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UNITED STATES ATOMIC ENERGY COMMISSION
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lr KING OF PRUSSI A, PENNSYLVANI A 19406 su NOV2 01975 Jersey Central Power and Light' Company License No. Dpa-16
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', Attentions Dr. D. 5. Bartnoff.
Docket No. 50-219 fp President Inspection No. 75-07 Madison Avenue at Punch Bowl Road Morristown, New Jersey 07960 Gent 1====
This refers.to the March 10-14, 1975 Quality Assurance implementation inspection, by Wasers. R. Glasscock, E. Or
, W. Ruhlman aged J. Smith of this office, of Oyster Creek Nuclear Generating Station activities authorised by NM License No. DPR-16. Enforcement correspondence for i w' this inspection has been separately provided from NRC Headquarters.
In accordance with Section 2.790 of the NRC's " Rules of Practice," Part 2, Title 10. Code of Federal Regulations, a copy of this letter and the enclosed inspection report will be placed in the NRC's Public Document Room. If this report contains any information that you (or your con-tractor) believe to be proprietary, it is necessary that you make a f
written application within 20 days to this office to withhold such information from public disclosure. Any such application must include a full statement of the reasons on the basis of which it is claimed that the information is proprietary.and should be prepared so that 0 03 *.
proprietary information identified in the application is contained in a separate part of the document. If we do not hear from you in this l
regard within the specified period, the report will be placed in the i
Public Document Room.
No reply to this letter is required, however, should you have any i
further questious concerning this inspection, we will be pleased to discuss them with you.
1 Sincerely, i
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j James P. O'Reilly Director
Enclosure:
Inspection Report 50-219/75-07
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cc:
- 1. R. Pinfrock, Jr., Vice President
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Iscal PDE NSIC TIC REG:I Reading Room Region Directors (II, III, IV) (Report only)
State of New Jersey A. R. Roismen, Counsel for Citisens Committee for Protection of the Revironment i
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W. P. Ellis, Enforcement Specialist, Division of Field Opetations yij Office of Inspection and Enforcement, Headquarters JERSEY CENTRAL POWER AND LIGHT COMPANY We have reviewed the JCP&L response to the strong Notice of Violation transmitted by Mr. Davis' letter of October.17,1975. -
We recommend the enclosed letter for Mr. Davis' signature.
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ary Ac.ng Ass stan o the Director
Enclosure:
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SENT HAf,. CARD 11/21/75 UNITED STATES NUCLEAR REGULATORY COMMISSION
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NOV 211975 Jersey Central Power' and Light Company Docket No. 50-219 ATTN: Dr. S. Bartnoff, President Madison Avenue at Punch Bowl Road Morristown, New Jersey 07960
Reference:
Your letter dated November 5, 1975 In. response to our letter dated October 20, 1975 Gentlemen:
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.Thank you for your response to our correspondence. The corrective l
actions you documented will be examined during subsequent inspections of your licensed program.
We understand from the phone conversation on November 24 between Mr. Finfrock of your staff, and Mr. Brunner of our Region I office, that modifications of commitnents to WASH documents and ANSI Standards
'will be submitted to the Office of Nuclear Reactor Regulation. We WWtti understand this also includes any modification of commitments to per-sonnel experience and training requirements.
Your cooperat. ion with us is appreciated. '
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John G. Davis Deputy Director Office of Inspection and Enforcement cc:
.I. R. Finfrock, Jr., Vice President J
A. Z. Roisman, Counsel for Citizens Committee for Protection of the Environment
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E. J. Brunner, Chief, Reactor Operations Branch, IE:I 711RU:
E. C. McCabe, Jr., Senior Reactor Inspector, Nuclear Support j
Section, Reactor Operations Branch, IE:I INSPECTOR'S EVALUATION MEMO IE INSPECTION REPORT No. 50-219/75-07
, JERSEY CENTRAL POWER AND LIGHT COMPAt%,
OYSTER CREEIL FACILITY After participating in the recent inspection of the Operational Quality Assurance Plan at Oyster Creek, I have reached the following conclusions.
1.
The Operational Quality Assurance Program is not implemented'at
.j Oyster Creek as of March 14, 1975.
2.
Jersey Central Power and Light management has failed to implement a series of informal (i.e., not legally binding) commitments made to this office dating from about October 1972 relating to QA/QA Program implementation.
