ML19273B531
| ML19273B531 | |
| Person / Time | |
|---|---|
| Site: | Brunswick  |
| Issue date: | 02/16/1979 |
| From: | Ashenden M, Kellogg P, Ruhlman W NRC OFFICE OF INSPECTION & ENFORCEMENT (IE REGION II) |
| To: | |
| Shared Package | |
| ML19273B523 | List: |
| References | |
| 50-324-79-02, 50-324-79-2, 50-325-79-02, 50-325-79-2, NUDOCS 7904090072 | |
| Download: ML19273B531 (28) | |
See also: IR 05000324/1979002
Text
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UNITED STATES
NUCLEAR REGULATORY COMMISSION
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Report Nos. . 50-324/79-2, 50-325/79-2
Licensee: Carolina Power and Light Company
336 Fayetteville Street
Raleigh, North Carolina
27602
Facility Name: Brunswick Steam Electric Plant, Units 1 and 2
Docket Nos. : 50-324, 50-325
Inspection at Brunswick ite near Southport, North Carolina
Inspectors:
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W. A. Ruhlman
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M. C. Ashenden
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H. D. Jenkitis
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J. A. Mcdonald, Jr. [
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Accompanying Personnel:
P. J. Kellogg
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Approved by:
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P. J. Kellogg, Secgion Chief, RONS Branch
Date ' Signed
SUMMARY
Inspection on January 8-12 and 15-16,1979
Areas Inspected
This routine announced inspection involved 158 inspector-hours onsite and at
the Company offices in the areas of QA Program, QA Audits and Surveillances,
Procurement, Design Changes / Modifications, Records, Calibration, Housekeeping,
and Maintenance.
,
09 0 3 co~( 7,,
Inspection Summary
-2-
Results
Of the eight areas inspected, no apparent items of noncompliance or devia-
tions were identified in one area; eleven apparent items of noncompliance
were found in seven areas (Deficiency - Failure to carry out assigned duties
- Paragraph 5.b; Deficiency - Failure to follow audit procedures - Paragraph
6.b; Deficiency - Failure to meet required audit frequency - Paragraph 6.c;
Infraction - Failure to establish shipping, handling, and storage controls -
Paragraph 7.b; Infraction - Failure to follow material handling procedure -
Paragraph 7.c; Infraction - Failure to provide / document required training -
Paragraph 7.d; Deficiency - Failure to establish bases for safety evaluation -
Paragraph 8.b; Infraction - Failure to establish required QA Program - ' ,
document control - Paragraph 9.b and in housekeeping - Paragraph 11.b; Infra-
ction - Failure to establish calibration measures - Paragraph 10.b; Infraction
- Failure to prescribe / follow calibration procedures - Paragraph 10.c; Infrac-
tion - Failure to indicate calibration status - Paragraph 10.d).
.
.
DETAILS
1.
Persons Contacted
Licensee Employees
- D. Allen, QA Supervisor
- H. Banks, Manager-Nuclear Generation
- W. Dorman, QA Specialist, Operations Qtality Assurance (0QA)
- B. Furr, Manager-Generation Department
J. Jeffries, Principal Engineer-Nuclear Safety
- J. Johnson, Manager-Operations Quality Assurance
- L. Jones, Principal QA Specialist-Power Plant Construction
D. McGav, Principal Vendor Surveillance Specialist
- S. McManus, Manager-Corporate Nuclear Safety and Quality Assurance Audit
G. Milligan, Instrument and Control Group Supervisor
- R. Pollock, Principal QA Specialist-QAA
- C. Rose, QA Specialist-0QA
- R. Starkey, Manager-H. B. Robinson Plant
- A. Tollison, Manager-Brunswick Plant
W. Triplett, Engineering Supervisor
- W. Tucker, Technical and Administrative Superintendent
V. Wagoner, Maintenance Supervisor
Other licensee employees contacted during this inspection included
maintenance, warehouse, technical, clerical and quality assurance
personnel.
- Attended exit interview.
The following term is defined as used throughout this report.
" Accepted Quallity Assurance Program" means the material in the
CP&L Corporate Quality Assurance Manual in addition to the commit-
ments contained in letters to the NRC dated February 27, August 26,
and September 11, 1975, and the letter dated March 30, 1977.
2.
Exit Interview
The inspection scope and findings were summarized on January 16, 1979
with those persons indicated in Paragraph I above.
The inspectors informed the licensee that the items which recaired
management attention (identified in Paragraphs 5.c, 6.d through 6.j ,
7.e, 7.f, 8.c, 8.d, 9.c, 12.b and 12.c) would be inspected at a later
-2-
date.
In addition, the inspector follow item (Paragraph 7.g) would be
inspected to ensure implementation.
The licensee acknowledged the
inspectors' statements.
3.
Licensee Action on Previous Inspection Findings
Not inspected.
4.
Unresolved Items
Unresolved items were not identified during this inspection.
5.
QA Program-Periodic Review
a.
Inspection Items
The changes made to the licensee's QA procedures during the pre-
ceding calendar year (1978) were reviewed with respect to main-
taining the implementation of the accepted QA Program. The
licensee's current "Q" List was reviewed for consistency with the
items used in the safety related operations of the facility. In
addition, selected personnel were interviewed during the conduct
of other areas of the inspection as documented in this report to
assure that changes in procedures were understood and available
for use. The accepted QA Program was not changed in 1978, so that
aspect of revision control was not inspected. The specific
procedures reviewed were:
QAP-1,
Preparation and Control of Quality Assurance Instruct-
ions and Procedures, Revision 2 dated 12/78
QAI-6,
Electrical and Instrumentation C.-ble, Conduit, and
Raceway Installation, Original
AI-1,
Material Requisition, Receiving and Storage, Revision 13
dated 9/78
AI-2,
Collection, Maintenance, Control and Storage of Plant
Records, Revision 10 dated 12/78
AI-2.1,
Control of Drawings, Specifications and Document
Control, Revision 3 dated 12/78
AI-6,
Plant Filing Instructions, Revision 11 dated 12/78
QAAP-1,
Procedure for Corporate QA Audit as Required by CP&L
Corporate QA Program and ASME QA Program, Revision 4
dated 12/78
.
