ML20129G799
| ML20129G799 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 10/23/1984 |
| From: | Belisle G, Casey Smith, Upright C, Whitcomb H NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML20129G765 | List: |
| References | |
| 50-338-84-35, 50-339-84-35, NUDOCS 8507180274 | |
| Download: ML20129G799 (22) | |
See also: IR 05000338/1984035
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UNITED STATES
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NUCLEAR REGULATORY COMMISSION
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REGION 11
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101 MARIETTA STREET, N.W.
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ATLANTA, GEORGI A 30323
'+9.....
NOV 011984
Report Nos.:
50-338/84-35 and 50-339/84-35
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Licensee:
Virginia Electric and Power Company
Richmond, VA 23261
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Docket Nos.:
50-338 and 50-339
License Nos.:
Facility Name: North Anna 1 and 2
Inspection Conducted:
September 17-21, 1984
Inspectors: 88/ [de.<_)
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G. A. Belisle
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C. F. Smit '
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Approved by:
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C. M. Upright, }pi:tig Chief
Ofte S'igned
Operations Branth
Division of Reactor Safety
SUMMARY
Scope: This routine, unannounced inspection involved 90 inspector-hours on site
in the areas of Licensee Actions on Previous Enforcement Matters; QA Program
Review; QA/QC Administration; Procurement; Receipt, Storage, and Handling; Design
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Changes and Modifications; Measuring and Test Equipment; Records; Document
Control; and Licensee Action on Previously Identified Inspection Findings.
Results: Of the ten areas inspected, no violations or deviations were identified
in eight areas; one apparent violation was found which involved two areas.
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85071B0274 841101
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ADOCK 05000338
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REPORT DETAILS
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1.
Licensee Employees Contacted
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C. Baird, Supervisor, Construction Engineering
.R. Berquist, Instrument Supervisor
- R. Bilyeu, Licensing Coordinator
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- M. Bowling, Assistant Station Manager
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L. Carter, QA/QC Training Coordinator
- R. Collins, Supervisor, QA/QC
- S. Eisenhart, Licensing Coordinator
- R. Hardwick, Manager, Nuclear Programs and Licensing
- E. Harrell, Station Manager
K. Hinkle, Project Construction Supervisor
- A. Hogg, Manager, QA
R. Hurd, Staff Engineer
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T. Johnson, QA Staff Engineer
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P. Knutsen, Supervisor, Nuclear Engineering
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F. Miller, QC Supervisor
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- M. Pinion, Engineering Supervisor
P. Quarles, QC Supervisor (M&TE)
J. Smith, QC Supervisor (Inspections, Document Control (QC Logroom) and
Warehouse)
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D. Snodgrass, Assistant Instrument Supervisor
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- F. Terminella, QC Supervisor
D. Thomas, Mechanical Maintenance Supervisor
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- J. Waddill, Executive Manager, QA
V. West, Supervisor, Planning and Support Services
Other licensee employees contacted included technicians and office
personnel.
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NRC Resident Inspector
- J.
Luehman
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- Attended exit interview
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2.
Exit Interview
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The inspection scope and findings were summarized on September 21, 1984,
with those persons indicated in paragraph 1 above. The licensee acknow-
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ledged the following inspection findings,
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Violation:
Failure to provide procedural acceptance criteria required
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by 10 CFR 50, Appendix B, Criterion V, paragraphs 7 and 10.
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Inspector Followup Item:
Procedural guidance in determining the
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requirements for conversion of Engineering Work Requests (EWRs) to
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Outside Technical Support Requests (Types 1, 2, 3, or 4) has not been
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delineated in ADM-3.7.
Additionally, procedural guidance is not
provided in the working level procedures of the group which makes the
decision as to whether or not work will be processed under the EWR
program, or the integrated design control and document control program,
paragraph 9.
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The licensee was informed of an unresolved item relating to lack of
procedural guidance for completing procurement document reviews.
Upon
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review by Region II management, this item was included in the violation
listed above.
The licensee was informed by telephone of. this action on
October 5, 1984.
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3.
Licensee Action on Previous Enforcement Matters (92702)
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(0 pen) Violation 338, 339/83-01-02:
Failure to Establish a System to
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Evaluate Equipment Failures.
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Licensee responses dated March 8,
March 17, and May 11, 1984, were
considered acceptable by Region II.
The inspector reviewed ADM 16.10,
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Class 1E Equipment Failure Analysis dated March 31, 1984, and ADM 16.16,
Equipment Failure Analysis Program dated July 19, 1984.
These procedures
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delineate the licensee failure analysis program. The inspector conducted an
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interview with the staff engineer responsible for this functional area and
was informed that he had been on this assignment for approximately three
weeks.
This program is not scheduled to be fully implemented until three
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months after program development. An informational data base is currently
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under development.
The inspector also reviewed a memo from G. Clark to
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M. Bowling dated August 22, 1984.
This memo transmitted Audit N84-34
findings relating to failure to properly implement ADM 16.10 requirements.
