ML20133D454
| ML20133D454 | |
| Person / Time | |
|---|---|
| Site: | North Anna  |
| Issue date: | 11/30/1984 |
| From: | Stewart W VIRGINIA POWER (VIRGINIA ELECTRIC & POWER CO.) |
| To: | James O'Reilly NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| References | |
| 656, NUDOCS 8507220209 | |
| Download: ML20133D454 (6) | |
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VIHOINIA ELucritIc AND POWElt CO>IIUNY llICIIMOND, VIItO IN IA C O 2 61
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W.L.srnwaar Vara Pammansw,
November 30, 1984 Nt' CLEAR oruB4Taons Mr. James P. O'Reilly Serial No. 656 Regional Adninistrator N0/JHL:acm Region II Docket Nos. 5 - 3 U. S. Nuclear Regulatory Commission 50-339 101 Marietta Street, Suite 2900 License Nos. NPF-4 Atlanta, Georgia 30323 NPF-7
Dear Mr. O'Reilly:
We have reviewed your letter of November 1,
1984 in reference to the inspection conducted at North Anna Power Station between September 17, 1984 and September 21, 1984 and reported in IE Inspection Report Nos. 50-338/84-35 and 50-339/84-35. Our response to the specific infraction is attached.
We have determir.ed that no proprietary information is contained in the report.
Accordingly, the Virginia Electric and Power Company has no objection to this inspection report being made a matter of public disclosure.
The information contained in the attached pages is true and accurate to the best of my knowledge and belief.
Very truly yot rs, l
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4*h6 f, W. L. Stewart /
Attachment cc:
Mr. Richard C. Lewis, Dircctor Division of Project and Resident Programs Mr. James R. Miller, Chief Operating Reactors Branch No. 3 Division of Licensing Mr. M. W. Branch NRC Resident Inspector North Anna Power Station i\\
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Att.tchcant Pega 1 1
Serial No. 656 l
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-338/84-35 AND 50-339/84-35 NRC COMMENT:
10 CFR 50 Appendix B Criterion V and the licensee QA Program VEP-1-4A Section 17.2.5 collectively require that, for activities affecting quality, procedures shall include appropriate quantitative or qualitative acceptance criteria for determining that important activities have been satisfactorily accomplished.
Contrary to the above, management controls had not been established which ensure that appropriate quantitative or qualitative acceptance criteria are provided in all procedures controlling safety-related activities.
The following examples involve controlling procedures which require decisions and actions affecting quality but did not describe or reference criteria needed to accomplish these important activities.
ADM 12.1, Measuring and Test Equipment Calibratien Program, dated a.
July 12, 1984 (1)
Paragraph 3.1 did not specify criteria by which the cognizant supervisor or Supervisor-Quality Control may change calibra-tion intervals.
(2)
Paragraph 8.6 and 9.1 did not specify criteria by which the Supervisor-Quality Control takes action on M&TE failing calibration and evaluates the validity of tests and measure-ments conducted since the last acceptable calibration.
(3)
Paragraph 9.3 did not specify criteria for conducting retests of systems or components.
The procedure did not require evaluation of the safety significance and reportability of systems or components that may be out of the required operat-ing range.
Criteria was not provided for the evaluation and final disposition of M&TE consistently failing calibration.
b.
ADM 4.0, Procurement Document Control, dated February 22, 1984 Neither this procedure noy any other procedure cpecified criteria which delineated how procurement document reviews were performed by construction personnel, procurement coordinators, site engineering personnel, or QA/QC personnel.
This is a Severity Level IV violation (Supplement I).
I b
Attachment Page 2 4
Serial No. 656 N
i RESPONSE TO NOTICE OF VIOLATION 3
INSPECTION REPORT NOS. 50-338/84-35 AND 50-339/84-35
RESPONSE
(1) ADMISSION OR DENIAL OF THE ALLEGED VIOLATION:
The content of the controlling administrative procedures for measuring y'
and test equipment (M&TE) cited as examples in the Notice of Violation is correct as stated.
However, Vepco believes that adequate management controls to ensure that quantitative or qualitative acceptance criteria, l
appropriate t_o the circumstances, have already been provided in the procedures.
It has been our policy to take advantage of the experience and judgement of the responsible supervisor and the assigned reviewer and the strengths of the review processes in lieu of highly specific acceptance criteria.
This has been regarded as an acceptable policy in previous compliance inspections.
Moreover, there have been no detected failures as a result of this policy.
Specific comments are provided below:
a.(1) " Paragraph 3.1 did not specify criteria by which the Cognizant Supervisor or Supervisor-Quality Control may change calibration intervals."
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!3 Comment 3
'i The criteria are somewhat subjective and are based on the failure rate of like devices.
The decision to change calibration intervals requires the concurrence of both the i
Cognizant Supervisor and Supervisor-Quality Control and i
because of the experience level, required by their position, T
they are qualified to make that judgement.