3.
Management meetings, such as those in October 1972 and November 1973, have not provided the necessary impetus to implement an Operational Quality Assurance Program.
O 4.
Eccalated enforcement action at Oyster Creek appears necessary be-cause of ineffectiveness of past enforcement measuras.
License modification may be a more appropriate action than issuance of a civil penalty for this licensee.
With respect to item 1. above, there is no contention from the licensee.
Our audit and the licensee's audits have both indicated that there is no implemented QA program.
The Details of Report 50-219/75-07 document the bases for this conclusion.
The following are worth noting.
i 1.
In a letter from J. P. O'Reilly to JCP&L dated November 8,1972, Region I stated its understanding, based on an October 13, 1972 meeting, that:
.your formal Quality Assurance Plan will be approved and issued by November 15, 1972, and that detailed imple-menting procedures required by your QA Plan will be issued by January 15, 1973.
It is also understood that all aspects of your QA program as required by the above plan will be fully implemented by March 31, 1973."
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L1 E. J. Brunner.
j Not one of these commitments was made by the indicated date.
Comple-
.gg kW; tion of all required implementing procedures and full QA program im-j plementation have not yet been accomplished.
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2.
In a letter from JCP&L to J. P. O'Reilly dated December 8,1972, a j
JCP&L Vice President took one exception to the letter quoted above.
in that he changed the date of approval and issuance of the Quality
, Assurance Plan from November 15, 1972 to December 15, 1972.
Nonethe-1ess, the Plan was not formally submitted to the Division of Reactor Licensing until March 15, 1973.
The March 15, 1973 submittal (FSAR Amendment 71) was unacceptable to Licensing.
The document finally accepted by RL was based on Revision 2 of Amendment 71 which was forwarded to RL on October 1, 1974 - three years and four months after the first submittal made to comply with the legal requirements of 10 CFR 50, Appendix B and two years after the management meeting held in IE:I to expedite an acceptabic QA Plan.
r 3.
The Jersey Central Power and Light Operational Quality Assurance Plan (0QAP) dated December 14, 1973 states, on page 4, "It is the policy of Jersey Central Power and Light Company to meet the require-ments of the Code of Federal Regulations,10 CFR 50, Appendix B and f
pqq the applicable regulatory requirements...."
On page 5 of the OQAP, the following statement is provided: "The Jersey Central Power and Light Company has authorized the establishment of a formal and com-prehensive Operational Quality Assurance Program for the Oyster Creek Ibclear Generating Station.
This program shall be imple-mented throughout plant life in accordance with approved policies, procedures and instructions."
This OQAP was submitted to RL as Revision 1 to Amendment 71 in December 1973.
4.
llad an Operational QA Plan been implemented at Oyster Creek, the present condition would constitute a major QA breakdown.
This.li-censee has not only failed to implement his program, he has not even completely defined the system to which it will apply.
(50-219/
75-07, Details,Section II, Paragraph 6.c)
This lack of an implemented program comes:
four years and eight months after the requirement for an applicant to establish "at the carliest practicable time, consistent with the schedule for accom-plishing the activities, a quality assurance program which complies with the requirements of...." 10 CFR 50, Appendix B; three years,and 4
cight months after the applicant made the submission of Igis first e
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program ' designed to meet those requirements; two years af ter the date by
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which the licensee stated to IE:I that "all aspects" of the quality assur-ance program would be " fully" implemented.
It should also be noted that Oyster Creek in a facility of older design which was upgraded to a higher power level than originally called for.
Protective instrumentation at this facility has been an-example of a' repetitive inability of equipment to meet Technical Specification re-t quirements (setpoint drif t).
As this facility ages further, the impor-tance of careful implementation _of quality maintaining and upgrading activities, by operating and staff personnel, will become more and more important to the assurance of public health and safety. Firm action to increasc quality assurance effectiveness for this facility is strongly t :-
urged.
.aak..di William A. Ruhlman i
Reactor Instructor cc:
E. G. Greenman-i i
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Tot. E. C. M'cCabe INSPECT 0li'S EVALUATION OF OYSTER CREEK QUALITY ASSURANCE q.,
W4 These are my impressions of the Oyster Creek Quality Assurance, activities f"'
as a result of inspection 75-07 (March 10 through 14). There appeared to be a, general apathy by the management and working personnel (except plant QA) toward the Quality Assurance procedures. The personnel seems unconcerned that they had a responsibility to understand and implement the procedures.