A response to this memo is under dnelopment. This item will be reinspected
at a later date to verify full implementation of the licensee failure
analysis program.
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4.
Unresolved Items
Unresolved items were not identified during this inspection.
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5.
QA Program Review (35701)
The references and documents mentioned throughout this report were reviewed.
Licensee procedures were verified to be in compliance with referenced
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documents.
Changes to these procedures were also verified to be in
compliance with referenced documents.
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Numerous discussions were conducted with plant personnel during inspec' ion
activities in various functional areas referenced by the inspectors. Plant
personnel were knowledgeable in their specific disciplines.
The inspector
conducted an interview with the QA/QC Training Coordinator and determined
that QA/QC personnel are being trained in various interdiciplinary
functions. This program was comprehensive and well maintained.
Personnel
records were accurate and easily retrievable.
The QA Department has undergone a reorganization. Reporting to the Depart-
ment Manager are the training staff; management staff; QA supervisor
responsible for QA engineering, auditing, and surveillance activities; QC
supervisor responsible for warehousing, design changes, maintenance, and
document control activities.
The management staff is a technical position
being filled by an SRO qualified individual. This person, due to a strong
operational background, acts as a technical advisor to QA and also has other
job functions as stated in the classification summary for this position.
Implementation was verified by performing inspections in specific areas
described in the remainder of this report.
Within this area, no violations or deviations were identified.
6.
QA/QC Administration (35751)
References:
(a)
10 CFR 50, Appendix B, Quality Assurance Requirements for
Nuclear Power Plants and Fuel Reprocessing Plants
(b) Regulatory Guide 1.33, Quality Assurance Program Require-
ments (Operations)
(c) ANSI N18.7-1976, Administrative Controls and Quality
Assurance for the Operational Phase of Nuclear Power
Plants
The inspector reviewed the licensee QA/QC administration program required by
references (a) through (c) ta verify that the program had been established
in accordance with regulatory requirements and industry guides and
standards. The following criteria were used during this review to determine
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the overall acceptability of the established program:
The QA program documents clearly identify those structures, systems,
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components, documents, and activities to which the QA program appites.
Procedures and responsibilities had been established for making changes
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to QA program documents.
Administrative controls for QA/QC procedures require review and
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approval prior to implementation, control of revisions, and control of
distribution and recall.
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Responsibilities had been established to assure overall evaluation of
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the effectiveness of the QA program.
Methods existed to modify the QA program to provide increased emphasis
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on identified problem areas.
The documents listed below were reviewed to verify that these criteria had
been incorporated into QA/QC administration activities:
VEPCO Topical, VEP-1-4A
ADM 2.1, Classification of Systems, Components, and Structures dated
July 12, 1984
NPSQAM Section 2, Quality Assurance Program dated February 1, 1984
NPSQAM Section 6, Document Control dated February 1, 1984
NPSQAM Section 16, Corrective Action dated February 1,1984
NPSQAM Section 18, Audits dated February 1,1984
QADI 1.0, Quality Assurance Department Organization dated August 25,
1983
QADI 6.0, Preparation and Control of Quality Assurance Department
Instructions dated August 25, 1983
QADI 10.1, QA Surveillance / Inspection Activities dated February 23,
1984
QADI 16.0, Corrective Action Audit Program dated October 31, 1983
QADI 18.1, Quality Assurance Audit Program dated February 29, 1984
ADM 2.1 contains a broad list of critical structures, systems, and
components (CSSC) but this list does not go into component level speciff-
city. ADM 2.1 is augmented by a more specific Class 1E electrical component
list.
This additional CSSC listing is planned to be added to ADM 2.1.
The inspector interviewed the Executive Manager QA when he was on site.
General QA activities and responsibilities were discussed.
The inspector
was informed during this interview that the licensee is planning an
indeper ent QA review by an outside contractor. This review is tentatively
arrangcd for the latter part of 1984.
Within this area, no violations or deviations were identified.
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7.
Procurement (38701)-
References: (a)
10 CFR 50, Appendix B, Quality Assurance Criteria for
Nuclear Power Plants and Fuel Reprocessing Plants
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(b)
10 CFR 50, Part 21, Reporting of Defects and Noncompliance
(c) Regulatory Guide 1.38, Quality Assurance Requirements for
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Packaging, Shipping, Receiving, Storage, and Handling of
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Items for Nuclear Power Plants
(d) ANSI N45.2.2-1972, Packing, Shipping, Receiving, Storage,
and Handling of Items for Nuclear Power Plants
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(e) Regulatory Guide 1.33, Quality Assurance Program Require-
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ments(Operations)
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(f) ANSI N18.7-1976, Administrative Controls and Quality
Assurance for the Operational Phase of Nuclear Power
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Plants
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(g) Regulatory Guide 1.58, Qualification of Nuclear Power
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Plant Inspection, Examination, and Testing Personnel
(h) ANSI N45.2.6-1978, Qualification of Inspection, Examina-
tion, and Testing Personnel
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(i) Regulatory Guide 1.123, Quality Assurance Requirements
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for Control of Procurement of Items and Services for-
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Nuclear Power Plants
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(j) ANSI N45.2.13-1976, Quality Assurance Requirements for
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Control of Procurement of Items and Services for Nuclear
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Power Plants
The inspector reviewed the licensee procurement program required by
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references (a) through (j) to determine if the program had been established
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in accordance with regulatory requirements and industry guides and
standards. The following criteria were used during this review to determine
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the overall acceptability of the established program:
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Controls had been established to assign departmental responsibilities
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for procurement activities.