-3-
QAAI-1,
Instructions for Preparing, Distributing, and Main-
taining the Corporate QA Audit Documents and the Corp-
orate QA Program, Revision 3 dated 12/78
QAAI-2,
Instruction for Training and Qualifi. . ion of Quality
Assurance Program Audit Personnel, h /ision 2 dated 12/78
QAAI-3,
Instructions for the Collection, Storage, and Maintenance
of QA Records Within the Quality Assurance Units, Revision 2
dated 12/78
As a result of this inspection activity, one item of noncompli-
ance and one item requiring followup were identified as set forth
in Paragraphs 5.b and 5.c below.
b.
Failure to Involve QA in QA Procedures
The four (4) Administrative Instructions sAI's) listed in Para-
graph 4.a above all involve QA activities. The document control-
ling the initiation, review, and approval of AI's did not include
QA personnel. Criterion I of 10 CFR 50, Appendix B and Paragraph
2.4.5 m of the licensee's accepted QA Program require that QA
personnel have review / approval authority on procedures covering
QA activities.
This failure to include QA personnel in the review and approval
of QA related procedures constitutes an item of noncompliance
(324-325/79-02-01).
However, prior to the completion of the inspection, the QA Sup-
ervisor reviewed all four (4) of these procedures, signed a memo-
randum addressed to the Plant Manager in which he attested that
the QA apsects had been adequately covered, and action to assure
that the QA Supervisor would be included in review of all such
future proredures had been taken administratively. Therefore,
since both immediate and permanent corrective actions had been
completed and reviewed prior to the completion of the inspection,
this item does not require any additional action or response.
c.
Inclusion of Consumable Items on the "Q" List
Prior to this inspection, the Plant QA group had identified that
consuaable items were not included on the current CP&L list of
"Q" items. This problem was identified in QA Surveillance Report
- 472 dated 1/5/79. As of the completion of the inspection, the
response to this item had not been reviewed. However, in a phone
conversation on 1/19/79, the Plant Manager gave a target comple-
tion date of September
1, 1979, for completing the review of
-4-
consumable items ured at Brunswick, the inclusion of appropriate
items on the "Q"
list, and the delineation of what portion (s) of
the current QA Program would be applied to control of these
items. This item (324-325/79-02-12) will be reviewed during a
future inspection.
6.
Quality Assurance Audits and Surveillances
References:
(a) Plant and OQA Audit Instructions
(b) QAAP-1, Procedure for h r
'.e QA Audit as
Required by CP&L Corporate yA Program and
ASME QA Programs, Revision 4 dated 12/78
(c) QAAI-1, Instruction for Preparing, Distrib-
uting, and Maintaining the Corporate QA
Audit Documents and the Corporate QA Pro-
gram, Revision 3 dated 12/78
(d) QAAl-2, Instruction for Training and Qual-
ification of Quality Assurance Program Audit
Personnel, Revision 2 dated 12/78
a.
Inspection Items
The completed Quality Assurance audits for the preceding calendar
year (1978) were reviewed. Three (3) audits had been completed
for the ectivities related to the Brunswick Plant. These audits
were numbered 21-08, 21-09, and 21-10.These audits were reviewed
with respect to the requirements of the accepted QA Program to
assure that they were conducted in accordance with written check-
lists, by trained personnel not having direct responsibility in
the area being audited, with the results documented and reviewed
by the managers responsible for the audit area and by those
directing the QA Program, with a frequency as stipulated in the
accepted Program, and with timely corrective action taken and
reported.
Surveillance activities of the Plant QA group and the OQA group
were also reviewed with respect to items which remained either
uncorrected or unanswered as of this inspection.
As a result of these reviews, two items of noncompliance and
seven items requiring followup action were identified. These
items are delineated in Paragraphs 6.b through 6.j below.
b.
Failure to Follow Audit Procedure
Criterion V of 10 CFR 50, Appendix B and Section 11.2.7 of Part 2
of the licensee's accepted QA Program both require that audit
procedures be followed. Paragraph 6.5.2.c of Procedure QAAP-1
.
-5-
requires that the Manager-CNS&QAA shall confirm that corrective
action is acccmplished as scheduled. However, the second finding
in audit QAA/21-09 was improperly closed when the Lead Auditor
for that audit incorrectly interpreted the results of the fol-
lowup audit QAA/21-10. The finding was officially closed in a
letter from the Lead Auditor on QAA/21-09. Although no corrective
action had been taken as of Jcnuary 16, 1979, the problem had
been recognized by other members of the CP&L organization. The
operations personnel at Brunswick had noted that the item was
incorrectly closed, and the Lead Auditcr for audit QAA/21-10 had
been notified. Although action had not been taken, that Lead
Auditor was in the processing of preparing a letter which would
correct the problem.
This failure to follow procedures constitutes an item of noncom-
pliance (324-325/79-12-02).
c.
Failure to Meet Audit Frcquency Specified in Program Commitment
Draft 4, Revision 1 of ANSI N45.2.12 was given (in the letter to
the NRC dated February 27, 1975; General item 3.A) as the docu-
ment controlling the activities of the CP&L QA Audit Program.
Paragraph 3.5.2 of that Standard states that " Applicable elements
of the quality assurance program shall be audited at least an-
nually or at least once within the life of the activity, which-
ever is shorter."
A question was raised with respect to the definition of the word
" applicable" in the stated quotation. The inspector told the
licensee that, unless otherwise specified, the dictionary defini-
tion was used for all words. In this case, the dictionary gave a
definition of " capable of being applied." The inspector stated
that " applicable" <ould mean, therefore, that if an element were
being conducted, or if records were available relating to the
past conduct of an element; that element would be " applicable."
The licensee acknowledged the inspector's statement.
In reviewing the licensee's records, the inspector found that the
following elements had not been audited annually as required:
Organization and Responsibility (Criteria I, II, IV, V, VII,
.
X and XVII) was audited 11/7f and 11/78; the area was not
audited in 1977.
Procurement Control (Criteria I, IV, V, VI, VII, XIII, and
.
XVII) wat audited 6/76 and 5/78 the area was not audited in
1977.
.