The, inspectors were shown a letter dated 3-10-75 (the starting date of the inspection) from the Vice-President Generation, to the Managers which stated essentially, "Each manager is to'take action to immediately implement the.QA Program".
The letter offered no suggestion as to what was to be,,done to accomplish this.
Of more importance, however, was that no requirements
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were included in the letter for feed back of any kind from the managers to indicate what was being done to affect this "immediate implementation".
The letter had indications of more of a "show" for the inspectors than an 3
instrument to create action to implement the program.
The QA Manager does not appear to stand up to his responsibility as defined i
in the operational Quality Assurance plan,Section II, which states in f
art:
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"...The Manager-Operations Quality Assurance has the direct responsibility g
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and that it provides for control of all activities affecting quality on P
nuclear and safety related items.."
dN $The QA Manager was very defensive when something was found wrong with func-N tions his department was performing.
Ile seemed almost unconcerned when any problem was identified to him relating to procedures, and their implementation, i
by other departments.
Plant QA personnel appeared aggressive in implementing their functions.
i Their relations and communications with the plant personnel did not appear to be effective in relating a mutual respect and understanding of each other's responcibilities. An excellent example of this was the handling of the three nonconformance reports against the condensate Transfer System.
The reports identified several deviations from the standard to which the work weo to be performed and tested. The plant put the system into service without approval of QA, contrary to procedure, and prior to the procedurally, required resolution of the nonconformance reports.
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.2-This is the fifth utility in which I have participated in performing the QA implenhentation inspection. Jersey Central is, without a doubt, the>
most deficient in implementing their QA procedures.
It is my feeling that considerable pressure, including strong enforcement action and com-
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prehensive followup inspection, is required to assure effective imple-mentation of the QA program.
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R. B. Glasscock Reactor Inspector 9
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E. J. Brunner, Chief, Reactor Operations Branch, IE:I OYSTER CREEK QA Oyster Creek QA Inspection 50-219/75-07 identified a substantive number
.of QA noncompliances which a; pear to constitute a major breakdown in management control over QA. Review of the facility inspection record.
shows that this licensee has been stating, since at least November 1972,
'to both Region I and our headquarters, that he was going to establish and implement an operational QA program at Oyster Creek.
Although these commitments did not meet IE criteria for enforcement action be-fore FSAR Amendment 71, the documentation does show that statements by this licensee about his QA program implementation have not been 1
reliable, and that management meetings have produced statements which have not been followed by effective action to implement a QA program.
It is my recommendation that this licensee be measured solely by results achieved and not by his statements.
It is my opinion that the situation documented by Report 50-219/75-07 indicates a real need for escalated enforcement action, and that there is no reason to believe another 9 49 management meeting vill correct the problem.
It is also my opinion that Oyster Creek's inattention to development of sound procedural controls over safety-related activities, and to adherence to such con-trols as are provided, will, if not firmly dealt with, increase with time and produce a concurrent decrease in assurance of public health and safety.
Q. C. 00Sthl" E. C. McCabe, Jr.
Senior Reactor Inspector Nuclear Support Section J. P. O' Reilly (/
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cc D. L. Caphton E. G. Greenman l
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4 APPENDIX A
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j JCP6L RESPONSES TO SPECIFIC NRC AUDIT FINDINGS DURING MARCH 10-14, 1975 INSPECTION j
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1.
Criterion II, Appendix B,10CFRSO requires that the quality assurance program shall be documented by written policies, procedures, or instruc-tions and shall be carried out throughout plant life in accordance with
- A those policies, procedures, or instructions; that the program shall provide j
for indoctrination and training of personnel performing activities affect-
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ing quality as necessary to assure that suitable proficiency is achieved and maintained; that the quality assurance program provide control over activities affecting quality to an extent consistent with their importance i
to safety.
a.
The Operational Quality Assurance Plan, Revision 1, dated September 30, 1974,Section II, states that the licensee will utilize the guidance of ANSI N45.2.6-1973.. Articles 3 and S of ANSI N.2.6-1973 require qualification and certification of Level' I, Level II, and Level III Inspection, Examination and Testing Personnel.