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Controls had been established to identify safety-related equipment,
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supplies, consumables, and services to be procured under the QA
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program.
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Controls had been established to provide measures and assign respon-
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sibilities for the preparation, review, approval, and changes to
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Procedures had been established for qualifying and maintaining approved
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vendors, suppliers, and contractors.
Procedures had been established to assure that vendors, contractors,
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and suppliers conform to procurement and quality assurance document
requirements, industry standards and codes, and that nonconformances
are properly reported and corrected.
Controls had been established to provide for audits and surveillances
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of procurement activities.
The documents listed below were reviewed to verify that the above criteria
had been incorporated into the licensee QA program to control procurement of
safety-related items and services:
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VEPC0 Topical, 17.2.4, Procurement Document Control
NPSQAM Section 4 Procurement Document Control, Revision 3
ADM-2,1, Classification of Systems, Components, and Structures dated'
July 12, 1984
ADM-4.0, Procurement Document Control dated February 22, 1984
ADM-4.1, Purchase Requisition / Order Procedures dated January 18, 1984
ADM-4.2, Repeating Purchase Requisitions dated April 5, 1984
ADM-4.3, VEPC0 Local Draft dated March 30, 1984
ADM-4.4, Letters of Authorization dated December 21, 1983
VEPC0 Procurement Policy Manual dated June 22, 1984
S0P 8.3.1, Processing Stores Requisitions dated February 14, 1984
POP 2.8.0, Purchasing-Multiple Power Projects dated November 1, 1983
Licensing and Quality Assurance Department VEPC0 Vendors List
VEPC0 Topical Section 17.2.4 states that policies are established in the
Nuclear Power Station Quality Assurance Manual (NPSQAM) to ensure that
procurement documents reference all actions required by a supplier in
accordance with the applicable codes, specifications, and drawings. These
documents are reviewed by the QC staff to confirm accuracy and adequacy of
the quality references and requirements. Procurement documents incorporate
the design basis technical requirements including the applicable regulatory
requirements, component and material identification requirements, drawings.
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specifications, codes, industrial standards, test and inspection require-
ments, and special process instructions.
NPSQAM Section 4 delineates
responsibilities for licensee personnel relating to purchase requisitions.
Section 5.6 requires reviews to be performed by licensee personnel to assure
that accurate information is provided for purchase requisitions. ADM 4.0
expands responsibilities for licensee personnel relating to purchase
requisitions. The inspector interviewed licensee personnel responsible for
purchase requisitions.
The inspector interviewed six construction personnel in the following
positions:
Project Construction Supervisor
Supervisor, Construction Engineering
Senior Specialist (2)
Staff Engineer
Electrician, Material Control
These personnel translate design change material lists into purchase
requisitions. When submitted to the purchasing department, these purchase
requisitions are translated into purchase orders for material requisition.
Four personnel interviewed represented civil, mechanical, and electrical
disciplines. When a design change is formulated and sent to construction, a
parts list is included for all material required to complete the design
change. This material parts list includes QA categories for equipment to be
purchased and applicable specifications for this material.
Construction
personnel do not classify or specify material to be purchased.
If this
information is not included in the design package, construction personnel
resolve questions with design engineering personnel prior to generating
purchase requisitions.
The inspector interviewed a procurement coordinator to determine how QA
categories are assigned and specifications are delineated.
For repeating
requisitions, this information is already established.
For non-repeating
requisitions, this information is provided by cognizant supervisors or the
material coordinator.
The inspector interviewed licensee engineering personnel to determine how
purchase requisition cards were evaluated for QA Category assignment and how
accurate material specifications were delineated.
The inspector also
interviewed QA personnel to determine how QA aspects of purchase requist-
tions were reviewed.
In all interviews conducted, licensee personnel were
knowledgeable in their task functions.
Personnel were assigned in these
positions based on previous experience and knowledge.
However, in all
interviews, procedures could not be produced that described these reviews.
The inspecter recognizes that due to a large purchase requisition volume
(approximately 10-15,000 per year), individual procedures for each different
type of material would be impractical.
However, a generic type procedure
would assure a uniform review by all personnel involved.
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Within this area, one item contributing to a violation was identified.
Criterion V requires that procedures include
appropriate quantitative or qualitative acceptance criteria for determining
that important activities have been satisfactorily accomplished.