-6-
Material and Equipment Control (Criteria II, V, VII, XIII,
XIV, XV, XVI and XVII) were last audited 2/77 and were
scheduled for audit 3/79; this area was not audited in 1978.
General Plant Operating Procedures (Criteria V,
V1, and
.
XVII) were not audited in 1975; the area was first audited
11/76. (This example applies only to Unit 2 since the OL for
Unit I was not issued until 9/76)
Annunciator Procedures (Criteria V, VI and XVII) were not
audited until 11/76, and were not audited again until 5/78;
this area was not audited in either 1975 or 1977.
Document Control (Criteria V and VI) was audited 9/75 and
.
11/77 and the next audit was scheduled for 7/79; the area
was not audited in 1976 or 1978.
These six examples, collectively, constitute an item of noncom-
pliance (324-325/79-02-03). The fact that all areas were either
audited in 1978 or were scheduled for audit in 1979 was con-
sidered in assigning a severity level to this item.
d.
Need to Document Current Auditing Practices
During the course of the inspection in the auditing area, the
inspector was informed of several practices which were not cur-
rently documented.
In each case, the practice was in accordance
with the requirements stated in the accepted QA Program.
Five
specific items were noted, although this list is not to be con-
sidered all inclusive.
(1) One audit report contained a statement that "13 design
packages had been reviewed." In all other cases reviewed by
the inspector, the auditor had listed the specific title or
unique identification of the items inspected. The Manager-
CNS&QAA stated that auditors were expected to specify which
items were inspected so that subsequent identification could
be performed.
(2) The field notes that are used to generate the inspection
findings in the audit reports are required to be retained by
the accepted QA Program's commitraent to ANSI N45.2.12.
However, neither the Standard nor the licensee's current
procedures specify the retention period for such records.
The Manager-CNS&QAA stated that such records were not re-
tained after the report was officially issued.
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(3)
In the three audit reports reviewed, the inspector was
unable to identify cases where the QAA findings duplicated a
Plant or OQA surveillance finding.
The Manager-CNS&QAA
stated that, where the problem identified in a Surveillance
report remained uncorrected and was reidentified during a
QAA audit, the item would be carried in the QAA audit report
as "open" pending completion of the proposed / initiated
corrective action.
(4)
k'h e n a condition requiring immediate corrective action is
discovered during the course of an audit, the management of
the affected organization would be notified immediately so
that the item would be corrected prior to the issuance of
the audit report.
This is the action that would be taken
according to the Manager-CNS&QAA.
(5) One audit response had not been received within 30 days of
issuance of the audit report as required by the accepted QA
Program. In this case, action had been taken and informally
documented. The specific action to be taken was dependent
upon several criteria, according to the Manager-CNS&QAA, but
neither the criteria nor the action to be taken was docu-
mente.d in current procedures.
The Manager-CNS&QAA stated that the current practices in the
above areas would be documented. Speaking for the Manager-CNS&QAA,
the Plant Manager gave a completion date of March 1,
1979, for
this item (324-325/79-02-13).
e.
Documentation of Pre-audit Conference Attendees
The accepted QA Program's commitment to ANSI N45.2.12 (Draf t 4,
Rev. 1) thereby includes a specific requirement to document per-
sons contacted during pre-audit meetings.
Currently, only the
senior official (s) present are documented.
The Manager-CNS&QAA
had already initiated action to assure that the specific list of
persons contacted at such meeting would be included in future
audit reports.
Speaking for the Manager-CNS&QAA, the Plant
Manager gave a completion date of Maich 1,
1979, for implemen-
tation of this item (324-325/79-02-14) .
f.
Review of Plant Operating Manuals
Section 5.6 of the licensee's BSEP OM/1 requires a periodic
review of the procedures contained in the Plant Operating Manual.
All but 5 of the 20 volumes of procedures require an annual
review.
OQAS-78-12 dated 11/1/78 identified that all annual
reviews had not been completed.
Corrective actie: was underway
-8-
during this inspection and the Plant Manager stated that all
required reviews would be completed by February 1,1979, and the
item (324-325/79-02-15) would then be corrected.
g.
Transfer of Operationally Identified Items to Construction
During the review of Plant Surveillance items, the inspector
found one case where a construction iteu had been found by Plant
Surveillance personnel. No formal method exists at this time for
transferring such items from operations to construction.
The
Plant QA Supervisor stated several acceptable methods which he
had been considering. The Plant Manager stated that the mechanism /
procedures to be used and the documents showing the authority for
such transfers would be completed and implemented by March 1,
1979. When this action has been completed, this item (324-325/
79-02-16) will be corrected.
h.
Control of Items Undergoing Rework or Repair
In two surveillance reports which were reviewed because answers
had not been received, the inspector noted that the reports
documented rework or repair items. As such, no answer (as re-
quired by the Surveillance Report handling instructior.s) could be
received, since none was required. The inspector was informed by
the Plant QA Supervisor that this action was really using the
Surveillance Report for a purpose other than the one for which it
was designed.
Since he had recognized the problem, a procedure
was in the process of being drafted during this inspection which
will define how rework / repair items will be tracked and controlled.
The Plant Manager stated that the instruction / forms necessary to
implement these controls will be in use by March 1,
1979, at
which time this item (324-325/79-02-17) will be corrected.
i.
Timeliness of Responses and Corrective Action - Surveillance
Reports
An Infraction (324-325/78-30-01) was issued on a specific example
of failure to obtain a timely response / timely corrective action
for an item in a Plant Surveillance Report.
The Plant Manager
wrote a memorandum (BSEP/79-16) on January 4,
1979, which ad-
dressed responses and corrective action to Plant Surveillance
items in a more generic manner. As of this inspection (January 8-
12)
at the Brunswick Station, insufficient time had elapsed to evaluate
the adequacy of this corrective action.
In addition, the Plant
Manager indicated that he was also monitoring this area, and
additional action would be taken if required. The Plant Manager
stated that this area would be ready for reinspection and evalua-
tion by NRC no later than May 1,1979. The NRC inspectors will
-9-
also monitor the plant's actions with respect to this item
(324-324/79-02-18) and evaluation will be conducted af ter the
Plant Manager has completed his corrective actions.
j.