Contrary to the above, certain site personnel engaged in maintenance testing examination, and inspection activities did not have the required certification defining levels of capability, in that persons performing testing following maintenance were not certified as Level I or II, nor were persons interpreting test data certified as Level II as specified by Section 3 of N45.2.6-1973.
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This is a deficiency.
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RESPONSE
In the review of the various ANSI Standards which are endorsed by the
" WASH" Documents, JCP6L has determined that the requirements of ANSI N45.2.6 are, in part, contradictory to requirements outlined in ANSI N18.1.
Our Operational Quality Assurance Plan provides for this situation in that, "whenever there is a contradiction within the referenced documents, Jersey Central Power 6 Light Company shall determine which ' guidance' is most appropriate and imolement it in lieu of the contradictory ' guidance' ".
Guidelines have long been established in the company with respect to awarding jobs to plant individuals who may be involved in testing, examination, and in-the,ction activities. Personnel are qualified in accordance with spe Jersey Central Power 6 Light Company Job Description Manual.
We believe that the requirements specified in the Job Description Manual meet the intent, and in many cases exceed the requirements, of ANSI N18.1. There have been individuals in the past, and probably will be individuals in the future, qualified by JCP6L because it feels the individual is capable of performing a job, even though they do not meet the guidance contained in ANSI N18.1 4
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with respect to experience and training. JCP6L has elected to
- comply with the intent of ANSI N18.1 in lieu of the guidance contained in ANSI N45.2.6 with regard to plant inspection, examination, and testing personnel.
b.
Section III of the Operational Quality Assurance Plan states that
,V the Oyster Creek Superintendent is responsible for preparation, li review, and approval of the plant maintenance procedure which specifies the manner in which plant maintenance and repair is controlled by distinguishing between different types of mainten-ance and repair and specifying the applicable requirements for the control of each.
Implementing Procedure 105, " Maintenance, Repair and Modification Control", states that items which fall under the cognizance of the QA Plan shall be segregated and handled in accordance with this procedure.
Contrary to these requirements, twelve job orders reviewed during the inspection, all of which involved maintenance of safety related systems, were not segregated and handled as being under the control of the quality assurance pmgram.
This is a deficiency.
RESPONSE (Includes response to Items 3.b and 6)
These violations.cre identified as a result of the review of a Job Order Form which had been in effect and used prior to the NRC inspection of March 1975. The need to revise our Job Order Form to Q
incorporate the various requirements of the Operational Quality Assurance Plan, as it relates to maintenance activities, had been identified; and in fact, during the inspection period, a new Job Order Form was delivered to the site and has subsequently been placed into effect. This new form has since been revised and we would expect, that with further usage, additional revisions will be made to improve its effectiveness. The Job Order Form now includes:
(1)
Identification of applicability to the Quality Assurance Program, (2)
Identification of procedures, instructions, or drawings that shall be used in performing the maintenance and testing, (3) Notification of Quality Assurance prior to the start of such maintenance work, (4) Tabulation of outstanding deficiencies at the completien o'f the maintenance work, (5)
Required signatures attesting to the acceptability of the installation and testing performed, (6)
Review / sign off by the maintenance supervisor.
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- APPENDIX A -
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Revisions have been made to Procedure 105 (Maintenance, Repair, g
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and Modification Control) specifying when detailed procedures must be used for maintenance. As those detailed procedures are developed, testing that is required upon completion of the main-!
.tenance job will either be specified in the procedure or reference-
,s 6j given to appropriate test procedures, instructions, or drawings.
QQ Procedure 107 (Procedure Control) specifies the review'and approval-i i
requirements associated with any of the procedures used at the station on safety related items. An' instruction, which will be incorporated into Procedure 105 (Maintenance, Repair, and Modifi-cation Control) by November 14, 1975, has been issued to describe the use of the Job Order Form. This instruction provides defini-j tive steps that will be followed in processing the maintenance job l
order, including the notification of site quality assurance personnel prior to the commencement of work so that appropriate logging and review can be made.
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s 2.
Criterion III, Appendix B,10CFR50 requires establishment of measures to i
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- 1) assure'that the design basis, as defined in '10CFR50.2, is correctly translated into specifications, drawings, procedures, and instructions, and 2) for the identification and control of design interfaces and for coordination among participating design organizations. The OQAP,Section III, Revision 0, dated December 14, 1973, states that design control is implemented by Generation Engineering procedures which include design review requirements, internal and external interface control considera-tions, and appropriate design bases.
