter 81-01 and delineated specific educations and experience requirements for personnel performing inspection, examination and testing activities.
Contrary to the above, the following examples of noncompliance were identified:
1.
The Level II certified quality control inspectors, who verified conformance of work activities to quality requirements, were not certified in accordance with the education and experience require-ments stipulated on September 15, 1982 by the licensee in response to Generic Letter 81-01.
RESPONSE
This non-compliance references our letter of September 15, 1982, which was sub-mitted to the NRC in response to Generic Letter 81-01.
It is important to note that this letter was submitted following several telephone conferences with the NRC-Headquarters staff.
Specifically, Generic Letter 81-01 was discussed via telephone on September 9, 1982. This conversation served to delineate our qualification methods and commitments. We stated during this conversation that
'JPS is committed to ANSI N45.2.6-1973 by its Operational Quality Assurance Program and that ACD 9.6 is our method of implementing this commitment.
Following this conversation WPS submitted the September 15, 1982 letter to docu-ment a few select points of the conference call. As such it presented the qualification requirements contained in Administrative Control Directive (ACD) 9.6 without the introductory modifying paragraph which states:
"The education and experience requirements specified for the various levels should not be treated as absolute when other factors provide reaso-nable assurance that a person can competently perform a particular tesk."
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Mr. J. F. Streeter August 22, 1983 Page A-4 This letter was not meant to change or modify the connitments contained in our Operational Quality Assurance Program or ACD 9.6.
We believe this non-compliance has misinterpreted the intent of our September 15, 1982 letter.
Since your inspector agreed and noted in the body of the inspection report that the two Level II inspectors in question are qualified to perform their tasks, we feel that this non-compliance should be withdrawn.
2.
Two Quality Control inspectors were verifying conformance of work activities to quality requirements prior to their certification as Level I inspectors.
RESPONSE
We acknowledge the above as a Level V violation. Although the qualification of the individuals involved was fully established prior to assigning Level I type work, it was not properly documented as required by procedure.
This situation has been corrected by completing the certification documentation.
The responsible supervisor is now fully aware of the responsibilities concerning certification and we feel this will prevent further occurrence.
C.
10 CFR 50, Appendix B, Criterion V, requires that activities affecting quality be prescribed by documented instruction or procedures.
Contrary to the above, the following examples of noncompliance were identified.
1.
Forms which were not referenced by procedures or instructions were being used to document the results of inspections, examinations, and tests important to gaality. Procedures or instructions had not been established to control the use, distribution, or retention of the forms.
Mr. J. F. Streeter August 22, 1983 Page A-5
RESPONSE
Two of the subject forms were originally generated to document the performance of construction activities and have continued to be used for maintenance repairs and plant design changes. Upon completion these forms are included in the maintenance work request package, reviewed, and filed as permanent records in the QA Vault. The third form (originally a quality assurance checklist) became a convenient means of documenting quality control inspections of fuel assemblies.
As noted, these forms do not have formalized control procedures. WPS is currently establishing directives to better detail the activities of the quality control group. These directives will include controls for the forms and checklists in use by the quality control group for activities affecting quality.
2.
Procedures or instructions had not been established which prescribed the metnods to assure that conditions adverse to quality are identi-fled, controlled, and corrected during maintenance or modifications to structures, systems, or components.
RESPONSE
Maintenance or modifications to structures, systems, or components are performed per Administrative Control Directive (ACD) 5.4, " Work Request". This directive provides for: 1) QC Supervisor review for conformance to Plant QA Standards l
before the job is started, 2) QC Technician review of the work request for any special procedural or testing requirements, 3) QC Technician inspections at QC checkpoints, if any, and at the completion of the maintenance actions with sign off, and 4) QC Supervisor review and sign off prior to routing the completed package to the QA Vault. ACD 9.1, " Quality Control Group Organization", states thtt the QC Supervisor or QC Technician can specify a QC hold point if ia his opinica
Mr. J. F. Streeter August 22, 1983 Page A-6 conditions may b,e developing which could adversely affect the quality of the job.
until the appropriate management level can be notified. WPS considers this program adequate to identify and control conditions adverse to quality. However, a quality control directive specifying QC group actions and required documentation when an adverse condition is identified will be established to assure corrective actions are completed. The existing Operating Experience and Assessment Program will be used to make plant personnel-aware of these items and to monitor for trends contrary to quality.
WPS expects to have the quality control directives addressing these two items issued by March 1, 1984 and in full compliance at that time.
D.
10 CFR 50, Appendix B, Criterion II, states in part tnat the Quality Assurance Program shall provide for indoctrination and training of personnel performing activities affecting quality as necessary to assure that suitable proficiency is achieved and maintained.
The WPSC Operational Quality Assurance Program description, dated September 28, 1982, states that the program complies with the provisions of ANSI N18.7-1976, " Administrative Controls and Quality Assurance for the Operational Phase of Nuclear Power Plants." ANSI N18.7-1976, Section 3.3, requires that provisions shall be made for indoctrination and training of those personnel in the owner organization performing activities affecting quality to assure that suitable proficiency is achieved and maintained, including as a minimum procedures or instruc-tions which implement the program related to the specific job-related activity. Additionally, the WPSC Operational Quality Assurance Program, Section 13, states that the training program shall provide suitable
' training of other station personnel who do not have to obtain an NRC operating license, and the training shall be provided to achieve special skills required in the performance of plant operation, including job-related procedures and instructions.
Contrary to the above, a training program has not been established which includes formalized training in job-related procedures, instructions, codes and standards for personnel such as supervisors, engineers and other professionals.
't*
Mr. J. F. Streeter August 22, 1983 Page A-7
RESPONSE
WPS acknowledges the violation.
Since our recognition that the existing training program was inadequate in 1981, a number of steps have been taken to improve the program. The staff size of the training group has been increased to add a training supervisor-nonlicensed, two nonlicensed training specialists, a training supervisor-technical, and two training instructors.
The nonlicensed training positions have been filled and these individuals will be presenting the maintenance training program for maintenance men, plant electricians, and instrumentation and control men this September.
The training program for the chemistry and radiation protection technologists will be presented in early 1984. WPS expects to fill the technical training positions in late 1983 or early 1984. A job related training program for supervisors, engineers, and other professionals is scheduled to be in place in late 1984.
In the interim job related training with durations of several days to several weeks is being presented to engineers and supervisors to augment their on-the-job training. Past training topics have included ASME Boiler and Pressure Vessel Code Sections III and XI, Quality Assurance codes and standards, plant design changes, plant systems operation, engineering control directives" admin-istrative control directives, engineering specifications, and fire protection.
WPS will continue this approach until implementation of a training program for supervisors and engineers in 1984. Full compliance should be achieved at that time.
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