Escalation of Surveillance Response
When Surveillance Reports are answered by plant personnel, in a
manner which is not consistent with the auditor's evaluation of
the identified problem the Surveillance Item remains "open"
Several surveillance auditors were interviewed and each gave a
different interpretation of the actions which he felt were required /
allowable in such cases under currently documented instructions.
The lack of uniformity of approach and the need for a consistent
polic'/ were discussed with the Manager-Operations Quality Assurance
(M0QA). The M0QA stated that steps, similar to those prescribed
for the QAA audits, could be detailed under the aegis of the
currently accepted QA Program.
The Plant Manager, speaking for
both the Plant QA group and the OQA group, stated that a procedure
or mechanism to escalate responses to higher authority for resolu-
tion would be documented by May 1, 1979. These mechanisms are to
assure that timely corrective actions are taken. The NRC will
further evaluate action to correct this item (324-325/79-02-19)
during a subsequent inspection.
7.
Procurement
References:
a)
AI-1, Material Requisition, Receiving, and Storage,
Revision 13 dated 9/78
b)
AQAS-6, Preparation, Distribution, and Filing of
Audit Reports, Revision 1 dated 12/78
c)
AQAS-7, Quality Assurance Audits, Revision 2 dated
1/79
d)
Qualified Suppliers List, Revision 6 dated 12/78
e)
MI-10-2A, Motor Storage, Revision 2 dated 1/77
a.
Inspection Items
The inspector reviewed the procurement area to verify that the
procurement specifications used in the purchase of compcnents and
material from selected systems included proper approval, quality
control inspection requirements and quality record requirements.
Components were selected from the reactivity control, reactor
-10-
coolant, and emergency core cooling systems. The specific items
inspected were:
(1) Control Rod Drive Parts, P.O. 693662
(2) Recirculation Pump Parts, P.O. 680354
(3) EGM Control Box for HPCI/RCIC, P.O. 686488 Core Spray Line,
P. O. 671805
For the items selected, the inspector verified that documentary
evidence was available onsite to support its conformance to
procurement requirements. In reviewing activities to assure that
these items were inspected upon delivery and that they were being
handled in accordance w.;h established controls in addition to
being supplied by an approved vendor, the inspector reviewed the
warehouse and related activities.
As a result of the review, the inspector found three (3) items of
noncompliance (Paragraphs 7.b,
7.c and 7.d below) and two (2)
items which will require management action for correction (Para-
graphs 7.e and 7.f below)
b.
Failure to Establish Shipping, Handling and Storage Controls
The inspector toured three warehouses onsite where Q-listed
(safety-related) materials were stored to assure that the con-
trols required by the accepted QA Program and its commitment to
ANSI N45.2.2-1972 were being implemented and the controls of
reference a) were being followed.
The results of the tour are
given in specific terms below. Only inadequacies are listed.
(1) Warehouse H
(a) Bags of salt stored openly in warehouse in the prox-
imity of Q-list material and stainless steel piping.
(b) Stainless steel piping stored without end caps, banded
with carbon steel bands and on the floor of the ware-
house or outside on the ground.
- (c) Handling of stacked or piled items not proper in that
items were stacked without consideration for racks,
cribbing or crates bearing the full weight without
distortion of the item.
.
-11-
(d) Motor generation set motors not adequately covered.
- (e) Adequate cleanliness not practiced
(i.e.,
salt, soda
ash, resins and charcoal bags broken open (caked on and
around storage pallets).
(f) Food was prepared within the varehouse.
- (g) No rodent control program implemented.
(h) Humidity control non-existent.
(i) Safety relief valves (4) not being controlled as Q-items.
(j) No Q-list segregation within the warehouse.
- (k) No level segregation for Q-list items.
- (1) Bags and packaging open to atmosphere (specifically on
carbon filters).
(m) Q-list wire reels without wire securely fastened and
capped.
(n) Q-list items not segregated from standard supply parts.
(o) Receipt inspections not conducted in areas equivalent
to storage level requirements.
(2) Warehouse C
(a) Q-list Recirculation pump parts not adequately con-
trolled (fence unlocked, radioactive material).
(b) No access control to the warehouse.
(c) Stainless steel piping on the ground, outside, not
capped nor adequately identified.
(d) No temperature control within the storage area.
(3)
Inplant Warehouse
(a) Valves not stored in shut positions.
(b) No shelf-life expiration control.
- Denotes those items common to all warehouses, (parenthetical
comment specify items for Warehouse H).
-12-
The only handling equipment currently used for Q-list material in
storage, according to the licensee, was a fork lift. The inspec-
tor noted that several large pieces of equipment would require
other lifting equipment. These large items were placed in the
warehouse, according to the licensee, during construction and had
not been moved since coming under the operational QA Program.
The inspector acknowledged the licensee's statements and then
stated that the requirements of the accepted QA Program as set
forth in its commitment to Sections 7.3 and 7.4 of ANSI
N45.2.2-1974Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.2-1974" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. would be required if other handling equipment is
used.
Criterion XIII of 10 CFR 50, Appendix B requires that measures be
established to control the handling, storage, and preservation of
materials and equipment. The accepted QA Program states that the
controls of ANSI N45.2.2-1974 will be applied at Brunswick Station
to meet this requirement.
The examples of inadequate controls
documented above, and the list is not all inclusive but 13 repre-
sentative of the current activities, plus the inspector's review
of the current procedures in this area indicate that the accepted
QA Program has not been implemented in this area. Current prac-
tices and/or procedures did not implement the specific require-
ments of Sections 3.0, 4.3, 5.2, 6.1, 6. 2, 6. 3, 6. 4, 6. 6, 7. 3,
7.5 and Appendix A-3 of ANSI N45.2.2-1972 as committed to by the
accepted QA Program.
This failure to establish the controls required for the handling,
storage, shipping, receiving and preservation of safety-related
items constitutes an item o noncompliance (324-325/79-02-04).
c.
Failure to Follow Procedures
The inspector reviewed the licensee's program for segregating
Q-list items into the required four (4) storage levels. Although
exception was taken to the Standard's specification of level
segregation, the licensee's Administrative Instruction 1 (AI-1)
requires by Section 5.4.1 that "Q-list material shall be stored
so as to meet or exceed the storage requirements set forth in
Appendix A . . .