The
licensee procurement procedures do not contain acceptance criteria relating
to the scope, depth, or basis for each group's review of purchase requisi-
tions.
This example and others identified in paragraph 10 constitute a
violation (338, 339/84-35-01).
8.
Receipt, Storage, and Handling of Equipment and Materials (38702)
References:
(a)
10 CFR 50, Appendix B, Quality Assurance Criteria for
Nuclear Power Plants and Fuel Reprocessing Plants
(b)
10 CFR 50, Part 21, Reporting of Defects and Noncompliance
(c) Regulatory Guide 1.38, Quality Assurance Requirements
for Packaging, Shipping, Receiving, Storage, and Handling
of Items for Nuclear Power Plants
(d) ANSI N45.2.2-1972, Packaging, Shipping, Receiving,
Storage, and Handling of Items for Nuclear Power Plants
(e) Regulatory Guide 1.33, Quality Assurance Program Require-
ments (Operations)
(f) ANSI N18.7, Administrative Controls and Quality Assurance
for the Operational Phase of Nuclear Power Plants
(g) Regulatory Guide 1.58, Qualification of Nuclear Power
Plant Inspection, Examination, and Testing Personnel
(h) ANSI N45.2.6-1978, Qualification of Inspection, Examina-
tion, and Testing Personnel
The inspector reviewed the licensee receipt, storage, and handling program
required by references (a) through (h) to determine if the program had been
established in accordance with regulatory guides and industry guides and
standards. The following criteria were used during this review to determine
the overall acceptability of the established program:
Controls had been established for conducting and documenting receipt
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inspections and reporting nonconformances.
Controls had been established for item disposition marking, storing,
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and protection of items during storage.
Controls had been established for limited shelf life items and for
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performing audits and surveys of storeroom activities,
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Controls had been established for qualification of inspection
personnel.
Controls had been established for item conditional release.
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Controls had been established for item storage.
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Controls had been established for item handling.
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The documents listed below were reviewed to verify that the above criteria
had been incorporated into the licensee QA program to control receipt,
storage, and handling of equipment and materials:
VEPC0 Topical, 17.2.7, Control of Purchased Material, Equipment, and
Services
VEPC0 Topical, 17.2.13, Handling, Storage, and Shipping
NPSQAM Section 7, Control of Purchased Materials, Equipment, and
Services, Revision 2
NPSQAM Section 13, Handling, Storage, and Shipping, Revision 2
ADM-7.0, Control of Purchased Materials, Equipment, and Services -
Receipt Phase dated March 31, 1983
ADM-8.0, Identification and Control of Materials, Parts, and Components
dated June 7, 1984
ADM-8.1, Control of Consumable Material dated February 29, 1984
ADM-13.0, Handling, Storage, and Shipping dated April 5, 1984
ADM-13.1, Maintenance of Items in Storage dated June 23, 1983
ADM-13.2, Shelf Life Program dated June 7, 1984
ADM-13.3, Use of Operating Station Stores Facilities and Services dated
November 2, 1983
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ADM-13.4, Field Staging and Control of Category 1 Materials dated
February 15, 1984
ADM-13.5, Material Control for Appendix R Repairs dated July 26, 1984
QADI 10.1, QA Surveillance / Inspection Activities' dated February 23,
1984
SOP 8.12.0N, Material Control dated December 16, 1983
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S0P 8.12.1N, Field Staging and Control for Category I Material dated
December 6, 1983
S0P 8.12.2N, Issue of Material dated December 16, 1983
SOP 8.12.3, Inventory Control dated December 17, 1984
S0P 8.12.6N, Material Identification dated February 22, 1984
S0P 8.12.7N, Shelf Life Program dated February 23, 1984
S0P 8.12.8, Material Shipping and Receiving dated June 20, 1984
S0P 8.12.9, Material Storage dated December 16, 1983
S0P 8.12.10, Discrepant Shipment Reports dated January 10, 1984
POP 2.9.2, Inventory Procedure Multiple Power Projects dated August 3,
1981
The inspector conducted a tour of three warehouses (5, 7, and 10) where
items are stored for plant use. Warehouse 10 is specifically used by site
construction personnel.
During the warehouse tour, the inspector randomly
selected various material and verified storage requirements.
The inspector
verified preventive maintenance requirements for several large pumps
(electrical elements heated and shafts periodically rotated) for material in
storage for Units 3 and 4.
This material was awaiting disposition.
The
inspector verified Level A storage requirements for those items classified
Level A by the licensee.
Both warehouses 5 and 10 had designated hold
areas.
The inspector selected five items in the warehouse 5 hold area to
determine why the material was on hold.
The following five items were
selected: PO N 10119, 10143, 09363, 07163, and 07787. These items were on
hold due to lack of specified documentation (two were missing Certificates
of Conformance, one needed a Certified Material Test Report, and the
remaining two were missing shelf life information). These items were being
handled in accordance with existing program requirements.
Within this area, no violations or deviations were identified.
9.