W Contrary to the above, regarding plant modifications, measures were not taken to include 1) consideration of design bases, 2) control of design interfaces, and 3) the coordination among participating design organiza-tions, until the issuance on March 7,1975, of Procedure 6003 (Modifications, Non-routine Maintenance, and Repair). Even then, the referenced procedure l
did not provide for the consideration of the design bases, not for coordination among participating. design organizations in design review requirements for plant modifications.
This is a deficiency.
RESPONSE
Generation Engineering Procedure 6003 (Modification, Non-routine Maistenance, and Repair) is being revised in order to meet all of the requirements of N45.2.11, " Quality Assurance Requirements for the Design of Nuclear Power 1
Plants". The revised procedure is scheduled for issue during January 1976.
In the interim, the existing revision of Procedure 6003 is being implemented and your identified concerns are being addressed in plant modifications.
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'APPENDI.X A *
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- 3.
Criterion 'V,' Appendix B,10CFR50 requires that activities affecting quality shall be prescribed by documented instructions, procedures, or drawings of a type appropriate to the circumstances and shall be accomplished in accordance with these. instructions, procedures, or-drawings.
Instructions, procedures, or drawings shall include q9 appropriate quantitative or qualitative acceptance criteria for
?.kh determining that important activities have been satisfactorily accomplished.
a; ne Operational Quality Assurance Plan,Section IV requires that procurement documents prepared by or' for the Generation-Department
.p be approved in accordance with the Generation Department Procedure.
Generation Department Procedure 2001, Administration of Procurement, Revision 1, dated October 4, '1974, Section 3.2.2 requires Operational Quality, Assurance review of and concurrence with procurement documents.
Contrary to the above, procurement documents for chemicals ha[not received Operational Quality Assurance review..
i-This is an infraction.
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RESPONSE
Re Operational Quality Assurance Plan states, in Section II*, first paragraph, "Th+ structures. systems and compenents covered by this i
program are identified in Appendix A, the Quality Assurance Systems List".
In the preparation of the Quality Assurance Systems List, JCP6L did not consider items such e chemicals and condensate domineralizer resins.
In reviewing your finding, JCP6L agrees that there are certain items, such as primary sampling chemicals and condensate demineralizer resins,which should be within the scope of the Operational Quality Assurance Plan. Since these items do not fall within the scope of a Quality Assurance Systems List, we are evaluating the scope of your concern and considering several alternatives of Plan revision to resolve the finding.
The following actions have been taken a,s immediata corrective action:
(1) Chemical purchase requisitions are being reviewed by Site Quality Assurance, (2) A specification for the procurement of resins has been prepared, concurred with by Quality Assurance and approved by Generation Engineering, in accordance with Procedure 2001, Administration of Procurement, Revision 1.
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-APPENDIX A Phg1 Y
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o b.
Section V of the Operational Quality Assurance Plan requires that instructions and procedures associated with maintenance be implemented' in accordance' with the 0QAP.
In:;truction SQA-1-74-G-004 requires a QA Specialist to review and then log QA related jobs in the inspection
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log, including the name of the job or system, the present plans for, and nature of the work to be done, qy
'l Contrary to the above, twelve safety-related job orders were neither reviewed nor logged by a QA Specialist.
1his is an infraction.
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RESPONSE
' Refer to the RESPONSE to Item 1.b.
I The Operational Quality Assurance Plan, Revision 0, dated Dece"mber 14,
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y 1973, provides in Section III, for a System Boundary and Classification Book for expanding the Quality Assurance Systems List (QASL) into categories of safety classes using Regulatory Guides 1.26 and 1.29 for guidance and specifying the basic codes, st:ndards, and regulatory requirements for each category. The 0QAP, Appendix C, Revision 0, dated December 14, 1973, " Preliminary List of Procedures Implementing the Quality Assurance Program", lists, as one of the procedures which should bc ready and i:::ued by April 1974, the Systcr Boundary and 1
Classification Book, M
Contrary to the above, required definition of equipment and component safety classification had not been accomplished; in that the System Boundary and Classification Book was not provided as of March 12, 1975.
This is a deficiency.