"to the instruction. As of January 10, 1079,
none of the warehouses were arranged to provide for the four (4)
storage levels specified.
AI-1 also stipulates that a program will be implemented to ensure
that shelf-life expiration dates be controlled for such products
as rubber / synthetic o-rings, diaphragm valves, etc.
Section
5.3.6
states in part:
"All items with a shelf-life will be
indicated
to remove these items at expiration of their
. . .
shelf-life." The inspector observed that some limited shelf-life
-13-
material was appropriately marked on the item, but when the
supervisor of procurement and warehousing was asked about a
specific program to denote all shelf-life expiration dates, he
confirmed that no documented program was in effect.
These two examples of failures to accomplish activities affecting
quality as prescribed by documented instructions, collectively,
constitute an item of noncompliance (324-325/79-02-05).
d.
Failure to Provide / Document Required Training
Criterion II of 10 CFR 50, Appendix B requires traiaing for
personnel engaged in activities af fecting quality. The accepted
QA Program commits CP&L to the requirements of ANSI N45.2.6-1973
and ANSI N45.2.2-1972, both of which specify training /certifica-
tion requirements.
In reviewing activities in the warehouses, the inspector found
that personnel performing receipt inspections were certified as
required by Section 1.3 of ANSI N45.2.6.
The licensee was unable
to show the inspector any program which established, verif;td or
docun.ented the training / certification of receipt inspectors.
The demonstration of satisfactory performance in operating equip-
ment used to handle safety-related equipment is stipulated in
ANSI N45.2.2, Section 7.5.
The inspector was shown no object.ive
evidence that personnel performing fork lift operations in the
warehouse for handling safety-related equipment had demonstrated
satisfactory performance as required.
The two examples of failure to provide / document required training
in accordance with the accepted QA Program, collectively, consti-
tute an item of noncompliance (324-325/79-02-06).
e.
Supplier Evaluation
The inspector reviewed the procurement process by which the
licensee evaluates the performance of the supplier and ascer-
tained that the present program makes no provisions for an eval-
uation of each supplier.
ANSI N45.2.13, Section 6.1 is a re-
quirement of the accepted QA Program.
It states that:
" Purchasers at all times shall retain the responsibility of
monitoring and evaluating supplier performance
."
In the
. .
event that improper material is received or products currently in
service are either failing or performing marginally, no method
exists for the Brunswick Station to formally report these in-
congruities to the cognizant purchasing organization in order
that appropriate action of ensue to verify the credibility of the
supplier.
-14-
In Paragraph 11.c of this report, a lack of systematic review,
reporting, and evaluation of specific component failures is
documented.
This aspect of a supplier's pe rfo rmance is also
necessary to properly evaluate his capability.
While a single
system to harMle both the failure and procurement feedback con-
trols is not required; a single system could accomodate both
requirements. Therefore, this aspect of procurement control is
being combined with the performance evaluation aspect of main-
tenance control, for record purposes, into a single item desig-
nated (324-325/79-02-20).
The Plant Manager gave a date of
August 1, 1979, for the creation of a system or systems to meet
current QA Program requirements in both areas.
f.
Q-List Material Receipt After-Hours
The inspector reviewed Q-list material receipt procedures and
determined that no provision existed to correctly receive ma-
terial onsite other than during hours that the warehouse is
manned.
All material receipts reviewed by the inspector were
correctly completed in accordance with requirements.
However
when employees were questioned as to the method to be employed
after-hours, there was no cencensus on provisions to be used to
accomplish this receipt.
Since the inspector had received a wide variety of answers on how
such an after-hours receipt would/should be handled, the Manager
agreed to stipulate the policy to be followed for such receipts
with distribution to all affected persons to be accomplished by
March 1, 1979. The action on this item (324-325/79-02-21) will
be reviewed during a future inspection.
g.
Reaudit of Inactive Vendors
The inspector reviewed the area of vendor qualification and the
Qualified Suppliers List (QSL) with respect to recertification of
previously identified inactive vendors. AQAS-7, " Quality Assur-
ance Audits," provides an annual evaluation in which the CP&L
vendor auditing group ascertains the current status of all ap-
proved vendors listed on the QSL. If a vendor is either inactive
or has postponed production or delivery for an extended period of
time, there exists a means by which auditing that vendor's ac-
tivities may be postponed.
When questioned by the inspector on
how CP&L verifies adequate production by such a vendor prior to
revitalizing procurement contracts, the Principa' Vendor Surveil-
lance Specialist stated that he personally ensures each vendor is
reaudited.
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-16-
One item of noncompliance is documented in Paragraph 8.b below.
Two items requiring followup were also found as set forth in
Paragraphs 8.c and 8.d below.
b.
Failure to Establish Bases for Safety Evaluations
Of the eleven (11) design changes packages reviewed (four (4) at
Brunswick Station and seven (7) at CP&L Company offices), five
(5) packages contained insufficient safety evaluations. A safety
evaluation sheet was prepared for each design change, which
listed the three questions required by 10 CFR 50.59; in each case
reviewed, the questions were answered with a check in the "no"
box.
A summary was not always written, and when a summary was
written, it did not include "The bases for determination that the
change
does not involve an unreviewed safety question" as
.
required by 10 CFR 50.59.
The specific design change packages
reviewed were:
-
77-082
RCIC Space Heater (Unit 2)- 77-092
Deinerting Primary Containment
-
78-043
ISI/HPCI Test Point
-
78-059
ADS (B21 R614) Alarm Setpoint Change
-
78-074
RWCUS Flexible Coupling
These examples of failures to provide the bases for determining
that a design change does not involve an unreviewed safety ques-
tion, collectively, constitute an item (324-325/79-02-07) of
noncompliance.
c.
Interface Communications
The inspector reviewed the methods employed by the licensee to
transmit design information through his organization.
There
existed no system to control the flow of design inf ormation
between organization to the extent that a request could not be
directly related to a subsequent response. The inspector was
told that an inter-organization written memorandum system existed,
but he could not determine the source requiring said memorandum.