Design Changes (37702)
References:
(a)
10 CFR 50, Appendix B, Quality Assurance Criteria for
Nuclear Power Plants and Fuel Reprocessing Plants
(b) Regulatory Guide 1.64, Quality Assurance Requirements for
the Design of Nuclear Power Plants, Revision 2
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(c) ANSI N45.2.11-1974, Quality Assurance Requir'ements for
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the Design of Nuclear Power Plants
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(d) Regulatory Guide 1.33, Quality Assurance Requirements
(Operations), November 1972
(e) ANSI N18.7-1976, Administrative Controls and Quality
Assurance for the Operational Phase of Nuclear Power
Plants
(f) Technical Specifications, Section 6, Administrative
Controls
(g) Regulatory Guide 1.120, Fire Protection, Guidelines for
Nuclear Power Plants, Revision 1
The inspector reviewed the licensee design change program required by
references (a) through (g) to determine that the program had been estab-
lished in accordance with regulatory requirements, industry guides and
standards, and approved Technical Specifications. The following criteria
were used during the review to determine the overall acceptability of the
established program:
Procedures have been established to control design changes which
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include assurance that a proposed change does not involve an unreviewed
safety question or a change in technical specifications as required by
Procedures and responsibilities for design document control have been
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established including responsibilities and methods for conducting
safety evaluations.
Administrative controls for design document control
have been
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established for the following:
Controlling changes to approved design change documents
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Controlling or recalling obsolete design change documents such as
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revised drawings and modification procedures
Release and distribution of approved design change documents
.
Responsibilities have been assigned in writing to assure implementation
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of the release and distribution of approved design change documents.
Administrative controls and responsibilities have been established
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commensurate with the time frame for implementation to assure that
design changes will be incorporated into:
Plant procedures
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Operator training programs
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Plant drawings to reflect implemented design changes and
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modifications
Design controls require that implementation will be in accordance with
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approved procedures.
Design controls require assigning responsibility for identifying
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post-modification testing requirements and acceptance criteria in
approved test procedures and for evaluation of test results.
Procedures assign responsibility and delineate the method for reporting
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design changes to the NRC in accordance with 10 CFR 50.59.
Controls require review and approval of temporary modifications in
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accordance with Section 6 of the Technical Specifications and 10 CFR 50.59.
The documents listed below were reviewed to verify that these criteria had
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been incorporated into the licensee design change program:
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VEPC0 Quality Assurance Topical Report, VEP-1-4A, Quality ' Assurance
Program Operations Phase, through Amendment 4
Nuclear Power Station Quality Assurance Manual (NPSQAM).
Section 3.0, Design Control, Revision 3
Section 16.0, Corrective Action, Revision 3
Station Administrative Procedures
ADM-3.1, Control of Design Change Implementation dated May 23,
1984
ADM-3.7, Engineering Work Request dated May 29, 1984
ADM-3.8, Design Input Procedure dated February 22, 1984
ADM-3.9, Evaluation for Potential Unreviewed Safety Questions
dated May 17, 1984
1
ADM-1.1, Station Nuclear Safety and Operating Committee dated
April 5, 1984
ADM-1.2, Safety Engineering Staff
VEPC0 Nuclear Design Control Interface Manual (NDCIM)
NDCIM-1, PO-PSE&C Project Interface Procedure, Revision 1
NDCIM-2, Standard Instructions for Design Change Packages,
Revision 1
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NDCIM-3, Integrated CesignL ontrol and D'ocum nt' Control Program
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for VEPC0 Nuclear N wer Stations, PO-PSE&C Interface
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Procedure,Revijion1
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NDCIM-4, Processing of Design Control Documents, Revision 1
NDCIM-5, Nuclear C;erations - Engineering and Construction
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Document at:d Drawing Control Interface Procedure,
Revision 1
NDCIM-6, N0D-PSE Interface Procedures for Drawing Update Program,
Revision 1
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Engineering and Construction Nuclear Design Control Program Manuals,
Volumes I and II.
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Section 1.0, Organization, Revision 1
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Section 2.0, Program Plan, Revision 1
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Section 3.0, Design Input, Revision 1
Section 4.0, Design Process, Revision 1
Section 5.0, Design Verification, Revision 1
Section 6.0, Docun,ent Control, Revision 1
Section 7.0, Design Change Control, Revision 1
Section 8.0, Interface Control, Revision 1
The inspector reviewed licensee administrative and design control procedures
and conducted interviews with_ licensee management to determine the; status of
the design change program. The inspector determined that responsibility for
providing design engineering sWport to the cperating stations has been
assigned to Power Station Engineering (PSE).
A Site Engineering Office
(SEO) provides design engineering support within the limit of its resources
and acts as an interface with Power Operations for outside technical
(architect / engineering) support. Nuclear Design Control Interface Manual
procedure NDCIM-1 delineates the requirements for the provision of design
engineering support by PSE and categorizes the levels of support ~as follows:
Type 1 - Engineering assistance from PSE as requested by Power
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Operations.
It may include specific tasks, problem
evaluation, or feasibility study.