RESPONSE
i JCPGL is presently developing the System Boundary and Classification Book as required by the Operational Quality Assurance Plan.
At this time, it is estimated that the System Boundary Book will be completed by February 1,1976, and that the System Classification Documents will be completed by July 1, 1976.
d.
Technical Specification 6.2.C requires that operating procedures be followed.Section V of the 0QAP states that Oyster Creek Superintendent is responsible for ensuring the instructions and procedures associated with operational testing are prepared, reviewed, approved, and imple-mented in accordance with the OQAP.
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APPENDIX A Page'VI g
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s Contrary to the above,1) the diesel fuel inventory log entries-
' which serve to document maintenance of minimum fuel levels established by the Technical Specifications were not made as required by Procedure 601 for the period January 6-February 3, 1975, 2) Station Battery "B" discharge test log entries required
- )j by Procedure 601 were not made on December 18-20, 1974, and j.
- 3) Control Rod Drive System testing log entries required by.
Procedure 603.3 were not made on January 27, 1975.
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This is a deficiency.
RESPONSE
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In reviewing this finding, we determined that it is an error in the logging of reading and test results rather than an oversight in the requirement to take the reading or conduct the test. This conclusion was established through the review of other logs aAd
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the Surveillance Test File. As part of a complete revision of I
the operating, maintenance, and surveillance test procedures (a
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task of which Region I of the NRC is aware), JCP6L is reviewing the procedures and logs to minimize the need for redundant documentation of log entries. JCP6L feels that this action will correct the cause of this finding. The procedure review effort 2
is a continuing one which requires a significant commitment of time and effort. The status of the procedure review program is updated at frequent intervals and is available for your review during future inspections.
WM e.
The Operational Quality Assurance Plan,Section V, states that the Oyster Creek Superintendent is responsible for ensuring that i
instructions and procedures are implemented.
Procedure 102,
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Training of Nuclear Generating Station Personnel, Revision 0, i
dated July 18, 1974, states that site training is conducted in accordance with detailed procedures specified in the Oyster Creek Training Manual.
Contrary to the above, detailed procedures specified in the Oyster Creek Training Manual were not being used to train non-licensed technicians and repair personnel, in that non-licensed technicians and repair personnel training was being conducted pursuant to Job Qualification Review Sheets prepared on each individual.
This is a deficiency.
RESPONSE
Procedure 102, Training of Nuclear Generating Station Personnel, has been revised to be consistent with existing practices and is being implemented.
APPENDIX A '
.. Ptge VII j
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4.
Criterion.VI, Appendix B, 10CFR50 requires that safety-related documents i
be reviewed for adequacy and approved for release by authorized personnel; that safety-related document changes be reviewed and approved by the same
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organizations that performed the original review and approval unless the-applicant designates another responsible organization; and that safety-Ej related documents be distributed to and used at the location where the
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prescribed activity is performed.
t Technical Specifications Sections 6.1.C.I.d, 6.2.D and 6.2.E require a.
Plant Operations Review Committee (PORC) review and Station Super-intendent approval of plan' operating and surveillance procedures t
prior to implementation.
Contrary to the above, procedure review and approval requirements were not met at the site; in that the procedure used on March 12, 1975, to obtain an Air Ejector radioactive Off-Gas sample had,,not received PORC review and Station Superintendent approval; and in that eight (8) of twenty-five (25) surveillance test procedures sampled were not reviewed by PORC prior to their implementation.
This is an infraction.
RESPONSE
'Ihese specific deficiencies with respect to our procediires have been rectified. However, as noted on this and subsequent inspections, problems exist with our procedure control system. We are currently taking those necessary actions to insure that a system to control M
the use of procedures is implemented by December 15, 1975.
b.
Technical Specification 6.2.F provides that temporary procedure changes which do not change the intent of the original procedure may be made under specified circumstances which include subsequent review by PORC and approval by the Station Superintendent.
Contrary to the above, a temporary change made on January 24, 1974, to Procedure 609, was not subsequently reviewed by PORC and approved by the Station Superintendent.
1 This is an infraction.
RESPONSE
This particular deficiency has been corrected.
Further, steps have been taken to require PORC review of all temporary changes on a quarterly basis and documentation of that review is maintained by the PORC secretary.
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APPENDIX A
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c.