There were no instances where the inspector noted where such lack
of traceability produced a problem in this area. However, until
the licensee takes action t( stipulate his method of requiring
that the control of the flow of design information, spe 'fically
in the event information is transmitted orally or informally, be
confirmed by a controlled document, this item is designated
(324-325/79-02-22).
The Plant Manager committed to a completion
date of March 1,1979, for this item.
.
-17-
d.
PNSC Review Requirements
The Design Changes / Modifications Program employed at the Brunswick
Station requires the Plant Nuclear Safety Committee review of all
Q-List proposed changes; however, there were no provisions to
incorporate the Technical Specification requirement (Section
6.5.1. 7.b) that the PNSC render determinations as to whether or
not a proposed modification to plant systems on equipments af fects
nuclear safety.
The licensee's procedure ENP-3, Paragraph 3.8
and Figure 1, do not clearly specify PNSC review of a non-Q-List
change which could possibly af fect nuclear safety.
Until the licensee takes action to align his procedures with his
Technical Specifications requirement, this item is desig,nated
(324-325/79-02-23). The Plant Manager has committed to a comple-
tion date on March 1,1979, for the item.
9.
Records
References:
a)
AI-2, Collection, Maintenance, Control and Storage
of Plant Records, Revision 10, dated 12/78
b)
AI-2.1, Control of Drawings, Specifications and
Document Control, Revision 3, dated 12/78
c)
AI-6,
Plant Filing Instructions, Revision II,
dated 12/78
a.
Inspection Items
The inspector veritied the program for control storage, retention
and retrieval of records and documents pertaining to six (6)
safety related systems iccluding:
(1) TR-2-M-1124, Control Rod Drive System maintenance report,
dated 6/78
(2)
PT-92, High Pressure Coolant Injection System surveillance
report, dated 11/12/78
(3) MI2-3F, Reactor Recirculation System flow switch (B32-FS-F012)
calibration records, IB dated 3/6/74, ID dated 5/28/75, 2B
and 2D dated 2/1/74
(4) Reactor Recirculation System suction temperature recorder
log 1A, ending date 12/2/78
-18-
(5)
PT-15.1, Standby Gas Treatment System high efficiency parti-
culate air filter DOP test, dated 10/23/78
(6)
PT-17.3, 250 VDC Battery surveillance report, dated 10/13/78
The inspector verified that as-built drawings and vendor instruc-
tion manuals were being maintained by reviewing fifteen (15)
copies of vendor instruction manuals and the following drawings:
(1) FP-5078, Core Spray System, Revision 2
(2) 9527-D-2513,
High Pressure
Coolant
Injection System,
Revision 14, dated 10/77
(3) 9527-LL-9111, Emergency Distribution Diagram,
Sheet 10
Revision 4, dated 5/75
(4)
9527-LL-9114, Core Spray Pump 2B, Sheet 22, Revision 5,
dated 3/77
(5) F-2089, Condensate System, Sheet 1, Revision 20, dated 12/78
(6) FP-6493,
Condensate
Deep
Bed
Demineralizer
System,
Revision 1, dated 12/78
Additionally, records of reactor operations and equipment perfor-
mance were reviewed to assure availability of sufficient informa-
tion to detect adverse performance trends.
As a result of this inspection activity, one item of noncom-
pliance and one item requiring followup were identified as set
forth in Paragraphs 9.b and 9.c below.
b.
Failure to Establish Document Control Program
10 CFR 50, Appendix B, Criterion II requires a Quality Assurance
program which complies with the requirements of Appendix B.
The
accepted QA Program (Letter dated February 27, 1975) Paragraph I
says that the administrative controls of ANSI N45.2-1971 will be
followed.
Additionally, Paragraph 10 says that the record
keeping requirements of ANSI N45.2.9-1974 will be followed and
further describes the construction and utilization of the tem-
porary and permanent storage vaults.
Section 5.1 of ANSI N18.7-1972 requires control of the issuance
of documents and AI-2 further requires that issuance and serializa-
tion of vendor instruction manuals be controlled by the Library.
Seven (7) file cabinets of vendor instruction manuals (many of
.
-19-
which were safety-related) were maintained in Document Control
and not serialized or checked out from the Library. Additional-
ly, of fifteen copies of vendor instruction manuals inspected in
the Maintenance Shop files and the Library, seven (7) were not in
their designated locations and one was not identified in the
Master Index for control by the system.
Section 5.2 of the ANSI N45.2.9-1974 requires QA record files to
be stored in predetermined locations. Paragraph 10 of the Licensee's
letter designated these locations as temporary or permanent
storage vaults. QA records were not stored in these locations as
follows:
master copies of engineering drawings were maintained
in the Document Control room; master copies of vendor instruction
manuals were maintained in the Library; and approximately three-
fourths of all safety-related instrument calibration records were
maintained in the Maintenance Shop files.
Paragraph 10 of the Letter required modification and utilization
controls of the permanent storage vault which had not been ef-
fected as follows:
(1) No written procedures existed for the immediate evacuation
of the vault in the event of smoke detector actuation.
Additionally, the vault custodian stated that, in the event
of a small fire, she would disable the Halon System and
fight the fire with the available portable fire extinguisher.
(2) The vault was required to be a minimum use area; however,
microfilming operations were established inside the vault.
(3) Combustibles were not to be stored in the vault; however
there were several empty cardboard boxes stored in the
vault. These boxes were removed prior to the conclusion of
the inspection; therefore, the licensee need only address
actions taken to prevent recurrence in response to this
portion of the item.
These three examples of failure to establish the required
document control program combined with a similar failure in
Paragraph 11.b collectively constitute an item of noncom-
pliance (324-325/79-02-08).
c.
Failure to Update Drawings / System Descriptions
Drawings and system descriptions were not updated and did not
reflect as-built conditions.
This item was identified by the
licensee in Audit Report No. QAA/21-09 and Surveillance Report
Nos. 241 and 292 which cover these findings. The Plant Manager
-20-
stated that due to the large magnitude of work involved in this
item (324-325/79-02-34) the licensee would give responsibilities
and completion dates for the following milestones in the response
to this inspection report:
(1) Completion of a review of all prints and establishment of a
priority list for revisions.