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Type 2 - A potential station project requiring.evalua' tion and
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conceptual engineering.
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Type 3 - A defined and approved station project requiring engineering,
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procurement, and/or construction.
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Type 4 - A project requiring Power Station Construction (PSC) procure-
ment and/or_ construction support only.
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The inspector determined that design engineering activities for the nuclear
power stations are conducted under the Integrated Design Control and
Document Control Program.
The requirements of this integrated program are
delineated in the NDCIM which provides a single source reference and means
of control for procedures which govern design contrcl and document control
interfaces of licensee organizations.
The inspector reviewed the Engineering and Construction Nuclear Design
Control Program Manuals, Volumes I and II, to assure that design activities
are carried out in a planned, controlled, orderly, and correct manner. The
ir.spector verified that program procedures have been prepared which
addresses the requirements of ANSI N45.2.11-1974. Additionally, require-
ments for the preparation of working level implementing procedures;
i.e.,
departmental design control and document control procedures, have been
delineated in writing.
The inspector reviewed the programmatic controls applicable to activities
performed in the preparation of an Engineering Work Request (EWR).
Administrative procedure ADM-3.7 is the controlling procedure for these
activities and defines the purpose of the EWR program as follows:
Documentation by Power Operations of requests for Engineering Services
support
Prioritization of the request
Documentation of a controlled resolution to the request.
Depending on the nature of the request for engineering support, an EWR can
result in plant activities that do not require the support of PSE or it
could conceivably result in a request to PSE for either types 1, 2, 3, or 4
engineering support.
The Engineering Design Control group is assigned
responsibility for the review and determination of whether an EWR is
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adequate or if a Design Change, a Setpoint Change, or Engineering Study is
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required.
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The inspector interviewed licensee management concerning the updating of
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drawings impacted by design changes and reviewed the following documents:
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Memorandum from E. W. Harrel to Mr. W. L. Stewart dated May 26, 1983,
Subject:
Backlog of Design Change Package Completion
Memorandum from E. W. Harrel to Mr. W. L. Stewart dated September 14,
1984, Subject:
Design Change Close-Out Status
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The inspector determined that the SEO provides drafting support necessary
for updating drawings impacted by design changes. Based on the inspector's
observations and discussions with licensee management, the drawing update
program appears to be adequately implemented.
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Within this area, an inspector followup item was identified involving
procedural guidance for converting EWRs to requests for outside technical
support. Administrative procedure ADM-3.7 is the controlling procedure for
processing EWRs and delineates programmatic controls applicable from the
recognition of a condition which requires engineering services support to
the final disposition of the request as documented by the EWR. ADM-3.7
states that the EWR is the specific task that is to be accomplished to
create or to establish the condition of a predetermined goal.
It further
adds that the intent can be defined as follows:
The demonstration of operability or level of operability by estab-
lishing system or component performance acceptance criteria
The proper sequencing of activities that would affect the satisfactory
completion of the task
The specific actions that must be accomplished to assure satisfactory
completion of the task
Depending on the nature of the condition for which engineering services
support is required, an EWR can result in a design modification.
The
integrated design control program assigned PSE the responsibility for
providing "Outside Technical Support." This support consists of any outside
services related to or in support of Design Engineering and has been
categorized as type 1, 2, 3, or 4 support.
ADM-3.7 fails to delineate programmatic controls which provide adequate
quantitative and/or qualitative guidance in the determination of when an EWR
should be converted to a Type 1, 2, 2, or 4 support request to PSE.
Additionally, quantitative or qualitative guidance is not delineated in
working level procedures of the group assigned responsibility for making
this decision.
Licensee management agreed that a programmatic deficiency exists and
informed the inspector that this problem had been previously identified by
VEPC0 personnel.
Corrective action is currently being developed to resolve
this deficiency.
Until the licensee provides appropriate instructions or
procedures which ensure that EWRs are correctly converted to Outside
Technical Support Request (Types 1, 2, 3, or 4) for work performed under the
Integrated Design Change program, this is identified as an Inspector
Followup Item (338, 339/84-35-02).
10. Measuring and Test Equipment (61724)
References:
(a)
10 CFR 50, Appendix B, Quality Assurance Criteria for
Nuclear Power Plants and Fuel Reprocessing Plants
(b) Regulatory Guide 1.33, Quality Assurance Requirements
(Operations), Revision 2, February 1978
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(c) ANSI N18.7-1976, Administrative Controls and Quality
Assurance for the Operational Phase of Nuclear Power
Plants
(d) Technical Specifications (TS)
The inspector reviewed the licensee measuring and test equipment (M&TE)
program required by references (a) through (d) to verify that the program
had been established in accordance with regulatory requirements, industry
guides and standards, and Technical Specifications. The following criteria
were used during this review to determine the overall acceptability of the
established program:
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Criteria and responsibility for assignment of the calibration / adjust-
ment frequency have been established.