The Operational Quality Assurance Plan,. Revision 0, dated December j
14, 1973,Section VI, states that 1) a standard Generation Department procedure for document control includes basic generic controls to be -
i incorporated by each manager, 2) the Generation Department document control procedure requires measures to insure documents are available
,, j when required, 3) the implementing procedures, including the document "h
control procedure, should be complete and issued during April 1974, I
and 4) the Oyster Creek Superintendent is responsible for the imple-mentation of the document control system for documents received or i
prepared at the generating station.
Contrary to the above, required document control was not provided in that 1) the document control procedure, or an equivalent control over 4
as-built drawings and site issued documents was not provided as of l
March 12,1975, and 2) as-built engineering drawings were not distri-buted to the licensee's Morristown Plaza Offices where Generation j
Engineering Department personnel are regularly engaged in decision-making engineering work requiring the use of as-built drawings.
1 This is an infraction.
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RESPONSE
l With respect to as-built drawings, JCPSL is in the process of preparing the Oyster Creek drawings for microfilming.
~No original microfilms and three microfilm copies will be made of each drawing. One original set will be for safe storage, one original set and two copies will be kept in the hbrristown Plaza Document Control Center, and one copy will M
be kept in the Oyster Creek Site Document Control Center. The drawing control procedure is being prepared and will establish the drawing revision and control mechanism.
At this time, it is planned to have the drawings microfilmed and the drawing control procedures completed.
by February 16, 1976.
The control of site issued documents and its respective procedures are part of the Generation Department Document Control and Record Retention Program which is presently being established.
During the early stages of tne Quality Assurance Program implementation, it was determined that Document Control and Record Rotention are two areas which would require a significant effort to implement and should be considered as a single project.
In this light, JCPSL decided to utilize a consultant who would develop and assist JCPSL in implementing a comprehensive system of Document Control and Record Retention. During your audit in March, we were still in the conceptual stages of program development and had decided to
-delay preparing detailed procedures which may not necessarily reflect the eventual system. This did not mean that we were i
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proceeding without guidance because procedures numbered 2004 I
(Generation Department Document Control) and 2005 (Generation Department Document Retention) had been written and issued to establish a basis for our program.
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Since your inspection, JCP6L has:
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(1) Completed a master document index for indexing all documents, (2) Established a document control center at Morristown Plaza, (3) Hired a Document Control Supervisor and two clerks for Morristown Plaza, y
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(4) Established mail routing control at Morristown Plaza, (5) Started indexing documents and filing them in the Morristown 7
Document Control Center, 1
-l (6) Maintained duplicate copies for eventual transfer to the Oyster Creek Site Document Control Center, (7) Established the Technical Specifications as a controlled
- document, (8)
Initiated steps to control site procedures, (see RESPONSE to Item 4.a),
tilWei (9)
Initiated steps to establish the Document Control Center at the Oyster Creek Site.
The implementation program is progressing on an established schedule which is available to your inspectors. Morristown Plaza was chosen as the initial implementation site because of convenience and the desire to minimize difficulties at the Oyster Creek Site while the system startup problems were being resolved. Complete implement:. tion of this comprehensive program will not be achieved until late 1976 or early 1977.
S.
Criterion VII, Appendix B,10CFR50 requires establishment of measures for identification and control of materials, parts, and components to assure that identification of the item is maintained throughout installation and Section VIII of the OQAP states that the Oyster Creek Superintendent use.
is' responsible for maintaining identification and control of materials, parts, or components received, stored, installed, and used at the plant site. Procedures covering the identification and control of materials, l
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J parts, and components are prepared by the plant staff, reviewed by PORC, and approved by the Plant Superintendent. These procedures will be reviewed and concurred with by the Quality Assurance Supervisor for compliance with the OQAP. The Quality Assurance Supervisor is responsible for surveillance and audit of the implementation of these procedures by y
plant staff and by site contractors. Station Procedure 3005 states that q*'
once an item is installed or used, the " RELEASED FOR USE" tag is removed and returned to Quality Assurance who records this fact on the Material Identification and Control Sheet and destroys the tag.
Contrary to the above, " RELEASED FOR USE" tags for materials used in the Core Spray System and the Fuel Pool Filter dated February 17, 1975, were neither on the equipment nor recorded on the Material Identification and Control Sheet.
l This is a deficiency.