(2) Completion of revision of f requently used safety-related
prints.
(3) Completion of revision of infrequently used safety-related
p rints . The response need not address system descriptions
as audit QAA/21-09 specifies a completion date of December 1,
1979, for these revisions.
10.
Calibration
References:
a)
MP-3, Calibration of Process Instruments, Revision 12
dated 2/77
b)
MP-1, Control of Measuring Devices and Test Equipment
Revision 9, dated 1/ 77
c)
MI3-3A, General Pressure Switches Revision 3 dated
9/77
d)
MI3-3F, Magnetrol Flow Switch Revision 2,
dated
10/74
e)
MI3-2Bl. GE Panel Meter Model 180, Revision 0,
dated 4 78
f)
MI3-15M, CAC Particulate and Gaseous Iodine Monitor
Calibration, Revision 6, dated 5/78
g)
CP&L Radiation Control and Protection Manual,
Revision 3, dated 7/78
h)
Brunswick Plant Operating Manual Volume VIII
Radiation Control and Protection
i)
Radiation Control and Test Procedure:
0004,
Instrument Calibration Control, Revision 5, dated
11/78
j)
Radiation Control and Test Instruction:
4030,
Colorimetric Method for Chloride Ion Revision 0,
dated 5/74
-21-
k)
Radiation Control and Test Instruction:
4131,
Glass Electrode Method for pil Determination,
Revision 1, dated 2/77
1)
Beckman Model RC-19 Conductivity Bridge, Revised
10/72
a.
Inspection Items
The referenced documents were reviewed to verify that specific
requirements had been established for calibration of safety-
related instruments utilized to verify Technical Specifications,
but whose calibration is not specified in the Technical Specifi-
cations. Thirteen (13) of these instruments under the Instrument
and Control Group cognizance were selected to verify that they
satisfied operating range and accuracy requirements and that
calibration procedure for these instruments were approved.
The
technical content of three (3) of these calibration procedures
(references (c), (d) and (e) were verified. One (1) calibration
in progress (reference (f)) was observed to verify procedural
compliance and the accuracy of standards used in the calibration.
The inspector also selected the Chemistry Laboratory conductivity
meter and pH meter to verify their calibration in accordance with
reference (h) as noted in the accepted QA Program.
The inspector identified three items of noncompliance which are
documented in Paragraphs 10.b,10.c and 10.d below.
b.
Failure to Establish Calibration Measures
10 CFR 50, Appendix B, Criterion XII requires the establishment
of measures to assure that gauges and instruments affecting
quality are calibrated at specified periods.
The accepted
Quality Assurance Program (Corporate Quality Assurance Program,
Part 2) Sections 6.2 and 6.4 collectively require the development
of a program for periodic calibration of safety-related installed
plant instrumentation.
Contrary to the above, as of January 16, 1979, measures had not
been established to assure that instruments were calibrated at
specified intervals as follows:
(1) There was no program in effect for periodic calibration of
Instrument and Control Group safety-related instruments
which are utilized to verify Technical Specification
re-
quirements but whose calibration is not specified in the
Technical Specifications.
The licensee identified the need
to investigate and propose corrective action for this item
-22-
in Surveillance Report No. 471 revised January 8,
1979;
however, corrective action was not scheduled or completed.
The inspector noted that of thirty (30) examples of the
thirteen (13) types of Unit I and 2 instrLzents inspected,
thirteen (13) had not been calibrated within the past
eighteen (18) months.
(2) Calibration procedure MP3-3F could not be utilized to assure
the calibration of the recirculation system flow switch
instruments (1,2 B32-FS-F012, B,D) for which it was desig-
nated because:
(a) Th procedure contains a technically inaccurate step of
averaging setpoint values which were taken both before
and af ter setpoint adjustment in order to determine the
"as lef t" setpoint value.
(b) The procedure could not be performed, as written,
subsequent to flow switch installation in the plant.
These two examples of failure to establish measures to
assure that instruments are calibrated at specified inter-
vals, collectively, constitute an item of noncompliance
(324-325/ 79-02-09).
c.
Failure to Prescribe / Follow Calibration Procedures
10 CFR 50, Appendix B, Criterion V, requires quality activities
to be prescribed and accomplished in accordance with documented
procedures. The accepted QA Program (Paragraph 5 of the letter
of March 30, 1977) requires radiation survey / measurement and
radiochemical / chemical analysis instruments to be calibrated as
outlined in Volume VIII of the Plant Operating Manual, Radiation
Control and Protection.
However, this manual did not address
instrument calibration as required by both the accepted QA
Program and Sections 1.1 and 13 of the CP&L Radiation Control and
Protection Manual.
Section 15 of the CP&L Radiation Control and
Protection Manual did prescribe
calibration program which was
a
inspected for implementation in the Station Chemistry Laboratory.
This program required calibration procedures and records in-
cluding correct certifications of all reference standards.
No
approved procedure existed for the calibration of the Chemistry
Laboratory conductivity meter.
The conductivity meter technical
manual, reference (1), does not give a procedure for calibration.
The Chemistry Laboratory Foreman stated the manual was used for a
calibration procedure. The resistance box and thermometer used
as reference standards in conductivity meter and pH meter cali-
brations, respectively, had no records of current certifications.
-23-
These two examples of failure to prescribe activities affecting
quality by documented procedures and two examples of failure to
follow procedures, collectively constitute an item of noncom-
pliance (324-325/79-02-10).
d.
Failure to Indicate Calibration Status
10 CFP 50, Appendix B, Criterion XIV requires the indication of
status of inspections and tests by markings such as labels. The
accepted Quality Assurance Program (CP&L Corporate Quality Assurance
Program, Part 2) Section 6.5.2 requires calibration status to be
indicated on stickers or tags attached to or accompanying the
equipment.
None of the licensee's procedures for installed
safety-related instruments required calibration status indica-
tors.
Additionally, there were no stickers or tags on any in-
stalled plant instrument observed during the course of the
inspection.
This example of failure to establish measure to indicate the
status of calibrations of safety-related instruments constitutes
an item of noncompliance (324-325/79-02-11).
11.