Also, further guidance is given in Paragraph 9.3 which specifies that appropriate acticn be taken when two (2) of the past three (3) calibrations of M&TE is found to be out of tolerance.
a.(2) " Paragraph 8.6 and 9.1 did not specify criteria by which the
'5 Supervisor-Quality Control takes action on M&TE failing calibration and evaluates the validity of tests and j
measurements conducted since the last acceptable calibration."
Comment C
Paragraph 8.6 addresses the notification process rather than the out-of-calibration evaluation process.
It provides i
guidance for routing notices of Instrument Restrictions.
However, Paragraph 8.7 gives criteria for initiating a a
" Record of Evaluation" form for any instrument not found within its specified tolerance when presented for j
I calibration.
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Prg2 3 Serial No. 656 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS.- 50-338/84-35 AND 50-339/84-35 Whenever a " Record of Evaluation" is received by the Supervisor-Quality Control an evalaation is initiated concerning the validity of test and measurements conducted since its last calibration as specified in Paragraph 8.7 and 9.1.
a.(3) " Paragraph 9.3 did not specify criteria for conducting retests of systems or components.
The procedure did not require evaluation of the safety significance and reportability of systems or components that may be out of the required operating range.
Criteria was not provided for the evaluation and final disposition of M&TE consistently failing calibration."
Comment The criteria used for conducting retest are based on the experience and training of the evaluator.
In addition, the Supervisor-Quality Control determines the final disposition of the evaluation which ensures adequate management controls.
When retest is performed as recommended by the evaluation it will identify systems or components that were outside the required operating range, other management controls (ADM-16.1 i
" Station Deviation Reports") are in place to evaluate the significance and reportability of these events.
The last j
sentence of Paragraph 9.3 states:
"If it is found a record of evaluation was required on two (2) of the three (3) past calibrations, an attempt will be made to determine the cause I
of the failures, and appropriate action taken."
Appropriate action is determined by the Supervisor-Quality Centrol and the Cognizant Supervisor and may consist of deleting the instrument from the NQC program in accordance with Paragraph 13.0, increasing the frequency of calibration in accordance with Paragraph 3.1 or restricting its use in accordance with Paragraph 8.5.
In addition to the above discussion, Reg. Guide 1.33, February 1978 Appendix A Paragraph 8.a states: " Procedures
.of a
type appropriate to the circumstances should be provided...."
VEP-1-4A also states:
"... appropriate quantitative and qualitative acceptance. criteria..."
are required.
It has been judged that existing procedures are
" appropriate to the circumstances." This is supported by the fact that no physical deficiencies with M&TE have been identified, nor have adverse plant conditions been attributed to poor M&TE controls.
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Serial No. 656 j
RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-338/84-35 AND 50-339/84-35 b.
ADM-4.0, Procurement Document Control, dated February 22, 1984 "Neither this procedure nor any other procedure specified criteria which delineated how procurement document reviews were performed by construction personnel,- procurement coordinators, site engineering personnel. or QA/QC personnel."
Comment The Procurement Document. Review Program governed by-ADM-4.0 is
.a very subjective activity..
Experience has shown that each ' procurement is somewhat unique which causes the review process to be a
very
" knowledge related" function.
Those criteria that are common to all procurements are specified in the. NPSQAM section. 4 and ADM-4.0.
Other criteria must be integrated from many : sources which vary depending on the "end use" of the item to be procured.
This cannot be proceduralized in a meaningful way.
The individuals involved must be trained and' experienced in order to
. conduct procurement reviews. 'The specific strength of this activity-is in the ' number of reviews conducted by the organizations holding the
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expertise to ensure the highese quality product.
(2)' REASONS FOR VIOLATION:
.Not Applicable (3) CORRECTIVE STEPS WHICH HAVE BEEN TAKEN AND THE RESULTS ACHIEVED:
Not Applicable
- (4)' CORRECTIVE STEPS WHICH WILL BE TAKEN TO AVOID FURTHER VIOLATIONS:
To prevent further concerns and to clearly emphasize the strengths of our activities, the following getions-have been undertaken:
(a) There are existing plans to upgrade the training and procedural l
controls within the QA' Department.in 1985..QA Department activities
.have been divided into 104. separate disciplines. M&TE Monitoring and Procurement Document Review are each included in these disciplines.
It is intended to develop training and certification' requirements for each -discipline.
It:. is further intended.to develop ~ individual activity checklists-for each discipline.where appropriate. This will enhance the present capability to perform QA/QC functions.
(b)'An evaluation will be made - by the QA Department to determine if additional qualitative guidelines can be added to ADM 12.1.
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Serial No. 656 RESPONSE TO NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-338/84-35 AND 50-339/84-35 (c). Qualitative guidelines to ' facilitate implementation of ADM 4.0 will be developed and implemented by the Engineering Department.
(5) THE DATE WHEN FULL COMPLIANCE WILL BE ACHIEVED:
.The additional items identified in (4) above will be implemented by December, 1985 for item (4a), and March 31, 1985 for items (4b) and (4c).
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