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An equipment inventory list has been prepared which identifies equip-
ment used on safety-related structures, systems, or components and
calibration frequency of each piece of equipment.
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Requirements exist for marking the latest calibration date on each
piece of equipment or otherwise identifying the status of calibration.
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A system has been provided for assuring that equipment is calibrated
before the date required.
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Requirements have been established which prohibit use of equipment
which has not been calibrated within the prescribed frequency and
describes controls to prevent the inadvertent use of such equipment.
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Calibration controls have been established which require evaluation of
the cause and the acceptability of items calibrated when a piece of
M&TE fails calibration.
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New equipment will be added to the inventory list and calibrated prior
to being placed in service.
The following documents were reviewed to verify that these criteria had been
incorporated into the licensee's administrative procedures for M&TE
activities:
ADM-5.14, Calibration Procedure Format dated January 11, 1984
ADM-12.0, Control of Measuring and Test Equipment dated August 23, 1983
ADM-12.1, Measuring and Test Equipment Calibration Program dated
July 12, 1984
ADM-6.18, Control of Vendor Manuals, Vendor Files, and Interface dated
August 2, 1984
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ADM-2.1, Classification of Systems, Components, and Structures dated
July 12, 1984
NPSQAM Section 12, Control of Measuring and Test Equipment, Revision 2
QADI 2.4, Attachment 6.3, Training Plan and Qualification Record:
Measuring and Test Equipment Evaluation, Revision 0
QA Audit N-83-24, Measuring and Test Equipment dated April 12, 1983
Quality Control Inspection Report IR-N-84-506 dated July 6, 1984
NQC Test Equipment Listing dated June 19, 1984
Mechanical NQC Instruments - October Recall List dated September 19,
1984
VEP-1-4A, Topical Report - QA Program Operations Phase, Amendment 4
The inspector reviewed the licensee NQC test equipment list (dated June 19,
1984) which identifies all M&TE by NQC number, equipment description, model
number, serial number, calibration frequency, and the current calibration
-status. The following 16 individual items were evaluated to ensure that the
current status was accurately indicated, equipment in the " restricted" or
"no calibration required" categories were appropriately labeled, and that
approved calibration procedures were written in the format prescribed by
licensee administrative procedures.
NGC #
NGC #
003
542
028
584
106
1044
150
1094
197
1188
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244
1204
445
6288
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498
6402
The inspector interviewed the Instrument Supervisor responsible for the M&TE
program to verify that the program was being implemented in accordance with
the Measuring and Test Equipment Calibration Program (ADM-12.1). Interviews
were also conducted with QC supervisory personnel assigned specific
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responsibilities in the M&TE program. Based on this programmatic review and
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interviews with licensee representatives, the existing procedural guidelines
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specified in licensee administrative procedures do not fully comply with the
requirements of an M&TE program as required by references (a) through (d).
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Within this area, several items contributing to a violation were identified.
10 CFR 50, Appendix B, Criterion V states that procedures shall include
appropriate quantitative or qualitative acceptance criteria for determining
that important activities have been satisfactorily accomplished. Acceptance
criteria have not been specifically delineated in ADM-12.1 in the following
areas:
a.
Paragraph 3.1 states that the calibration interval of measuring and
test equipment may be varied, based on experience and failure rate of
like devices, with the concurrence of the Supervisor-Quality Control
and the cognizant Supervisor. The criteria by which the Supervisor-QC
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or the cognizant Supervisor arrives at their concurrence is not
specifically described in this procedure.
b.
Paragraph 5.1 of ADM-12.1 states that devices whose calibration
interval is designated as prior to use and are in continuous use will
be calibrated every 30 days or less as determined by the Supervisor-
Quality Control.
Due to the absence of specific procedural guidance,
interviews with supervisory personnel in both the quality control and
instrument departments indicate that each group would control items in
this category by different methods.
c.
Paragraphs 8.6 and 9.1 collectively require the Supervisor-Quality
Control to review the notice of instrument restriction and cause an
evaluation to be performed concerning the validity of tests and
measurements conducted since the last calibration for instruments whose
calibrat. ion was not within the established limits when presented for
calibration. Qualitative or quantitative acceptance criteria used as
the basis for this evaluation is not specifically described in this
procedure.
In the event that an evaluation is made to repeat tests
with questionable validity, specific guidance is not prescribed which
requires an evaluation of the safety significance or reportability of
the problem.
d.
Paragraph 9.3 requires that for instruments consistently found out of
calibration (two of the past three calibrations), an attempt will be
made to determine the cause of the failures and appropriate action
taken. Qualitative or quantitative acceptance criteria to be used as
the basis for this determination, the corrective action, and the plant
group responsible for this action are not specifically described in
this procedure.
These examples of failure to include appropriate quantitative or qualitative
acceptance criteria as discussed above and in similar examples discussed in
paragraph 7 constitute a violation (338, 339/84-35-01).
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11.