Housekeeping
Reference:
MP-12 General Cleanliness Procedure, Revision 1, dated
10/75
a.
Inspection Items
The inspector reviewed the above referenced procedure to ensure
that adequate rantrols had been established for housekeeping and
cleanliness as committed to in the accepted QA Program.
The
inspector noted the Diesel Generators were not included in Table 1
of the referenced procedure which assigns cleanliness classifica-
tion to the listed systems.
As a result of this inspection
activity, one item of noncompliance was identified as set forth
in Paragraph 11.b below.
b.
Failure to Establish Program - Housekeeping
10 CFR 50, Appendix B, Criterion II requires the establishment of
a QA program at the earliest practicable time and that this
program be documented by written policies and procedures. The
accepted QA program requires that applicable Section of ANSI
N45.2.3-1973Property "ANSI code" (as page type) with input value "ANSI</br></br>N45.2.3-1973" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process. be followed at BSEP.
Section 1.1 of the Standard
states in part, " Housekeeping encompasses all activities related
to control of facilities, cleanness of material and equipment,
fire protection and fire prevention including disposal of combus-
.
-24-
tible materials and debris
." Section 3.1 states in part,
.
" Areas for specific activities shall be assigned and regulated."
Section 3.2.3 states in part, " Equipment and instruction for the
protection from and prevent damage by fire shall be provided."
Section 3.5 state in part, "Peiodic inspection and e amination of
the work areas .
shall be performed .
."
.
During a plant tour, the inspector noted that approximately 10
gallons of oil was laying on the pipes in the trenches leading to
and from the diesel generators and on the area under the diesels
themselves. The inspector brought this matter to the attention
of the Maintenance Supervisor who caused cleanup operations to
begin.
The inspector reinspected the area and found the oil
removed and that the general cleanliness of the Diesel area
improved.
This example of failure to establish a program has been combined
with a similar faihre documented in paragraph 9.b and, collec-
tively they constitute an item of noncompliance (324-325/79-02-03).
12.
Maintenance
References:
(a)
MP-4, General Maintenance Procedure, Revision 2,
dated 5/78
(b)
MP-7,
Reactor Head Installation and Removal,
Revision 4, dated 8/78
(c)
MP-8, Reactor Drywell Head Installation and Removal,
Revision 3, dated 4/76
(d) MP-9 Dryer / Separator Installation and Removal
Revision 1, dated 3/76
(e) MP-10 Preventive Maintenance Program, Revision 9,
dated 4/77
(f) MP-11 Control of Relay and Overload Settings,
Revision 2, dated 12/77
(g) MP-12 General Cleanness Procedure, Revision 1,
dated 10/75
(h) MP-14 Corrective Maintenance' Revision 1,
dated
5/78
.
-25-
a.
Inspection Item
The referenced documents were reviewed with respect to the require-
ments of the accepted QA Program and ANSI 18.7-1972 as committed
to in that Program. The inspection was conducted to verify that
responsibilities had been established for the initiation, approval
inspection and review of preventive and corrective maintenance of
safety-related systems, components and structures.
The inspector selected thirty-five (35) work requt-t for corree-
tive raintenance that were complete from the Control Rod Drive
and Residual Heat Removal Systems. The inspector verified the
activities were performed and that the Limiting Conditions for
Operation were met while the components were removed from service
during the maintenance, and that functional testing and calibra-
tion were performed. The inspector further verified, by direct
observation, that two maintenance activities were performed by
qualified personnel, that the applicable controls were in effect,
and existing procedures were utilized.
One item requiring additional action was found as set forth in
Paragraph 12.b and an example contributing to another item is
described in Paragraph 12.c.
b.
Procedure Review and Approval
Technical Specification 6.8.1.a and 6.8.2 require review by the
Plant Nuclear Safety Committee (PNSC) and approval of the Plant
Manager for all procedures listed in Appendix A of Regulatory
Guide 1.33.
The inspector found that the licensee had previously
interpreted this requirement to apply only to generic procedures.
When informed of this inadequacy by the inspector, the Plant
Manager stated that all required procedures would be reviewed by
the PNSC before January 31, 1980. The licensee also stated that
he might seek an exception to this requirement by amendment of
the Technical Specifications. The inspector found no cases where
the technical adequacy of the procedures was unacceptable because
of the lack of PNSC review.
Until the licensee's proposed ac-
tions have been completed and evaluated, this item (324-325/79-02-25)
will be reviewed during subsequent inspections for progress
commensurate with the licensee's commitment.
c.
Repetitive Failures - Evaluation
During his review of the current maintenance program, the inspec-
tor found several failures for motor operators on valves F008 and
F009. While review of plant logs indicated that no Technical
.
-26-
Specification limits had been exceeded and that no Limiting
Conditions for Operations had been entered, the failures had not
received prompt attention for correction.
Persons interviewed
stated that the failures usually occured as the plant conditions
required these valves to operate to be placed into the Shutdown
Cooling Mode.
An Engineering Work Request ,78-463, had been
initiated to determine if the subject motors were properly sized.
The licensee's accepted QA Program includes a commitment to ANSI
N18.7-1972Property "ANSI code" (as page type) with input value "ANSI</br></br>N18.7-1972" contains invalid characters or is incomplete and therefore can cause unexpected results during a query or annotation process.. This Standard requires (Sections 4.1 and 5.1.6) that
actions be taken to detect trends and to identify components
which perform unsatisf actorily or marginally in service.
The
licensee has no current program for this specific purpose al-
though his NPRDS could be adapted to provide the information. A
similar requirement for feedback and evaluation of failures and
marginal performance was identified in the Procurement area
(Paragraph 7.c).
While a single system to handle both main-
tenance and procurement issues is not required, a single system
could accomodate both requirements.
Therefore, this aspect of
maintenance control is being combined with the supplier evalu-
ation aspect of procurement control, for record purposes, into a
single item (324-325/79-02-20).
d.
The inspector followed up on this item with respect to Farr
Company Part 21 report dated October 19, 1978. Thirty-five (35)
cells were purchased by the licensee on order number 654098. The
inspector determined by review of the documentation that the
cells had been retested and were now installed and in use.
The inspector identified no items of noncompliance or deviations
during this review.