L*l RESPONSB i
t This deficiency is related to " Material Conformance Status" as defined in Procedure 3005. As a result of this deficiency and other difficulties in the procedure effectiveness, the procedure is being revised to more clearly define the scope and requirements associated with Material Conformance Status. *This procedure revision will be completed by December 15, 1975.*
6.
Criterion XI, Appendix B,10CFR50 requires establishment of a test program Xf*i" to assure that all testing, including operational testing, required to demonstrate that structures, systems, and components will perform satisfactorily in service is identified and performed in accordance with written test procedures which incorporate the requirements and acceptance limits contained in applicable design documents. The OQAP,Section XIV, requires,1) that maintenance testing be conducted in accordance with specifications, maintenance procedures, etc., 2) that the work performance procedures require sign off to assure that required inspections and tests are performed, 3) that the procedures be prepared and approved by the responsible organization, and 4) that the procedures be reviewed and audited by Operational Quality Assurance.
Contrary to the above, written and approved procedures which 1) defined the testing Iequired, 2) identified individuals responsible for procedure and test review, and 3) specified the required test documentation, were not provided for at least one of the routine post maintenance testing activities covered by the twelve job orders referred to in Items 1(b) and 3(b) above.
This is an infraction.
t h
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RESPONSE
Refer to the RESPONSE for Item 1.b.
7.
Criterion XV, Appendix B,10CFR50 requires establishment of measures to jpg control materials, parts, or components which do not conform to, require-ments in order to prevent their inadvertent use or installation.
Section 4,<
XV of the OQAP requires that nonconforming items found during checks of modification, maintenance or repair work be clearly identified and documented, and that supervision and management be notified so that appropriate corrective action can be taken.
In the event prompt corrective action is not taken, the QA Supervisor notifies the Manager-Operational Quality Assurance and the Oyster Creek Superintendent so that corrective action can be expedited.Section XVI of the OQAP states that corrective action procedures include provisions for evaluation of nonconformances, determination of suitable corrective action, responsibility for timely disposition and followup action, authority for approval of proposed corrective action, and the required documentation. Evaluation of a nonconformance includes consideration of the cause, other areas which could experience similar nonconformances, and solutions that would prevent a repeti-tion of the nonconformance.Section XVI also states that Operational Quality Assurance procedures include provisions to assure that corrective action and documentation are accomplished.
Contrary to the above, the Condensate Transfer System was returned to service with unresolved nonconformances involving use of backing rings gq in welded pipe joints which is not permitted by the Engineering Specifi-cations for the project (identified by licensee 10/25/74), failure to apply a protective coating before other welds are made as specified by the welding procedure (identified by licensee 10/24/74), field fit-up of a pipe section not provided for in the procedure (identified by licensee 10/24/74), cutting and rewelding a 20-foot section of pipe not covered in the procedure or in a written Engineering authori::ation (identified by licensee 10/24/74), and failure to conduct a required hydrostatic test (identified by licensee 3/8/75).
/.s of March 12, 1975, these matters had not been resolved.
This is an infraction.
RESPONSE
A1.1 outstanding nonconformances are being reviewed and actions that need be taken to resolve any of the remaining deficiencies are expected to be completed by November 28, 1975.
In those cases where the nonconformance cannot be finally resolved prior to that date, specific direction to resolve the deficiency will have been identified by that date.
In addition to addressing outstanding nonconformances, the nonconformance l
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and corrective action p16cedures are being revised to minimize administra-tive problems.which we are experiencing with the present procedures.
4 It is: intended to have this procedure revision issued by November 28, 1975.
4 8.
Section 4, Appendix A,10CFR55 requires annual written examinations of
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.y@g.9 licensed operators. The licensee's operator requalification pro, gram, approved by Reactor Licensing letter dated November 13, 1974, states that December 17, 1973 is the starting date for the annual cycle of the requalification program.
l Contrary to the above, written examinations of licensed operators were not given when required, in that none of the twenty licensed operators j
were given written examinations on or before December 17, 1974.
This is a deficiency.
RESPONSE
o All the required examinations were completed and graded prior to the 2
completion of your inspection of March 10-14, 1975.
In the future, when it is anticipated that the requirements of our Operator Requalifi-cation Program will not be met, the NRC will be so advised.
In this nocification, JCPSL will state the reasons why the requirement cannot be met and specify the date when the required action will be completed.
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