Records (39701)
References:
(a)
10 CFR 50, Appendix B, Quality Assurance Criteria for
Nuclear Power Plants and Fuel Reprocessing Plants
(b) Regulatory Guide 1.88, Collection, Storage, and Mainte-
nance of Nuclear Power Plant Quality Assurance Records,
Revision 2, October 1976
(c) ANSI N45.2.9-1974, Requirements for Collection, Storage,
and Maintenance of Quality Assurance Records for Nuclear
Power Plants
(d) Regulatory Guide 1.33, Quality Assurance Requirements
(Operations), Revision 2, February 1978
(e) ANSI N18.7-1976, Administrative Controls and Quality
Assurance for the Operational Phase of Nuclear Power
Plants
(f) Technical Specifications (TS)
The-inspector reviewed the licensee records program required by references
(a) through (f) to veri fy that this program had been established in
accordance with regulatory requirements, industry guides and standards, and
Technical Specifications.
The following criteria were used during this
review to determine the overall acceptability of the established program:
Requirements and provisions have been established to maintain the QA
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records required by references (a) through (f).
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Responsibilities have been assigned to assure that these records will
be maintained.
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Record storage controls have been established which describe the record
storage facility, designate a storage facility custodian, describe a
filing system to be used in the retrieval of records, describe a method
for verifying that records received are in agreement with the trans-
mittal document or a pre-established record checklist, describes
provisions for governing access to files, and establishes methods for
correcting or filing supplemental information including the designation
of required reviews and approvals.
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Retention periods for required QA records have been established.
Responsibilities have been assigned for establishing the retention
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periods of records not covered by references (a) through (f).
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Authority, responsibility, and methods for disposal of superceded
records has been specified.
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The following documents were reviewed to verify that these criteria had been
incorporated into licensee administrative procedures for the established
records programs:
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ADM-6.5, Completing and Forwarding Documents to Station Records dated
June 21, 1984
ADM-17.4, Record Control and Retrieval dated March 31, 1983
ADM-17.3, filing System dated August 9, 1984
NPSQAM Section 17, Records
The review of the licensee administrative procedures indicates that
sufficient programmatic measures have been established to satisfy the
requirements specified by references (a) through (f).
Although the
inspector's review was primarily concerned with assessing the programmatic
adequacy of the established program, interviews with several licensee
representatives indicate that the actual implementation of the program
closely follows the established station administrative guidelines. Based ~on
this review, the established records program appears to be adequate.
Within this area, no violations or deviations were identified.
12.
Document Control (39702)
R,eferences:
(a)
10 CFR 50, Appendix B, Quality Assurance Criteria for
Nuclear Power Plants and Fuel Reprocessing Plants
(b) Regulatory Guide 1.33, Quality Assurance Requirements
(Operations), Revision 2, February 1978
(c) ANSI N18.7-1976, Administrative Controls and Quality
Assurance for the Operational Phase of Nuclear Power
Plants
-(d) Technical Specifications (TS)
The inspector reviewed the licensee document control program required by
references (a) through (d) to verify that the program had been established
in accordance with regulatory requirements, industry guides and standards, and
Technical Specifications.
The following criteria were used during this
review to determine the overall acceptability of the established program:
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Administrative controls have been established which require current
as-built drawings to be provided to the plant site in a timely manner,
provide for the control of obsolete drawings, ensure that discrepancies
found between as-built drawings and the as-constructed facility are
handled as design changes, and assign responsibilities to ensure that
these activities are implemented.
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Master indices are being maintained for drawings, manuals, Technical
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Specifications, FSARs, and procedures which indicate the current
revision.
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Measures are established that provide a mechanism for the issuance and
distribution of controlled documents, require periodic reviews, and
assign responsibility to ensure that these activities are implemented.
The following docum'ents were reviewed to verify that these criteria had been
incorporated into the licensee's administrative procedures for the
established document control program:
ADM-6.1, Document Control dated March 31, 1983
ADM-6.2, Controlled Documents dated July 26, 1984
ADM-6.3, Control Levels for Distribution of Controlled Documents dated
March 31, 1983
ADM-6.4, " Controlled Document" Holders Responsibilities dated March 31,
1983
ADM-6.5, Completing and Forwarding Documents to Station Records dated
June 21, 1984
NPSQAM Section 6, Document Control
DCM-75, Manufacturer Technical Manuals and Drawing Control
The inspector reviewed the established measures to ascertain that the
document control administrative procedures satisfy the criteria specified in
references (a) through (d).
Based on this review, it appears that
sufficient controls have been established to meet regulatory requirements.
Within this area, no violations or deviations were identified.
13.
Licensee Actions on Previously Identified Inspection Findings (92701)
(0 pen) Inspector Followup Item 338/84-14-01, 339/84-13-01: Clarification of
Valve Tests and Inspection Requirements.
The inspector discussed this item with the cognizant maintenance supervisor.
Immediate corrective action for several inspector concerns had been taken
but all concerns were not addressed.
Long term corrective action was
scheduled by the licensee for completion by the end of September 1984. This
item will be reinspected upon completion of the long term corrective action.
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